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flowing. Cutbacks and emulsions are liquid at ambient temperature, and because of their low viscosity, they <br /> may <br /> flow when discharged onto the ground. All of these oils are regulated under the SPCC rule to prevent discharges <br /> to navigable waters or adjoining shorelines. <br /> However, hot-mix asphalt(HMA) and HMA containers are exempt from the SPCC rule. HMA is a blend of <br /> AC and aggregate material, such as stone, ground tires, sand, or gravel, which is formed into final paving <br /> products for use on roads and parking lots. HMA is unlikely to flow as a result of the entrained aggregate, such <br /> that there would be very few circumstances, if any, in which a discharge of HMA would have the potential to <br /> reach navigable waters or adjoining shorelines. <br /> Pete Reich <br /> U.S. EPA Region 9 Oil Program <br /> Clean Water Act Compliance Office <br /> Enforcement Division <br /> 75 Hawthorne Street(ENF-3-2) <br /> San Francisco CA 94105 <br /> 0: 415-972-3052 <br /> reich.peter@epa.gov <br /> www.cpa.�ov�oilspill <br /> From: Deporto, Courtney<Courtney.Deporto@gcinc.com> <br /> Sent:Thursday, May 23, 2019 11:01 AM <br /> To: Reich, Peter<Reich.Peter@epa.gov> <br /> Subject: Cutback Oil Tanks <br /> Hi Peter, <br /> We met in Reno when you presented for the Environmental team earlier this year. I was wondering if you could help <br /> clarify whether cutback oil is subject to APSA. We have exempted asphalt cement tanks from our APSA regulated sites <br /> and the cutback oil has similar characteristics: <br /> • Asphalt cement and cutback oil are both heated oils and semi-solids at 60 degrees Fahrenheit. <br /> • Asphalt cement and cutback oil are both categorized as UN3257-Elevated Temperature Liquid in the SDS. <br /> • Cutback oil is a combination of asphalt cement (-80%) and petroleum solvents ("30%). See SDS: <br /> https://tricorrefining.com/pdf/sc-800.pdf <br /> • Cutback oil is used to reduce asphalt viscosity for lower temperature uses. <br /> Thank you, <br /> Courtney DePorto <br /> Environmental Coordinator II <br /> Valley Region <br /> 4001 Bradshaw Road <br /> Sacramento,CA 95827 <br /> Direct:916-855-4514 <br /> Cell: 916-825-5708 <br /> Email: courtney.deporto gcinc.com <br /> www.ciraniteconstruction.com <br /> GRMITE <br /> MIM© <br /> 2 <br />