USED OIL AND OIL FILTERS CUSTOMIZED ENVIRONMENTAL TRAINING WELCOME USED OIL 1/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC INSTRUCTOR Insert Instructor Name Here USED OIL 2/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC OBJECTIVES Define Used Oil. Discuss How Used Oil is Recycled. Discuss the Different Uses for Used Oil. Explain What Businesses Handle Used Oil. Discuss the Different Standards for Used Oil. Explain How to Conserve Oil. Discuss Records. Recommend Inspection Items. Discuss Use of Contractors. USED OIL 3/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC GOALS Understand the Definition of Used Oil. Understand How Used Oil Can Be Recycled. Be Familiar With the Different Uses for Used Oil. Understand What Businesses Handle Used Oil. Understand the Different Standards for Used Oil. Understand the Importance of Conserving Oil and Some of the Ways to Conserve Oil. Be Familiar With Required Records. USED OIL 4/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC BACKGROUND EPA estimates that of the 1.3 billion gallons of used oil generated annually, less than 60% is recycled. One pint of oil can produce a slick of approximately 1 acre on the surface of water. EPA estimates that the largest source of oil pollution fouling the nation’s waters comes from Do-It-Yourself oil changers. Crankcase oil accounts for 40% of total oil pollution of the nations harbors and waterways. USED OIL 5/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC LEARNERS Supervisors Facility Engineers Maintenance Personnel Department Managers Building Occupants Process Specialists Environmental and Safety Committees USED OIL 6/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC OVERVIEW The goal of this course is to provide supervisors with the tools needed to manage used oil. It recommends practical, actions that can be carried out by facility management, maintenance personnel and building occupants. The course will help you to integrate good used oil management activities into your existing organization and identify which of your staff have the necessary skills to carry out those activities. USED OIL 7/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC WHAT THIS COURSE DOES NOT DO The course is not intended to provide information to start a used oil collection center or how to process or re-refine used oil. These specialties required training beyond the intended scope of this course. Where this expertise is needed, outside assistance should be solicited. USED OIL 8/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) Congress passed the Used Oil Recycling Act (UORA) in 1980, requiring EPA to address the hazards posed by used oil, and develop a regulatory scheme to ensure proper management and disposal practices. The provisions of the UORA were incorporated into both the Hazardous and Solid Waste Amendments to the Resource Conservation and Recovery Act (RCRA); however, used oil emerged as a separate issue apart from hazardous waste. In developing regulations for used oil, EPA has tried to balance the RCRA mandate to protect human health and the environment with the RCRA mandate to conserve resources through used oil recycling. USED OIL 9/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC FEDERAL REGULATIONS Pertinent Regulations: 40 CFR Part 266, Subpart E. This used oil program that primarily regulates used oil recycled by being burned for energy recovery. 40 CFT Part 279. This regulation establishes standards for generators, transporters, transfer facilities, collection centers, processors and re-refiners, burners, and marketers. This rule also included provisions for cleanup in the case of a spill or release of used oil. USED OIL 10/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC WHAT IS USED OIL? EPA's regulatory definition of used oil is as follows: “Used oil is any oil that has been refined from crude oil or any synthetic oil that has been used and as a result of such use is contaminated by physical or chemical impurities.” Simply put, used oil is exactly what its name implies any petroleum-based or synthetic oil that has been used. During normal use, impurities such as dirt, metal scrapings, water, or chemicals can get mixed in with the oil, so that in time the oil no longer performs well. Eventually, this used oil must be replaced with virgin or re-refined oil to do the job at hand. USED OIL 11/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC OIL MANAGEMENT STANDARDS EPA's used oil management standards include a threepronged approach to determine if a substance meets the definition of used oil. 1.Origin - Used oil must have been refined from crude oil or made from synthetic materials. Excluded: Animal and vegetable oils are excluded. 2. Use - Oils used as lubricants, hydraulic fluids, heat transfer fluids, buoyants, and for other similar purposes are considered used oil. Excluded: Unused oil such as bottom clean-out waste from virgin fuel oil storage tanks or virgin fuel oil recovered from a spill, some solvents, antifreeze and kerosene. USED OIL 12/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC OIL MANAGEMENT STANDARDS 3. Contaminants--the third criterion is based on whether or not the oil is contaminated with either physical or chemical impurities. In other words, to meet EPA's definition, used oil must become contaminated as a result of being used. This aspect of EPA's definition includes residues and contaminants generated from handling, storing, and processing used oil. Physical contaminants could include metal shavings, sawdust, or dirt. Chemical contaminants could include solvents, halogens, or saltwater. USED OIL 13/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC USED OIL IS: Synthetic oil Engine oil Transmission fluid. Refrigeration oil. Compressor oils. Metalworking fluids and oils. Laminating oils. Industrial hydraulic fluid. Copper and aluminum wire drawing solution. Electrical insulating oil. Industrial process oils. Oils used as buoyants. This list does not include all types of used oil. USED OIL 14/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC USED OIL IS NOT: Waste oil that is bottom clean-out waste from virgin fuel storage tanks, virgin fuel oil spill cleanups, or other oil wastes that have not actually been used. Products such as antifreeze and kerosene. Vegetable and animal oil, even when used as a lubricant. Petroleum distillates used as solvents. Oils that do not meet EPA's definition of used oil can still pose a threat to the environment when disposed of and could be subject to the RCRA regulations for hazardous waste management. USED OIL 15/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC USED OIL IS NOT: Wastewater Wastewaters contaminated with de minimis quantities of used oil are also excluded from the present requirements because these wastewaters are regulated by the Clean Water Act. De minimis quantities of used oil are small spills, leaks, or drippings from pumps, machinery, pipes, and other similar equipment during normal operations, or when small amounts of oil are lost to the wastewater treatment system during washing or draining. Any used oil that is recovered from wastewater, however, falls under full regulation as used oil. USED OIL 16/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC USED OIL IS NOT: PCBs Used oils that are contaminated with PCBs in concentration of 50 ppm or greater are subject to regulation under the Toxic Substances Control Act (TSCA) and are not considered used oil, but must be handled at a PCB waste. USED OIL 17/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC HOW IS USED OIL RECYCLED? Once oil has been used, it can be collected, recycled, and used over and over again. Recycled used oil can sometimes be used again for the same job or can take on a completely different task. Benefits of Recycling: 1.Clean Water 2. Saving A Resource 3. Saving Money USED OIL 18/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC HOW IS USED OIL RECYCLED? Reconditioned On Site If a used oil needs only reconditioning it can often be done on site. This involves removing impurities from the used oil and then using it again. This usually involves a system of filters. While this form of recycling might not restore the oil to its original condition, it does prolong its life. USED OIL 19/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC PETROLEUM REFINING Petroleum Refining If used oil is sent to a refinery, it can be used in one of two ways. It can be used as feedstock that ends up being re-refined oil or It can be used as coker to produce gasoline and coke. USED OIL 20/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC RE-REFINED OIL Re-refined involves treating used oil to remove impurities so that it can be used as a base stock for new lubricating oil. Re-refining prolongs the life of the oil resource indefinitely. This form of recycling is the preferred option because it closes the recycling loop by reusing the oil to make the same product that it was when it started out, and therefore uses less energy and less virgin oil. One gallon of used motor oil will yield about 0.7 gallons of re-refined oil. USED OIL 21/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC PROCESSED AND BURNED Involves removing water and particulates so that used oil can be burned as fuel to generate heat or to power industrial operations. This form of recycling is not as preferable as methods that reuse the material. Eleven percent of used motor oil collected is used in specially designed space heaters in automotive bays and municipal garages across the nation. This practice is not recommended for home use. The country's approximately 75,000 space heaters use about 113 million gallons of used oil per year. USED OIL 22/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC REPROCESSING Reprocessing is the most common method of recycling used oil in the U.S. Each year processors treat approximately 750 million gallons of used oil. Seventy-five percent of used oil is being reprocessed and marketed to: • 43% asphalt plants; • 14% industrial boilers (factories); • 12% utility boilers (electric power plants for schools, homes, etc.); • 12% steelmills; • 5% cement/lime kilns; • 5 % marine boilers (tankers or bunker fuel); • 4% pulp and paper mills; • 6% other. USED OIL 23/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC RECYCLING OIL IS GOOD FOR THE ENVIRONMENT Recycling Used Oil Is Good for the Environment and the Economy--Here's Proof: Re-refining used oil takes only about one-third the energy of refining crude oil to lubricant quality. It takes 42 gallons of crude oil, but only one gallon of used oil, to produce 2 quarts of new, high-quality lubricating oil. One gallon of used oil processed for fuel contains about 140,000 British Thermal Units (BTUs) of energy. USED OIL 24/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC DOES MY BUSINESS HANDLE USED OIL? Generators Generators are businesses that handle used oil through commercial or industrial operations or from the maintenance of vehicles and equipment. Generators are the largest segment of the used oil industry. Examples of common generators are car repair shops, service stations, quick lube shops, government motor pools, grocery stores, metal working industries, and boat marinas. Excluded: Farmers who produce less than an average of 25 gallons of used oil per month. Individual’s personal vehicles and equipment. USED OIL 25/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC COLLECTION CENTERS Used Oil Collection Centers: Any site or facility that is registered, licensed, permitted, or recognized by a state, county, or municipal government to manage used oil and accept, aggregate, or store used oil collected from used oil generators. The used oil generator must deliver the used oil in shipments of 55 gallons or less. Used oil collection centers may also accept used oil from household do-it-yourselfers. Used Oil Aggregation Points Any site or facility that accepts, aggregates, or stores used oil collected only from other used oil generation sites owned or operated by the owner or operator of the aggregation point. USED OIL 26/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC TRANSPORTERS Transporters are companies that pick up used oil from all sources and deliver it to re-refiners, processors, or burners. Transfer facilities include any structure or area where used oil is held for longer than 24 hours, but not longer than 35 days. Examples of transfer facilities are loading docks and parking areas. Used oil transporters may consolidate or aggregate used oil for the purposes of transporting and may conduct incidental processing operations that occur during the normal course of transportation (e.g., separating water from used oil that has settled during the aggregation or transportation process). Transporters who otherwise produce used oilderived products or make these products more amenable for production are considered used oil processors. USED OIL 27/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC TRANSPORTERS Used oil transporters must not only notify EPA of their activities, but must also track their shipments and maintain compliance with the management standards of 40 CFR Part 279, Subpart D. These standards are similar to regulations for hazardous waste transporters in many respects, including a provision for used oil transfer facilities. USED OIL 28/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC PROCESSORS Re-refiners and processors are facilities that blend or remove impurities from used oil so that it can be burned for energy recovery or reused. These operations include but are not limited to blending used oil with virgin petroleum products, blending used oils to meet fuel specification, filtration, simple distillation, chemical or physical separation, and re-refining. Does not include generators processing used oil generated on-site for use on-site. If transporters or transfer facilities filter oil from oil-bearing transformers before returning it to its original use, they would not be subject to processing standards. USED OIL 29/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC BURNERS EPA’s used oil program only regulates the burning of off-specification used oil. Off-specification used oil fuel can only be burned in the following three types of devices: •Industrial furnaces •Boilers •Hazardous waste incinerators subject to regulation under Part 264/265, Subpart O. Prohibits the burning of used oil in non-industrial boilers, including boilers located at single or multifamily residences; etc. USED OIL 30/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC MARKETERS A used oil fuel marketer as any person who either (1) directs a shipment of off-specification used oil from that facility to a used oil burner, or (2) first claims that the used oil going to be burned for energy recovery meets the specification requirements. Used oil marketers can be divided into two categories: those that market off-specification used oil and those that market oil that meets specification. For each category different regulations apply under 40 CFR Part 279, Subpart H. USED OIL 31/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC STANDARDS What Standards Should My Business Follow? EPA has developed required good housekeeping practices that you must follow. These required practices, are called "management standards." The standards apply to all used oil handlers, regardless of the amount of the oil they handle. Although different used oil handlers may have specific requirements, the following requirements are common to all types of handlers. These requirements relate to storage, transporting, cleaning up leaks and spills, and record keeping. USED OIL 32/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC STORING OIL There are no time limitations on storage of used oil; however, if it is stored greater than 1 year and there doesn’t appear to be any definite plan to remove the oil, it may be considered disposal. Used oil should only be stored in tanks and containers that are not leaking, rusting, deteriorating, or having other defects. Containers, aboveground tanks, and fill pipes for underground storage tanks (UST) of used oil should be marked with the words "Used Oil." USTs that store used oil should also comply with the UST general operating requirements. USED OIL 33/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC STORAGE Never store used oil in anything other than tanks and storage containers. Used oil may also be stored in units that are permitted to store regulated hazardous waste. Tanks and containers storing used oil do not need to be RCRA permitted, however, as long as they are labeled and in good condition. Storage of used oil in lagoons, pits, or surface impoundments that are not permitted under RCRA is prohibited. USED OIL 34/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC TRANSPORTING All shipments of used oil in quantities greater than 55 gallons are transported off-site only by transporters who have an EPA identification number. Used oil generators may transport, in their own vehicles, up to 55 gallons of used oil, that is either generated on-site or collected from Do-It-Yourself (DIY) used oil generators, to a DIY used oil collection center, used oil collection center, or aggregation point (e.g., one that is licensed or recognized by a state or municipal government to manage used oil or solid waste). A used oil generator is not required to obtain an EPA identification number for this off-site transportation activity. USED OIL 35/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC OIL LEAKS AND SPILLS Take steps to prevent leaks and spills. Keep machinery, equipment containers, and tanks in good working condition and be careful when transferring used oil. Have absorbent materials available on site. If a spill or leak occurs, stop the oil from flowing at the source. If a leak from a container or tank can't be stopped, put the oil in another holding container or tank. Contain spilled oil. USED OIL 36/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC OIL LEAKS AND SPILLS Clean up the oil and recycle the used oil as you would have before it was spilled. If recycling is not possible, you first must make sure the used oil is not a hazardous waste and dispose of it appropriately. All used cleanup materials, from rags to absorbent booms, that contain free-flowing used oil also must be handled according to the used oil management standards. If you are a used oil handler, you should become familiar with these cleanup methods. They may also be part of a spill response action plan. Remove, repair, or replace the defective tank or container immediately. USED OIL 37/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC STANDARDS FOR BURNING Off-specification used oil can only be burned for energy recovery in industrial and utility boilers, industrial furnaces, used oil-fired space heaters, and hazardous waste incinerators. Used oil is considered to be off-specification if it has a flash point below 100 degrees Fahrenheit, or contains more than the allowable levels of any of certain constituents: - Arsenic 5 ppm maximum - Cadmium 2 ppm maximum - Chromium 10 ppm maximum - Lead 100 ppm maximum - Total Halogens 4,000 ppm maximum USED OIL 38/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC STANDARDS FOR BURNING Used oil can be burned in oil fired space heaters if: The heater burns only used oil generated on site or from a household "do it yourselfer," The heater has a maximum capacity of 0.5 million British thermal units per hour The combustion gases are vented directly to the outside air. Check with your Air Pollution Control District if there are any other restrictions. USED OIL 39/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC STANDARDS FOR BURNING Burners of used oil that meets a certain set of quality standards called the used oil specifications are not regulated under the used oil management standards, as long as the used oil is burned in appropriate boilers, furnaces, or incinerators. Know and understand your state regulations governing the management of used oil they might be stricter than EPA's. Contact your state or local environmental agency to determine your best course of action. USED OIL 40/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC BLENDING Blending used oil to meet specification is permitted, since EPA believes blended oil poses no greater hazard than dirty virgin fuel oil. Used oil with over 1,000 ppm total halogens, however, may not be blended to lower the halogen level. A used oil handler blending used oil for purposes of meeting specification would be subject to the processor and re-refiner regulations in 40 CFR Part 279, Subpart F. USED OIL 41/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC MIXING USED OIL AND HAZARDOUS WASTE Mixing Used Oil and Hazardous Waste If used oil is contaminated with hazardous waste, manage it as a hazardous waste. Hazardous waste disposal is a lengthy, costly, and strict regulatory process. The only way to be sure your used oil does not become contaminated with hazardous waste is to store it separately from all solvents and chemicals and not to mix it with anything. USED OIL 42/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC MIXING USED OIL AND NON-HAZARDOUS WASTE Mixing used oil with other non-hazardous wastes, such as wastewater or solvent, may make management of the mixture more complicated. These mixtures are regulated under both the used oil regulations and solid waste regulations. A receiving facility which accepts used oil for recycling may not have permits to accept other solid wastes. Mixing used oil and other waste may make disposal of the mixture more difficult and more expensive. USED OIL 43/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC AVOIDING COSTLY CLEANUPS How Can My Business Avoid Costly Cleanups? Prevention of spills by installing good housekeeping practices is the best way to avoid costly cleanup. Regular inspections and employee training will also minimize cleanup costs. If a spill does occur, protect storm drains with spill absorbent mats. Confine spills to concrete or other pavement. For small spills, surround the spill with absorbent socks or absorbent material and then pick up and properly dispose. USED OIL 44/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC RECOMMENDED CLEANUP PRACTICES Recommended Cleanup Practices EPA recommends, but does not require, the following cleanup practices for used oil handlers: (1) maximize the recovery of used oil; (2) minimize the generation of used oil sorbent waste by choosing reusable sorbent materials; (3) use the spent sorbent materials to produce recycled (4) buy sorbent materials with recycled content. USED OIL 45/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC RECOMMENDED CLEANUP PRACTICES Extraction devices (e.g., centrifuges, wringers, and compactors) can be used to recover used oil from reusable sorbent materials. Sorbent pads can be reused between two and eight times depending on the viscosity of the used oil. These technologies, while not required, can be used to reduce the number of sorbent pads ultimately sent for remanufacture, energy recovery, or disposal. The potential to reduce waste and save money (i.e., lower disposal costs for spent pads and lower per use cost of sorbent pads) by reusing and recycling sorbent pads can be substantial. USED OIL 46/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC RECOMMENDED CLEANUP PRACTICES Managing Cleanup Materials If you have used oil on rags or other sorbent materials from cleaning up a leak or spill, you should remove as much of the free-flowing oil as possible and manage the oil as you would have before it spilled. Once the free-flowing used oil has been removed from these materials, they are not considered used oil and may be managed as solid waste as long as they do not exhibit a hazardous waste characteristic. USED OIL 47/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC CONSERVING OIL What Can My Business Do to Conserve Oil? Minimize the amount of used oil you produce. Businesses can filter, separate, and recondition used oil to prolong its usable life. Purchase re-refined used oil products instead of virgin oil products. Products that display the American Petroleum Institute (API) "starburst" meet the same high-quality specifications as virgin oil. Practice safe management of used oil. Don't mix used oil with anything. Always store used oil in leakproof containers that are in secure areas safely away from workers and the environment. Send used oil to a re-refiner whenever possible. USED OIL 48/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC CONSERVING OIL Reducing the amount of used oil that you generate is an important pollution prevention (P2) measure. Use longer lasting synthetic oils to minimize the amount of used oil and used oil filters generated. Reduce the amount of virgin oil purchased by reconditioning and then reusing used oil. Manage used oil safely. Do not mix it with other materials. Store the oil in leak proof containers and tanks in secure areas away from workers and the environment. Label all containers of used oil and other wastes to avoid inadvertent mixing. Use reusable oil filters. Recycle used oil filters. USED OIL 49/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC DUST SUPPRESSANT In the past, used oil has been used as a dust suppressant on roads. This practice is now prohibited except in a few states where the practice is tightly regulated to a few instances. USED OIL 50/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC USED OIL FILTERS How Should My Business Manage Used Oil Filters? The Filter Manufacturers' Council maintains a regulatory hotline and database to encourage the proper management of used oil filters. By calling the hotline at 800 99-FILTER, you can access the proper management requirements for your particular states. The database contains: Overviews of federal and state regulations relevant to the management of oil filters. Addresses and phone numbers of the regulatory agencies governing the management of used filters in each state. A listing of companies, by state, that transport, process, and recycle used filters. USED OIL 51/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC USED OIL FILTERS Non-terne plated used oil filters are not hazardous waste and can be disposed of as general refuse if they are properly drained. Terne is an alloy of tin and lead. Terneplated filters may be hazardous waste because of their lead content. Draining used oil from your filters can be performed using one of the following methods: – Puncturing the filter anti-drain back-valve contained in most automotive oil filters or the filter dome, and then hot draining; the anti-drain back-valve consists of a rubber flap that creates a vacuum to prevent oil from draining back into the engine – Hot draining and crushing – Dismantling and hot draining USED OIL 52/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC RECORDKEEPING EPA uses 12-digit identification (ID) numbers to track used oil. Transporters hauling used oil must have a valid EPA ID number, and generators, collection centers, and aggregation points must use transporters with EPA ID numbers for shipping used oil off site. If you need an ID number, contact your EPA regional office or your state director.(You also can call the RCRA Hotline for more information.) Generators, collection centers, aggregation points, and any handler that transports used oil in shipments of less than 55 gallons do not need an ID number, but may need a state or local permit. USED OIL 53/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC RECORDKEEPING Used oil transporters, processors, burners, and marketers also must record each acceptance and delivery of used oil shipments. Records can take the form of a log, invoice, or other shipping document and must be maintained for three years. Re-refiners, processors, transfer facilities, and burners must have secondary containment systems (e.g., oil-impervious dike, berm, or retaining wall and a floor) so that oil can not reach the environment in the event of a leak or spill. EPA also encourages generators to use a secondary containment system to prevent used oil from contaminating the environment. USED OIL 54/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC RECOMMENDED INSPECTION ITEMS 1. Determine if used oil is generated and if it is off specifications or not. 2. Verify that used oil is not used for dust suppression. 3. Determine if used oil fuel is burned at your facility for energy recovery. If so, is it within specifications or is it off specifications. 4. If off specification used oil is burned, is it burned in an approved industrial furnace, boiler or hazardous waste incinerator? USED OIL 55/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC RECOMMENDED INSPECTION ITEMS 5. Verify that used oil is not managed in surface impoundments or waste piles. 6. Verify that when a release is detected, the following is done: - the release is stopped - the released is contained (especially before entering storm water drains) - the oil is cleaned up properly and the managed properly - repairs and replacement of any leaking storage containers or tanks takes place prior to returning them to service. USED OIL 56/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC RECOMMENDED INSPECTION ITEMS 7. Determine if used oil is used in oil-fired space heaters. If so, is the oil within specifications and is the combustion gases from the heater vented to the outside ambient air? 8. If more than 55 gallons of used oil is transported, does the transporter have an EPA ID number? 9. Does the used oil transporter have a tracking mechanism (e.g. logs, manifests, etc.)? 10. Verify that the used oil is not mixed with hazardous waste or solid waste. USED OIL 57/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC RECOMMENDED INSPECTION ITEMS 11. Verify that used oil containers and tanks are not leaking, bulging, rusting, damaged or dented. 12. Verify that containers, above ground storage tanks and fill pipes used to transfer used oil are clearly marked with the phrase “Used Oil.” USED OIL 58/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC TIPS FOR USING CONTRACTORS Remember, You Control Your Facility or Area! Review Procedures With Them Before Starting the Job! Ensure They Are Properly Trained! Determine Their Environmental Compliance Record! Determine Who Is in Charge of Their People! Determine How They Will Affect Your Facility’s Environmental Compliance! USED OIL 59/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC ELEMENTS OF A SUCCESSFUL USED OIL PROGRAM 1. DETAILED WRITTEN USED OIL INSPECTION GUIDELINES. 2. DETAILED WRITTEN USED OIL BEST MANAGEMENT PRACTICES. 3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS 4. PERIODIC REINFORCEMENT OF TRAINING 5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION 6. PERIODIC FOLLOW-UP USED OIL 60/61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC THE IMPORTANCE OF A CLEAN ENVIRONMENT “I would ask all of us to remember that protecting our environment is about protecting where we live and how we live. Let us join together to protect our health, our economy, and our communities -- so all of us and our children and our grandchildren can enjoy a healthy and a prosperous life.” USED OIL 61/61 © Copyright Training 4 Today 2001 Carol Browner Former EPA Administrator Published by EnviroWin Software LLC