DEPARTMENT: Design and Construction PAGE: 1 of 3 EFFECTIVE DATE: January 12, 1999 POLICY DESCRIPTION: Environmental – Waste Oil Management REPLACES POLICY DATED: REFERENCE NUMBER: DC.012 SCOPE: All Company facilities, including but not limited to, hospitals, ambulatory surgery centers, home health agencies, physician practices, and all Corporate Departments, Groups and Divisions. PURPOSE: To require each facility to manage waste oil handling and disposal in accordance with applicable Environmental Protection Agency (EPA) regulations. POLICY: 1. To minimize the waste oil generation onsite, a facility should consider using a commercial garage for servicing Company vehicles and retaining credible maintenance contractors to properly handle the waste oil for boiler and other equipment services. Facilities must not accept waste oil generated by non-Company sources. 2. In a county where an agency-administered program is available, the facility is encouraged to participate in the community-wide collection and recycling program. If a permitted used oil recycling firm is available in the area, the facility should establish a contract for disposal. The Corporate Legal Department must review the contract. Utilizing a hazardous waste transporter or a hazardous waste landfill should be the last resort for waste oil disposal. This policy addresses federal regulatory requirements. State laws or regulations may impose additional requirements. Each facility should consult with Corporate Engineering Services and the facility’s Operations Counsel to identify and comply with any such additional requirements. PROCEDURE: Analytical Testing 1. Waste oil testing is not required if the waste oil collector, recycling firm, or disposal facility routinely tests the oil. A facility must ask for a copy of the test results and keep it on file. 2. If a facility generates an unusual shipment of waste oil from specific projects other than the routine maintenance activities, the waste oil must be tested for total halogens. The designated recycling firm or fuel blending facility should be provided with the test results. 3. A batch of waste oil with an unknown generation process or unspecified date of generation requires a PCB test in addition to the total halogens test. 4. If the hazardous waste treatment/disposal facility is used as a last resort, a complete one-time DEPARTMENT: Design and Construction PAGE: 2 of 3 EFFECTIVE DATE: January 12, 1999 POLICY DESCRIPTION: Environmental – Waste Oil Management REPLACES POLICY DATED: REFERENCE NUMBER: DC.012 waste profile will be tested by the contracting facility. Handling 1. A facility must not dump waste oil on roads or on land for purposes of dust suppression or weed control. This practice was common in the past; however, current regulations prohibit introducing petroleum pollutant into the environment. 2. A facility must not pour waste oil into the sanitary or storm drainage systems. 3. A facility must not burn waste oil in the onsite medical waste incinerator. The onsite incinerator is permitted to burn medical waste only. 4. A facility must not dump waste oil into the underground fuel storage tank. Most of the onsite boilers are not permitted to burn waste oil. 5. A facility must never mix waste oil with other types of waste materials. Waste oil must be separated from general trash, which is usually deposited in the county landfill. No matter how minute the amount is, a facility must not pour degreaser solvents, coolant (ethylene glycol), xylene, formaldehyde, freon, or other hazardous materials into a waste oil container. 6. A facility must not use containers or drums for waste oil holding. The holding area should be equipped with containment to recapture spills. A facility must inspect the holding tank and its surroundings periodically. An underground storage tank is not recommended for waste oil holding. A facility must not store waste oil for more than 180 days. 7. Waste oil holding containers must be properly labeled. Transportation 1. Facility personnel may transport a small amount of waste oil, 20 gallons or less, for a distance of no more than 30 miles. The facility must to get a receipt from the used oil collector. 2. A facility must verify the registration (Department of Transportation and State Environmental Agency) of the waste oil transporter and have the transporter sign the collection logs for each removal. Disposal 1. The facility may send used oil to those service stations offering a used oil collection program, provided there is a written agreement between the facility and the service station. In some states, service stations collecting used oil must be registered with the state. The facility must DEPARTMENT: Design and Construction PAGE: 3 of 3 EFFECTIVE DATE: January 12, 1999 POLICY DESCRIPTION: Environmental – Waste Oil Management REPLACES POLICY DATED: REFERENCE NUMBER: DC.012 verify that the used oil is ultimately recycled in accordance with all applicable state and federal requirements. 2. If a shipment of waste oil is determined to be hazardous, a facility must manifest it and have a hazardous waste contractor remove it. 3. Liquid and sludge/residue removed from the fuel tank replacement or tank maintenance projects are generally non-hazardous and must be sent to a recycler. Record-keeping 1. If a facility has a contract in place with a permitted recycling firm, the facility must use collection logs or receipts, in lieu of manifests, for the waste oil shipment. 2. A facility must use a hazardous manifest only if a shipment of waste oil is determined to be hazardous. The facility must receive an executed manifest, signed and returned by the treatment/disposal facility within 30 days after removal from the facility. If this manifest is not received, the facility must call the disposal facility and request the executed manifest. 3. A complete file must include: a. waste oil collection logs or manifests; b. analytical testing results; c. registration of commercial recycling firm or disposal facility; and d. inspection log of waste oil storage. A facility must keep all waste oil related documents in the Plant Operations Department for 3 years and then archive. REFERENCES: Company Waste Oil Management Guidelines Federal Regulation 40 CFR 266