Previously, I wrote about used oil vs waste oil. If you’re still not clear on the difference between used oil and waste oil, read this. It’s critical you know and understand the difference between used oil and waste oil! Educating the industry in the difference is one of my missions in life, since I constantly still see the used oil tanks marked as waste oil incorrectly, when they indeed contain used oil! And yes, there is a difference between the two – and it does matter!
Used oil is a form of universal waste, and as such is governed by several government rules and regulations. Here are seven things that you ought to know in order to ensure you’re doing things right and avoiding trouble:
Label those tanks correctly! You wouldn’t label a water tank as gasoline, would you? If it’s used, label it as such. Don't call it waste oil, not recycled oil, or anything else. If it truly is waste oil, that’s fine, but don’t mislabel a tank or drum of used oil. In addition, fill pipes used to transfer used oil into underground storage tanks must be labeled or marked clearly with the words used oil as well.
Used oil counts towards your total volume for SPCC threshold applicability. Count it just like any other oil. If the total volume of all oil containers (down to and including 55-gallon drum size) is greater than 1,320 gallons, then you need an SPCC plan.
Put your used oil tanks in secondary containment! First off, it’s a general requirement of SPCC regulations. Secondly, it’ll help immeasurably in the event of a spill or leak, which will be captured in the containment area, making your cleanup a lot easier. Third, if contained, your oil spill or leak may not need to be reported as a release to the environment under certain circumstances.
Do NOT neglect your oil containers. I’ve been to a lot of facilities where the new oil tanks looked great, but the used tanks were a mess. Treat them just the same! Inspections, spill prevention and cleanup, proper labeling, etc. – just like a new tank!
Clean up spills of oil correctly. According to the Federal regulations (40 CFR 279.22(d)), you must do the following in the event of a spill of any oil:
Stop the release
Contain the released oil
Clean up and manage properly the released oil and other materials
If necessary, repair or replace any leading oil storage containers or tanks before putting them back into service
Know when a spill or leak is a reportable release to environment – and when it isn’t. Releases to the environment must be reported to appropriate USEPA and state authorities. A spill of oil onto or into a containment pad such as a concrete floor or other impervious containment area would not be considered a release to the environment if the response steps above have been followed, provided the releases don’t go beyond the containment area. Spills or leaks of any oil within an area with a concrete floor inside a building and that are cleaned up according to the cleanup steps above as a matter of standard practice are also not releases provided the oil doesn’t go beyond the containment area.
Know your state's rules for used oil – they might be more strict than the Federal rules. Check carefully and make sure you follow them!
Managing used oil at your plant, garage, or shop isn’t a hard thing, provided you follow the steps above. If you're struggling to evaluate your oil needs, or believe you might be out of compliance with your SPCC Plan, click here to contact us or give us a call at 609-693-8301 today.
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