Safety News You Can Use- Waste Oil Management Tips

WASTE OIL MANAGEMENT
Management of waste oil is sometimes an overlooked but none the less important element in the overall business plan. Here is a brief discussion on waste oil management that hopefully will assist you and your company’s efforts in its environmental compliance program.
EXAMPLES OF USED OIL
• engine oils from vehicles and equipment
• lubricating oil
• brake/transmission fluid
• hydraulic fluid
• insulating oil
• metal cutting fluid —
• compressor or refrigerant oil

Used Oil Does Not Include
• oil products (unused/new)
• cleanup material from oil product spills
• animal/vegetable oil —
• sludge from virgin oil storage tanks —antifreeze —kerosene (unless used for lubricating purposes)
• petroleum distillate solvents
• gasoline, diesel fuel
• wash waters that may be contaminated with used oil

Mixing Used Oil With Other Materials
• Be careful when mixing used oil with other materials materials, especially chemicals like used solvents, brake fluids, etc.
• You may cause the whole mixture to become a hazardous waste. Or, it may be harder to recycle the used oil.

Mixing Used Oil With Other Wastes
• Mixing is acceptable under some circumstances. Conditionally Exempt Small Quantity Generators (CESQGs) can mix their hazardous waste (listed or characteristic) and used oil together and still manage it as used oil.
• A CESQG generates less than 220 lbs. (or about 25 gallons) of hazardous waste in a calendar month.

Mixing Used Oil With Other Wastes
• Used oil mixed with listed waste generated by generators who generate greater than 220 lbs. in a calendar month is regulated as listed hazardous waste.
• Used oil mixed with hazardous waste that is only ignitable (D001) can be managed as used oil if the mixture is not ignitable. —
• Used oil mixed with hazardous waste that is corrosive, reactive or TCLP toxic can be managed as used oil if the mixture does not exhibit any characteristic.

What Is Used Oil
• EPA defines used oil as 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.

Rebuttable Presumption
• Used oil with >1000 ppm total halogens (Chlorine, Fluorine, Bromine compounds) is presumed to be mixed with halogenated hazardous waste
• You may rebut the presumption by: ◦Demonstrating that you are a CESQG ◦Demonstrating that it contains insignificant levels of halogenated hazardous constituents ◦Demonstrating that they are cutting or machining oils containing chlorinated paraffins that are reclaimed under a tolling agreement.

Who Is a Used Oil Generator
• A person whose action first causes used oil to become subject to regulation. Examples:
• manufacturers
• machine shops
• metal working shops
• quick lube and auto service shops —
• equipment servicing (compressors, forklifts, field vehicles, other large equipment)

Used Oil Containers and Aboveground Tanks
• Label used oil tanks or containers with the words “Used Oil”
• Containers and tanks must be in good condition (no rust, leaks)

Make sure your containers are in good condition and managed to prevent spills or leaks.
• Ohio EPA has a list of companies that recycle used oil.
• Used oil CANNOT go into the dumpster, a septic system or on the ground!

Used Oil Releases
• If you have a spill or leak of used oil:
• Stop the release Clean up the spill
• Remove contaminated soil
• Replace/repair tanks or containers if needed
• Visual Standard
• Soils you will dispose must be evaluated to determine if they are hazardous waste

Make sure you don’t pour used oil or any other chemical wastes into your floor drains!
• DON’T pour your used oil into a sewer or down a storm drain!
• Not only does this cause environmental damage, it can also lead to violations or penalties.

• DON’T use used oil outside on the ground for any reason!

Used Oil Shipments Off-Site
• The transporter picking up your used oil must have an identification number from Ohio EPA.
• —You can check on a transporter’s number by calling the Division of Hazardous Waste at (614) 644-2621.
• The transporter picking up your used oil must have an identification number from Ohio EPA.
• You can check on a transporter’s number by calling the Division of Hazardous Waste at (614) 644-2621.

Used Oil Transportation
• If your used oil is reclaimed under a contractual agreement, your transporter does not need an EPA identification number.
• The transport vehicle must be owned by the processor. The reclaimed oil must be returned to you for use as a lubricant, cutting oil or coolant.

What About Used Oil Filters?
• Used oil filters should be properly drained. The EPA has guidelines on how to properly “hot drain” filters.

What About Used Oil Filters?
• Once the filters are drained, the best option is to have them sent to a scrap metal recycler.
• Used oil generated from draining filters must be managed properly.

 

 

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