ECAR Fact Sheet for Connecticut
Used Oil

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources

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The following fact sheet was prepared by the ECAR Center staff. Once prepared, each ECAR Center fact sheet undergoes a review process with the applicable state environmental agency(ies). You can check on the status of the review process here. Please read the disclaimer on the status page. While we have tried to present a summary of the essential information on this topic, you should be aware that other items, such as local regulations, may apply to you.

What You Need to Know

Used oil is insoluble, persistent and may contain toxic chemicals and heavy metals. If spilled on the ground, poured down storm drains or disposed of with trash, it can pollute surface water or groundwater. Used oil is not inherently hazardous, but if it contains certain additives, or if it has become contaminated with other solvents, it can fall under the hazardous waste rules.

You can avoid the burden of treating used oil as a hazardous waste:

• If you do not contaminate it with other fluids, and
• If you handle and store it properly, and send it to an approved used oil processor by a certified transporter.

The Connecticut Department of Environmental Protection (CT-DEP) has prepared a guidance document to help auto recyclers manage used oil. Much of that information is included in the fact sheet below. You can access the link to CT-DEP’s used oil fact sheet under Other Relevant Resources.

This fact sheet will tell you what you need to do to avoid problems with used oil.

Regulations

Used oil is considered a “regulated waste” in Connecticut and must be recycled. This includes burning for energy recovery. Used oil is not considered hazardous waste unless it is mixed with a hazardous waste such as a chlorinated solvent.

Used oil includes crankcase (engine) oil, brake fluid, automatic transmission fluid, power steering fluid, liquid and semi-solid gear, chain, and ball bearing lubricants, and hydraulic fluid. Used oils can be mixed and managed together.

Materials that contain or are contaminated with used oil can also fall under the definition of used oil, such as used oil filters, oily rags, used absorbents, and oily wastewater.

Storage of Used Oil. Any storage tank or container for used oil must be on an impervious base. The area should be free of cracks, gaps or bare earth, away from any floor drains or catch basins and cannot be damaged or degraded by contact with used oil. If the tank or container is outdoors, you must provide for secondary containment equal in volume to the capacity of the storage tank.

• Do not mix used oil with anything else, such as chlorinated solvents, or expose oil to electrical contact cleaner or carburetor cleaner which can contaminate used oil while in an engine. Doing so will result in the need to perform a hazardous waste determination on the used oil mixture to establish whether or not the mixture must be managed as a hazardous waste.
• Label the tank or container “Used Oil”.
• Lock the tank or container’s fill spout when not in use.
• Use a licensed waste oil transporter to haul the oil to a treatment facility for processing.
• Keep results of used oil testing.
• Prepare a Spill Prevention, Control, and Countermeasure (SPCC) Plan if you store more than 1,320 gallons of used (or new) oil. Containers of less than 55 gallons are exempt.
• Visually inspect the tank or container on a regular basis for leaks or malfunctions.
• Maintain written inspection records.
• Instruct all employees who handle used oil on the proper operation and management of the oil storage area. Assign one person the responsibility for monitoring oil storage and make sure a back-up person is assigned.
• Do not use oil to control dust or weeds.

Management/Disposal Options. Collect and store used oil in a secure collection tank or drum, separate from other wastes. Test the used oil for total halogen content. Maintain records on site.

If the used oil tests positive for hazardous constituents by exceeding the regulatory level for total halogen content, it must be managed as hazardous waste. If the used oil does not test positive for hazardous waste, the options for management are:

• Ship off-site for recycling:
• Contract with a permitted waste oil transporter to haul oil to a permitted recycling or disposal facility. Commercial haulers of such used oil must be permitted to transport used oil in Connecticut.
• Burn on-site in space heater. Burn the used oil in space heaters for energy recovery, i.e., to heat your shop, providing the heater burns only used oil generated on-site or received from “do-it- yourself” oil changers.

NOTE: Used oil heaters must be designed for such purpose and:

a. have a maximum design capacity of not more than 0.5 million BTU’s per hour; and

b. vent combustion gases outside the building; and

c. burn only used oil that you generate or that you have collected from your do-it-yourself oil changers.

In addition, Connecticut requires the use of analytical testing to show that the used oil does not exceed the allowable levels of constituents and properties under federal used oil regulations.

Unlike the federal rules that do not have a requirement for minimum heat content, Connecticut requires that used oil burned in used oil-fired space heaters have at least 5,000 BTUs per pound.

If your business burns used oil for energy recovery, check with your state or local air quality division to inquire about air quality requirements, and check with state building code personnel to inquire about building codes for the installation and use of the burner.

Used Oil Management.  As a used oil generator, you must ensure that used oil is properly managed by a recycling or disposal company. The best way to manage used oil is to send it off-site to a recycling company. The regulations encourage different recycling options such as reconditioning, refining, reusing or burning for energy recovery.  Contact the CT-DEP to obtain a list of used oil management companies.

Uses of Used Oil. It is illegal to dispose of used oil improperly. Note the following important restrictions:

• Do not discharge used oil to sewers, drainage ditches, septic tanks, or streams.
• Do not dispose of used oil in landfills or mix used oil with wastes that will be disposed of in landfills.
• Do not mix used oil with gasoline or cleaning solvents.  The resulting mixture may be a hazardous waste.  This classification brings into effect a lot of additional regulations.
• Do not use used oil for road oiling, dust control, weed control or for similar purposes.

Storage of Used Oil. Used oil must be stored in tanks or containers (including DOT approved drums) that are in good condition.  This means:

• No severe rusting;
• No bulging or major dents; and
• No visible leaks.

If you store more than 55 gallons of used oil in tank and container storage areas, they must be equipped with an impervious surface sufficient to prevent any used oil released from entering the soil, groundwater, or surface water. If stored outdoors, the storage area must also comply with secondary containment standards.

Used oil transfer facilities are allowed to store used oil for 10 days.

Many of the used oil regulations relate to good housekeeping practices.  As a used oil generator, you must:

• Label all storage containers or tanks with the words “Used Oil;”
• Store used oil in containers or tanks in good condition;
• If there is a leak of used oil: stop the leak, contain it, clean it up and properly manage the cleanup materials;
• Use a transporter with an EPA identification number to ship used oil off-site.

Transporting Used Oil.  You are required to obtain an EPA ID number prior to transporting any used oil. You may require a permit for transferring used oil from one transport vehicle to another.

Used Oil Spill Prevention. If you handle oil or oil products at your facility, you may be subject to the Spill Prevention Control and Countermeasure (SPCC) regulations. These regulations require that companies prevent and contain discharges of oil or petroleum products.

In determining whether these regulations apply, you must consider the capacity of your tanks and containers and not the actual amount of oil stored. You should be aware that the definition of oil is very broad and includes heating oil, crude oil, mineral oil, gasoline and diesel fuel. If you are subject to the SPCC rules, you must provide secondary containment for oil or petroleum product storage units to contain any releases. You must also prepare a written SPCC plan that describes all measures taken at your facility to prevent and control a release of oil or petroleum products.

The SPCC plan must be written within six months after you begin storing oil and it must be updated every three years, or whenever significant changes in oil storage occur. The SPCC plan must be signed by your management and certified by a professional engineer. You management must review and sign the plan every three years, even when there are no changes. The SPCC plan must be kept on-site and be available for review.

Oil Spills.  In the case of a spill, you must clean up the material spilled and any part of the environment affected by the release. If a spill occurs, you must perform the following cleanup steps:

1. Stop the release;
2. Contain the released used oil;
3. Clean up and properly manage the released used oil and other materials; and
4. If necessary, repair or replace any leaking used oil storage containers or tanks prior to returning them to service.
5. Notify the Department Spill Hotline by calling 860-424-3338. 

Links to the Regulations. Use the following links to view the regulations pertaining to used oil storage and management.

Connecticut Used Oil Regulations (22a-449(c)-119)

Technical Standards And Corrective Action Requirements For Owners And Operators Of Underground Storage Tanks (UST), Code of Federal Regulations, 40 CFR Part 280

Self-Audit Checklist

When an inspector comes to your facility, there are certain things he or she checks to see if you are in compliance with environmental regulations.  It makes good sense for you to think ahead and perform a “self-audit” and catch and correct problems before they result in penalties.  Also, there are some compliance incentives associated with self-audits (see Audit Policy Page).

Use the following list to audit your used oil storage areas and management procedures.

1. Is used oil stored in drums, tanks or other containers that are in good condition?  Open containers, and rusting or leaking containers cannot be used for oil storage.
2. Are used oil storage containers and tanks properly labeled?  All used oil storage tanks must be labeled "Used Oil." If underground tanks are used, then the fill pipes should be labeled.
3. Is the area around the used oil storage containers free of releases?  Releases must be stopped and the released material cleaned up and managed properly.  If a release of used oil occurs, it must be contained and reported to the CT-DEP.
4. Do you have a SPCC plan?  Verify whether your facility is subject to the SPCC rules. If so, maintain your plan, update it every three years and keep on-site for review.
5. Is used oil transported to a recovery facility by a certified transporter?  Check your records and verify that all shipments of used oil  were removed from your property by a state certified transporter. 
6. Is solvent or other materials mixed with used oil?  Verify that there are separate, clearly labeled containers for each type of material, and that used oil is not mixed with solvents and other materials.

Best Management Practices (BMPs)

Most regulations tell you what you have to do to be in compliance, but they don’t explain how to do it.  That’s where “best management practices” come into play.  BMPs are proven methods that help you to get into compliance and stay there.  The following BMPs are recommended for used oil storage areas and management procedures.

• Train your employees on the proper methods for handling used oil.
• Do not contaminate used oil with even small amounts of gasoline, brake cleaner, carburetor cleaner, or other solvents.  Even small amounts of solvents turn recyclable oil into a hazardous waste.
• Keep storage containers closed when not actively adding or removing material.
• When storing drums keep an aisle space between drums to allow for inspection for leaks and damage.
• Install secondary containment to prevent the release of used oil to the environment.
• Inspect containers and secondary containment structures on a weekly basis to be certain that they are in good condition.  Keep written records of these inspections for at least 3 years.
• Try to prevent spills when dismantling vehicles. If spills do occur, clean up with rags. After wringing out the saturated rag into the used oil drum, you can have the rags laundered. 
• Avoid using absorbents for oil spills unless there is a threat of the spill spreading to soil or water. Oily absorbents must be evaluated prior to disposal to determine whether they are hazardous or nonhazardous.
• Before contracting a transporter for your used oil, make sure to check for the transporter’s state certification.
• Get receipts for used oil shipments and store them in your records for at least 3 years.

Contacts

1. For more information, contact the Connecticut Department of Environmental Protections’ (CT-DEP) Bureau of Waste Management at 860-424-3021.
2. To report a spill or leak, immediately call the CT-DEP’s Oil and Chemical Response Division at 860-424-3338, 24 hours/day.  Should this number become unavailable for any reason, call 860-424-3333. Within 24 hours of the spill you are required to complete a written Report of Petroleum or Chemical Product Discharge.
3. To report an environmental incident or complaint, contact the CT DEP.

Related ECAR Fact Sheets

1. Used Oil Filters.
2. Hazardous Waste.

Other Relevant Resources

1. Connecticut Auto Recycling Guide
2. Connecticut — Proper Management of Used Oil
3. Connecticut — Regulated Wastes Fact Sheet

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