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ECAR Fact Sheet for Pennsylvania
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
Waste 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.
This fact sheet will tell you what
you need to do to avoid problems with used oil.
Regulations
The Pennsylvania Department of Environmental
Protection (DEP) views used oil as a marketable product that can
be sent off-site for recycling. However, the DEP also recognizes
that if used oil is not properly handled, it can cause significant
environmental damage. For these reasons, used oil has special
rules that don’t apply to some other materials. These rules deal
with the storage of oil, cleanup of spills and transport of oil
off-site.
In Pennsylvania, used oil is not
regulated as a hazardous waste if it is recycled or burned as a
fuel. This means that your used oil, if not mixed or contaminated
with other compounds (e.g., gasoline, solvents, degreasers), can
be managed under the used oil regulations (see link below). Some
examples of used oil include used engine oil, lubricating oil, gear
oil, transmission fluid, brake fluid and hydraulic fluid. Used oil
is not the same as waste oil.
Burning Used Oil as Fuel. In general, generators may burn used oil in oil-fired space heaters.
The heater must burn only used oil that the owner or operator generates,
on specification oil, or used oil received from household "DIY"
generators. The heater must be designed to have a maximum capacity
of not more than 0.5 million Btu/hr and the combustion gases must
be vented to the outside air.
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. For a list of used oil recycling
companies, see the link under "Other Relevant Resources."
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 cleaning
solvents or fuel. 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.
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 "Waste 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.
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. If a spill occurs,
you must perform the following cleanup steps:
- Stop the release;
- Contain the released used oil;
- Clean up and properly manage the
released used oil and other materials; and
- If necessary, repair or replace
any leaking used oil storage containers or tanks prior to returning
them to service.
- Notify DEP’s 24-hour hotline at
800-541-2050.
Links to the Regulations. Use
the following links to view the regulations pertaining to used oil
storage and management.
Pennsylvania
Code Used Oil Management Regulations
Federal
EPA Used Oil Management Requirements
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.
- 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.
- Are used oil storage containers
and tanks properly labeled? All used oil storage tanks
must be labeled "Waste Oil." If underground tanks are used, then
the fill pipes should be labeled.
- 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 DEP.
- 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.
- 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.
- 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 fuel, solvents and other materials
that may make the mixture a hazardous waste.
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 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
- For more information, contact
the DEP’s Bureau of Waste Management at 800-346-4242.
- To report a spill, contact DEP’s
24-hour hotline at 800-541-2050.
- To report an environmental incident
or complaint, contact the DEP
Field Office
Related
ECAR Fact Sheets
- Used
Oil Filters.
- Hazardous
Waste.
Other
Relevant Resources
- Pennsylvania
Used Oil Collection and Recycling Sites
- DEP
Used Motor Oil Recovery
- DEP
Regulations on Used Oil Management
- Recycle Used Oil Filters
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