Properly managing used oil is
important for four main reasons:
-
To protect the environment.
- To protect human health.
- To protect against liability for environmental damages.
- To reuse, rather than waste, a valuable resource.
Used oil, even when not
classified as a hazardous waste under RCRA, can have harmful effects if it
is released into the environment. In addition, people's health can be
affected if used oil is handled improperly.
Superfund regulations allow
the federal government to hold any party that creates or contributes to
the creation of a hazardous waste spill (including some used oil)
financially responsible for cleanup costs.
Used oil is a valuable
resource because it has lubrication value and heat value. When treated to
remove contaminants, the used oil can be used as a base stock to produce
new lubricating oil. Used oil also has heat value and can be burned as
fuel. Properly burning used oil keeps its heat value from being wasted
and saves virgin heating oil that would be burned instead.
Purpose:
BYU-Idaho has developed this
plan to properly handle used oil at various campus sites. This plan
informs employees about the university's compliance with Environmental
Protection Agency (EPA) requirements (40 CFR
279) for used oil
generators.
This plan provides a written
description of used oil management procedures, disposal methods, and
transportation requirements. We encourage any suggestions that our
employees have for improving our written plan for used oil management, as
we are committed to developing and maintaining an effective protocol. We
strive for clear understanding, environmentally sound practices, and
involvement in the plan from every level of the company.
Administrative Duties:
The BYU-Idaho Safety Office
is responsible for developing the written used oil management plan; for
ensuring that our written plan is complete, kept up to date, and made
available to applicable or required authorities; and for maintaining used
oil management records. A copy of our used oil management plan may be
reviewed by employees. It is located on the Safety Office Web Page which
can be accessed from the main university web site.
Used Oil Defined
The 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." Used oil can be generated from automotive
sources, or during Physical Plant maintenance operations. This includes
oils that are used as hydraulic fluid as well as oils that are used to
lubricate automobiles and other machinery, cool engines, or suspend
materials in industrial processes. Oils used for these purposes can become
contaminated with physical materials (such as metal particles from engine
wear) or chemical contaminants (such as gasoline combustion products, like
toluene).
Used Oil Management
At this facility, used oil is
generated from Physical Facilities Service Station, HVAC Shop, Electrical Shop
and Vehicle Maintenance Shop as well as from the Farm Mechanics facility,
the Austin Building automotive labs and livestock center operations.
The university adheres to the
following practices. University personnel are expected to:
==> Never dump or
dispose of used oil in the trash, in sewers, storm drains, or on the ground.
==> Make sure our collection and storage set-up is
leak proof, spill proof, and
that tanks have lids or are covered to prevent water from entering.
The storage set-up must also include a spill containment area/container.
==> Control access to prevent dumping of materials into a storage container
when it is not supervised.
==> Maintain our collection containers regularly, comply with local fire and
safety regulations, and avoid leaks and spills.
==> Label storage tanks "Used Oil."
==> Clean up any used oil spills or leaks. This includes providing soak-up
material (e.g., kitty litter, or a commercial sorbent product) for minor
spills. It keeps the area clean and helps prevent personal injury.
==> Keep records of used oil transported by contractors for recycling or
disposal.
Storing Used Oil
The university stores used oil
in specifically designed and labeled waste oil drums with secondary
containment. Drum storage for waste oil is utilized because generators
accumulate a relatively small amount of used oil each month, or used oil
is accumulated from different sources which must be segregated until it
can be tested for contaminates. This facility follows these storage
practices. University personnel are expected to:
Never mix used oil with any other material. This facility keeps gasoline,
solvents, degreasers, paints, and so on, from making the used oil a
hazardous waste and increasing collection costs.
Carefully record the amount of used oil placed into and removed from
storage devices. Record keeping plays an important role in leak detection
for ASTs, USTs, and drums.
Have constructed secondary containment around our drums/tanks with a
capacity for 100 percent of the contents of the drums we store; the base
of the containment area is sloped so that any spilled oil may be
recollected and removed.
Equip storage containers with wide-mouth, long-necked funnels to reduce
spills during filling.
Equip storage containers with a pressure relief valve to reduce a build up
of pressure, which could cause leaks.
Keep sorbent materials nearby to clean up any spills that occur.
Keep the area near the storage devices neat and clean.
Responding to Releases of
Used Oil
Even though all steps have
been taken to prevent leaks or spills from occurring, the university is
also prepared to respond to spills of used oil. We instruct workers to use
the following protocol to manage spills of used oil and provide any
necessary equipment:
Stop the release. This action will vary depending on why the release is
occurring. For example, if the spill occurs because a 55-gallon drum has
been knocked over, the drum should be righted to stop more used oil from
being released.
If the spill occurs because a valve on a storage device has been left
open, the valve should be closed. If a leak is a result of a puncture in
the tank or drum, rags or similar materials should be used to plug the
leak.
Contain the release. We strive to prevent the used oil that has been
released from spreading. For example, a sorbent should be spread over the
spilled used oil.
Clean up the release. Depending on the extent of the release, cleaning up
the used oil can be a simple or a complicated task. For small spills on
the ground, the soil can be dug up and disposed of. (The soil must be
tested to determine if it exhibits hazardous characteristics.) For larger
spills where puddles of used oil have formed, vacuum-type machinery can be
used to collect the used oil before the soil is dug up for disposal.
Because releases that contaminate a great deal of soil or ground or
surface water are very difficult to clean up, the university contacts
professionals to conduct the cleanup operation.
Properly manage the used oil that has been cleaned up. Any leaked or
spilled used oil is managed just like any other used oil under 40 CFR 279.
Properly manage the solid materials generated during the cleanup. We place
solid materials used to clean up a spill of used oil in a sieve-like
container to allow the used oil to drip from the solid materials into a
storage device. In addition, we compact the materials to remove the used
oil. (Removal is complete when there are no more signs of free-flowing
oil.) Materials contaminated with used oil that are burned can be managed
in the same manner as used oil.
Contaminated materials that will not be burned for energy are tested to
determine if they exhibit hazardous waste characteristics. If they do not
test hazardous, they are disposed of in a RCRA subtitle D facility. If
they are hazardous, they are disposed of in a RCRA subtitle C facility.
Remove the storage device from service and repair or replace it.
Managing and Disposing of
Used Oil Filters
Whenever university personnel
change the oil in a fleet vehicle, the oil filter is also changed to keep
the solid contaminants of the old oil from immediately contaminating the
new oil. Used oil filters can contain 10 to 16 ounces of used oil,
therefore proper management of this source of used oil is a concern of the
university. Used oil filters are not considered a hazardous waste under
RCRA if they are not terne-plated and have been properly drained of oil.
When used oil filters are
removed from a warm engine, the university uses the Gravity draining -
when the filter is removed from the engine, it should be placed with its
gasket side down in a drain pan. If the filter has an anti-drain valve,
the "dome end" of the filter should be punctured with a
screwdriver (or similar device) so that the oil can flow freely. The
filter should then be allowed to drain for 12 to 24 hours. method to drain
the filter.
We store our drained used oil
filters in a covered, rainproof container to prevent used oil from being
washed from the filters to the surrounding environment. Our used oil
filters are then recycled or properly disposed of.
Shipping/Transporting Used
Oil
All used oil transported from
the BYU-I campus is managed through the University Safety Office -
Hazardous Materials Specialist.
The used oil management
standards define a used oil transporter as any person who transports used
oil, any person who collects used oil from more than one generator and
transports the collected oil, and owners and operators of used oil
transfer facilities." BYU-Idaho has chosen Safety Kleen to transport
our used oil. Our transporter has an EPA ID number and complies with all
relevant used oil regulations, including maintaining tracking records of where
the used oil is collected and where it will be transported to.
When
working with our transporter, we:
Ensure that the hauler has a current EPA ID number.
Measure the level of oil in a tank before and after the hauler collects it
to be certain the oil collected matches the amount the hauler reports
collecting.
Make sure a company representative signs and dates the hauler's tracking
sheet.
Receive a receipt from the transporter that states how much used oil was
collected from our facility and where the used oil will be taken.
Make sure that the hauler maintains storage tanks/containers; labels
containers "Used Oil"; stores used oil over oil-impervious
surfaces; has secondary containment structures in place; stores used oil
for no more than 35 days; tests waste in out-of-service tanks; closes
out-of-service tanks containing hazardous waste according to EPA
standards.
Employee Training
Although training is not required under the regulations, we have designated the Safety
Office to train personnel who will handle used oil. Direct any questions
concerning used oil training to this office.
Under this plan, employees
are informed of used oil management procedures relevant to the positions
in which they work. This training occurs both in the classroom and on the
job.
We keep records of job titles
and written job descriptions for all positions related to used oil
management and the names of employees filling each job. We also keep
records describing the type and amount of training provided.
Related Requirements
Related regulations that we
must still comply with include:
Underground Storage Tank regulations (40 CFR 280)
Spill Prevention Control and Countermeasures requirements (40 CFR 112)
Hazardous Materials Transportation Act regulations (49 CFR 130)
Resource Conservation and Recovery Act requirements (40 CFR 260-268)
Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution
in Commerce, and Use Prohibitions (40 CFR 761). 40 CFR 761.20(e), contains restrictions, and testing and
record keeping requirements for marketers and burners.
Please see related documents
for information on how the university meets these additional requirements.
Reporting
BYU-Idaho performs the
following reporting activity:
Reports are
submitted to the Idaho Division of Environmental Quality as required
and
to the Idaho Division of Hazardous Materials pursuant to established
reporting procedures.
Record keeping
The University Safety Office
is responsible for keeping the following records:
The Idaho Hazardous Waste
Generator Annual Report, the Emergency and Hazardous Chemical Inventory
Report and waste disposal records.
Maintaining the Plan
The BYU-Idaho Safety Office
is responsible for:
Conducting periodic site audits.
Keeping records of all inspections and reports.
Reviewing and updating the plan as needed by incorporating any necessary
updates resulting from major changes in our facility's operation or
maintenance or by changes in government regulations.