Question: When I’m storing used oil, do I need to meet secondary containment or closed container regulations?
Answer: Yes, both closed container and secondary containment are required in order to be compliant when storing used oil. You may also need to be aware of a few more regulations as well.
Storing used oil properly is important because just one 55-gallon drum of oil can pollute 1 million gallons of drinking water and kill most wildlife in about one week. Keeping containers closed with latching drum lids and funnels and capturing spills at the source by slipping a spill containment pallet or deck under your drums is one of the best ways to prevent releases and water pollution.
The Environmental Protection Agency (EPA) allows used oil to qualify for a hazardous waste exemption if the oil is destined for a legitimate form of recycling and stored in appropriate tanks or containers that comply with the requirements of 40 CFR 264 or 265 [40 CFR 279.22(a)].
RELATED POST: Best Management Practice for Used Oil
If you don’t wish to recycle the used oil, you’ll need to make a hazardous waste determination and follow the appropriate hazardous waste generator rules that are applicable to that waste stream.
Because the EPA assumes that a facility generating used oil is going to recycle it, we’ll continue on with those requirements. Used oil needs to be stored in containers or tanks that are:
- Kept closed when oil is not being added or removed
- In good condition
- Not leaking
- Properly labeled
- Stored in a compliant secondary containment system
You are free to design a secondary containment system that meets your needs as long as it complies with the requirements of 40 CFR 264.175.That means that pallets, decks, berms and other methods are all among the possibilities that you can explore to create a compliant system.
RELATED POST: 5 Main Points of Secondary Containment Regulations
The main goals of keeping containers closed and providing a secondary containment system are to prevent used oil from entering the environment. You’ll also need to be prepared for releases, in the event that your secondary containment system and other countermeasures fail [40 CFR 279(d)].
It’s also important to note that if your facility has the ability to store 1,320 gallons of oil aboveground or 42,000 gallons in an underground storage container, you’ll also need to follow all applicable Spill Control and Countermeasures (SPCC) Rules [40 CFR 112]. For oil stored in underground storage tanks, 40 CFR 280 also applies.
Some states have additional rules. In fact, in some states, used oil is automatically considered a hazardous waste and is subject to state-specific hazardous waste storage rules. Local used oil recycling companies are often a good resource for more information on state-specific used oil requirements.
Download this white paper to learn more about used oil management and how to qualify for the EPA’s hazardous waste exemption.
Mark Grubersays:05/21/2019 at 10:22 am
My name, address & phone were required to drop off my used motor
oil today at a Victory Lane store, first time this has happened. I was
told this was required by the EPA. True?
Isabella Andersensays:07/02/2019 at 11:58 am
Hi there, at the federal level, there is a limit to how much used oil you can take to a collection center at one time (55 gallons) but there is no requirement to provide personal information when dropping off used oil at a used oil collection center.
This may be a state or local requirement, or it could be required by the store itself – especially if they have received used oil from do-it-yourselfers (DIY) that contains water or hazardous materials. When water or hazardous materials are mixed with used oil, it changes it from being a valuable product that can be recycled and reused to a waste that is very costly to treat and handle.
Many collection centers are not required to accept DIY oil: they do it as a community service. They dump the oil that they receive into the same tank with the oil that they generate at their establishment and then send it for recycling.
The company that recycles it will test it to make sure it is “just” used oil. If it is not, they can refuse to recycle it and send the whole load back to the collection center, or they could charge the collection center more money to treat and recycle it. Either one is a costly option for the collection center. If the collection center has been hit with excessive fees for their batches of used oil being “off-specification” (contaminated with hazardous materials, excessive metals, etc.,) they may be requiring identification from anyone bringing in DIY oil to help determine if someone in particular is causing the problem.
Hope this helps!
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