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)].
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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.