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Automotive Service &
Small Business Environmental Assistance
Program
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The Small Business Environmental Assistance Program (SBEAP) covers used oil disposal activities of all automotive service and repair shops, regardless of the amount of used oil generated. Topics
Used oil is any oil refined from crude oil or synthetic oil which has been contaminated by physical or chemical impurities as a result of being utilized. Examples of used oil are motor oil, hydraulic fluid, and piston engine crankcase oils. Other types of used oil include lubricants, emulsions, and oil coolants. Used oil is not waste oil. Waste oil comes from oil wastes that have not been used, such as virgin fuel storage tank bottoms or virgin fuel oil-spill clean up residue.
Stored used oil must be stored in compliance with existing underground storage tank or aboveground storage tank standards or in containers. Spills and releases must be
immediately stopped and cleaned up. Measures must be put in place to
prevent future releases. Spill materials used to clean up oil spills must
be properly disposed. Keep collection drums covered and labeled, in good
condition, secure from vandals, and in compliance with local fire codes.
Inspect frequently for leaks, corrosion and spillage. Label drums, tanks,
and piping with the words "Used Oil". Consider converting used oil
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It is in your best interest not to mix used oil with other materials without consulting your oil recycling company or the V.I. Waste Management Office of the Division of Environmental Protection. Generally, you can mix the following oil-based fluids with used engine oil:
Never mix gasoline, wastewater, a listed hazardous waste, an unknown waste, halogenated solvents or antifreeze with used oil.
Used oil that is moved off-site must be picked up by transporters that have an EPA identification number. Your used oil must be transported by a DPNR permitted used oil transporter. While the shop owner is not required to keep any formal records, it is best that a log be kept of who, how much, when and where the used oil was sent. All used oils should be sent for re-refining or burnt for energy recovery or for any other EPA or DPNR approved method. The used oil requirements are not burdensome. Common sense and good management practices are what is required to comply.
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Accepting used oil from the public is a two-edged sword for the auto shop owner. On one hand, the owner wants to offer a community service by collecting used oil and making sure it is properly disposed (sometimes voluntary, sometimes DPNR mandated). At the same time, the shop could be potentially liable to enforcement action if the used oil is not truly used oil. As a shop owner, it is imperative that you contact the V.I. Waste Management Office to get the facts on your responsibilities as well as liabilities. From the federal perspective, automotive service and repair shops which meet the "service station" definition are exempt from Superfund liability for used oil shipments, so long as the shop complies with the Used Oil Management Standard, and is willing to accept used oil from do-it-yourselfers (DIYs). Here are some guidelines to consider:
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Used oil may be burned on site for energy recovery if the oil has been tested and contains less than 1,000 ppm halogen content. Space heaters for burning used oil on site must not exceed a maximum capacity of 0.5 million BTU per hour. Combustion gases must be vented and must not exceed maximum allowable ambient air emissions. Contact SBEAP for information on federal and V.I. air quality regulations.
Generators of Used Oil
Storage of used oil must be in tanks, containers or other units subject to regulation. When storing used oil, containers and tanks must be in good condition and show no signs of severe rusting, apparent structural defects, deterioration or visible leaks. All tanks, underground storage tank fill pipes, and containers utilized to store used oil must be clearly labeled with the words "Used Oil." This includes drip pans and roll-around containers used for changing oil. Other provisions for storage of used oil require floors and secondary containment at transfer, processing and re-refining, and burning facilities. Floors must be of a material that oil cannot penetrate such as cement, clay, asphalt, plastic, or steel. The storage area must be equipped with dikes, berms, or retaining walls to prevent an oil spill from moving to soil, ground water, or surface water. Leaks must be stopped, contained, and cleaned up and measures must be taken to prevent future releases. |
Under EPA's final rule, effective on June 19, 1992, non-terne plated filters are exempt from the hazardous waste regulations if these oil filters have been gravity hot-drained using one of the following methods:
The EPA requires a minimum 12-hour hot-draining time period and defines hot-draining as drained at or near engine operating temperature and above room temperature (i.e., 60 degrees Fahrenheit). If a filter exhibits free liquids when the drain plate is turned down, then it is not considered drained. Terne, an alloy of tin and lead, serves as a plating on some oil filters. The lead concentration found in unused terne-plated oil filters can render the oil filter a hazardous waste. Heavy duty vehicle operations such as buses, semi-tractors, mining and construction equipment sometimes use terne plated filters. Typically, light duty vehicle operations such as automobiles and light duty trucks use non-terne plated filters. Your filter supplier or the manufacturer should be able to determine if the filter you are using is terne plated or non-terne plated. If you are using or generate a terne plated filter in your operation and you are a regulated generator, you must manage that filter in accordance with the regulations by testing the filter through the Toxic Characteristic Leaching Procedure (TCLP) to determine if the filter is hazardous waste. If the filter exceeds the regulatory standard of 5 ppm lead, then the filter must be managed in accordance with the V.I. Hazardous Waste Regulations. |
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