Properly managing used oil is important for four main reasons:
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 created or contributed to the creation of a hazardous waste site (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, used oil can be used as a base stock to produce new lubricating oil. Because used oil has heat value it can be burned as fuel. Properly burning the used oil keeps its heat value from being wasted and saves the virgin heating oil that would be burned instead.
This plan provides one source of written documentation for used oil records for the Community College of Rhode Island. In addition, this plan will inform interested persons, including College and contractor employees, of our compliance with Environmental Protection Agency (EPA) requirements (found at 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 College.
A copy of CCRI's used oil management plan may be reviewed by employees. It is located in the offices of the Security and Safety and College Police Department and in the office of the Director of Administration.
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 during "do-it-yourself" projects, from automotive sources, or during industrial 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).
At this facility, we generate used oil from routine maintenance of motor vehicle, snow blowers and lawn mowers. Since we do not mix engine lubrications oil with other wastes it does not contain any contaminants that would preclude it from being recycled.
The Community College of Rhode Island adheres to the following practices. We:
Our facility stores used oil in fifty-five gallon drums. We opted for drum storage of our used oil because we accumulate a relatively small amount of used oil each month. This facility follows these storage practices. We:
Recycling used oil cashes in on either its lubricating value or heat value. We use this method of management whenever possible because is easier to do and more cost effective than properly disposing of used oil.
At this facility, we recycle our used oil from vehicle maintenance. It is pumped out and taken away by a licensed recycling company because we consider it the most environmentally safe method.
Even though all steps have been taken to prevent leaks or spills from occurring, this company 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:
Whenever a mechanic changes 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 College. Used oil filters are not considered a hazardous waste under RCRA if they have been properly drained of oil.
When used oil filters are removed from a warm engine, the mechanic uses the gravity draining 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 properly disposed of.
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". The Community College of Rhode Island has chosen Western Oil, Inc. of Providence, RI. to transport used oil. Our transporter has an EPA ID number and complies with all relevant used oil regulations, including keeping tracking records of where the used oil is collected and where it will be transported to. When working with our transporter, we:
Although training is not strictly required under the regulations, we have designated Michael Archetto and Daniel Farrell to train personnel who will handle used oil. Direct any questions concerning used oil training to the Physical Plant Directors.
Under this plan, employees are informed of used oil management procedures relevant to the positions in which they work. This training occurs 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 doing each job. We also keep records describing the type and amount of training provided.
Our company performs the following reporting activities:
The Rhode Island Department of Environmental Management and the local fire and police departments of the cities of Warwick, Providence and Lincoln have copies of our emergency contingency plan.
The Department of Security and Safety and College Police is responsible for keeping and maintaining copies of the Waste Automotive Oil Manifest forms
The Chemical Safety Coordinator is responsible for:
Conducting periodic site audits. Keeping records of all inspections and reports. Updating the plan as needed by incorporating any necessary changes resulting from major changes in our facility's operation or maintenance.