Community College of Rhode Island

Used Oil Management Plan

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 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.

Purpose

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 Campus Police Department and in the office of the Dean of Administration.

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 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).

Used Oil Management

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:

• Never dump or dispose of used oil in the trash, in sewers, 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.

• Use lockable fills to prevent dumping of materials into the tank when it is not supervised.

• Maintain our collection containers regularly, comply with local fire and safety regulations, and avoid leaks and spills.

• Post a "Waste Oil" sign over each collection drum.

• Label storage drums "Used Oil." In addition, each drum must have a hazardous waste label with the following information written on it:  Waste Oil, Combustible Liquid, UN 1270, Packing Group 3 and Class 3.

• Clean up any used oil spills or leaks. This includes providing soak-up material (e.g., sawdust, kitty litter, or a commercial product) for minor spills. It keeps the area clean and helps prevent personal injury.

• Keep records of used oil removed by outside vendors.

Storing Used Oil

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:

• 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.
• 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.
• Keep sorbent materials such as kitty litter and sawdust to clean up any spills that occur.
• Keep the area near the storage devices neat and clean.

Recycling Used Oil

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.

Responding to Releases of Used Oil

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:

• 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, such as kitty litter or sawdust, 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 removed by a licensed cleanup company. (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 College maintains a list of professional cleanup vendors to conduct the cleanup operation.
• Properly manage the used oil that has been cleaned up. Any leaked or spilled used oil is managed like a hazardous waste 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 into a leakproof storage device.  Materials contaminated with used oil are managed in the same manner as hazardous waste.
• 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 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.

Shipping/Transporting Used Oil

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:

• Know that the hauler has an EPA ID number.

• Check our used oil hauler's qualifications to make sure the hauler takes the oil to a reputable recycling operation.

• 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.

• Ask for a receipt from the transporter that states how much used oil was collected from our facility and where the used oil will be taken. (These records are not required under the used oil management standards, but may be useful should a problem arise.)

• 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 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.

Reporting

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.

Recordkeeping

The Department of Security and Safety and Campus Police is responsible for keeping and maintaining copies of the Waste Automotive Oil Manifest forms

Maintaining the Plan

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.