"Do -It- Yourselfer" Recycling
Department of Environmental Protection
GUIDELINES FOR SITING
Many New Jersey residents change their own motor oil in their cars, boats and lawnmowers. Although this oil should be collected and recycled, much of it is disposed of improperly, and eventually finds its way onto our land and into our lakes and streams. Used oil contains toxic substances, (halofgens, organics, PCBs) aand metals (lead, cadmium, chromium, arsenic), which are generated during engine use, and which are contained in oil additives designed to improve engine performance. These contaminants can harm fish and wildlife, and can easily enter the food chain.
Still, many New Jersey residents do not realize that disposing of used oil by pouring it down the drain or in the back yard, or even putting it out with the trash, or using it for dust suppression, is illegal, under the regulations at N.J.A.C. 7:26A-6, and can cause environmental damage. The only acceptable way to dispose of used motor oil is to bring it to a used oil collection site, where it will be transferred to a registered waste transporter, for transport to a recycling facility where it will either be reprocessed for use as boiler fuel or re-refined into "new" lubricating oil.
State law (NJSA 13:1E-99.36) requires all retail auto mechanic services with oil collection tanks to accept used motor oil from DIYs. Additionally, many municipalities and counties, and retail businesses offer collection programs. Further, towns and counties educate "Do-It-Yourselfers" (DIYs) in proper recycling. But there is a need for both more outreach, more cooperation from small auto repair businesses, and additional collection sites, and it is important that the sites be designed to protect the environment and promote the success of the collection program.
Who can benefit from this guide?
Whether you own an auto repair shop or represent a government or volunteer organization, this guide can help you plan a collection site that works well for you and the community. You may be setting up the site at a city- or county-owned facility, fire station, landfill or transfer station, recycling center, or a privately owned business. The guide addresses the concerns that frequently arise: the costs of establishing a collection site, the receipt of contaminated used oil, and the liability for any costs of disposal.
These guidelines were developed in 1992 by the New Jersey Department of Environmental Protection, (NJDEP) in conjunction with the Division of Law, the Compliance and Enforcement Program, and local recycling coordinators, to assist you in siting used oil collection tanks. This 2001 revision aligns the guide with recent regulatory changes.
The guide is more specific to New Jerseyís environmental regulations than the USEPAís guide, "How To Set Up A Local Program To Recycle Used Oil". The Department recommends this and other USEPA guides available at www.epa.gov/epaoswer/hazwaste/usedoil/index.htm.
You may wish to retain the services of a qualified N.J. Licensed Professional Engineer for the siting and design of your used oil collection facility, or you may find that this is not necessary. For any additional information, you may contact the individuals listed throughout the guide, or Sondra Flite, NJDEP Bureau of Recycling and Planning, at (609)984-4621.
SITING USED OIL COLLECTION TANKS
What locations make the best used oil collection sites?
Repair shops, Public Works yards and recycling centers arenít the only appropriate sites; consider landfills, transfer stations or waste-to-energy facilities, or other publicly-owned property. The site that's best for a particular area will depend upon ease of access, and the environmental sensitivity of the area. Consider establishing a cooperative arrangement with a private entity, such as a local auto parts store or other motor oil retailer. Retailers are required to post signs informing the public of the importance of the proper collection and disposal of used oi1, but are not currently required to accept used oi1 from the public. (See N.J.S.A. 13:1E-99.36, section 44 of New Jersey's Mandatory Recycling Act.)
NJDEP recommends that the local Fire Marshall and building inspector be contacted prior to siting the collection tank, for information on any local regulations or permit requirements.
What type of tank should I use?
NJDEP's Solid and Hazardous Waste Management Program strongly recommends the use of above ground storage tanks for used oil collection. Underground storage tanks are now subject to extensive State and Federal regulations. Should a leak occur in an underground storage tank, it is much more costly to repair, and the tank owner is liable for all costs of site cleanup and remediation, including excavation and disposal of any contaminated soil surrounding the tank.
Above ground tanks are preferable to drums, as drums are not suitable for long-term storage, with repeated and constant handling. Cylindrical, horizontal tanks with supports that keep the tank just high enough off the ground to be visually inspected are suitable. NJDEP recommends a double-walled tank with a screened and covered drainage area. The tank should be maintained in good condition, free of any rust or corrosion. It should be constructed of material that meets the American Petroleum Institute and the American Society of Lubricating Engineers Standards for flammable and combustible liquids (UL No. 142 Standard). The tank should be equipped with a wide-mouthed, long-necked funnel, or other similar apparatus, in order to minimize spillage when transferring used oil into the tank. The tank should also be equipped with a pressure relief valve or vent to provide tank ventilation. This is of the utmost importance in preventing a build-up of potentially volatile fumes within the tank.
A lock on the tank is recommended, to keep material from being emptied into it after hours, or when the tank is not attended. If residents are expected to leave their jugs of used oil at the site, to be emptied into the tank by an employee, the collection area for the jugs should be clearly marked. A fence around the collection site, with locking gate, is recommended if the collection tank itself does not have a lock.
A tank gauging or measuring stick is also recommended, to avoid overfilling. Caution should be exercised to prevent damage to the tank, which may result from careless handling of the stick. Repeated jabbing with a measuring stick can lead to a weak spot in the bottom of the tank. A reinforcement, such as a metal plate, may be needed to maintain tank integrity.
If a drum is used as a short-term collection tank, it should meet DOT specifications for usability. It should be kept closed, except when filling or emptying, and should be equipped with a funnel to prevent spillage. The recommendations in the section entitled How should the site be prepared? would also apply to drums.
Regardless of the type of tank used, the tank should be visually inspected for signs of rust or corrosion on a monthly basis.
What tank size is best?
A tank designed to hold 150 or 275 gallons should be sufficient, but a large town may find it useful to obtain a larger tank. Bear in mind that Federal Oil Pollution Prevention Regulations (40 CFR Part 112) require the development of a Spill Prevention Control and Countermeasures (SPCC) Plan for facilities that store over 1320 gallons of oil above ground. SPCC Plans are not required for facilities with 1320 gallons or less, provided no single container has a capacity In excess of 660 gallons. In other words, a single tank containing 750 (greater than 660, but less than 1320) gallons would require an SPCC Plan, but two standard 500 gallon tanks at one site would not.
For further information on SPCC regulations: Contact Christopher Jimenez, USEPA, at (732)906-6847.
How should the site be prepared?
The tank site should be prepared so as to contain any leaks or spills which might occur. This requires both a secondary containment structure for the collection tank, and weather protection. This protection is not required by law, but NJDEP recommends that the operator of the used oil collection center should protect against possible releases.
The secondary containment should consist of a concrete pad surrounded by concrete retaining walls high enough to hold at least 110% of the contents of the tank(s) in case of a rupture. The walls should be far enough from the tank(s) to contain any release. Some tanks are now sold with built-in steel containment systems.
It is recommended that the tank should be protected from the weather to prevent rainwater from accumulating in the containment structure. A metal roof (not wood) over the tank, with open sides to prevent a build-up of fumes, is sufficient.
A sump, or depression, in the floor of the containment structure will allow liquids to pool in one spot, so that any oil or water can be easily removed. If a sump is provided, the floor of the containment structure should be sloped so that liquids flow toward the sump.
Absorbent materials, such as sawdust, sorbent granules or sorbent pads, should be kept on hand to soak up any minor spills that may occur.
What types of signs are needed at the collection center?
The following information should be included on signs posted at the used oil collection center:
Although only the first item is required by law, the others will facilitate cooperation from Do-It-Yourselfers". The second will remind residents of the importance of keeping their oil uncontaminated, and may prevent contamination of the oil and consequent higher disposal costs.
What costs are involved in establishing and maintaining a collection site?
It is estimated that an environmentally sound used oil collection site can be prepared for approximately $2500 - $3000. If your business already collects used oil, you may find no need to add capacity. The total cost depends on the type and size of the tank purchased, and whether the site preparation is done in-house or contracted out.
In addition to the capital costs of setting up the site, you may expect to be charged a fee to have the used oil removed from the collection tank. This fee is generally in the range of $0.10 to $0.25 per gallon. The value of used motor oil fluctuates in relation to the value of crude oil. Collectors are allowed to charge a small fee to cover expenses.
Do I need an attendant on duty at the site?
NJDEP strongly recommends that the collection site be attended. The attendant should visually inspect the contents of each container of used oil before emptying it into the tank. This will help to ensure that only used oil is being deposited in the tank, and not other materials, such as antifreeze, gasoline, paint thinner or other solvents, which will contaminate the contents of the tank, and result in higher costs to have the oil removed. The attendant, rather than the Do-It-Yourselfer, can then pour the used oil into the collection tank, which will help to minimize the risk of spilling.
As an extra precaution against contamination, some collectors require residents to sign a log when they drop off their used oil. You may wish to consider establishing a practice such as this. Some municipalities scan incoming used oil with a halogen detector to detect unwanted contamination before the oil is placed in the tank. Halogen detectors are hand-held devices that detect the presence of added hazardous substances which contain halogens, such as pesticides and solvents. Halogen detectors can be purchased through safety equipment suppliers, starting at about $100. Transporters often use them to determine the total halogen content of the used oil. If the total halogen content is above 1,000 ppm, the used oil may be regulated as a hazardous waste.
Provide your staff with oil-resistant gloves and splash goggles, to protect them from exposure to used oil.
When the collection tank is full, how do I go about having the oil removed?
Used oil must be transported by a solid waste hauler registered with NJDEP. Transporters are listed in the yellow pages, and a list of all registered transporters may be obtained from the Licensing and Registration Unit of the Department's Waste Compliance and Enforcement Program at (609) 292-7081. Some used oil recycling facilities also provide pick-up service. For a list of NJDEP-registered Class D recycling centers that handle used oil, visit the Solid and Hazardous Waste Management Programís website, at www.state.nj.us/dep/dshw.
You may want to sign a contract with a transporter for a specified period of time, at a set rate. Don't wait until your tank is filled to capacity before making arrangements to have it emptied!
You may also wish to include in the contract provisions for handling used oil which has become contaminated by the addition of incompatible materials. If the tank is contaminated with water, the waste transporter will probably be able to accept it, but at a higher cost. Many solid waste transporters also register a vehicle for the removal of hazardous waste, and can remove the occasional "hot load" as well. Discuss whether this will entail an extra charge.
You may wish to contact other collectors in your area, to find out what experiences they have had with their transporters, any charges or payments they have received for the oil, and the quality and timeliness of service. Charges or payments will vary, depending on the transporter, the time of year, and the region of the state.
What type of record-keeping is required?
Because used oil is rarely hazardous waste, you should not initiate a hazardous waste manifest. Your solid waste transporter should provide you with copies of the bills of lading or other shipping papers. You must retain receipts for three years, indicating the name of the waste transporter, date and amount of used oil collected. (See N.J.A.C. 7:26-7.7). If your agency is a municipality, this information should be included on the annual municipal /county tonnage grant application, so that you receive credit for the amount of used oil collected for recycling. If your agency is a private entity, please let your municipality know how much oil you recycled during the calendar year.
What should I do if there's an accidental oil spill?
Itís best to train your staff so that they know what to do in case of a spill. First, the attendant should take immediate action to contain the spill. The oil should be soaked up using an absorbent material such as sawdust, sorbent granules or sorbent pads, until there are no free liquids remaining. The cleanup wastes should then be triple-bagged, and disposed of as New Jersey ID27, non-hazardous dry industrial waste, in your commercial trash.
If the spill remains within the secondary containment, you need only clean the spill and dispose of the sorbents. If the spill escapes the secondary containment, then you must report it to the NJDEP Hotline, at 1-877-WARN-DEP, or 1-877-927-6337.
What about the disposal of used oil filters or containers?
Filters may be recycled for their steel content. Whether generated by the public, service stations, or public works departments, these filters are not regulated as waste if they are collected for recycling, and if all free-flowing oil has been removed. Recommended practices for the removal of oil include crushing the oil filter and piercing the filter and allowing all free-flowing oil to drain. Any method is acceptable that removes all free-flowing oil. Although you may dispose of the drained filters with your trash, NJDEP encourages their recycling, and DIYs will probably show interest in recycling them.
The jugs or containers used by residents to transport the used oil to the collection site can either be disposed of as household waste, after all free-flowing liquids have been drained into the collection tank, or reused when it's time for the next oil change.
Can we burn the used oil we collect in a waste oil space heater?
This was formerly illegal, and is still limited by regulation. The December 6, 1999, Used Oil Combustion Rule can be found on DEPís Air Quality Regulation Program web site (www.state.nj.us/dep/aqpp). N.J.A.C. 7:27-20.3 "Burning of On-Specification Used Oil in Space Heaters Covered by a Registration" allows you to file for a registration to burn used oil if your boiler meets the specifications. Major registration requirements are that only used motor oils be burned, the total gross heat input of all used oil space heaters at the facility is not greater than 500,000 BTU/hr (approximately 3.5 gallons per hour), and an annual tuneup be conducted. If the boiler does not meet the specifications, you may still apply for a an Air Pollution Control Permit application, pursuant to N.J.A.C. 7:27-20.4. Several such permits have been granted. These regulations are intended to protect the health of staff in the shop heated by the used oil.
For detailed specifications and guidance in application, contact Mr. Joel Leon, NJDEP, Air Quality Regulation Program, at (609) 984-3019.
Environmental Protection Agency Publications: Many publications are available from USEPAís website, at www.epa.gov/epaoswer/hazwaste/usedoil/index.htm.
Specifically, the Environmental Regulations and Technology Report, "Managing Used Oil", EPA Document Number: EPA/625/R-94/010 , may be ordered at no charge. Call or fax your request to ORD Publications at (phone) 513/569-7562 or (FAX) 513/569-7566.
USEPA document number EPA530-F-96-004, November 1996, entitled "Managing Used Oil: Advice For Small Businesses", may be ordered from the RCRA hotline: Phone: 800 424-9346 or TDD 800 553-7672, Fax: 703 412-3333
Additionally, the Hotline answers questions on matters related to used oil, solid waste, hazardous waste, or underground storage tanks.
Household Hazardous Waste Project, University of Missouri: Waste Management publication WM6010, "Household Hazardous Waste Management: Setting Up a Used Oil Collection Site", available at http://muextension.missouri.edu/xplor/wasteman/wm6010.htm . The Household Hazardous Waste Project is a program of the University of Missouri Extension System. Contact: HHWP, 1031 E. Battlefield, Suite 214, Springfield, MO 65807, (417) 889-5000.