RCRA - STORAGE/DISPOSAL > Overview

Although it is probably not a large volume waste stream, the used oil that is generated by the cafeterias on your campus must be managed according to regulations. To meet the statutory requirements of the Resource Conservation and Recovery Act (RCRA), in 1992 the EPA finalized standards for generators, transporters, transfer facilities, collection centers, processors, refiners, burners and marketers of used oil (40 CFR 279). This section of the EVC treats the following three RCRA categories of used oil:

• Used Oil Storage/Disposal
• Used Oil Record Keeping
• Used Oil Training/Other

Since the cafeterias on your campus do not operate as a transporter, transfer collection center, processor/refiner or burner and marketer of used oil, the regulations governing these activities are not addressed in the EVC. More typically, your facility generates, stores and has a contractor transport the used oil off site to a permitted facility for disposition. As mentioned in the activity introduction, oil that has been used in a cafeteria setting (i.e., cooking oil) does not fit the EPA's definition of used oil, so it is not regulated under 40 CFR Part 279. However, it should be containerized and kept separate from the regular trash until it is disposed of or recycled.

Most states have record-keeping and emergency-preparedness requirements for used oil. The following are the Massachusetts Department of Environmental Protection's (DEP's) requirements:

• Labeling: The oil must be stored in a tank allowed by DEP and labeled "USED OIL." The date oil is first deposited in it should be marked on the tank, and the oil must be transported offsite within 6 months of that date. Each new collection cycle must be documented similarly.
• Inspections: The attendant should perform regular inspections of the collection area to assure that the containers of the collected materials are tightly covered and not leaking or deteriorating.
• Generator ID/Status: You will need a site-specific generator ID number. If you collect only used oil, at a volume of less than 275 gallons per month, you can use the DEP registration form. If you collect more than 275 gallons of used oil per month, you will need a federal EPA ID number.
• Record Keeping: All shipping records for oil and other hazardous waste should be kept in your files for at least 3 years.
• Emergency Preparedness: Employees handling used oil must have immediate access to alarm or communication devices, either directly or through another employee. To minimize the risk of fire or a release, you should have a telephone or two-way radio, with the following information posted nearby:

The cafeteria must also have portable fire extinguishers and/or fire control equipment (e.g., foam or inert gas), absorbent materials and spill/decontamination equipment.