Texas Used Oil Management: A Practical Guide For Environmental Compliance

Used oil management in Texas provides significant and unique compliance challenges. In an effort to assist those that are involved in or contemplating participation, this guide has been developed to provide an overview of used oil management environmental compliance requirements associated with Used Oil Handlers (UOH) in Texas. The typical facility covered by this guide would store from 50,000 gallons to 1,500,000 gallons, and perform used oil collection services and used oil filter and absorbent collection with limited processing. Generator, Storage, Processor, Re-Refiner, Transfer Facility, Transporter,Marketer, and Do-it-Yourself Collection Center requirements are addressed. This guide does not address all the requirements associated with operation of a used oil refinery. The content of this guide addresses the state of Texas and federal requirements associated with defining used oil intended for recycle under the Resource Conservation and Recovery Act (RCRA); permitting; associated compliance; storage; reporting; Texas Commission of Environmental Quality (TCEQ) overview; enforcement; TCEQ support; oil spill prevention associated with Spill Prevention, Control, and Countermeasure (SPCC) and Facility Response Plan (FRP) requirements; Tier II reporting, Environmental Management Systems (EMS); and compliance training associated with permits and plans. This guide provides a limited overview and possible applicability requirements related to The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) associated with All Appropriate Inquiry (AAI), due diligence associated with sale or facility acquisition, Clean Air Act (CAA), Clean Water Act (CWA), Resource Conservation and Recovery Act (RCRA), and Texas Industrial And Hazardous Wastes management. This guide is intended to provide awareness of the typical associated environmental compliance with comments provided by the author from decades of corporate, company on-site compliance management, and consultant services provided to petroleum facilities.