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printreg, December, 2002
"Inactive Equipment Containing Used Oil or Other Fluids"

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From: Debra Jacobson (djacobson@istc.illinois.edu)
Date: Tue, 24 Dec 2002 07:20:53

EPA regulates the oil in equipment and other related mechanical fluids such as coolant, etc. Keep in mind these requirements apply to the storage and transport of new and used equipment. This is a commonly overlooked issue when shipping equipment between plants, receiving new equipment, and storing obsolete or moth-balled machines. Take particular note of these requirements when considering storing any such equipment outside (note - stormwater permit issues too). Most states and many local governments have oil management requirements as well that you should be familiar with.
Debra Jacobson


How should materials contaminated with used oil be managed?
According to 40 CFR 279.10(c), most materials containing or otherwise contaminated with used oil from which the used oil has been properly drained or removed to the extent possible such that no visible signs of free-flowing oil remain in or on the material: - is not used oil and thus not subject to the used oil regulations in 40 CFR 279
- if the material displays a hazardous waste characteristic or is a listed hazardous waste, it is subject to the hazardous waste regulations
- if the material contains or is otherwise contaminated with used oil and will be burned for energy recovery, it can still be regulated as used oil under 40 CFR 279.

Source: Source: "reg of the day" listserv operated by Tammy Silverthorne @ the Environmental Resource Center

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