TSCA, Tanks and Trouble

TSCA, Tanks and Trouble One Program’s BMP Update for Used Oil -Rick Gilbert, Kitsap County Solid Waste


TSCA, Tanks and Trouble. One Program’s BMP Update for Used Oil -Rick Gilbert, Kitsap County Solid Waste. Kitsap County, Washington. Locations Volume “If It Ain’t Broke…” Is it Broke? Operations Policies Incidents Other Issues. Current Used Oil Program. - PowerPoint PPT Presentation

Transcript of TSCA, Tanks and Trouble

Page 1: TSCA, Tanks and Trouble

TSCA, Tanks and TroubleOne Program’s BMP Update for Used Oil-Rick Gilbert, Kitsap County Solid Waste

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Kitsap County, Washington

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Current Used Oil Program

• Locations• Volume• “If It Ain’t

Broke…”• Is it Broke?• Operations

Policies• Incidents • Other Issues

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Hey, Look What Was in the Paper!

• EPA Enforcement Against City of Tacoma

• Very Similar Collection Program to Ours

• If it can Happen There…

News Releases from Region 10City of Tacoma settles with EPA for violating federal rules on PCBs in used oil

• Release Date: 09/30/2013Contact Information: Suzanne Skadowski, EPA Region 10 Public Affairs, 206-295-4829, [email protected]

(Seattle – September 30, 2013) The City of Tacoma has settled with the U.S. Environmental Protection Agency for violating federal rules on used oil contaminated with toxic polychlorinated biphenyls or PCBs.

“Today’s settlement should serve as a reminder that handling used oil requires attention to the requirements designed to prevent the distribution of PCBs,” said Edward Kowalski, Director of EPA’s enforcement program in Seattle. “Simple testing for PCBs before shipping used oil off-site helps protect people and the environment and prevents contamination of oil that can otherwise be recycled and reused.” …

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The EPA TSCA Response to Finding Collaborative Solutions…

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Now What?

• Ecology’s Response?• Vendor’s Response?• Do We Take Our Chances and See What

Happens?• Do We Ditch our Program and Start Over?

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Somewhere Between Nothing and Radical Change…

• Considerations• Future Enforcement• Unclear Path

Forward• Customer Demand• Geography• Infrastructure

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Best Management Practices

• Volume Limits• Product Limits• Source Limits• Declaration Form• Attendant Oversight


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Best Management Practices

• Outreach

• Signage• Press Release• Handouts• Web Changes• Brochure Changes

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Looking Ahead

• Development of Ecology’s BMP’s

• Response (if any) from TSCA/EPA

• Coordination of Existing BMP’s with new Guidelines

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Thank You