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TSCA, Tanks and Trouble

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.

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TSCA, Tanks and Trouble

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

  2. Kitsap County, Washington

  3. Locations Volume “If It Ain’t Broke…” Is it Broke? Operations Policies Incidents Other Issues Current Used Oil Program

  4. EPA Enforcement Against City of Tacoma Very Similar Collection Program to Ours If it can Happen There… News Releases from Region 10 City 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, skadowski.suzanne@epa.gov(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.” … Hey, Look What Was in the Paper!

  5. The EPA TSCA Response to Finding Collaborative Solutions…

  6. Ecology’s Response? • Vendor’s Response? • Do We Take Our Chances and See What Happens? • Do We Ditch our Program and Start Over? Now What?

  7. Considerations • Future Enforcement • Unclear Path Forward • Customer Demand • Geography • Infrastructure Somewhere Between Nothing and Radical Change…

  8. Operations • Volume Limits • Product Limits • Source Limits • Declaration Form • Attendant Oversight Best Management Practices

  9. Outreach • Signage • Press Release • Handouts • Web Changes • Brochure Changes Best Management Practices

  10. Development of Ecology’s BMP’s • Response (if any) from TSCA/EPA • Coordination of Existing BMP’s with new Guidelines Looking Ahead

  11. Thank You

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