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

Kitsap County, Washington

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

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 10 City of Tacoma settles with EPA for violating federal rules on PCBs in used oil Release Date: 09/30/2013 Contact Information: Suzanne Skadowski, EPA Region 10 Public Affairs, , (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.” …

The EPA TSCA Response to Finding Collaborative Solutions…

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?

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

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

Best Management Practices Outreach Signage Press Release Handouts Web Changes Brochure Changes

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

Thank You