Used oil storage for businesses: tanks, containment, spill kits and SPCC plans

This guide is for businesses that keep used oil on site, such as auto shops, fleet yards, dealerships and plants. Our guide to used oil generator rules covers the federal basics. This one covers how to set up the storage area, how to be ready for a spill, and when a business needs a written spill plan under the federal SPCC rule.

This article explains federal rules in general terms. It is not legal advice. State and local rules can be stricter, so check with your state environmental agency before you make changes at your site.

The federal used oil storage rules in short

Under 40 CFR 279.22, a business that generates used oil must:

• Store it only in tanks or containers. Pits, lagoons and open piles are not allowed unless they are units regulated under the federal hazardous waste rules (40 CFR Parts 264 and 265).
• Keep them in good condition, with no severe rust, no structural damage and no leaks.
• Label them "Used Oil." That applies to every container and aboveground tank, and to the fill pipe of an underground tank.
• Deal with any spill right away. Stop it, contain it, clean it up, and repair or replace a leaking container before you use it again.

Your state can add storage rules to these four, so ask its environmental agency what your tanks and drums need.

The same section points to two other sets of rules. Used oil kept in underground tanks follows the underground storage tank rules in 40 CFR Part 280, which leave out tank systems of 110 gallons or less. And a site that stores enough oil of any kind, where a spill could reasonably be expected to reach navigable waters, needs a spill plan under 40 CFR Part 112, known as the SPCC rule. Both are covered below.

Setting up a used oil storage area

The steps below go beyond the federal minimum. They make the rules above easier to meet, and they make pickups faster.

• Pick a spot away from floor drains, storm drains and outside doors. Oil that reaches a drain is much harder to clean up.
• Keep tanks and drums indoors or under a roof when you can. Rain that collects around a tank needs checking for oil before it is drained.
• Set drums and smaller containers on a spill pallet or in a drip tray.
• Keep containers closed except when you are adding oil. A drum funnel with a lid helps.
• Post a sign by the tank that says what goes in and what stays out. Solvents, degreasers and antifreeze stay out of the used oil tank.
• Leave a clear path to the tank or drums, so our driver can reach them with the hose.

Free download

What goes in the used oil tank: shop sign

A one-page sign for the wall by your tank. Goes in, keep out, and why it matters.

Download the signPDF, 1 page, 222 KB

Secondary containment for used oil tanks and drums

Secondary containmentA second barrier, such as a berm, dike, double-walled tank or spill pallet, that holds oil if the tank or container leaks. is a second barrier that holds oil if a tank or container leaks. It can be a berm, a curb, a dike, a double-walled tank or a spill pallet.

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The federal used oil rules for generators do not require it, though EPA encourages it. The SPCC rule requires it at the sites it covers. There, the containment around each tank, drum or tote of 55 gallons or more must hold the full capacity of the largest container, plus extra room for rain if it is outdoors (40 CFR 112.8(c)(2) for tanks and 112.8(c)(11) for drums, totes and other portable containers). Some states add their own requirements, so check our guide to state used oil rules.

When a business needs an SPCC Plan

SPCC stands for Spill Prevention, Control, and Countermeasure. The rule covers oil of any kind (40 CFR 112.2), so new motor oil, fuel, hydraulic oil and used oil all count together.

A business needs a written SPCC PlanA written Spill Prevention, Control, and Countermeasure Plan that a site storing enough oil, where a spill could reasonably be expected to reach navigable waters, must prepare under 40 CFR Part 112. when both of these are true (40 CFR 112.1):

• Its aboveground oil storage capacity adds up to more than 1,320 gallons. Count only containers that hold 55 gallons or more. Completely buried tanks have a separate limit of 42,000 gallons, and buried tanks that fall under all the technical requirements of the underground storage tank rules (40 CFR Part 280 or an approved state program) are left out of that total.
• A spill could reasonably be expected to reach navigable waters of the United States or the shorelines next to them. These can include many creeks, rivers and lakes. You decide this from where the site is, including nearby drains and ditches and the slope of the land. Do not count any containment you already have when you decide.

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Count the full size of each container, not how much oil is in it today (40 CFR 112.2). Containers under 55 gallons, the fuel tanks that power vehicles and permanently closed tanks are left out of the count (40 CFR 112.1(d)). If your site is close to the 1,320-gallon line, work through the count with EPA's SPCC guidance before you decide on a plan, and ask your state whether it has spill rules of its own.

What an SPCC Plan covers

A plan written for a shop or fleet yard covers these points (40 CFR 112.7 and 112.8):

1. Containment. Barriers sized for the tanks and drums, and for the kind of spill that is likely to happen.
2. Inspections and records. Tanks and drums checked on a schedule set by industry standards, with signed records kept for three years.
3. Training. Staff who handle oil are trained, and get a spill prevention briefing at least once a year.
4. A site diagram. A drawing that shows where each fixed oil container is and what it holds, and the area where drums and other portable containers are kept, plus a list of who to call after a spill.
5. Certification. A Professional Engineer certifies the plan. A site with 10,000 gallons or less of aboveground oil storage can certify its own plan if, in the three years before it certifies the plan, it has had no single spill of more than 1,000 gallons and no two spills of more than 42 gallons each within any 12 months (40 CFR 112.3(g)). Only oil that reached navigable waters or their shorelines counts toward those amounts. A site open less than three years looks back to when the rule first applied to it. If none of its aboveground containers is over 5,000 gallons, it can use the plan template from EPA.

Keep a complete copy of the plan at the site if someone works there at least four hours a day. If not, keep it at the nearest field office. Either way, it must be available for EPA to review on site during normal working hours (40 CFR 112.3(e)). This is a short summary of a long rule, so work from EPA's SPCC guidance or with a Professional Engineer when you prepare a plan.

Keeping a spill kit by the tank

A spill kit within reach of the tank lets you follow the federal steps for a spill (40 CFR 279.22(d)): stop it, contain it, clean it up and fix or replace the container. A basic kit for a used oil area holds:

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• absorbent pads for drips and small spills;
• absorbent socks to circle a spill and keep it from spreading;
• loose absorbent for floors;
• a drain cover;
• gloves and eye protection;
• a closed container for the used pads and absorbent.

Oil that is cleaned up is still managed as used oil. Keep used absorbents in their own closed container. We can often collect spent absorbents on the same visit as your used oil.

A simple routine for checking used oil storage

Pick a day each month and look at the whole storage area:

• tanks and drums for rust, dents and leaks;
• labels that still read "Used Oil";
• lids and bungs closed;
• containment free of oil and water;
• the spill kit full;
• the tank level, so a pickup is booked before the tank is full.

Free download

Used oil storage checklist

One page to keep by the tank: storage, labels, spills, pickups, plus a monthly check log.

Download the checklistPDF, 1 page, 201 KB

Write down the date and what you found. If your site has an SPCC Plan, the plan sets the inspection schedule, and the signed records are kept for three years (40 CFR 112.7(e)).

If a containment area, sump or oil and water separator collects oily water, our vacuum services pump it out and haul it away. If you are a recurring pickup customer, we can time your pickups to how fast your tank fills.

Request a used oil pickup

Tell us where you are and what you need collected on our used oil pickup page, or find your state on our locations page. You can also call 800.988.7977. We reply the same business day, and no account is needed to ask.

UES locations serve Georgia, Texas, Tennessee, Arizona and 24 more states.