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Page 85 - Written Analysis Plan (279.55)
WRITTEN ANALYSIS PLAN (279.55)
279.53: To ensure that used oil managed at our facilities is not hazardous waste under the rebuttable presumption of 40 CFR 279.10 (b) (1) (ii) the used oil is tested for halogen content using a halogen detection meter prior to the material being pumped onto the oil collection truck. If the driver receives an indication of halogen content in the used oil he is obligated to test the used oil using a Dexsil Clor-d-tect test kit. This test is performed at the customers expense and if the customer chooses not to pay for having the test performed our driver will not pickup the used oil. If the Clor-d-tect test is run on the used oil and the test fails, we have a procedure to sample and submit the used oil to an independent lab for analysis. Mesa Oil will not pump the oil until we receive an analysis certifying the used oil is not contaminated with hazardous waste.
Each collection is documented on a Mesa Oil recycling manifest. On the manifest the generator certifies that they have not mixed hazardous waste with the used oil and the Mesa Oil driver certifies that the used oil has been tested and is less than 1,000 PPM Total Halogens. Each driver upon returning to Mesa Oil recycling facilities must combine all manifests for the truckload of used oil they are about to unload and prepare a Daily Driver Unload Ticket. Each driver has an assigned "guard" tank which they a required to unload into. To insure that the drivers are doing their job correctly and testing all of the used oil prior to pickup, the plant operator samples and tests the used oil with a halogen meter prior to transferring the used oil contained in each guard tank, into the plant. If there is an indication of halogen content the load is sampled and tested using a Dexsil Clor-d-tect test kit. The plant operator prepares an Oil Processing Report for each guard tank when transferred which references the Daily Driver Unload Ticket and corresponds to the manifests which make up the total gallons in the tank. The plant operator certifies on the Oil Processing Report that the load transferred is less than 1,000 PPM Total Halogens.
279.72: Mesa Oil processes oil used oil into fuel to be burned for energy recovery. Our used oil fuel does not exceed the specification levels listed in 40CFR 279.11. The end portion of our recycling process is to consolidate used oil fuel into one of several 150,000 gallon or larger tanks. These are our Specification Used Oil Fuel storage tanks. After a tank is filled to capacity and before any fuel is sold from these tanks a sample is taken and analyzed by an outside certified laboratory. The laboratory tests for the constituents listed in 279.11 in accordance with EPA approved test methods and provides Mesa Oil with a certified lab report documenting the results. The results are compared to Table 1 requirements in 279.11 to determine that the used oil fuel does not exceed the standards for Specification Used Oil Fuel. Once the fuel has been determined to meet the specification, a Mesa Oil Spec. Fuel Analysis Sheet is started by the plant operator. This sheet lists the tank number, total gallons and the lab analysis number. All Delivery Ticket numbers for used oil delivered out of this tank are recorded on this sheet, and the lab analysis number and tank number are recorded on each Delivery ticket. This procedure continues until the tank is empty. While Mesa Oil is selling out of a tank in our facility which has been determined to be spec. fuel, we are filling another tank with used oil fuel as used oil is processed.
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