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COMBINED ENVIRONMENTAL AUDIT PACKAGE FOR USED OIL PROCESSING FACILITIES AT:
17300 HWY 72
ARVADA, CO 80007
20 LUCERO ROAD
BELEN, NM 87002
209 S. 57TH AVE
PHOENIX, AZ 85043
Page 86 - Hazardous Waste Determination Training

HAZARDOUS WASTE DETERMINATION TRAINING
The United States Environmental Protection Agency has decided to presume that used oil is a hazardous waste unless the presumption can be rebutted. A person can rebut the presumption by proving that the oil contains less than 1,000 parts per million (PPM) of total halogens. Mesa Oil is not permitted to handle hazardous waste. Until we can prove that the used oil is not contaminated, it is against the law for us to collect and recycle the used oil.

Halogens come from chlorinated solvents. Chlorinated solvents are hazardous waste. Under normal conditions, used oil does not contain any chlorinated solvents. For used oil to be contaminated, these chlorinated solvents would most likely be mixed in with the used oil by the generator of the used oil. The generator is Mesa Oil's customer. We collect and recycle used oil generated by our customer.

Mesa Oil Inc's policy and procedure for the collection and recycling of used oil is guided by the following statement:

USED OIL IS HOT UNTIL WE PROVE IT'S NOT!

By HOT we mean hazardous waste. The following procedures outline the required steps needed to document to the EPA that we have proven the used oil is not hazardous waste. Our employees must follow these procedures with no exceptions. These procedures will include tests used to prove that the oil is not contaminated. The following procedure is very serious. Failure of an employee to follow this procedure in full detail, is grounds for immediate termination!

1. Drivers must always check in with the customers authorized representative before loading the used oil.

a. Authorized representative - The contact name is printed on your manifest. This is the person the customer has designated as being responsible for this area of their business. If the customer temporarily assigns some one other than the contact, you must write that persons name in next to the contact name. If the contact name is a permanent change, write the new name and an explanation in the special instructions section of the manifest.
b. No exceptions - even if the customer says you don't have to check in with them! - even if we have been servicing the customer every week for ten years!
Understand that each time we go to a customers location to collect the used oil, we are facing a new batch of used oil. The customer is the only one who knows if anything has changed regarding his used oil disposal practices, so we must give him the opportunity to tell us before we begin loading.
c. The customer is signing the certification part of our manifest stating that no hazardous waste has been mixed with the used oil. We must give the customer the chance to tell us if something is in the used oil before we load if we expect him to sign the certification.

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