Hazmat fines

[B Aceves]

Originally Posted by Bill Harris

I was at Gainesville and was handed a package of information while sitting in the ridiculously slow moving line at the gate on Thursday AM. The company that has contracted with NHRA to manage our environmental compliance was essentially selling their services and products. The package included a NHRA release form which had to be signed and turned in to the trailer when you registered after tech (essentially indemnifying them from everything). The information in the package also included a copy of the relevant STATE (Florida) statute concerning hazardous materials and their disposal. My take on it was that at Gainesville it was primarily a state issue, not federal. There was also a statement from the NHRA on their policy toward environmental issues, which puts 100% of the responsibility on the "Participant". It also prohibits the use of any halogenated or chlorinated brake cleaners. The statement also requires that waste oil generated during the event must be disposed of through the licensed HazMat vendor at the track. The implication is that you are not supposed to take it with you.

The company representatives were friendly enough, but it was pretty obvious that they are also doing their best to profit from the situation. They take waste oil for a price, and the price is based on how contaminated the used oil is. If it is full of solvents, particularly chlorinated stuff, it costs the racer more to get rid of it. They charge for the test for contaminates and disposal of the oil . It cost $45 to set up an account which included two tests. It cost $35 for a drum of non-hazardous oil (or $0.75/gal) and went up to $425 for a badly contaminated drum (or $125 for 5 gal).

The included (and highlighted) Florida statute requires that any container with waste oil be clearly marked and in good condition. If it is not double-walled it must be stored on a secondary containment with 110% capacity. There is no mention of quantity so that would imply that if you drained 8 quarts of oil from your engine whatever container it is in would need a secondary containment with at least 8.8 quart volume. Wonder how many racers have that setup? Florida can bust you for not having the secondary containment and hit you with a misdemeanor with a $1000 fine and/or 6 months in the local rectal stretching facility.

Finally, I was parked across the road from the HazMat contractor, and I didn't see much activity over there, although there was plenty of product for sale and/or lease.

Ok that explains it all, Thanks Im off my soapbox now, BTW Thank you NHRA for giving me another reason to go Bracket Racing......what a joke

[7820]

Always happy to see another Pontiac racer move to brackets.

Another enhancement from NHRA.

[Jeff Teuton]

Just to show a real life situation, about 4 years ago the old Southland Dragway property was sold. The company that was doing the Phase 1 enviornmental is a company that I know and they asked that if I remembered if they had waste oil containers back in that day. I found some old photos, and in a couple, there are the containers. This was about 30 years after it sold. Did someone get fined at Gainesville?

[Rick Bailey]

Bill Harris,
Thank-you for your great and informational report. By reading, we now have a better idea what where up aginst.

Sounds like some of us northern racers will have a little time to figure out the container deal, if it even applies to some of the states north of Fla.

Sounds like the safe thing to do is just do your maintaince @ home.

Rick

[Bret Kepner]

Originally Posted by B Aceves

Thank you NHRA for giving me another reason to go Bracket Racing......what a joke

What makes you think local tracks won't eventually become a target for similar legislation...or worse?

[Sean Kennedy]

The way I read the explanation, it gives me the impression we are not supposed to take the oil off site and recycle it ourselves. Am I correct in this understanding?

My old man and I have always been good about this, we ALWAYS save out oil... at home and the track... and take it to a parts store to be recycled.

This is nuts.

[B Aceves]

Originally Posted by Bret Kepner

What makes you think local tracks won't eventually become a target for similar legislation...or worse?

I do not think for one minute think that this is not a enhancement by NHRA to take more money out of our pockets, why? Because the EPA would be enforcing this not NHRA, Can you tell me that a fine paid by a racer is going straight to the EPA, I doubt it.
I will say that if you sign anything when you dispose of your oil to a SafetyClean type company, Do you realize you are responsible for the clean up and fines if something happens in the way of a spillage until it reaches the disposal site!! even if you pay a
removal fee. Besides were we not already paying a fee for disposal? I do remember a increase in track fee's to cover this at least in CA.

[Bill Harris]

Directly from the NHRA Environmental Management Plan.
Quote:
Removal of Waste From Site:
Each team will be required to make necessary provisions for removing any waste generated by it through a licensed vendor (Hazmat/Recycle hauler) designed by the track.
Any arrangements for and/or charges incurred for the removal of solid, recyclable or hazardous waste will be the responsibility of the race team generating the waste, and it will be the responsibility of the race team to contract with the on-site vendor for such disposal.
Unquote.

I ain't no englush majur, but that sez to me that if you generate waste on site, it must be disposed of through the on-site contracted vendor.

I ain't no lawyer neither, but it sure looked to me like all the hooks were in place to obligate the "participant" to dispose of waste oil on site with the contract vendor. You had to sign a document that said you agreed to the NHRA plan in order to complete your registration.

At Gainesville, the package handed out included a "Race Team Setup Form" for the purpose of establishing a contractual relationship with the vendor. The "Race Classifications" included "Street Racer", "Pro", and "Top Fuel". I guess we are street racers.

Being the devil's advocate and looking at the worst case scenario, what Jeff Teuton suggested is still a violation of the Florida statute. If you are transporting used motor oil in a container, it has to have a secondary containment that will accommodate the entire volume plus 10%. Will the Florida environmental cops bust you for a few quarts of dirty oil, probably not, but it is technically a violation anyway. If you had a wreck on the way home and dumped oil all over the place, that might be a different story.

For me, I think I will change my oil at home....

[A100]

Originally Posted by Bill Harris

Directly from the NHRA Environmental Management Plan.
Quote:
Removal of Waste From Site:
Each team will be required to make necessary provisions for removing any waste generated by it through a licensed vendor (Hazmat/Recycle hauler) designed by the track.
Any arrangements for and/or charges incurred for the removal of solid, recyclable or hazardous waste will be the responsibility of the race team generating the waste, and it will be the responsibility of the race team to contract with the on-site vendor for such disposal.
Unquote.

I ain't no englush majur, but that sez to me that if you generate waste on site, it must be disposed of through the on-site contracted vendor.

I ain't no lawyer neither, but it sure looked to me like all the hooks were in place to obligate the "participant" to dispose of waste oil on site with the contract vendor. You had to sign a document that said you agreed to the NHRA plan in order to complete your registration.

At Gainesville, the package handed out included a "Race Team Setup Form" for the purpose of establishing a contractual relationship with the vendor. The "Race Classifications" included "Street Racer", "Pro", and "Top Fuel". I guess we are street racers.

Being the devil's advocate and looking at the worst case scenario, what Jeff Teuton suggested is still a violation of the Florida statute. If you are transporting used motor oil in a container, it has to have a secondary containment that will accommodate the entire volume plus 10%. Will the Florida environmental cops bust you for a few quarts of dirty oil, probably not, but it is technically a violation anyway. If you had a wreck on the way home and dumped oil all over the place, that might be a different story.

For me, I think I will change my oil at home....

So why can't you just put the oil bottles in a cooler?

[Chad Rhodes]

well they have no idea what goes on inside my trailer with the AC on and the doors closed. I've changed a transmission in the trailer, I can change the oil or trans fluid in there.