Today’s environmental laws and regulations put the responsibility of tracking used oil and similar waste streams on the user. In fact, when it comes to the streams that are generated in companies operating throughout the United States, all have one thing in common: cradle-to-grave responsibility.
Each state has specific requirements, but the general concept of unreliquished responsibility is a universal theme. Some companies have the luxury of internally processing used oil streams by re-refining them (for example, crude oil refineries). However, most companies must rely on a qualified used oil management company that can handle this stream for them. If the waste stream is improperly handled, the generating company could end up part of a superfund site - a very expensive proposition for any business.
How does a used oil generator assure that the used oil collector is managing the disposal and documentation issues properly? Three words: Do some homework!
Understanding the terminology is a great place to begin. Some common terms that should be clearly understood are:
The characteristics of the stream and how each state views that stream ultimately determine whether or not the used oil stream is in fact “waste” in the eyes of the law. If it is a waste, it must be treated as such through a company or agency qualified to handle waste streams. If it’s not classified as waste and it is a “recyclable stream”, then it is appropriate to find a company that can handle the used oil and the associated environmental concerns.
Used Oil Is*
Used Oil Is Not
• Synthetic oil — usually derived from coal, shale or polymer-based starting material.
• Engine oil — typically includes gasoline and diesel engine crankcase oils and piston-engine oils for automobiles, trucks, boats, airplanes, locomotives and heavy equipment.
• Transmission fluid
• Refrigeration oil
• Compressor oils
• Metalworking fluids and oils
• Laminating oils
• Industrial hydraulic fluid
• Copper and aluminum wire drawing solution
• Electrical insulating oil
• Industrial process oils
• Oils used as buoyants
* This list does not include all types of used oil.
• Waste oil that is bottom clean-out waste from virgin fuel storage tanks, virgin fuel oil spill cleanups, or other oil wastes that have not actually been used.
• Products such as antifreeze and kerosene
• Vegetable and animal oil, even when used as a lubricant
• Petroleum distillates used as solvents
* Oils that do not meet EPA’s definition of used oil can still pose a threat to the environment when disposed of and could be subject to the RCRA regulations for hazardous waste management.
How to Select an Oil Recycler
How does one select the right oil recycler for his company? There are several factors to consider, such as:
To answer the preceeding questions, visit the supplier to make sure you’re comfortable with the quality and integrity of the process.
How is the used oil recycled? So, where does all the used oil go? The size of the used oil market is impressive: according to both the American Petroleum Institute (API) and a 1998 U.S. Department of Energy study, there is more than a billion gallons of used oil generated in the United States.
Products from the waste stream are resupplied in a variety of uses, as shown in Figure 1.
Figure 1. Applications of Recycled Oil
Each use of used oil has its own requirements and/or specifications. One of the largest uses is burning for energy recovery (for example, in boilers and asphalt plants). Table 2 summarizes some of the specifications used oil must meet in order to be burned for energy recovery.
|Arsenic||5 ppm maximum|
|Cadmium||2 ppm maximum|
|Chromium||10 ppm maximum|
|Lead||100 ppm maximum|
|Total Halogens||4,000 ppm maximum|
|PCBs||<2 ppm maximum|
Table 2. Constituent/Property - Allowable Levels2
State-specific rules can vary, but the federal rules that must be adopted by each state as the minimum requirements are found under Title 40 of the Federal Regulations at Part 279.
The EPA also maintains a Web site for used oil at www.epa.gov/epaoswer/haswaste/usedoil/.
2. 40 CFR §279.11
“Managing Used Oil.” Machinery Lubrication, September-October 2004.