United States
Environmental Protection
Agency
Office of Research and
Development
Washington, DC 20460
EPA/625/R-94/010
December 1994
xvEPA
Environmental
Regulations and
Technology
Managing Used Motor Oil
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EPA/625/R-94/010
December 1994
Environmental Regulations and Technology
Managing Used Motor Oil
Center for Environmental Research Information
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, OH 45268
Printed on Recycled Paper
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Notice
The information in this manual has been funded wholly or in part by the U.S. Environ-
mental Protection Agency (EPA). It has been subjected to the Agency's peer and
administrative review and approved for publication as an EPA document Mention of
trade names or commercial products does not constitute endorsement or recommenda-
tion for use.
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Table of Contents
Chapter 1 Introduction 1
Who Is This Document Written For? 1
What Is the Purpose of This Document? 2
What Is Used Oil? 2
Why Must Used Oil Be Managed Properly? 4
Chapter-by-Chapter Overview of the Document . 5
Chapter 2 The Used Oil Management System 7
The Key Groups in the Used Oil Management System 7
The Flow of Used Oil Through the Used Oil Management System 9
How the Price of Virgin Oil Affects the Used Oil Management System . 11
Chapters The Regulations . 13
EPA's Used Oil Management Standards . . . . 13
RCR A Requirements That Apply to the Disposal of Used Oil 20
The Exemption From CERCLA Liability 20
Underground Storage Tank Regulations 21
Spill Prevention Control and Counter measures Requirements 21
The Department of Transportation's Hazardous Materials Transportation Act Requirements ... 21
Chapter* Options for Recycling Used Oil 22
The Major Used Oil Recycling Methods . . 22
Choosing a Recycling Option 26
The Option of Last ResortDisposal 27
Chapters Choosing a Used Oil Transporter . . 29
General Information About Transporters 29
How To Choose a Transporter 29
Working With a Transporter 32
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Chapter6 Onstte Management for Used Oil Generators. . . . 33
Collecting Used Oil From DIYs 33
Storing Used Oil 37
Burning Used Oil in Space Heaters 43
Responding to Releases of Used Oil to the Environment 43
Planning for Emergencies i 45
Chapter? Managing and Disposing of Used Oil Filters 46
Chapter 8 References 48
Appendix A Where To Get More Information ... |. ...... 50
Hotlines .- ...'.; 50
Trade Associations 51
EPA Regional Contacts ; 52
State Used Oil Contacts 53
Publications 53
Federal Register 59
Code of Federal Regulations ......:..... 59
Appendix B Summary of Resource Conservation and Recovery Act Disposal Requirements 60
Appendix C Summary of Underground Storage Tank Regulations . 63
Appendix D Summary of Spill Prevention Control and Countermeasures Requirements . . . 66
Appendix E Summary of U.S. DOT Hazardous Materials Transportation Act Requirements 69
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Figures
Figure 2-1. Quantity of used oil generated in the United States in 1991 9
Figure 2-2. The flow of used oil through the used oil management system, ............. 9
Figure 2-3. The used oil recycling and disposal methods used in the United States in 1991 .. . .10
Figure 2-4. Methods used to recycle and dispose of used oil in the United States in 1991 .... 10
Figure 2-5. The effect of virgin oil prices on payments made to generators for used oil 12
Figure 4-1. A simplified vacuum distillation/hydrotreating rerefining system 23
Figure 4-2. A simplified used oil processing system '. . 25
Figure 6-1. Collection log for DIY used oil ! 35
Figure 6-2. Sample design for an aboveground used oil storage tank ..;............. 39
Figure 6-3. Atypical UST i. 40
Figure 6-4. Label for used oil storage tanks and fill lines 41
Figure 6-5. Options for secondary containment , 42
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Tables
Table 1-1. Potentially Harmful Constituents in Used Oil Vs. Virgin Motor Oil 3
Table 3-1. Used Oil Specification Limits 15
Table 4-1. Questions for Recycling Facilities 28
Table 5-1. Questions for Transporters 31
Table 5-2. Sample Price Schedule 32
Table 6-1. Comparison of Storage Devices 38
Table A-l. EPA Offices '..... 53
Table A-2. State Used Oil Recycling Contacts ...... 54
Table B-l. Levels of Contaminants That Cause a Material to Exhibit the Toxicity Characteristic
Under RCRA .; 61
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Acknowledgments
This document is the product of the efforts of many individuals. Gratitude goes to each
person involved in the preparation and review of this document.
Author
Anne Donovan of Eastern Research Group, Inc., Lexington, MA, was the principal author
of this document !
Technical Contributors
The following individuals provided invaluable technical assistance during the develop-
ment of this document:
Rob Arner, Private Consultant, Edinburg, VA
Mike Barrette, U.S. EPA, Office of Compliance, Washington, DC
Diane Bartosh, U.S. EPA, Office of Solid Waste, Washington, DC
Janet Graham, Private Consultant, Tuscaloosa, AL
Don Grant, U.S. EPA, Region I, Lexington, MA
Bill Lienesch, U.S. EPA, Office of Compliance, Washington, DC
Mike Petruska, U.S. EPA, Office of Solid Waste, Washington, DC
Eydie Pines, U.S. EPA, Office of Solid Waste, Washington, DC
Michaelle Wilson, U.S. EPA, Office of Solid Waste, Washington, DC
Peer Reviewers
The following individuals peer reviewed this document:
Raoul Clarke and Rick Neves, Florida Department of Environmental Protection, Talla-
hassee, FL
Tony Puckett, Valvoline Environmental Services, Lexington, KY
Bernie Snyder, Eastern Oil Company, Alexandria, VA
Editorial Reviewer and Document Production
Heidi Schultz, Eastern Research Group, Inc., Lexington, MA, directed the editorial review
and production of this document.
Technical Direction and Coordination
Daniel Murray, U.S. EPA, Office of Research and Development, Center for Environ-
mental Research Information, Cincinnati, OH, coordinated the preparation of this
document and provided technical direction throughout its development!
VII
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Chapter I
Introduction
If managed properly, used oil is a valuable resource that
can be reused as a base stock for new lubricating oil
or as a fuel. If managed improperly, however, used oil
can threaten people's health, damage the environment, and
cause the generator and subsequent handlers of the used oil
to be held liable for the costs of environmental cleanup.
When managing used oil, therefore, knowing the responsi-
bilities involved and the proper management practices to
use is important
This document provides information on how to manage
used oil properly. In each chapter, a different aspect of used
oil management is considered. This chapter discusses the
purpose of this document, defines and describes used oil,
and emphasizes the importance of proper used oil manage-
ment practices. In addition, a chapter-by-chapter overview of
the rest of the document is given.
Who Is This Document Written For?
This document is written for people who own or work at
businesses or other facilities that generate used oil by chang-
ing the motor oil from automobile or truck crankcases, or
by collecting used motor oil from do-it-yourselfers (DIYs).
These businesses and facilities include:
Service Stations-Businesses that both sell gasoline and
other car maintenance products (such as oil, anti-freeze, and
windshield wiper blades) and repair and service automo-
biles and trucks for their customers. Service stations gen-
erate used oil from the oil changes they perform for their
customers. Some service stations also collect used oil from
DIYs. Although service stations generate other fluids, such
as hydraulic oils, that are considered used oil by federal
used oil regulations, used motor oil from car and truck
crankcases is the focus of this document.
Quick-Lube Shops-Businesses that only change oil and
other automotive fluids for their customers. Quick-lube
shops generate used oil from these oil changes and, like
service stations, some quick-lube shops collect used oil
from DIYs. Quick-lube shops also generate other fluids that
are considered used oil by federal used oil regulations, but
these oils are not the focus of this document.
Fleet Operations-Businesses or government agencies that
own or operate fleets of automobiles or trucks. Fleet op-
erations generate used oil when they change the oil in their
own vehicles. Fleet operations also generate other used oils
besides used oil from car and truck crankcases.
DIY Used Oil Collection Centers-Places that collect used oil
only from DIYs so that it can be properly managed. These
collection centers are usually owned and operated by state
or local governments or volunteer groups, and are not in-
volved with vehicle maintenance. Although some DIY used
oil collection centers collect other used oils, such as lawn
mower oil and hydraulic oil, they focus on collecting used
oil from car and truck crankcases.
Retailers-Businesses that sell motor oil and accept DIY
used oil for recycling. In some states, retailers of motor oil
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Key Terms
Do-Mourcelfer (D1Y)
Engine Btowby
Paris per Million (ppm)
Used Oil
Used Oil Generator
Also called a household do-it-yourselfer used oil generator in the federal used oil regulations, this is a person
who changes the motor oil in his/her cars, trucks, or other vehicles and equipment, such as tractors and lawn
mowers. For the purpose of this document, however, only DIY used oil from car and truck crankcases is
discussed.
The leaking of exhaust gases from engine combustion through the piston rings and into the motor oil. Engine
blowby causes the oil to be contaminated with gasoline and gasoline combustion products, such as benzene and
lead.
A unit of measure that shows the concentration of a particular substance in a mixture. It gives the ratio of the
number of parts of the substance being measured to every million parts of the mixture the substance is in.
Any oil that has been refined from crude oil, or any synthetic oil, that has been used and as a result of such use
is contaminated by physical or chemical impurities. For the purpose of this document, however, 'the term "used
oil" means motor oil that has been removed from the crankcase of an automobile or truck (unless otherwise
indicated).
Any person, business, or facility that conducts activities that produce used oil. The definition of generator in
federal used oil regulations does not include farmers that generate 25 gallons or less of used oil per month and
DIYs. When the term generator is used in a discussion of federal regulations in this document, therefore,
farmers that generate 25 gallons or less of used oil each month and DIYs are not included in the definition.
are required to accept used oil from people who buy motor
oil at their establishments. Many retailers also voluntarily
provide this service to their customers. Retailers focus on
collecting DIY used oil that has been drained from car and
truck crankcases.
What is the Purpose of This
Document?
The purpose of this document is to help used motor oil
generators properly manage their used oil. The document
gives detailed information on how to meet regulatory re-
quirements, particularly those in the Used Oil Management
Standards, which were finalized by the U.S. Environmental
Protection Agency (EPA) in September, 1992 (U.S. EPA,
1992c). The first step to ensuring that used oil is managed
properly is to follow these regulatory requirements. The
document also gives specific advice on how generators of
used motor oil can best protect human health and the
environment from the time the used oil is generated to the
time it is recycled.
What Is Used Oil?
Used oil is defined as "any oil that has been refined from
crude oil, or any synthetic oil, that has been used and as a
result of such use is contaminated by physical or chemical
impurities" (U.S. EPA, 1992c). This includes oils that are
used as hydraulic fluid as well as oils that are used to
lubricate automobiles and other machinery, cool engines, or
suspend materials in industrial processes. Oils used for
these purposes can become contaminated with physical
materials (such as metal particles from engine wear) or
chemical contaminants (such as gasoline combustion prod-
ucts, like toluene).
r
The type of used oil most commonly managed by service
stations, quick-lube shops, fleet operations^ DIY collection
centers, and retailers is lubricating oil that is removed from
the crankcases of automobiles and trucks. When the term
"used oil" is used in this document, it refers to motor oil
that has been contaminated through use and has conse-
quently been removed from a car or truck crankcase, unless
otherwise noted.
The properties of motor oil change during use for four main
reasons (Byrne, etal, 1989; Mueller Associates, 1989; U.S.
EPA, 1984b):
Engine heat can break down additives and other con-
stituents in the oil. This process can produce acids and
other substances that contaminate the oil.
Dirt, dust, and rust can get into the crankcase and into
the oil. Particles of metal dust from the engine also can
contaminate oil directly.
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Exhaust gases from combustion in the engine can leak
through the engine's piston rings and into the oil. This
"engine blowby" contaminates the oil with gasoline and
gasoline combustion products.
Fluids, such as water and antifreeze, can leak into the oil
during engine operation.
Because of the changes that occur through use, used motor
oil tends to differ from virgin motor oil in several ways.
Most importantly, used motor oil has (Mueller Associates,
1989):
Much higher water and sediment levels than virgin oil.
Relatively high levels of polynuclear aromatics, such as
benzo(a)pyrene.
Relatively high levels of metals, such as aluminum and
lead.
Table 1-1 compares some of the constituents found in used
motor oil from automobile and diesel truck crarikcases to
the constituents in virgin oil. The table shows the levels and
types of contaminants that can enter motor oil through use.
On May 20, 1992, EPA published its decision that used oil
destined for disposal is not a listed hazardous waste, which
means that used oil is not automatically considered a haz-
ardous waste when it is disposed. EPA based this decision
on the fact that federal regulations protect human health
and the environment from disposal of used oil. Federal
regulations mandate that used oil must be tested, or other
procedures must be used, to determine if the used oil is
hazardous before it is disposed. If testing or other proce-
dures determine that the oil is hazardous, it must be
disposed of as a hazardous waste under Subtitle C of the
Resource Conservation ami Recovery Act (RCRA), which
governs the disposal of hazardous wastes. If the used oil is
not hazardous, it must be disposed of under other federal
regulations, such as RCRA Subtitle D. In either case, the
regulatory requirements are designed to prevent used oil
from endangering human health and the environment
through disposal.
In addition, on September 10, 1992, EPA published its
decision not to list used oils destined for recycling as a
hazardous waste. EPA determined that used oils that are
properly managed and recycled do not significantly threaten
human health or the environment. Because EPA's Used Oil
Management Standards require used oil to be managed in
an environmentally safe manner, listing used oil that is to
be recycled as a hazardous waste is unnecessary (U.S. EPA,
1992c).
As a result of these EPA decisions, used motor oil that is to
be recycled generally is not considered a hazardous waste by
the federal government unless the oil has been mixed with
a listed hazardous waste, such as tetrachloroethylene and
other degreasing solvents, or has been mixed with a charac-
teristic hazardous waste, arid the resultant mixture exhibits
the characteristics of a hazardous waste. The used oils han-
dled by service stations, quick-lube shops, fleet operations,
DIY collection centers, and retailers, therefore, generally
must only be treated as hazardous wastes if they have been
managed improperly. Because used oil mixed with hazard-
ous waste increases risks to human health and the
environment, and costs significantly more to manage prop-
erly than normal used oil, keeping used oil from becoming
contaminated with hazardous wastes is very important. As
Table i-i. Potentially Harmful Constituents in Used Oil Vs. Virgin Motor Oil
Constituent
Cadmium
Chromium
Lead
Benzo(a)pyrene
aU.S. EPA, 1991
bU.S. EPA, 1984b
Used Oil from
Automobile Crankcases
(range in parts per
million or ppm)
0.5-3.4
0.8-23
5.5-150
25-86
Used Oil from Diesel Truck
Crankcases
(range in ppm)a
0.7-3
1.8-7.1
2.9-19
2.0
Virgin Lubricating Oils
(range in ppm)
0
0
0-3
0.03-0.28
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is discussed throughoutthis document, to help prevent used
oil from becoming a hazardous wastethe safest practice is
to never mix any other wastes with used oil.
It is important to note that even though federal regulations
do not list used oil as a hazardous waste, many states regulate
used oil as a hazardous waste and, therefore, have more
stringent requirements for management and disposal of
used oil than the federal government State regulations
pertaining to used oil are discussed in Chapter 3.
Why Must Used Oil Be Managed
Properly?
Properly managing used oil is important for four main
reasons:
To protect the environment
To protect human health.
*Ib protect against liability for environmental damages.
To reuse, rather than waste, a valuable resource.
Protecting the Environment
Even used oil that is not classified as a hazardous waste
under RCRA can have harmful effects if it is released into
the environment Consequently, used oil must be managed
properly to ensure that it is not released into the water, air,
or soil.
The Truth About the Consequences of Releasing Used
Oil to the Environment
Just one gallon of used oil (the oil from a single oil change)
can make a million gallons of fresh water undrinkable. A
million gallons of fresh water could supply the water needs
of 50 people for an entire year!
When used oil is dumped down the drain and enters a
sewage treatment plant, very small concentrations of oil in
the wastewater O'ust 50 to 100 ppm) can foul sewage
treatment processes.
A film of used oil on a water surface prevents oxygen from
entering the water and blocks sunlight This makes it
difficult for plants to photosynthesize and reduces plant and
animal life in a water body.
Significant long-term effects have been caused in freshwater
fish species in water with concentrations of oil of 310 ppm,
and in marine life forms at concentrations of oil of only
1 ppm!
Source: U.S. EPA, 1989b
Water, air, and soil are all connectedand substances, such
as used oil, that are released to any of these environmental
media can make their way to the others. This is why
improper management of used oil is such a major environ-
mental concern (Mueller Associates, 1989)1 Used oil that is
dumped onto soil can be washed into surface water by rain
or snow, or can seep through the soil into ground water.
Used oil in the soil can also evaporate into the air. Contami-
nants in used oil that enter the air through evaporation or
improper burning can settle, or be washed by rain or melt-
ing snow, into surface water or onto soil. Clearly, the only
way to be sure that used oil will not contaminate water, air,
or soil is to make sure that it is not released to the environ-
ment at all.
Protecting Human Health
People's health can be affected if used oil is handled improp-
erly. Most used oil contains small amounts of materials that
can cause cancer and other health problems if these materi-
als are inhaled or ingested (Mueller Associates, 1989).
Contaminants in used oil can be inhaled: when the oil is
burned without using proper management practices or
environmental protection devices. For example, burning
used oil in a space heater that is not vented to the outdoors
can expose people directly to toxic contaminants released
during burning (U.S. EPA, 1984a). In addition, toxic con-
taminants can be released if the used oil is burned in devices
that do not burn hot enough or consistently enough to
destroy organic chemicals.
Used oil, or contaminants in the oil, can be ingested if they
get into drinking water sources and are not detected and
removed. Common ways used oil or its contaminants get
into drinking water sources are when the oil is dumped
down storm drains and runs into surface water or is poured
on the ground and washes into ground water or surface
water.
Protecting Against Liability
The Comprehensive Environmental Response, Compensa-
tion, and Liability Act (CERCLA) was passed in 1980 (and
amended in 1986) to help finance the cleanup of sites
contaminated with hazardous wastes. CERCLA, also
known as Superfund, allows the federal government to
hold any party that created or contributed to the creation
of a hazardous waste site financially responsible for cleanup
costs. Under CERCLA, service stations, quick-lube shops,
fleet operations, DIY collection centers, pr retailers, that
manage used oil improperly, or give their used oil to a
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transporter or recycler that manages it improperly, can be
forced to pay large sums to clean up the resulting environ-
mental damage.
CERCLA has very strong enforcement provisions, and al-
lows the federal government to use strict liability on a "joint
and several" basis. This means that any generator that sends
a hazardous substance to a facility that ultimately becomes
a hazardous waste site can be forced to pay the entire cost of
cleaning up that site, even if other generators are responsible
for sending most of the hazardous waste to that site. In most
cases, the generator is only required to pay a portion of the
cleanup cost that is consistent with the amount of material
the generator has contributed to the site (Nolan el: al., 1990).
Partial costs of cleaning up a hazardous waste site can still
be staggering, however, and being forced to pay the entire
cleanup costs is always a possibility.
Also under CERCLA, the generator can be held liable for
cleanup costs even if the substance generated is not consid-
ered a hazardous waste, as long as that substance contains
materials that are listed as hazardous substances under
CERCLA. As discussed above, even though used oil gener-
ally is not considered a hazardous waste by the federal
government, most used oils contain constituents that are
considered hazardous (Nolan et al., 1990). Consequendy,
used oil generators are not guaranteed to be exempt from
CERCLA liability simply because EPA has decided not to
list used oil as a hazardous waste.
Finally, the generator cannot avoid CERCLA liability by
claiming that a contract was made with another party to
properly manage the substance. Unless the release of the
hazardous substance was caused by "an act of war, an act of
God, or an act of omission of a third party who is not
directly or indirectly involved in a contractual relationship"
with the generator, the generator can be held liable for
cleanup costs under CERCLA (Nolan et al., 1990). Again,
used oil generators cannot simply escape CERCIA liability
by hiring someone to transport and recycle their used oil.
Along with CERCLA liability, waste generators can be held
liable under RCR A for costs of cleaning up a spill that poses
"imminent and substantial endangerments to health or the
environment" (Nolan et al., 1990). RCRA liability is likely
to apply to used oil, unless courts rule that used oil is not a
waste but a valuable product that can be recycled. As with
CERCLA liability, because RCRA liability costs are so high,
extreme care should be taken to manage used oil properly
to reduce any chances of being held liable for environmental
cleanup costs.
To avoid the risk of liability, service stations, quick-lube
shops, fleet operations, DIY collection centers, and retailers
should be sure to manage used oil in a way that will not
harm the environment. In addition, CERCLA contains a
"service station dealers" exemption, which is discussed in
detail in Chapter 3. Through this exemption, service sta-
tions, quick-lube shops, and government-run DIY collection
centers that accept DIY used oil for recycling and comply
with EPA's Used Oil Management Standards, cannot be
held liable under CERCLA if transporters or recyclers mis-
handle their used oil. The service station dealers exemption
gives service stations and quick-lube shops an important
economic incentive to accept DIY used oil. As a result of the
exemption, more collection sites will be available for DIY
used oil, which should help reduce the problem of improper
DIY used oil management.
Reusing a Valuable Reso urce
Used oil is a valuable resource because it has lubrication
value and heat value. Although motor oil becomes contami-
nated during use with materials that reduce its ability to
adequately lubricate engine parts, it still maintains its basic
lubricating properties. When specially treated to remove
contaminants, the used oil can be used as a base stock to
produce new lubricating oil. This keeps the lubricating value
of the used oil from being wasted. In addition, reusing the
used oil as a base stock for lubricating oil saves the virgin
oil that would otherwise be used as the lubricating oil base
stock
Because used oil has heat value, it can be burned as fuel.
Burning the used oil keeps its heat value from being wasted
and saves the virgin heating oil that would be burned
instead. Proper burning procedures and equipment must be
used, however, to reduce risks to people's health and the
environment Because virgin oil is a limited resource, prop-
erly managing used oil so that its lubrication and heat value
is not wasted is very important.
Chapter-by-Chapter Overview of the
Document
The rest of this document gives specific information to help
service stations, quick-lube shops, fleet operations, DIY
collection centers, and retailers properly handle the used oil
that they generate. Chapter 2 is an overview of the entire
used oil management system. The chapter defines the key
groups in the used oil management system, and describes
in detail each group's typical management practices. The
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quantity of used oil generated and handled by each, major
group in the management system, and the flow of used oil
among these groups, also is considered. The chapter briefly
discusses acceptable ways that used oil can be recycled
within the used oil management system. Finally, the effect
that the price of virgin oil has on the used oil management
system is considered.
Federal regulations, particularly EPA's Used Oil Manage-
ment Standards, are discussed in detail in Chapter 3. The
chapter also discusses federal regulations concerning the
rest of the used oil management system. In addition, state
regulations are briefly considered.
Chapter 4 presents advice on how to select a recycling option
for used oil. The chapter explains in detail the different
recycling options within the used oil management system,
and gives tips on how to choose a reputable recycling opera-
tion. Information on how to properly dispose of used oils
that cannot be recycled also is provided.
Chapter 5 includes information on transporting used oil to
recycling facilities or disposal sites. It describes typical used
oil transportation operations. Finally, the chapter gives tips
on how to select and work with a used oil transporter.
Chapter 6 is a guide to properly managing used oil on site.
It describes procedures for collecting used oil from DlYs
and determining if this oil has been mixed with hazardous
wastes. The chapter also provides guidelines for storing used
oil on site and burning used oil in space heaters. Finally, the
chapter describes proper procedures for responding to re-
leases of used oil to the environment and developing
emergency plans.
Chapter 7 provides information on the management of used
oil filters. It describes proper methods for draining, storing,
recycling, and disposing of used oil filters. Chapter 8 lists
references on used oil management
Appendix A provides sources of additional information. The
section describes telephone hotlines on subjects related to
used oil management and provides their telephone num-
bers. Trade associations working on used-oil related topics
are also described, and their telephone numbers and ad-
dresses are given. The section lists state and EPA contacts
that can provide more information on regulations and used
oil management Finally, Appendix A describes useful pub-
lications on used oil management, and gives information on
how these publications can be obtained..
Appendix B summarizes the Resource Conservation and
Recovery Act (RCR A) regulations that apply to the disposal
of used oil, materials containing or otherwise contaminated
with used oil, and used oil filters. The disposal of both
hazardous and nonhazardous wastes is considered.
The Underground Storage Tank Regulations, from Subtitle
I of RCRA, are summarized in Appendix C. These regula-
tory requirements apply to service stations, quick-lube
shops, fleet operations, DIY collection centers, and retailers
that own or operate certain underground storage tanks.
Appendix D covers the Spill Prevention Control and Coun-
termeasures requirements from the Oil Pollution Act,
which is part of the Clean Water Act. Under these regula-
tory requirements, most used oil generators must develop a
plan to prevent the release of used oil into surface water
bodies.
Appendix E includes the requirements that must be met by
used oil generators and transporters under the U.S. Depart-
ment of Transportation's Hazardous Materials Transportation
Act regulations. Special packaging and transportation require-
ments apply to used oil that is considered a hazardous material
under these regulations.
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Chapter 2
The Used Oil Management System
Tie used oil management system is composed of the
ndividuals, businesses, and government entities
:hat participate in the recycling of used oil. This
includes those who generate, transport, or recycle used oil,
as well as those who burn recycled used oil for fuel. This
chapter defines and describes the key groups in the used oil
management system. The quantity of used oil generated and
handled and the typical management practices used by each
group are discussed. In addition, the flow of used oil from
one key group to another is outlined. This chapter also
addresses the most common ways that used oil can be prop-
erly recycled within the used oil management system and the
effect that the price of virgin oil has on used oil management
Because this document is targeted toward service stations,
quick-lube shops, fleet operations, DIY collection centers, and
retailers, the term "used oil" generally refers to motor oil that
has been drained from automobile or truck crankcases. In this
chapter, however, the broader definition from EPA's Used Oil
Management Standards is used, so that the entire used oil
management system can be characterized. So, throughout this
chapter, used oil is defined as any oil that has been refined from
crude oil, or any synthetic oil, that has been used and as a result
of such use is contaminated by physical or chemical impurities.
The Key Groups in the Used Oil
Management System
In the past, the participants in the used oil management
system have not always been clearly defined, largely because
of the overlap that exists; among generators, transporters,
and recyclers of used oil. For instance, many businesses that
process used oil for use as fuel also transport used oil from
the generator to the processing facility. This lack of clear
definition can cause confusion, because different terms are
used to mean the same thingand sometimes, the.same
term can have different meanings, depending on who is
using it ' ' ',
This publication attempts to avoid confusion by defining
the key groups in the used oil management system based on
definitions given in the Used Oil Management Standards,
which were published by the U.S. Environmental Protec-
tion Agency in 1992 (U.S. EPA, 1992c).
GeneratorAny person, business, or facility that conducts
activities that produce used oil. Generators of used oil can
be broken down into DIYs, automotive sources, and indus-
trial sources. The definition of generator used in EPA's
Used Oil Management Standards does not include farmers
that generate 25 gallons or less of used oil per month and
DIYs. Data given in this chapter for generators, however,
include these DIYs and farmers, unless otherwise noted.
Collection CenterA site or facility that is recognized by the
state or local government and that accepts used oil from
DIYs or other used oil generators in quantities of less than
55 gallons.
« DIY Collection Center-A site or facility that only accepts
used oil from DIYs.
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Key Terms
Automotive Sources of Used Oil
Halogens
Industrial Sources of Used Oil
Road Oiling
Specification Used Oil
Businesses or facilities that generate used oil from changing the oil in automobiles and trucks, such as
service stations, quick-lube shops, and fleet operations.
Organic compounds that contain chlorine, fluorine, bromine, and/or iodine.
Facilities that generate used oil through manufacturing, production, or other industrial processes.
The practice of spreading used oil on dirt roads to suppress dust
Used oil that has less than or equal to 5 ppm arsenic, 2 ppm cadmium, 10 ppm chromium, 100 ppm
lead, 4,000 ppm total halogens, and that has a flash point of 100°F or more. Under EPA's Used Oil
Management Standards, the burning of used oil that does not meet these specifications (i.e.,
off-specification used oil) is restricted. '
Tran$porter-Any person, business, or government agency
that hauls used oil in quantities greater than 55 gallons.
Most used oil transporters collect used oil from generators
and haul it to burners, processors, or rerefiners.
Transfer Faciltty-Any transportation-related site (such as a
loading dock or parking lot) where shipments of used oil
are held for more than 24 hours and less than 35 days.
Processor-A facility that uses chemical or physical opera-
tions (such as blending different quality used oils, filtering
out solid contaminants, or heating used oil to evaporate
water) to produce fuel oil from used oil.
RerefinerA facility that uses chemical or physical opera-
tions to remove impurities from used oil so that it can be
used as a base stock for lubricating oil.
BurnerAn individual or facility that burns used oil for
fuel, or to dispose of the used oil. Under EPA's Used Oil
Management Standards, burners are defined as facilities that
burn off-specification used oil in industrial furnaces, indus-
trial boilers, utility boilers, or hazardous waste incinerators.
This definition of burner does not include people or facili-
ties that burn specification used oils. In addition, generators
who burn used oil in used-oil fired space heaters are not
covered by the burner requirements in the management
standards, as long as they meet certain other requirements,
such as generating the used oil themselves or collecting it
from DlYs. Data given for burners in this chapter, however,
include burners of specification used oils, as well as gener-
ators who burn used oil in used-oil fired space heaters.
Marketer-Any person or business that either: (1) first de-
termines that used oil meets EPA's burning specifications,
or (2) directs a shipment of off-specification used oil from
their facility to a used oil burner.
i
Clearly, a large number of different groups participate in the
used oil management system. In general, these groups can
be broken down into the following four categories:
i
Those that introduce used oil into the used oil manage-
ment system, which includes automotive generators, in-
dustrial generators, and DIY collection centers.
Those that carry used oil from those that introduce the
used oil into the management system to; those who recy-
cle the used oil, which includes transporters and transfer
facilities. ',
Those that treat used oil so that it can be used again,
which includes processors and rerefiners.
Those that burn used oil.
DIYS and Used Oil Management
DlYs are considered household waste generators, and as such, are
not covered under federal regulations, such as EPA's Used Oil
Management Standards and RCRA. Consequently, DIY used oil
is only introduced into the used oil management system when it
is brought to a used oil collection center, a service station, a
quick-lube shop, or a retailer.
Even though each individual DIY generates only a small quantity
of oil, the total quantity of used oil generated by all DlYs is large.
In 1991, for instance, DIYs generated an estimated 210 million
gallons of used oil (Vorhees, 1992). Bringing DIY used oil into
the system, therefore, is an important goal. The efforts of DIY
collection centers, service stations, quick-lube shops, and retailers
are necessary to help make this goal a reality.
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The Flow of Used Oil Through the Used
Oil Management System
In 1991, an estimated 1.378 billion gallons of used oil were
generated in the United States (Vorhees, 1992). Figure 2-1
shows the quantity of used oil that was generated by DIYs,
other automotive sources, and industrial sources. As Figure
2-1 illustrates, automotive sources of used oil are the pri-
mary used oil generators. Clearly, service stations,
quick-lube shops, fleet operations, and similar automotive
establishments play an important role in the used oil man-
agement system. When the used oil that could be collected
from DIYs is considered as well, the quantity of used oil that
automotive operations and DIY collection centers can en-
sure is managed properly is even more significant
Figure 2-2 shows the pathways that used oil follows through
the used oil management system. Figure 2-2 does not in-
clude the used oil that does not enter (or escapes from) the
system and is improperly managed. Figure 2-3 gives infor-
mation on used oil handled both inside and outside of the
used oil management system. In this figure, used oil collec-
tion centers are combined with automotive sources of used
oil. Figure 2-3 shows the methods used by each used oil
generator to recycle or dispose of their oil, and how much
used oil is recycled or disposed of using each of these
methods.
In Figure 2-3, improper disposal includes dumping used oil
down storm drains or household drains, pouring used oil
on the ground, landfilling used oil in poorly designed land-
fills, road oiling, preserving wood with used oil, and stor-
ing used oil for extended periods of time. According to the
1991 estimates, 142 million gallons of the used oil gener-
ated by DIYs each year are disposed of improperly. In
addition, a great deal of used oil generated by automotive
sources is improperly disposed. Industrial sources properly
dispose of nearly all of the used oil they generate. The bulk
of the one million gallons of used oil disposed of improperly
by industrial sources in 1991 was road oiled (Vorhees,
1992), a practice that was legal at the time. Now that road
oiling has been banned under EPA's Used Oil Management
Standards, industrial sources will most likely divert used oil
from road oiling into proper management practices.
Figure 2-4 shows how much used oil was recycled and
disposed of in 1991, and which recycling or disposal meth-
ods were used. Clearly, the vast majority of used oil
generated in the United States is recycled by being burned
for heat Although much less used oil is rerefined and used
as a base stock for lubricating oil, the 56 million gallons of
Automotive Sources
647
Industrial Sources
521
Figure 2-1.
Quantity of used oil generated in the United
States in 1991 (in millions of gallons) (source:
adapted from,Vorhees, 1992).
End Users
Figure 2-2.
The flow of used oil through the used oil
management system (source: adapted from
American Petroleum Institute, 1991).
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Burned for Heat
910
DlYs
209 Million Gallons Generated
Improperly Disposed
142 Million Gallons
Collected by Automotive Sources
67 Million Gallons
Automotive Sources
647 Million Gallons Generated
+
67 Million Gallons Collected
(rom DlYs
714 Million Gallons
Collected by Transporters,
Processed, and/or Rerefined
415 Million Gallons
Burned for Heat
108 Million Gallons
Used for Diesel Fuel
16 Million Gallons
Sent to Industrial Sources
8 Million Gallons
Properly Disposed
6 Million Gallons
Improperly Disposed
161 Million Gallons
Industrial Sources
520 Million Gallons Generated
+
8 Million Gallons Collected from
Automotive Sources
528 Million Gallons
Collected by Transporters,
Processed, and/or Rerefined
398 Million Gallons
Burned for Heat
42 Million Gallons
Properly Disposed
87 Million Gallons
Improperly Disposed
1 Million Gallons
Figure 2-3. The used oil recycling and disposal methods
used in the United States in 1991 (source:
adapted from Vorhees, 1992).
Rerefined
56
Figure 2'4.
Used as Diesel Fuel.
16
Properly Disposed
102
Improperly Disposed
294
Methods used to recycle and dispose of used
oil in the United States in 1991 (in millions of
gallons) (source: adapted from Vorhees, 1992).
used oil that were rerefined in 1991 represent a significant
increase from the 31 million gallons of used oil that were
rerefined in 1988 (Arner, 1992).
Recycling utilizes either the heat or lubrication value of the
used oil and protects human health and the environment
In addition, recycling generally is easier and more cost effec-
tive than properly disposing of used oil, and almost all used
oil can be recycled (U.S. EPA, 1992c). Consequently, the
emphasis in EPA's Used Oil Management Standards is on
recycling, and very few used oil generators are expected to
opt for disposing of used oil instead of recycling it.
The five most common options for properly recycling used
oil are:
Direct Blirning^Used oil is burned to generate heat or to
power industrial operations. The used oil is not processed
before burning, either because it is specification used oil
and can be safely burned without special equipment, or
because it is burned in facilities that use pollution control
devices or operations that limit air emissions (Arner, 1992).
Processing-Used oil is treated to remove contaminants
so it can be used for fuel without endangering human
health and the environment or damaging equipment. Gen-
erally, off-specification used oil is processed so that it will
meet the burning specifications in EPA's Used Oil Man-
agement Standards. The most common processing meth-
ods are gravity settling, screening, centrifuging, and
filtering to remove solid contaminants; chemical treatment
to reduce chemical impurities; heat separation/dehydration
to remove liquid impurities; distillation to remove water;
10
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and blending different quality used oils to improve lower
quality used oils (Energy and Environmental Research Cor-
poration, 1988).
RerefiningUsed oil is treated to remove impurities so
that it can be used as a base stock for new lubricating oil.
Rerefining methods are more advanced, complicated, and
effective than processing methods, and rerefined lubricat-
ing oil is virtually indistinguishable from virgin lubricating
oil (Energy and Environmental Research Corporation,
1988). Avariety of different technologies and processes can
be used to rerefine used oil, but all rerefining operations
remove water, additives, sludge, dissolved hydrocarbons
and solvents, and impurities from the used oil.
Slipstreaming-Used oil is introduced in small amounts
into the refining process. No preprocessing is performed
because only very small quantities of used oil are inserted
into the refining process. Through slipstreaming, used oil
can be converted into gasoline, heating oil, or feedstocks
for other petrochemical products (Arner, 1992).
Supplementing Diesel Fuel-Used oil is filtered to remove
solid particles and then mixed with diesel fuel. Generally,
one part of used oil is mixed with nine parts of diesel fuel
to produce a mixture that can be used satisfactorily to fuel
diesel engines (Nolan etal., 1990). (Although this recycling
method has been common in the past, new air regulations
have begun to limit its use.)
Although recycling is the best used oil management option,
recycling is not always feasible. Some used oils are too
contaminated, generated too far away from recycling facili-
ties, or generated in quantities too small to be economically
recycled. In certain cases, therefore, disposal is an appropri-
ate option, as long as the used oil is disposed of in a way
that does not harm human health or the environment For
used oil that is not deemed a hazardous waste, appropriate
disposal options include incineration by a facility that ac-
cepts industrial liquids or placement of the used oil in a
properly designed and constructed landfill that accepts in-
dustrial wastes and meets RCRA Subtitle D requirements.
For used oil that is deemed a hazardous waste, disposal
practices include placing the used oil in a landfill that meets
RCRA Subtitle C requirements or burning the used oil in
a permitted hazardous waste incinerator.
How the Price of Virgin Oil Affects the
Used Oil Management System
The price of virgin oil dramatically affects the used oil
management system because used oil competes with virgin
oil as a source of fuel and as a base stock for lubricating oil.
Like all recycling markets,; in order to compete, recycled oil
products must be sold at a lower price than virgin oil
products (Nolan et al., 1990). The higher the price of virgin
oil, the higher the price charged for products made from
virgin oil, and the higher;the price that can be charged for
products made from used oil.
Used oil recyclers must cover the costs of collecting and
recycling used oil, and must maintain a profit to stay in
business. When the price of virgin oil is high, used oil
recyclers make large enough profits that they can pay gener-
ators for the used oil they produce, or pay transporters for
the used oil they collect (Nolan et al., 1990). As virgin oil
prices drop, however, used oil recyclers cannot pay gener-
ators as much for the oil since the profit margin for the
recyclers is reduced. When virgin oil prices drop below a
"break even" level, the recyclers or transporters can no
longer pay (or must charge) for the used oil collected from
generators.
Figure 2-5 shows how the price of virgin fuel oil affects used
oil generators. In the early 1990s, generators had to pay to
have their used oil collected by transporters or recyclers
when the price of virgin oil fell below approximately 40
cents a gallon. When the price of virgin oil rose above 53
cents a gallon, generators were paid for the used oil that was
collected (Arner, 1992). As the figure shows, the price of
virgin oil has fluctuated dramatically in recent years. These
dramatic fluctuations have caused substantial uncertainty
in used oil markets.
When recyclers and transporters pay for used oil, service
stations, quick-lube shops;, fleet operations, DIY collection
centers, and retailers have an economic incentive to have
their used oil recycled off site. As a result, high virgin oil
prices encourage used oil. processing and rerefining. Con-
versely, low virgin oil prices encourage onsite burning of
used oil in space heaters and supplementing diesel fuel with
used oil. Clearly, the projected price of virgin oil is a consid-
eration when deciding how to manage used oil. Choosing a
cost-effective recycling option will allow service stations,
quick-lube shops, fleet operations, DIY collection centers,
and retailers to increase the profits (or reduce the costs) of
properly managing their used oil.
11
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0.80
g> °-70 ~
Iraq Attack on Kuwait
Severe Winter 1989-1990
0.30 -
.-._ World Wide Oil Glut
-0.15.
-0.10
-0.05
Lo.01
T
I
Price Paid to
Generator
(or Used Oil
Free Zone
No Payment
No Charge
Charge to
Generator
JAN 1986 JAN 1987 JAN 1988 JAN 1989 JAN 1990
Figure 2*5. The effect of virgin oil prices on payments made to generators for used oil (source: adapted from Nolan et al., 1990).
Although cost-effectiveness is an important consideration
when choosing a used oil management option, protecting
human health and the environment must always be the
primary concern. In addition, service stations, quick-lube
shops, fleet operations, DIY collection centers, and retailers
have an economic incentive to manage their used oil in the
most environmentally sound way possible. Choosing the
most environmentally sound used oil management method
will minimize potential liability costs and eliminate fines
and other costs associated with enforcement actions for
violating environmental regulations.
12
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Chapter 3
The Regulations
EFA's Used Oil Management Standards form the
core of the federal regulatory requirements that
apply to the participants in the used oil manage-
ment system. Other federal regulations govern specific
aspects of, managing used oil, such as storing used oil in
underground storage tanks, responding to releases of used
oil into the environment, or disposing of used oil that is
determined to be a hazardous waste. This chapter discusses
the federal regulatory requirements concerning used oil
management, and gives special emphasis to regulations that
are likely to apply to service stations, quick-lube shops, fleet
operations, DIY collection centers, and retailers. In addi-
tion, a brief overview of state regulations is presented.
EPA's Used Oil Management Standards
EPA published its Used Oil Management Standards in the
Federal Register on September 10, 1992. The management
standards are part of the RCR A regulations and are codified
in Part 279 of Title 40 of the Code of Federal Regulations
(CFR). The regulatory requirements in the management
standards, along with other federal regulations referred to
in the management standards, mandate practices that must
be followed by generators, transporters, processors, rerefin-
ers, marketers, and burners of used oil.
The Used Oil Management Standards are meant to encour-
age recycling and prevent mismanagement of used oil,
without placing unnecessary regulatory burdens on partici-
pants in the used oil management system. The management
standards also specifically prohibit the used oil management
practices that have posed the greatest risks to human health
and the environment in the past The practices that are
prohibited are improper storage of used oil, road oiling, use
of the oil as a dust suppressant, and the mixing of used oil
with hazardous wastes. .The management standards also
require that proper methods be used to transport, process,
rerefine, burn, market, and dispose of used oil.
The Recycling Presumption
The Used Oil Management Standards include a recycling
presumption, which is an assumption that all used oil that
is generated will be recycled. The recycling presumption is
based on the fact that almost all used oil can be recycled.
The purpose of the recycling presumption is to make' it
easier for used oil handlers to comply with federal regula-
tions on used oil management, while still properly handling
their used oil. Without the recycling presumption, used oil
generators and others that handle used oil would have to
decide whether the used oil would ultimately be recycled or
disposed. This decision would affect what federal regula-
tions the used oil was regulated under. Used oil destined for
recycling would be subject to the Used Oil Management
Standards and used oil destined for disposal would be sub-
ject to other federal regulations, such as the hazardous waste
requirements in RCRA. Subtitle C and the nonhazardous
waste requirements in RCRA Subtitle D. The recycling
presumption allows the generation and handling of all used
oil (whether it will ultimately be recycled or disposed of) to
13
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Key Terms
Aggregation Point
Biu or British Thermal Unit
Closure
Container
Flash Point
Hazardous Waste
Impermeable
Secondary Containment
State Regulatory Authority
Tank
Tolling Arrangement
A site or facility where a used oil generator accumulates and/or stores used oil that the generator has
produced or has collected from DIYs.
A unit used to express energy output. It represents the amount of energy required to raise the temperature of
1 pound of water by 1°F.
The procedures that must be followed to prevent any future release of contaminants into the environment
when a facility or storage tank is removed from operation (i.e., when the facility or tank is closed).
A portable device in which a material is stored, transported, treated, disposed of, or otherwise handled.
The lowest temperature at which a flame or spark will cause the vapors above the surface of a liquid to ignite.
As defined in the RCRA regulations, a waste that is listed as hazardous, or that exhibits a hazardous
characteristic (ignitability, corrosivity, reactivity, or toxtcity).
Capable of preventing liquids from flowing through.
A wall, lining, or other type of material that provides a barrier between a tank or other container and the
environment so that leaks from the tank can be contained.
The state agency or department that is responsible for implementing RCRA requirements in authorized states.
A stationary device used to store a material.
A contractual agreement between a used oil generator and a processor or rerefiner that treats the used oil.
The processed or rerefined oil is returned to the generator to be used as a lubricant, cutting Ul, or coolant
be regulated under the management standards, until the
used oil is actually disposed of or sent for disposal.
The Rebultable Presumption for Used Oil
Some halogenated solvents are considered hazardous wastes
under RCRA. Because high levels of halogens generally
indicate the presence of halogenated solvents, used oil that
contains 1,000 ppm or more of total halogens is presumed
to be mixed with a hazardous waste under the Used Oil
Management Standards. Used oil with 1,000 ppm or more
of total halogens, therefore, must be handled as a hazardous
waste, meeting all RCRA Subtitle C requirements, unless
this presumption is rebutted.
One way the hazardous waste presumption may be rebutted
is by analyzing the used oil and determining that it does not
contain significant concentrations of individual halogen-
ated constituents, despite the high halogen content In the
management standards, EPA recommends that an analytical
method from a publication entitled Test Methods for Evalu-
ating Solid Waste (EPA/SW-846), Third Edition, be used to
rebut the hazardous waste presumption if the used oil han-
dler believes that the used oil has not been mixed with a
hazardous waste. This document contains test methods ap-
proved by EPA and is available from the Government
Printing Office for $319. To obtain a copy, call 202-783-
3238 and ask for document number 955-001-00000-1. Used
oil generators and other handlers that wish to rebut the
presumption that their used oil is hazardous can either test
the used oil themselves or send the used oil to a laboratory
that will conduct the test,
Used Oil Burning Specifications
Under the Used Oil Management Standards, burning used
oil that does not meet specification requirements for certain
metals, flash point, and total halogens is strictly regulated.
The specification limits are given in Table 3-1.
Used oil that meets all allowable levels in Table 3-1 is called
specification used oil, and can be burned anywhere. Used
oil that does not meet one or more of the allowable levels
listed in Table 3-1 is called off-specification used oil. The
burning requirements in the Used Oil Management Stand-
ards, which are discussed later in this chapter, apply to
burners of off-specification used oil. '
14
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Table 3-1. Used Oil Specification Limits
Contaminant or Property
Allowable Level
Arsenic
Cadmium
Chromium
Lead
Flash Point
Total Halogens
Maximum of 5 ppm
Maximum of 2 ppm
Maximum of 10 ppm
Maximum of 100 ppm
Minimum of 100°F
Maximum of 4,000 ppm
Requirements for Used Oil Generators
A used oil generator is "any person, by site, whose act or
process produces used oil or whose act first causes used oil
to become subject to regulation." Under this definition,
service stations, quick-lube shops, and fleet operations are
all considered generators of used oil. DIYs are not regulated
under the management standards (because of their status as
household waste generators), but DIY collection centers and
retailers that collect DIY used oil are considered generators
because the act of collecting DIY used oil "causes the used
oil to become subject to regulation."
The generator requirements under EPA's Used Oil Manage-
ment Standards are meant to ensure that used oil generators
use good housekeeping practices when handling used oil.
Although these requirements are the only ones in the man-
agement standards written specifically for generators,
generators using other management practices (such as proc-
essing used oil, burning off-specification used oil in
something other than a space heater, or disposing of used
oil) must comply with the used oil management standards
governing those practices. (The management standards do
not apply, however, to used oil that has been mixed with
diesel fuel, as long as the mixture will be used in vehicles
owned by the used oil generator.) The specific require-
ments that used oil generators must follow under the
management standards are listed below.
Except under the specific and limited circumstances
given in §279.10(b) of the Used Oil Management Stand-
ards, used oil mixed with a hazardous waste must be
handled as a hazardous waste, as discussed in more detail
in Appendix B. The costs associated with handling used
oil as a hazardous waste are high, and generators conse-
quently should avoid contaminating an entire batch of
used oil by mixing it with a hazardous waste. In addition,
mixing a RCRA hazardous waste with used oil is consid-
ered hazardous waste; treatment, unless this treatment is
performed in accumulation tanks or containers. Finally,
mixing used oil with a hazardous waste prevents the
generator from being eligible for the service station deal-
ers exemption from CERCLA liability, which is dis-
cussed in greater detail later in this chapter.
« In addition, the rebuttable presumption, which is dis-
cussed earlier in this chapter, applies to used oil gener-
ators. As a result, used oil containing 1,000 ppm or more
of total halogens is presumed hazardous and must be
handled as a hazardous waste, unless the presumption is
rebutted.
Generators must store used oil in tanks, containers, or
other RCRA regulated storage units (such as permitted
lagoons or pits). Tanks and containers must be kept in
good operating condition, free of any visible spills or
leaks, structural damage, or deterioration. All above-
ground tanks and fill pipes to underground tanks must
be clearly labeled with the term "used oil." Generators
also are subject to requirements under the Spill Preven-
tion Control and Qjuntermeasures regulations and the
Underground Storage Tank (UST) regulations, which are
described later in this chapter and in Appendix C.
Generators can burn used oil in oil-fired space heaters
as long as they follow the requirements set forth in
Chapter 4.
Any leaks or spills from aboveground storage tanks that
are released to the environment must be stopped as soon
as possible, and the 'released used oil must be contained
and cleaned up. The used oil that has been cleaned up
must be managed according to the management stand-
ards. Any soil or other materials that have been contami-
nated with the released used oil must be properly
managed (see next paragraph). The leaking tank must be
repaired or replaced. These requirements do not apply
to leaks or spills that: are not released to the environment,
such as those that;occur on concrete floors within a
storage building. Releases to the environment are also
regulated under CERCLA and the Clean Water Act, as
discussed later in the chapter.
Materials containing or otherwise contaminated with
used oil (for example, rags, wipes, and absorbent mate-
rials) are considered used oil, and must therefore be
handled under the used oil management standards, un-
less they show no signs of any free-flowing oil. On
addition, materials contaminated with used oil are con-
sidered used oil under the management standards if they
15
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are burned for energy recovery.) Contaminated materi-
als that no longer contain free-flowing used oil are not
considered used oil under the management standards
(unless they will be burned for energy) and are subject
to RCRA requirements. These materials must be tested
to determine if they exhibit the characteristics of a haz-
ardous waste. Alternatively, a generator may use his or
her knowledge of the materials or processes used to pro-
duce the waste in order to determine whether the waste
exhibits one of these hazard characteristics. If the con-
taminated materials are deemed hazardous, they must be
handled as a hazardous waste under RCRA Subtitle C.
If they are not hazardous, they can be handled as a solid
waste under RCRA Subtitle D. Any used oil drained or
otherwise removed from these contaminated materials
must be handled as used oil.
Generators must use transporters that have obtained
identification numbers from EPA (in accordance with the
management standards) to ship any used oil off site,
when the used oil is in quantities greater 55 gallons. A
generator that transports used oil generated on site or
collected from DIYs to an aggregation point or to a used
oil collection center is not required to obtain an EPA
identification number as long as the used oil is trans-
ported in vehicles owned by the generator in quantities
of 55 gallons or less.
Requirements for Used Oil Transporters and
Transfer Facilities
A used oil transporter is defined as "any person who trans-
ports used oil, any person who collects used oil from more
than one generator and transports the collected oil, and
owners and operators of used oil transfer facilities." A used
oil transfer facility is defined as "any transportation-related
facility including loading docks, parking areas, storage areas,
and other areas where shipments of used oil are held for
more than 24 hours and not longer than 35 days during the
normal course of transportation" or prior to certain proc-
essing activities (U.S. EPA, 1994). As discussed earlier in
this chapter, transporter requirements do not apply to gen-
erators who transport used oil on site or transport 55
gallons or less of used oil to offsite collection centers or
aggregation points.
Because the normal risks involved with transporting used
oil are greater than the risks involved with generating used
oil, used oil transporters are required to meet more strin-
gent requirements than generators. As with generators,
transporters that use other management practices (such as
processing used oil to meet burning specifications) must
also meet other applicable requirements under the manage-
ment standards. The requirements that [apply solely to
transporters are briefly described below. ;
Transporters must obtain an EPA identification number.
Transporters can only deliver used oil to facilities with
EPA identification numbers (i.e., other transporters,
used oil processing facilities, off-specification used oil
burners, or rerefining facilities), or to specification used
oil burners.
If a release to the environment occurs during transpor-
tation, transporters must take immediate actions to pro-
tect human health and the environment For example,
transporters should immediately notify local authorities
and institute emergency response measures, such as con-
structing a dike around the discharge area.
Transporters must determine if the used oil contains
1,000 ppm or more of total halogens. Transporters can
determine halogen content by testing the used oil or by
using their knowledge of the materials and processes that
generated the used oil. If the oil contains 1,000 ppm or
more of total halogens, the used oil is considered a haz-
ardous waste under the rebuttable presumption in the
management standards. This used oil must be handled
under RCRA Subtitle C, unless the transporter success-
fully rebuts the presumption. Transporters must keep
records for at least 3 years of any tests conducted or
information used to make the determination of the halo-
gen content of the used oil.
Transporters must track used oil shipments by keeping
records of each shipment of used oil collected and deliv-
ered. These records must be maintained for at least 3
years. When accepting a shipment for delivery or deliver-
ing a shipment, the transporter must record the following
information: name, address, and EPA identification num-
ber (if applicable) of the person or facility the oil is being
collected from or delivered to; dated signature of the
person or a representative of the facility; quantity of used
oil collected or delivered; and the date of collection or
delivery.
In addition, used oil transporters must comply with all
applicable U.S. Department of Transportation regulations
concerning used oil shipping and the release of used oil to
the environment. These regulations are discussed later in
this chapter and in Appendix E.
16
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Under the management standards, transfer facilities must
meet the following storage requirements:
Transfer facilities must meet the same storage tank, label-
ing, and response to release requirements as used oil
generators.
Both aboveground tanks and containers used to store
used oil must be equipped with secondary containment
systems. The secondary containment systems must be
impermeable so that any release of used oil into soil,
ground water, or surface water is prevented.
Requirements for Used Oil Processors and Rerefiners
A processor/rerefiner is a facility that uses "chemical or
physical operations designed to produce from used oil, or
to make used oil more amenable for production of, fuel oils,
lubricants, or other used oil-derived products. Processing
includes, but is not limited to: blending used oil with virgin
petroleum products, blending used oils to meet the fuel
specification, filtration, simple distillation, chemical or
physical separation, and rerefining." Used oil processors
and rerefiners manage large quantities of used oil using a
wide variety of procedures. The management options used
at processing and rerefining facilities, therefore, tend to
require stricter controls than are necessary for generators or
even transporters. In addition, mismanagement of used oil
at processing and rerefining facilities in the past has caused
damage to the environment. Consequently, under the man-
agement standards, stricter requirements are placed on
processors and rerefiners than on other participants in the
used oil management system (U.S. EPA, 1992a). The re-
quirements that apply only to processors and rerefiners are
listed below.
Processors and rerefiners must obtain an EPA identifica-
tion number.
Processing and rerefining facilities must be maintained
and operated in a manner that reduces the possibility of
fire, explosion, or release of used oil to air, soil, or water.
Processing and rerefining facilities must be equipped
with a communications or alarm system and emergency
response equipment such as portable fire extinguishers
and spill control equipment. All equipment must be
properly maintained and regularly tested.
The aisle space within processing and rerefining facilities
must be wide enough to allow personnel and emergency
equipment to move around without being obstructed.
Processing and rerefining facilities must make necessary
arrangements to ensure that local authorities are pre-
pared for an emergency at their facility.
Processing and rerefining facilities must develop a con-
tingency plan to minimize hazards to human health and
the environment from emergencies. In the case of an
emergency, this plan must immediately be carried out by
facility personnel. ;
« All processing and rerefining facilities are required to
have an emergency coordinator, someone who is on site
or on call and is responsible for coordinating emergency
response measures. If used oil is released to the environ-
ment during the emergency, the emergency coordinator
must notify local authorities and appropriate federal
authorities.
Facilities that process or rerefine used oil must follow the
same procedures as transporters to determine the halo-
gen content of the used oil. If the halogen level exceeds
1,000 ppm, the processor or rerefiner must handle the
used oil as a hazardous waste unless the presumption is
rebutted.
Processors and rerefiners must develop an analysis plan
that describes in detail the procedures that will be fol-
lowed to determine the halogen content of the used oil
and whether the used Oil meets burning specifications.
« Processors and rerefiriers must keep operating records
until the facility is closed. These records must include:
results of analyses conducted on the halogen levels; re-
sults of analyses conducted to determine if used oil meets
burning specifications; and summary reports of any in-
cidents that required the contingency plan to be used.
Processors and rerefiners must keep records of each ship-
ment of used oil they receive, and each shipment of
processed or rerefined used oil they send to another
facility for use. These records must be maintained for at
least 3 years.
Processors and rerefiners must follow the same storage re-
quirements as used oil transporters and transfer facilities.
Processors and rerefiners must follow the same require-
ments for responding to releases of used oil to the envi-
ronment as generators.
When tank systems are to be closed, processors and
rerefiners must decontaminate tanks, tank components,
and surrounding soils of used oil. In addition, all con-
tainers that stored used oil must be decontaminated and
removed from the site when the site is being closed.
17
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Processors and rerefiners that generate, transport, burn, or
dispose of used oil must meet the applicable requirements
for these activities under the management standards. In
addition, processors and rerefiners that first claim that used
oil meets specifications for burning, or that send off-specifi-
cation used oil directly to a burner, must meet the marketing
requirements of the management standards. ,
Requirements for Burners of Off-Specification Used Oil
Used oil that meets the burning specifications under EPA's
Used Oil Management Standards can be burned without
being subject to regulatory requirements. Off-specification
used oil, however, should only be burned with equipment
or procedures that limit emissions into the air. The burning
requirements in the management standards, therefore, only
apply to burners of off-specification used oil. A burner is
defined in the management standards as "a facility where
used oil not meeting the specification requirement. . . is
burned for energy recovery" in the following devices: indus-
trial furnaces, industrial boilers, utility boilers, hazardous
waste incinerators, or used oil-fired space heaters. (Gener-
ators who burn used oil in used-oil fired space heaters,
however, are not covered by the burner requirements in the
management standards, as long as they meet certain other
requirements discussed in this chapter, such as only burning
used oil they have generated or collected from DIYs.) These
devices are all defined in RCRA and are subject to appro-
priate RCRA requirements. In addition, burners who
generate, transport, process, rereftne, market, or dispose of
used oil, must comply with other applicable requirements
under the management standards. The burner requirements
under the management standards are as follows:
Burners must obtain an EPA identification number.
Burners must use the same procedures as transporters
to determine the halogen content of the used oil. If the
halogen content is greater than 1,000 ppm, then the
used oil must be handled as a hazardous waste, unless
the burner rebuts the presumption.
Burners must follow the same storage requirements as
used oil transporters.
Burners must follow the same procedures as used oil
generators to respond to releases of used oil to the envi-
ronment
Burners must keep records about each batch of used oil
received for burning. These records must be kept for at
least 3 years and must contain the following information:
the name, address, and EPA identification number of the
transporter; the name, address, and EPA identification
number (if applicable) of the generator, processor, or re-
refiner from which the used oil was collected; the quan-
tity of used oil accepted; and the date the used oil was
accepted.
Before the burner accepts the first shipment of off-
specification used oil from a generator, processor, or
rerefiner, the burner must give the generator, processor,
or rerefiner a signed statement that certifies that the
burner has notified EPA of its used oil management
activities and will only burn the used oil in an appropri-
ate device. A record of the certification must be main-
tained for at least 3 years after the last shipment of used
oil is received from the generator, processor, or rerefiner.
Requirements for Marketers of Used Oil
A marketer is defined as "any person who conducts either
of the following activities: (1) directs a shipment of off-
specification used oil from their facility to a used oil burner;
or (2) first claims that used oil that is to be burned for energy
recovery meets the used oil fuel specifications [in the man-
agement standards]." According to the management
standards, all marketers of used oil must also either be
generators, transporters, processors, rerefiners, or burners
of used oil. Consequently, all marketers must comply with
other applicable requirements under the management stand-
ards, as well as the requirements listed below.
Marketers must obtain an EPA identification number.
Marketers can determine that the used oil meets burning
specifications by performing analyses or obtaining analy-
ses that have previously been performed that show all
specification levels are met.
Marketers must keep copies of these analyses for at least
3 years. i
Marketers can only send off-specification used oil to a
burner who has an EPA identification number and burns
the used oil in an appropriate device.
For off-specification used oil, marketers must keep re-
cords for at least 3 years of each shipment of used oil to
a burner. The records must include: the name, address,
and EPA identification number of the used oil trans-
porter and the burner who received the oil; the quantity
of used oil shipped; and the date of shipment
For specification used oil, marketers must keep records
for at least 3 years of each shipment of used oil, and the
record must include: the name and address of the facility
18
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receiving the shipment; the quantity of used oil shipped;
and the date of shipment The record must also cross-
reference the analyses that were used to determine that
the used oil met burning specifications.
Before a marketer sends the first batch of off-specification
used oil to a burner, the marketer must obtain a signed
statement from the burner that certifies that the burner
has notified EPA of its used oil management activities
and that the burner will only burn the used oil in ap-
propriate devices. This certification must be kept for at
least 3 years after the last shipment of used oil is sent to
, the burner. . . > .
Requirements for Disposing of Used Oil
Used oil that will be disposed of because it cannot feasibly
or economically be recycled must be tested, or knowledge :of
the materials and processes used to generate the waste must
be applied, to determine if it is considered a hazardous waste
under RCRA. If the used oil is determined to be a hazard-
ous waste, it must be disposed of in compliance with Subtitle
C of RCRA. If the used oil is not hazardous, it can be
disposed of in compliance with Subtitle D of RCRA. Be-
cause used oil is a liquid, however, service stations,
quick-lube shops, fleet operations, DIY collection centers,
and retailers only can dispose of used oil in Subtitle D
disposal facilities that accept industrial liquid wastes. State
regulations regarding disposal of used oil may differ from
the federal regulations, so be sure to check with the state
environmental agency prior to disposing of used oil.
Requirements for Using Used Oil as a Dust
Suppressant
The use of used oil as a dust suppressant (which includes
road oiling) is banned, except in states that petition EPA to
allow road oiling within their jurisdictions. States can peti-
tion EPA to allow road oiling of used oils that do not contain
hazardous wastes. Any states petitioning EPA must show
that road oiling will not adversely affect human health and
the environment.
State Regulations on Used Oil Management
Under RCRA, states can become authorized by EPA to
implement and enforce federal regulatory requirements. As
of 1994, all states except Wyoming, Iowa, Alaska, and Ha-
waii have become authorized by EPA. In addition, Guam
has become authorized by EPA, but Washington, DC, the
Commonwealth of Puerto Rico, the Virgin Islands, Ameri-
can Samoa, and the Commonwealth of Northern Mariana
Islands have not. In states and territories that are not author-
ized, EPA Regional Offices implement and enforce the
management standards.
In the unauthorized states (and territories), the Used Oil
Management Standards went into effect on March 8,1993.
In the authorized states, tihe management standards do not
go into effect until those states amend their programs to
incorporate the standards. According to the Used Oil Man-
agement Standards, this should have been done by July 1,
1994, unless implementing the standards requires the state
to change a law. In states where a legislative change is
required, the management standards should go into effect
by July 1,1995. :
In order for a state to become authorized under RCRA, its
standards must be at least: as stringent as the federal stand-
ards. Consequently, service stations, quick-lube shops, fleet
operations, DIY collection centers, and retailers in author-
ized states that have not yet implemented the management
standards should be prepared to at least meet the federal
requirements. In addition, the state environmental agency
should be contacted to determine if any additional state
requirements are currently in effect and if the state require-
ments implementing the Used Oil Management Standards
will be more stringent than the federal requirements.
Many states have regulatory requirements that go beyond
those in EPA's Used Oil Management Standards and the
supporting federal regulations. In addition, many states
developed a regulatory structure for used oil before the
federal management standards were finalized. As a result,
states vary widely in their approaches to regulating used oil
(American Petroleum Institute, 1991).
One of the major differences between state and federal
regulations is that several states list used oil as a hazardous
waste. These states include California, Massachusetts, New
Hampshire, New Jersey, Rhode Island, and Wyoming (Con-
venient Automotive Services Institute, 1992). In states that
list used oil as a hazardous waste, the management of used
oil must meet the states' hazardous waste regulations.
Many states also have more stringent regulations for the
management and disposal of used oil filters than the federal
government. States such as California, Massachusetts, Ore-
gon, and Rhode Island, list used oil niters as a hazardous
waste (Convenient Automotive Services Institute, 1992). In
these states, the handling, recycling, and disposal of used oil
filters must be in compliance with the states' hazardous
waste regulations. Other states, including California, Colo-
rado, Florida, Minnesota, Missouri, New Mexico, New
19
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York, Rhode Island, South Carolina, and Texas require that
used oil niters be recycled (Convenient Automotive Services
Institute, 1992). Some states also do not allow used oil
filters to be disposed of in municipal solid waste landfills
(Convenient Automotive Services Institute, 1992).
In some states, used oil is banned from being disposed of
in municipal solid waste landfills. These states include Flor-
ida, Iowa, Minnesota, Missouri, North Carolina, North
Dakota, Oregon, South Carolina, Texas, Vermont, Wash-
ington, and Wisconsin (BioCycle, May 1992). In these
states, used oil must either be recycled, disposed of in a
municipal incinerator, or disposed of in a hazardous waste
disposal facility.
Finally, many states actively encourage the recycling of DIY
used oil. Some of these states, including Arizona, Califor-
nia, and Texas, have instituted a deposit or fee system
(Convenient Automotive Services Institute, 1992). When
lubricating oil is purchased, the customer pays a deposit To
retrieve the deposit, the customer must return the used oil.
Other states, such as Alabama, California, Maryland, Michi-
gan, Minnesota, New Hampshire, New York, Rhode Island,
Vermont, and Washington, have state-wide DIY used oil col-
lection programs to give DIYs a convenient place to bring their
used oil (American Petroleum Institute, 1991).
The Western Michigan Environmental Action Council and
Alabama's Project R.O.S.E. (Recycled Oil Saves Energy) are
two very successful state-wide DIY used oil collection pro-
grams (Arner, 1988). Both of these programs use public
outreach materials, such as service announcements, pam-
phlets, and newsletters, to inform DIYs about how
improper disposal of used oil harms human health and the
environment These public outreach materials also stress
the need for recycling and tell DIYs where they can bring
their used oil. In Michigan and Alabama, DIYs can bring
used oil to collection centers that are run by public agencies
or volunteer groups, as well as to service stations and quick-
lube shops that voluntarily collect DIY used oil.
Information on state regulations concerning used oil man-
agement, as well as other state used oil programs, can be
obtained from state environmental agencies. A list of state
agencies that can be contacted for more information is
provided in Appendix A of this document
RCRA Requirements That Apply to the
Disposal of Used Oil
Subtitle C of RCRA regulates the handling and disposal of
hazardous wastes, while Subtitle D regulates non-hazardous
solid waste disposal facilities. As discussed above, used oil
that is to be disposed of is regulated under either Subtitle C
(40 CFR Parts 260 to 266, 268, 270, and 124) or Subtitle D
(40 CFR Parts 257 and 258) of RCRA, depending on
whether the oil exhibits characteristics of a hazardous waste.
In addition, any solids contaminated with used oil (such as
absorbent materials used to clean up a used oil spill) that
contain no free-flowing used oil are regulated under Subtitle
C or Subtitle D of RCRA, depending on whether they
exhibit characteristics of a hazardous waste. Solid materials
that contain free-flowing used oil must be disposed of as
used oil-
Consequently, before disposing of used oil pr solid materials
that have been contaminated with used oil, these materials
must be tested, or another approved method must be used,
to determine if they meet the characteristics of a hazardous
waste under RCRA. These characteristics, along with a
summary of Subtitle C andSubtitle D regulations, are given
in Appendix B.
The Exemption From CEROLA Liability
i
As discussed in Chapter 1, CERCLA liability is a very
important issue for individuals and facilities that handle
used oil. The strict liability language of CERCLA allows
individuals and businesses to be held liable for the misman-
agement of materials containing hazardous substances, even
if another individual or business was contracted to manage
the substance. In order to encourage service stations, quick-
lube shops, and government DIY collection centers to
accept DIY used oil, however, CERCLA contains a "service
station dealers" exemption from liability. To meet the
CERCLA definition of a service station dealer, a business
or facility must meet the following criteria (42 U.S.C.
§ 9601 Section 101 (37)):
The facility must be a "motor vehicle service station,
filling station, garage, or similar retail establishment"
that generates a significant percentage of its revenues
from "fueling, repairing, or servicing motor vehicles." A
facility run by a government agency for the sole purpose
of collecting DIY used oil is also considered a "service
station dealer" under the CERCLA definition.
The facility must accept DIY used oil for recycling.
Service stations, quick-lube shops, and government-run DIY
collection centers, therefore, can all meet the CERCLA
definition of "service station dealer" if they accept DIY used
oil for recycling. Along with meeting this definition, how-
ever, "service station dealers" must comply with EPA's Used
20
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Oil Management Standards to receive the exemption from
CERCLA liability. In addition, any used oil that has been
mixed with a hazardous waste is not exempt from CERCLA
liability.
Used oil generators that do not meet the requirements for
the service station dealer exemption and that contract with
a transporter or recycler to handle their used oil can be held
liable for cleanup costs if the transporter or recycler mis-
manages the oil. Used oil generators that do meet: the require-
ments for the service station dealer exemption, including
being in compliance with the Used Oil Management Stand-
ards, cannot be held liable under CERCLA for transporter
or recycler mismanagement The service station dealer ex-
emption, however, does hot apply to any onsite used- oil
mismanagement by the generator.
Overall, the service station dealer exemption makes accept-
ing DIY used oil for recycling a more attractive option for
service stations and quick-lube shops. The exemption from
potentially staggering liability costs is a very positive eco-
nomic incentive to bring DIY used oil into the management
system. ,
Underground Storage Tank Regulations
An underground storage tank (UST) is a tank (or combina-
tion of tanks) that is used to contain substances and that has
at least 10 percent of its volume underground (U.S. EPA,
1990). Most USTs that hold used oil, virgin petroleum, and
certain hazardous chemicals are regulated under Subtitle I
of RCRA (40 CFR Part 280). The goals of the UST regula-
tions-are to prevent, find, and dean up leaks and spills from
USTs, and to ensure that owners and operators of USTs can
pay for correcting any problems caused by leaks and spills.
The UST requirements are summarized in Appendix C.
Spilt Prevention Control and
Countermeasures Requirements
The Spill Prevention Control and Countermeasures
(SPCC) requirements implement Section 311 of the Clean
Water Act and can be found in 40 CFR Parts 110 to 112.
The SPCC requirements have been in place since 1973 and
were strengthened by the Oil Pollution Act of 1990. The
purpose of the Clean Water Act is to prevent the discharge
of pollutants into navigable waterways in the United States.
("Navigable waterways" include almost all surface water
bodies.) The Oil Pollution Act was passed to.deal with the
special problems associated with oil being released into
surface waters. The SPCC regulations (40 CFR Part 112)
require facilities that handle oil (and used oil) to develop a
plan to prevent discharges into surface water.
All facilities handling oil: must comply with the SPCC regu-
lations, except facilities that: -
Are located in areas where a release of oil could not be
expected to enter a navigable waterway.
Are subject to the control and authority of the U.S.
Department of Transportation, as defined in a Memo-
randum of Understanding between the Secretary of
Transportation and the Administer of EPA, dated
November 24, 1971.
Have an underground, storage capacity of 42,000 gallons
or less and have an aboveground storage capacity of
1,320 gallons or less (with no single aboveground con-
tainer having a capacity of more than 660 gallons).
The SPCC requirements that are likely to apply to service
stations, quick-lube shops, fleet operations, DIY collection
centers, and retailers that store used oil are given in
Appendix D.
The Department olf Transportation's
Hazardous Materials Transportation
Act Requirements
The Hazardous Materials Transportation Act (HMTA),
which is administered by:the U.S. Department of Transpor-
tation (DOT) and codified in 49 CFR Parts 171 to 199,
regulates the transportation of used oil that meets the DOT
definition of a hazardous material. Under these regulations,
used oil is considered hazardous if it is a "combustible
liquid" (i.e., has a flash point between 100°F and 200°F) or
a "flammable liquid" (i.e., has a flash point of 100°F or less).
In addition, any used oil that is destined for disposal must
be transported as a hazardous material. In 1994, these
regulations were being updated by DOT, and transporters
of used oil should contact DOT to .determine the final
outcome of that effort, HMTA requirements are discussed
in Appendix E. , -
21
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Chapter 4
Options for Recycling Used Oil
Used oil can be recycled in a variety of ways to
utilize its lubrication or heat value. For example,
used oil can be used to lubricate engine parts or
burned for heat This chapter describes the major used oil
recycling options that are currently available and presents
the advantages and disadvantages of each of these recycling
options. Information also is provided for service stations,
quick-lube shops, fleet operations, DIY collection centers,
and retailers on how to choose a recycler. Finally, this
chapter includes disposal options for used oil that cannot
feasibly or economically be recycled.
Although some of these recycling options are appropriate
for many types of used oil, this chapter is directed toward
the recycling of oil drained from automobile and truck
crankcases.
The Major Used Oil Recycling Methods
Recycling is reusing a substance or material in a beneficial
way. In the past, used oil was reused for a wide range of
different purposes. Unfortunately, many of the ways used
oil was reused caused environmental problems. For exam-
ple, used oil was sometimes used to kill weeds or keep dust
down on dirt roads (U.S. EPA, 1984b). As a result, the used
oil contaminated soils, ground water, and surface water in
the area. In recognition of these problems, EPA's Used Oil
Management Standards have banned options, such as road
oiling, that cause significant risks to human health and the
environment
The most common used oil recycling methods that are
approved by the management standards are:
Rerefining to use as a base stock for lubricating oil.
Slipstreaming to use as a base stock for other petroleum
products.
» Processing to burn for heat :
Direct burning for heat
Rerefining
With rerefining, used oil undergoes extensive physical and
chemical treatment to remove impurities so that the result-
ing rerefined oil product is of as high a quality as a virgin
oil product (Arner, 1992). Rerefined oil is sold to lubricating
oil producers who use the rerefined oil as a base stock and
blend it with additives (and sometimes virgin oil) to produce
new lubricating oil.
Until about 10 years ago, an acid-clay process was widely
used to rerefine used oil (Bryant, 1989). The acid-day proc-
ess is simple to design and operate, but it produces large
quantities of acid and clay waste products. This causes a
disposal problem because these waste products exhibit haz-
ardous characteristics and must be handled as a hazardous
waste (Nolan et al., 1990). The expense of disposing of these
materials, along with the environmental problems associ-
ated with generating large amounts of hazardous waste, has
caused the used oil rerefining industry to shift to new
rerefining methods.
22
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Key Terms
Aromatics A class of chemical compounds that all have a similar, special chemical structure. Aromatics are known for their
strong odors and their hazardous properties.
Bottom Sediment Solid materials that form a sludge-like layer, usually at the bottom of a settling tank.
i
Distillation A process that uses heat to purify a liquid by separating out solid materials and other liquids.
Today, the rerefining companies in existence in the United
States use a vacuum distillation/hydrotreating process
(Arner, 1992). Figure 4-1 diagrams this process. With vac-
uum distillation/hydrotreating rerefining systems, filtering,
heating, and settling are first used to remove water and
larger solid particles from the used oil. Then va.cuum strip-
ping and vacuum distillation are used to remove additional
contaminants (Bryant, 1989). With these methods, a vac-
uum is created within a column of used oil and con-
taminants within the used oil are stripped away or broken
down by the vacuum. Then, the used oil is treated with
hydrogen, which bonds with certain contaminants that then
settle and are removed. Finally the heavier lubricating oil is
separated from the lighter fuel oil. With this rerefining
process, the production of hazardous waste can be mini-
mized or eliminated and residuals from the process can be
burned as a fuel or used to produce asphalt (Energy and
Environmental Research Corporation, 1988).
Rerefining has a couple of major advantages. First, unlike
any other used oil recycling option, rerefining allows used
oil to be reused over and over again. In addition, rerefining
saves energy. It takes frc>m 50 to 85 percent less energy to
rerefine used oil than it takes to refine virgin oil into lubri-
cating oil (Byrne et al., 1989).
One disadvantage of rerefining is that it is more complicated
and expensive than other recycling options. However, rere-
fining used oil into lubricating oil is easier and less
expensive than rerefining crude oil into lubricating oil. In
addition, the costs associated with rerefining used oil into
lubricating oil usually can be recaptured when the lubricat-
ing oil is sold. Another disadvantage of rerefining is that
only a few rerefiners are currently in operation in the
United States. This means that unless the generator is
located close to one of the few rerefining plants, the costs
of transporting used oil to a rerefiner will be large.
Slipstreaming
With slipstreaming, very small amounts of used oil (ap-
proximately 1 percent of the feed-stock material) are
introduced into the virgin oil refining process (Arner,
Used
Oil
Figure 4-1. A simplified vacuum distillation/hydrotreating rerefining system (source: adapted from Energy and Environmental
Research Corporation, 1988).
23
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1992). The used oil does not require any pretreatment
before it is added to the virgin oil, because the refining
process removes any contaminants in the used oil that will
affect the quality of the resulting petroleum product
The major advantage of slipstreaming is that the heat or
lubrication value of the used oil can be utilized without
complicated processing methods. The slipstreamed used oil
could be a base stock for any number of petroleum products
including fuel oil, gasoline, and lubricating oil. In addition,
slipstreaming poses no greater environmental risk than
refining virgin oil.
The only disadvantage to slipstreaming is that it currently is
not a readily available used oil recycling option. Because of
the advantages of slipstreaming, however, it may become
more widely available over time. Furthermore, used oil in-
serted in the refining process after distillation or catalytic
cracking is exempt from EPA's used oil management stand-
ards provided that it is specification used oil (U.S. EPA,
1994). This exemption will have the effect of making slip-
streaming a more desirable, and therefore more available,
option.
Processing
Processing involves treating the used oil so it will make a better
fuel. Simple processing methods are used to remove water
from most used oil that is burned for heat in the United States
(Arner, 1992). Other contaminants that are commonly re-
moved from used oil during processing are bottom sediment,
other sediment particles, and ash. Once these materials have
been removed through processing, the quality of the used oil
can be very similar to that of virgin fuel oil (Mueller, 1989).
Physical treatment methods, such as settling, filtering, and
centrifuging, are used to remove water or solid contami-
nants (such as metal pieces from engine wear) from the used
oil (Mueller, 1989). Settling is a process where used oil is
held in large tanks for relatively long periods of time so that
gravity causes heavy contaminants to sink to the bottom
and light contaminants to rise to the top. Filtering is used
to screen out solid particles and is particularly useful for
smaller, lighter particles that do not settle to the bottom in
settling tanks. With centrifuging, the oil is spun at high
speeds and the resulting centrifugal force causes the oil to
be separated from substances with different densities, such
as water and solid contaminants. Processing can also in-
clude chemical treatment of the used oil to remove chemical
contaminants and improve burning characteristics. For ex-
ample, chemicals can be added to used oil to neutralize
acids. During processing, used oil can also be blended with
virgin oil to adjust its viscosity or improve its fuel quality.
Figure 4-2 is a diagram of a used oil processing system.
Processing can be as simple as filtering out large particles
and allowing the other contaminants to settle out from the
oil, or it can include more complicated steps, such as centri-
fuging and chemically treating the used oil.
The major advantage of processing is that it improves the
burning quality of used oil. Processing also can allow off-
specification used oil to be upgraded to specification used
oil so that it can be burned by a greater number of burning
facilities. In addition, processing used oil is a widespread
industry in the United States, with nearly 200 processors
around the country (Arner, 1992), most of which are small
operations that service local markets (Nolan et al., 1990).
Processing is consequently a much more readily available
recycling option for used oil generators than rerefining.
Direct Burning
Direct burning means burning used oil without processing
it first to remove water, solid particles, and other contami-
nants. Under the Used Oil Management Standards,
generators can burn used oil without meeting the burner
requirements, as long as:
The used oil is generated on site or collected from DIYs.
Space heaters with a maximum capacity of 0.5 million
Btu per hour or less are used to burn the used oil.
The gases from the space heaters are vented outside.
Generators may also burn used oil in other types of burners,
such as industrial boilers, but they must meet the burner
requirements in the management standards.
In addition, specification used oil can be burned for fuel in
space heaters, boilers, and industrial furnaces without being
subject to special burning requirements under EPA's Used
Oil Management Standards. The contaminant levels that
cannot be exceeded for used oil to meet burning specifica-
tions are given in Chapter 3 of this document Because
burning specification used oil does not pose any greater risk
to human health and the environment than burning virgin
fuel oil, special burning requirements for specification used
oils are unnecessary (U.S. EPA, 1991).
Burning used oil in small heaters, either on site or off site, is
a common method of recycling. Approximately 70,000 small
heaters are used every year in the United States to burn more
than 120 million gallons of used oil (Arner, 1992).
24
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Additional
Treatment
Options
Used Oil
Collection and
Storage
Coarse M Settling/
Filtration f*j Heating
Hazardous vs.
Nonhazardous
Waste Determination
Centrifuge
Chemical
Addition
J
(Fine Filtration/ j_
Ceintrifuge J~
Blended with
Virgin Product
or Other
Used Oils
Air, Water
Emissions;
Sludge from
Tank Bottoms
Figure 4-2. A simplified used oil processing system (source: Arner, 1992).
Burning off-specification used oil for fuel in large boilers and
furnaces is another acceptable direct burning method. Un-
der the Used Oil Management Standards, off-specification
used oil can only be burned: for fuel in industrial furnaces
or boilers (such as asphalt plants and cement kilns), for fuel
in utility boilers that generate electricity or other types of
energy, and in hazardous waste incinerators (U.S. EPA,
1992c). Off-specification used oil can safely be burned in
these large burners because they burn much hotter than
space heaters and other small heaters. The heat generated
causes the used oil and its contaminants to be burned almost
completely, reducing the quantity of contaminants that are
released to the air. In addition, these large burners usually
have pollution control equipment that further reduces emis-
sions (Nolan et al, 1990). Therefore, as long as the burning
of off-specification used oil meets the management stand-
ards, it is an effective way to recycle used oil.
The major advantage of direct burning is tha.t it allows the
heat value of used oil to be utilized without the expense of
processing the used oil before burning. When used oil is
directly burned on site this advantage is even greater. Not
only is the cost required to process the used oil eliminated,
but costs of transporting the used oil are eliminated as well.
Another advantage of direct burning is that a large number
of facilities around the country are capable of directly burn-
ing used oil. Unlike rerefining, therefore, direct burning is
a readily available recycling option for generators who are
also off-specification burners.
For service stations, quiick-lube shops, fleet operations, DIY
collection centers, and retailers, the major advantage of
directly burning used oil on site comes from using the used
oil they have generated for heating fuel. As discussed in
Chapter 2, generators of used oil sometimes have to pay to
have their used oil removed. In these cases, the generators
do not directly benefit from the value of their used oil.
When generators use the used oil as a source of heating fuel,
however, they can heat their establishments with used oil
and buy less heating fuel. Burning used oil on site for heat,
therefore, guarantees that the generator will receive an eco-
nomic benefit from its used oil.
The advantage of using used oil on site as a heating fuel can
only be gained in climates and during seasons that heating
is required. During seasons when heating is not required,
used oil will still have to be removed from the site by
transporters or recyclers, unless the generator stores the
used oil for use in colder months. Generators that choose
to store used oil will have increased storage costs.
One disadvantage of direct burning results from generators
burning off-specification used oil. Under EPA's Used Oil
Management Standards, generators who burn used oil in
space heaters do not have to test the oil to see if it meets
burning specifications, as long as the used oil is generated
25
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on site or collected from DIYs. Consequently, these gener-
ators potentially could burn off-specification used oil.
Emissions from burning off-specification used oil would be
higher than emissions from burning specification used oil.
In addition to this disadvantage, there are several factors
that should be considered when deciding whether to directly
burn used oil. First, onsite direct burning requires an initial
investment to purchase a space heater. A typical space heater
costs $5,250, including installation and the 250 gallon stor-
age tank used to feed the heater (Arner, 1992). In addition
to an investment of cash, space heaters require an invest-
ment of time. Periodic maintenance of space heaters is
necessary, and the ash from space heaters must be removed
and disposed of properly. Prior to disposal, a generator must
determine whether the ash is regulated as a hazardous waste
(see Appendix B), and if so, must dispose of it in a permitted
facility.
Finally, in many areas of the country, facilities must obtain
local or state air pollution control permits before they can
burn used oil in a space heater. Consequently, service sta-
tions, quick-lube shops, fleet operations, DIY collection
centers, and retailers that wish to directly burn used oil
should first check with their state and local governments to
determine if a permit is needed before they purchase a space
heater and begin direct burning.
Choosing a Recycling Option
When choosing a recycling option for used oil, the generator
must first decide whether the used oil will be recycled on
site or off site. As discussed earlier in this chapter, burning
used oil in space heaters is a readily available onsite recycling
option for service stations, quick-lube shops, fleet opera-
tions, DIY collection centers, and retailers. If the generator
decides the advantages to onsite recycling are greater than
the advantages of the other recycling options, and the gen-
erator decides that all of the used oil generated on site can
be recycled on site, then the generator does not have to
choose a recycling facility.
Used oil generators that decide not to recycle used oil on
site, or that decide to use an offsite recycling method for
some of the used oil they generate, must either:
Choose a used oil transporter that will collect the used
oil and bring it to a recycling facility of the transporter's
choice.
Choose a used oil recycling facility that arranges for
transportation of the used oil.
First choose a recycling facility and then choose a trans-
porter that will haul the used oil to that recycling facility.
Choosing a used oil transporter is discussed in Chapter 5.
As discussed in Chapter 3 and Appendix E, a used oil
generator must choose a used oil recycling facility itself
(rather than allow the transporter to choose the facility)
when the used oil is considered hazardous under DOT's
Hazardous Materials Transportation Act (HMTA). If the
generator does not choose a recycling facility (and an alter-
nate) the manifest requirements in the HMTA regulations
will not be met If the generator is not exempt fromCERCLA
liability through the service station dealers exemption, the
generator should strongly consider choosing its own used oil
recycler. This allows the generator to select the most reputa-
ble recycler possible to help ensure that the oil will be
managed properly and to limit the potential for liability
claims against the generator. Finally, a used oil generator that
is exempt from CERCLA liability but is interested in the
type of recycling option that is used (i.e., pr.efers rerefining
to processing) might still wish to select a particular recycler.
Many sources of information exist on used oil recycling
operations. State environmental agencies and trade associa-
tions can be contacted for lists of used oil recyclers. Appendix
A of this document gives lists of state contacts and trade
associations that would have such information. The yellow
pages can also be used to identify used oil recyclers in the
local area. Used oil recycling facilities are sometimes listed
under "oil," "petroleum," "used," "waste," or "recycle." In
addition, other service stations, quick-lube shops, fleet opera-
tions, DIY collection centers, and retailers can be contacted
for information about the used oil recyclers they are using. A
used oil generator should identify at least three or four
recycling operations to choose from (Nolan et al., 1990).
i
Once a list of potential used oil recyclers has been devel-
oped, a primary recycling facility (as well as an alternate) can
be chosen. The most important goal when choosing a used
oil recycling facility is to select a reliable recycling operation
that will recycle the used oil in an environmentally sound
manner. The secondary goal when choosing a recycling
facility is to maximize the used oil generator's profits (or
minimize the costs) from having the used oil recycled.
The first thing to do to determine if a recycling operation is
reliable and environmentally sound is to visit the facility.
Appointments should be made at the potential recycling
facilities to inspect their operations. When inspecting a
used oil recycling facility, the following things should be
26
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looked for to show that the facility is reliable (Nolan et al.,
1990; Arner, 1992):
Neatly kept appearance,
No evidence of oil leaks or spills.
Containment structures, such as walls and berms, that
would prevent spills or leaks from being released to the
environment.
No strong odors in the area.
No evidence of oil in surface water near the facility.
The facility has or uses an adequate laboratory that follows
appropriate quality assurance/quality control procedures.
If there is any visible evidence that the recycling facility is
not reliable, the facility should be eliminated from consid-
eration. Used oil recycling facilities that look substandard
probably are substandard (U.S. EPA, 1989b). If the recy-
cling facility looks acceptable, however, an interview should
be conducted with a representative of the facility to get more
information about facility operations and procedures. The
first question that should be asked is: Does the facility have
an EPA identification number? If the answer is "no," the
recycling facility is not in compliance with EPAs Used Oil
Management Standards and should not be used!
Table 4-1 gives a list of other questions that should be asked
to recycling facility representatives when trying to choose
the best facility. The table also gives the answers that indi-
cate the facility is reliable. Obviously, the more "desirable
answers" that are given by the facility representative during
the interview, the more reliable the used oil recycling facility
is likely to be. The facility for which the most "desirable
answers" are given during the interview should be consid-
ered as the top candidate for the used oil recycling facility.
Once reliability has been assessed, costs can be considered.
As discussed in Chapter 2, generators of used oil either get
paid by recyclers for their oil, or must pay recyclers to remove
and recycle the used oil, depending on the price of virgin
oil. Another factor that affects the price generators are paid
by (or must pay to) recyclers is the differences in operational
costs of the recyclers. For example, a processor that has
lower operational costs than another processor can pay
more for used oil and still generate a profit (This assumes,
of course, that both processors produce a fuel of the same
quality that sells for the same price.) As a result, different
recyclers are likely to offer different prices for used oil.
Consequently, when choosing the recycling facility to use,
the generator should consider how much the recycler is
willing to pay for the oil (or how little the recycler must be
paid to take the oil). If the generator is trying to choose
between reliable recycling facilities, costs can be the decid-
ing factor. Because of the need to keep any liability-costs to
a minimum and to ensure that used oil is managed properly,
however, an unreliable recycling facility should never be
chosen over a reliable one because of cost (Arner, 1992).
The Option of Last Resort-Disposal
Disposing of used oil wastes its heat and lubrication value
and should be avoided whenever possible. Circumstances
exist, however, when the costs of recycling used oil are so
high that recycling is not a practical option. For example, the
technology exists to recycle highly contaminated used oil.
The costs of recycling this highly contaminated used oil can
be much higher than the value of the oil, making recycling
impractical for the generator. In addition, in some cases, the
used oil is generated in such small quantities and so far away
from a recycling facility' that more fuel would be used to
transport the used oil for recycling than would be saved by
recycling the used oil. In cases such as these, the used oil
generator must consider disposing of the used oil.
The first step the generator must take when disposing of
used oil is to determine if it is hazardous. The generator must
test the used oil, use his or her knowledge of how the used
oil was generated, or use another acceptable method, to
determine if the used oil. has been mixed with a hazardous
waste or if it exhibits the characteristics of a hazardous waste.
As discussed in the section on the rebuttable presumption
in Chapter 3 and Appendix B, the generator must use his or
her knowledge or conduct a halogen test (or send the used
oil to a laboratory that will conduct the test) to see if the
used oil contains more than 1,000 ppm of total halogens.
The used oil must be disposed of as a hazardous waste under
Subtitle C if it:
Contains 1,000 ppm or more of total halogens, and the
generator cannot rebut the presumption that the used oil
is a hazardous waste by testing the oil again (as discussed
in Chapter 3).
Exhibits the characteristics of a hazardous waste.
The used oil can be disposed of as a solid waste under
Subtitle D if it:
Contains less than 1,000 ppm total halogens and does
not exhibit the characteristics of a hazardous waste.
Contains 1,000 ppm or more of total halogens, but the
generator can rebut the presumption that the used oil
27
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Table *t-i. Questions for Recycling Facilities
Questions
1. Is there a specific, documented procedure for accepting used oil from generators?
2. Are specific laboratory tests used to test the used oil before it is accepted? Does the laboratory follow
appropriate QA/QC procedures?
3. Is the used oil collected regularly from the same group of generators?
4. Is the used oil from each generator stored in separate tanks or containers until is has been tested?
5. Is the used oil recycled in a closed process system that minimizes emissions to the air?
6. Does the facility have provisions for proper treatment and disposal of wastewater and contaminated
stormwater, including proper permits?
7. Does changing the type of oil being recycled interfere with facility operations?
8. Are the residuals from recycling processes (e.g., sediment that has been removed from the used oil) disposed
of properly (e.g., used to make asphalt, burned in a cement kiln, or tested and landfilled)?
9. Are the facility's tanks cleaned often to prevent the buildup of sediment?
10. Does the facility have a Spill Prevention Control and Countermeasures Plan?
11. Has the facility recently been visited by state or federal environmental inspectors?
12. Can a copy of the inspection be reviewed?
13. Were any problems found during the inspection?
14. Has the local fire department inspected the facility?
15. Can a copy of the inspection be reviewed?
16. Were any problems found during the inspection?
17. Have releases of used oil to the environment occurred at the facility?
18. Have any environmental lawsuits been brought against the facility?
19. Does the facility have insurance that covers liability claims?
Desirable Answers
Yes
: Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes ' '
Yes
No
Yes
Yes
No
No
No
Yes
Adapted from: Arner, 1992
has been mixed with a hazardous waste by testing the oil
again (as discussed in Chapter 3).
If the used oil is to be disposed of as a solid waste under
Subtitle D, then the generator must identify a solid waste
facility that will accept the used oil. In general, this will
either be a Subtitle D industrial landfill or incinerator. As
discussed in Chapter 3, different states have different regu-
lations concerning whether or not solid waste facilities can
accept used oil. In addition, different solid waste facilities
within the same state can have different requirements about
what types of waste they will accept State contacts listed in
Appendix A can give generators information about the solid
waste disposal options that are available.
If the used oil is determined to be a hazardous waste, or if
no Subtitle D facilities can be identified that will accept the
used oil, then the generator must find a hazardous waste
facility to dispose of the used oil. State contacts or EPA
Regional contacts listed in Appendix A can provide infor-
mation on permitted hazardous waste disposal facilities.
Whether or not the used oil has a halogen content of 1,000
ppm or more or exhibits other hazardous characteristics, it is
considered a hazardous substance under DOT*s HMTA regu-
lations whenever it is transported. Consequently, the used oil
generator must meet all the HMTA requirements discussed in
Appendix E for a hazardous waste generator. Basically, this
includes preparing a proper manifest for the used oil, prop-
erly labelling the used oil, using DOT- approved packaging
for the used oil, and selecting a transporter that meets DOT
requirements.
-------
Chapter 5
Choosing a Used Oil Transporter
| s discussed in Chapter 4, some used oil is recy-
cled at the site where it is generated. Much of the
time, however, used oil must be transported to
another site for recycling. The transporter's role in the used
oil management network is to collect used oil from gener-
ators and transport it to processors, rerefiners, or burners
using collection, storage, and transport methods that pro-
tect human health and the environment. This chapter
describes the activities and responsibilities of used oil trans-
porters. In addition, the chapter gives advice to service
stations, quick-lube shops, fleet operations, DIY collection
centers, and retailers on how to choose and work with a
transporter.
General information About
Transporters
EPA's Used Oil Management Standards define a used oil
transporter as "any person who transports used oil, any
person who collects used oil from more than one generator
and transports the collected oil, and owners and operators
of used oil transfer facilities." Under the management stand-
ards, as well as earlier used oil regulations, used oil
transporters are required to inform EPA of their used oil
activities. Once EPA has been notified, the transporter is
assigned a unique, 12-digit number (U.S. EPA, 1992c). Ap-
proximately 400 used oil transporters in the United States
have obtained identification numbers from EPA (Arner,
1992).
Transporters normally collect and transport used oil in
tanker trucks. These trucks are equipped with a pump or
vacuum mechanism to remove the used oil from the gener-
ator's storage containers and transfer it into the truck's tank
(Washington Citizens for Recycling Foundation, 1992).
Usually, each truck collects used oil from several generators
in one run, mixing the collected used oil together in the
truck's tank. The practice of mixing the used oil into one
holding tank, however, is not advisable unless the used oil
is tested before it is pumped into the tank. If the used oil is
not tested and it is contaminated with a hazardous waste,
the entire batch of used oil in the tanker truck can become
contaminated. ' "
Once the truck is full, the transporter either delivers the
used oil directly to a recycling facility or to a transfer station.
At the transfer station, the used oil is stored so that larger
loads can be accumulated before the used oil is sent to a
recycling facility. Some transporters do not use tanker
trucks, but instead collect entire drums of used oil (Energy
and Environmental Research Corporation, 1988).
How To Choose a Transporter
As mentioned in Chapter 4, generators that decide not to
recycle their used oil on site must have their used oil trans-
ported to a recycling facility. These generators can choose a
used oil recycling operation that also transports used oil or
arranges with a transporter to collect the used oiL In these
cases, the generator does not have to select a used oil
29
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Key Terms
Tanker Trucks Trucks that are specially designed to hold liquids. The liquids are stored in large, tank-like compartments on the
bed of the truck.
VaCUlim Mechanism Equipment that uses the force of a vacuum to remove oil from a storage tank and then release it into a tanker
truck or another storage tank.
transporter. Generators also have the option, however, to
choose a transporter that transports the used oil to a recy-
cling facility of the transporter's choice, or to choose a
recycling facility and a transporter.
The first step in choosing a used oil transporter is to identify
several transporters in the local area. State used oil contacts
can provide information on transporters with EPA identifi-
cation numbers. Trade associations also might have listings
of transporters. Information on trade associations and state
used oil contacts is provided in Appendix A of this docu-
ment In addition, recommendations from service stations,
quick-lube shops, fleet operations, DIY collection centers,
and retailers in the area, as well as listings in the yellow
pages of the telephone book, can be good sources of infor-
mation for identifying local transporters.
Once several transporters have been identified, generators
should obtain information about each transporter's opera-
tions before choosing a transporter and entering into a
Transporter Testing of Used Oil
Under EPA's Used Oil Management Standards, transporters must
test (or use their knowledge of the materials or processes used to
generate) used oil to determine the total halogen content before
they deliver it to a used oil recycling facility, another transporter,
or a disposal facility. If the halogen level exceeds 1,000 ppm, the
used oil is presumed to be mixed with a hazardous waste. The
transporter or generator can rebut this presumption, as described
in Chapter 3, by demonstrating that the halogens come from a
nonhazardous source. If the presumption is not successfully
rebutted, or no attempt is made to rebut the presumption, the
used oil must be managed as a hazardous waste (U.S. EPA, 1992c).
Managing used oil as a hazardous waste dramatically increases
handling and liability costs. In order to avoid the risk of these
increased costs, it is in the best interests of the transporter to test
the used oil before collecting it and taking it off site. If the
halogen level is greater than 1,000 ppm, the transporter is likely
to refuse to accept the used oil, leaving the generator with the
responsibility for managing the used oil as a hazardous waste.
Consequently, generators should do everything possible to ensure
that their used oil is not mixed with a hazardous waste.
contract The primary concern when choosing a transporter
is that the transporter properly handles used oil and is in
compliance with all applicable regulations. A secondary
consideration is how much the transporter will pay for the
used oil that is collected (or in depressed markets, how little
the transporter must be paid for collecting the used oil).
To be in compliance with EPA's Used Oil Management
Standards, generators must select a transporter with an EPA
identification number. As mentioned above, this unique
12-digit number indicates that a transporter has given the
required notice to EPA concerning its used oil activities
(U.S. EPA, 1992c).
Transporters' operations should be visited and repre-
sentatives of these operations interviewed before a trans-
porter is selected. With larger transporters, appointments
can be made to inspect the transfer facility, and the trucks
can be inspected. Very small transporters, however, might
not have transfer facilities, and only the trucks can be
inspected. The same type of things as are discussed in
Chapter 4 for determining that a used oil recycling facility
is reliable should be looked for when inspecting the trucks
or the transfer facility of a used oil transporter. For example,
the transfer facility, trucks, and storage tanks should be
neatly kept, with no evidence of oil leaks or spills.
Just as with recycling facilities, the transporter should be
eliminated from consideration if there are any signs that the
transporter is unreliable, such as a leaking valve on a tanker
truck or spilled oil around a storage tank. If the trans-
porter's operations appear reliable, a representative can be
interviewed for more information about the operation. As
with choosing a recycling facility, the first question that
should be asked is: Does the transporter have an EPA
identification number? Another question that should be
asked at the start of the interview is: Does the transporter
keep tracking records of where the used oil is collected and
where it will be transported to? If the answer is "no" to either
of these questions, the transporter is not in compliance with EPA's
Used Oil Management Standards and should not lie used!
30
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A number of additional questions can be asked about a
prospective transporter's operations to help generators
make informed decisions about the ability of transporters
to protect human health and the environment Table 5-1
gives a list of questions, along with the answers that show
the transporter is reliable.
Costs are another factor in choosing a transporter, but
should be of lesser importance. As discussed in Chapter 2,
the price of virgin oil affects the economic value of used oil.
Table 5-2 is an example of a used oil transporter payment
schedule, which is based on the price of virgin oil. Again,
because of the importance of properly managing used oil
and the potential for liability, costs should not be considered
more important than reliability when choosing a trans-
porter (Nolan et al, 1990). ;
Transporter Receipts and DIY Collection Center Records
Public DIY collection centers are established with the goal of
collecting as much used oil for recycling as possible to prevent
used oil from being managed improperly. Consequently, the
success of a collection center can be measured by the quantity of
used oil collected. An easy way to record this quantity is to keep
receipts that indicate the amount of used oil picked up by the
transporter. ,
Information on the quantity of used oil collected can be used to
determine the success of specific aspects of a collection program.
For example, if a program changes its collection days from
Tuesday and Saturday to Friday and Sunday, a simple check of the
transporter receipts would show whether the change resulted in
an increase in the amount of used oil collected. The receipts also
could be used to quantify the success of a public education
program to promote used oil recycling.
Table 5-1. Questions for Transporters
Questions
Desirable Answers
1. Is there a specific, documented procedure for accepting used oil from generators? ;
2. Does the transporter keep samples of all out bound loads for at least 3 years?
3. Are specific laboratory tests used to test the used oil before it is accepted?
4. Does the transporter provide documentation of the laboratory analysis of the used oil to the used oil
generators?
5. If the used oil is not tested before it is accepted, is the used oil from different generators stored separately (in
separate containers or in a separate compartment within the tanker truck) until it has been tested?
6. Is the used oil collected from a standard group of generators?
7. Is the used oil transported to recycling facilities with EPA identification numbers?
8. Are specific procedures used to minimize spills when the used oil is collected? '
9. If the transporter operates a transfer facility, does the transfer iacility have a Spill Prevention Co'ntrol and
Countermeasures Plan?
10. Are specific procedures used to clean up spills that occur during collection or transportation?
11. Does the transporter properly maintain all vehicles used to transport used oil? Are there sufficient vehicles
available?
12. Does the transporter keep records of truck maintenance and storage tank maintenance and inspection?
13. Have releases of used oil to the environment occurred during transportation operations?
14. Have any environmental lawsuits been brought against the transporter?
15. Does the transporter have insurance that covers liability claims?
16. Does the transporter meet all DOT requirements?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
31
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Table 5-2. Sample Price Schedule
Price of Virgin Fuel Oil
per Gallon in the
Journal of Commerce
Price Paid or Charged to
Generators for Collecting
Each Gallon of Used Oil
55* to 64*
48« to 54
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Chapter 6
Onsite Management for
Used Oil Generators
Although used oil transportation and recycling is
a concern for service stations, quick-lube shops,
fleet operations, DIY collection centers, and re-
tailers, the primary responsibility for these generators is
properly managing used oil on site. This chapter discusses
onsite management procedures in detail, including collect-
ing used oil from DIYs, storing used oil, burning used oil
in space heaters, and responding to releases of used oil to
the environment. Information is given on how to properly
manage used oil throughout all of these phases of onsite
management. In addition, this chapter includes recommen-
dations for planning for emergencies.
Collecting Used Oil From DIYs
DIY collection centers (including service stations, quick-lube
shops, and retailers that collect used oil from DIYs) are
responsible for properly collecting used oil from DIYs. Col-
lecting used oil from DIYs includes accepting used oil from
these individuals, in some way promoting this service, and
storing the DIY used oil until it is recycled on site or
transported off site for recycling.
Advantages of Collecting DIY Used Oil
The main advantage of collecting DIY used oil is protecting
the environment As discussed in Chapter 2, much of the
used oil generated by DIYs never enters the used oil man-
agement system and is never recycled. Some of this oil is
dumped on the ground or poured down storm drains,
where it contaminates water and soil. Offering DIYs a place
to bring their used oil so that it can be properly recycled
helps to cut down on improper disposal.
As emphasized throughout this document, another impor-
tant advantage of collecting DIY used oil is the exemption
from CERCLA liability. The only way service stations and
quick-lube shops can be eligible for the service station deal-
ers exemption is to collect DIY used oil. Another advantage
to service stations and quick-lube shops, as well as to retail-
ers, is the positive publicity they can receive for providing
this valuable community service (Convenient Automotive
Services Institute, circa 1992a).
Disadvantages of Collecting DIY Used Oil
One potential disadvantage of collecting used oil from DIYs
is that the used oil might be contaminated with products
such as solvents, pesticides, and paint thinners (Convenient
Automotive Services Institute, circa 1992a). Fortunately,
however, DIY used oil is rarely contaminated with hazard-
ous materials (Hegberg et al., 1991). Educating DIYs about
how to properly handle their used oil before they bring it in
for recycling can also reduce this problem. In addition,
33
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Key Terms
Hit Sink
Sorbent
Stratified
Vacuum-Assisted Wand
Vacuum Hose
An opening in a storage tank or container where used oil or other, liquids are poured before they flow into the
tank or container.
A material that is spread over a spilled liquid to absorb the liquid so it can be cleaned up.
Layered.
A device with a long, thin tube attached to a hose. Vacuum pressure through the hose causes used1 oil or other
liquids to be drawn from a storage tank or container into the container used for transportation.
A device with a hose attachment that can be connected to an opening in a storage tank. Vacuum pressure
through the hose causes used oil or other liquids to be drawn from the storage tank into the container used for
transportation.
following the proper procedures for collecting DIY used oil
discussed later in this chapter will allow facility personnel
to identify almost all contaminated used oil.
Collecting DIY used oil requires staff time and often,
money. In some states and localities personnel must be on
hand to receive the used oil and to assist the DIYs, which
takes time. If separate storage containers are used for DIY
used oil, costs for these containers must be considered. In
addition, when transporters or recyclers charge for collect-
ing used oil from generators, the used oil collected from
DIYs will cause direct costs to be incurred by the service
station, quick-lube shop, DIY collection center, or retailer.
When transporters and recyclers pay for used oil, however,
the DIY used oil will bring added revenues (Convenient
Automotive Services Institute, circa 1992a).
Proper Procedures for Collecting DIY Used Oil
Like all onsite used oil management practices, the basis for
all proper procedures for collecting DIY used oil is good
housekeeping. The main emphasis should be to reduce
spills. In addition, facility personnel (rather than DIYs)
should always handle the used oil. Below is a list of specific
tips for properly collecting DIY used oil.
Used oil should be handled as little as possible. The
more the used oil is transferred from one storage con-
tainer to another, or transported around the facility, the
greater the potential for spills (Arner, 1992).
Used oil should only be accepted if the DIY has brought
it in a clean, leak-proof container, such as a milk jug
(Convenient Automotive Services Institute, circa 1992a).
A collection log should be kept and DIYs should be
asked to sign the log when they bring in the used oil.
This log can be used to prove that DIY used oil is
collected at the facility, in order to satisfy the require-
ments for the service station dealers exemption from
CERCLA liability (Convenient Automotive Services In-
stitute, circa 1992a). This log can also be used to evaluate
the success of the DIY collection operation by gauging
how much DIY used oil is collected (Massachusetts
Water Resources Authority, 1992). In addition, the log
can help reduce the chance of accepting contaminated
used oil if DIYs are asked to certify that the used oil has
not been mixed with other materials when they sign the
log (Barrett and Nightingale, 1992). Figure 6-1 gives an
example of a DIY used oil collection log.
Trash cans should be available for DIYs to dispose of the
containers they brought the used oil in (Arner, 1992).
These trash cans must be serviced regularly and contain-
ers should be disposed of in a secure Subtitle D disposal
facility. Containers should not be reused for carrying
other substances, although DIY collection centers cer-
tainly can encourage DIYs to reuse the containers the
next time they change their oil.
The area should be kept neat and clean to encourage DIY
participation and to set a good example for DIYs on how
to handle used oil (Massachusetts Water Resources
Authority, 1992).
A large, easily readable sign should be displayed to in-
form the public that DIY used oil is accepted at the site
and to give the hours when DIY used .oil can be brought
in for recycling (Arner, 1992). The sign also should in-
dicate what materials are not accepted.
34
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I hereby certify that the used motor oil I am depositing at this site was drained from the engine of a passenger
car or light truck and that it is free of contamination by solvents, gasoline, degreasers, paints, paint thinners,
pesticides, or any other substances not arising from normal use in a motor vehicle.
Date
Name/Signature
'
Address
'
!
Amount Deposited
Figure 6-1. Collection log for DIY used oil (source: Convenient Automotive Services Institute,1 circa 1992a).
All storage tanks and containers should be locked, except
when they are being filled or emptied, and only facility
personnel should have access to the tanks and containers
(State of Connecticut, no date).
The facility should be attended at all times, or should
have adequate security after hours, to reduce the threat
of vandalism and to keep individuals from leaving used
oil and other materials at the site (Arner, 1992).
Road access should be convenient when the facility is open,
but inaccessible when the facility is closed (Arner, 1992).
To help eliminate the problems of collecting DIY used oil
that has been mixed with hazardous substances, service
stations, quick-lube shops, fleet operations, DIY collection
centers, and retailers should educate DIYs on the impor-
tance of never mixing anything with used oil. In addition, the
following steps should be taken to identify DIY used oil that
has been contaminated with household hazardous wastes
and other substances: <
DIYs should be askbd if their used oil has been mixed
with any other substances (Convenient Automotive Serv-
ices Institute, circa 1992a).
The type of container the used oil is brought in should
be inspected so that used oil in bleach bottles, anti-freeze
jugs, paint thinner ca.ns, or other chemical containers can
be identified (Convenient Automotive Services Institute,
circa 1992a). Even small amounts of paint thinner,
35
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Community D1Y Collection Programs
Types of community DIY used oil collection programs vary
widely. Some communities encourage service stations, quick-lube
shops, and retailers to collect DIY used oil. With these programs,
the communities' role is to publicize the need to properly recycle
used oil and to let DIYs know which service stations, quick-lube
shops, and retailers provide a collection service. Other
communities run their own collection centers, where DIYs bring
their used oil. Still other communities provide curbside collection
of used oil (U.S. EPA, 1989b).
The key to a successful public DIY collection programs is to
educate DIYs on the need to manage used oil properly, as well as
to give them a convenient way to do it Another element of
success is flexibility. Every community is differentso each
community DIY collection program should be tailored to meet
the specific community needs and to use the available community
resources (Washington Citizens for Recycling Foundation, 1992).
bleach, or other substances remaining in these contain-
ers could cause the used oil to be off-specification for
burning (Massachusetts Water Resources Authority,
1992).
The used oil should be visually inspected for contamina-
tion. If the used oil is stratified, it is probably contaminated
with water, antifreeze, or other liquids (Massachusetts
Water Resources Authority, 1992).
Although used oil should never be sniffed to detect un-
usual odors, if an unusual odor is detected when the used
oil is being poured into the storage tank or container,
the facility employee should stop pouring the used oil.
Unusual odors can be a sign of contamination (Massa-
chusetts Water Resources Authority, 1992). ,
The used oil can be tested for halogen content, by using
a chemical test or a halogen leak detector (Washington
Citizens for Recycling Foundation, 1992). If the used oil
has 1,000 ppm or more of total halogens, it is presumed
hazardous, unless the presumption can be successfully
rebutted (for example, by documenting that the source
is household hazardous waste).
Whenever signs of contamination are detected, the used oil
should either be stored separately or tested for contamina-
tion before it is introduced into a storage tank or container
holding other used oil. In addition, all DIY used oil that is
collected can be stored in an intermediate storage container
until it is tested. This will prevent any contaminated DIY
used oil from contaminating all the used oil in the primary
storage tank (Washington Citizens for Recycling Founda-
tion, 1992).
Costs of Setting Up a DIY Collection Program
i
DIY collection center costs include the start-up costs for
buying equipment and preparing the site, and the continued
operational costs for personnel, publicity, and transporting
the used oil for recycling. These costs vary depending on the
type of equipment chosen, the level of personnel involve-
ment, the extent of publicity, and the price paid to or by
transporters for the used oil collected. Some typical costs
are discussed below (Washington Citizens for Recycling
Foundation, 1992):
* Tanks-Tanks are discussed in more detail later-in this
chapter. Typically, however, DIY collection programs will
use double-walled, steel tanks that cost from $500 to $2,000.
Preparing th8 Site-This includes the costs to lay a concrete
pad (to reduce the possibility that used oil spills will be
released to the environment), build a barrier around stor-
age tanks or containers (to prevent vehicles from colliding
into them), and build a rain shed (to keep water off the
storage containers). Costs to prepare a site in this way will
generally be less than $2,500.
Signs-Signs describing the purpose of the facility and
giving hours of operation will cost approximately $100.
» Spill Kfts-Sorbent materials that can be used to clean up
used oil spills must be kept at the site. Types of materials
include booms, kitty litter, saw dust, etc. Spill kits should
cost less than $250 a year.
Testing Kits-Chemical test kits run between $6 and $10
each. Halogen leak detectors (or "sniffers") cost approxi-
mately $100.
« Costs of Having Used Oil Removed by Tramsporters or Recyclers-
As discussed throughout this document, these costs vary
widely. Some typical costs reported for public DIY collec-
tion programs range from paying 25
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and public service messages can have nominal costs, while
flyers, brochures, and posters have higher costs, including
printing and development charges. One Florida DIY collec-
tion program spent $3,000 for 40,000 flyers, $3,300 for
500 brochures, $999 for 100 pennants, and $1,170 for 500
posters.
Storing Used Oil
Whether planning to transport used oil off site or reuse it
on site, all automotive service stations, quick-lube shops,
fleet operations, DIY collection centers, and retailers must
have a way to store the used oil that they generate or collect
The device used to store used oil must be easy to use, reduce
the potential for spills or leaks, and meet local, state, and
federal regulations.
According to EPA's Used Oil Management Standards, used
oil may be stored in either containers or tanks. Containers
are portable devices, such as 55-gallon drums, white tanks
are stationary devices that are designed to contain an accu-
mulation of used oil. Tanks, provide structural support and
are generally constructed out of non-earthen materials, such
as steel, concrete, and plastic.
Tanks have been divided into two categories: aboveground
and underground storage tanks. While underground tanks
have been widely used at service stations and other automo-
tive facilities in the past, the current trend is toward using
aboveground storage tanks because of the increasingly strin-
gent regulation of underground .storage tanks (Stltzel, 1991;
Washington Citizens for Recycling Foundation, 1992). In
addition, aboveground storage tanks cost less to buy and
install than underground storage tanks.
Aboveground storage tanks, underground storage tanks,
and containers are discussed below. In addition, advantages
and disadvantages of the most common types of storage
devices are given in Table 6-1.
Aboveground Storage Tanks
Aboveground storage tanks (ASTs) are the most frequently
used devices for storing used oil. Technically, an AST is a
tank that holds at least 90 percent of its volume above-
ground. In practice, however, most ASTs are completely
aboveground. Figure 6-2 gives the basic design of an AST
used to store used oil.
The two major types of ASTs are fiberglass tanks and steel
tanks. Steel and fiberglass ASTs are available in sizes that
can hold between 200 and 600 gallons. These sizes are
appropriate for most service stations, quick-lube shops, fleet
operations, DIY collection programs, and retailers. Fiber-
glass tanks frequently come in 220 and 330 gallon
capacities, while steel tanks come in a wider range of sizes
(Stitzel, 1991). Among the options for aboveground storage,
steel tanks are often preferred for reasons of cost and dura-
bility (State of Connecticut, no date; Washington Citizen's
for Recycling Foundation, 1992).
Underground Storage Tanks
Underground storage tanks (USTs) are another storage op-
tion for used oil. Figure 6-3 shows a typical UST, with a
double wall, leak detection, and spill overfill protection.
Several million USTs currently are used in the United
States (U.S. EPA, 1990). USTs have been popular in the past
because they have more storage capacity than the other
storage options and do not take up valuable aboveground
space. The major drawback associated with USTs is the
difficulty in detecting releases of used oil. Because USTs
cannot be visually inspected, leaks in the tanks often are not
detected until long after the used oil releases have begun.
As discussed in Appendix C, federal regulations for USTs
require corrosion protection and leak detection, among
other things, to help prevent used oil releases.
Containers
Containers are appropriate for storing smaller quantities of
used oil. They are also used to transport used oil. A wide
range of containers are commercially available for storing
used oil. One of the most common containers used for
storing used oil, however, is the standard 55-gallon steel
drum. The 55-gallon drum is popular because it is conven-
ient for storing small (quantities of used oil, particularly if
the used oil from different sources will be stored in separate
containers until it is tested for contamination. Because of
their small size and vulnerability to spills, however, steel
drums are not recommended for generators that anticipate
collecting more than 200 gallons of used oil per month
(Stitzel, 1991). In addition, local fire marshals often prohibit
the use of steel drums for used oil collection and storage.
Factors That Should Be Considered When Choosing a
Tank or Container
The storage needs of (different service stations, quick-lube
shops, fleet operations 1 DIY collection centers, and retailers
vary widely. Consequently, different storage tanks or con-
tainers are more appropriate for different used oil
generators. The following factors should be considered by
used oil generators before choosing a storage option:
37
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Table 6-1. Comparison of Storage Devices
TJpcof
Device
Advantages
Disadvantages
Typical Costs
Rberglass More resistant to corrosion than steel tanks.
Aboveground Attractive, recognizable design.
Tanks Double-walled construction provides
secondary containment, reducing the
possibility of leaks.
Equipped with fill sinks that are pressed
into the mold of the tanks' outer shells and
allow used oil to easily be poured into the
tanks.
Fill gauges and fire prevention accessories
can easily be used.
Steel Available in a wide range of designs and
Aboveground sizes which meet most regulations and
Tanks collection needs.
Double-walled models are available that
provide both secondary containment and
protection against vehicle collision.
Less expensive than fiberglass tanks of
comparable sizes.
Can be designed for easy access and effective
security.
Large size, often over 300 gallons, reduces
the frequency with which used oil must be
collected.
Drips and splatters are minimized because
vacuum hoses, rather than vacuum-assisted
wands, can be used to collect used oil from
the tank.
Underground Conserve aboveground space.
Storage Large size, often over 1,000 gallons, allows
Tanks larger quantities of used oil to be stored. For
generators that produce used oil at a relatively
fast rate, this larger storage capacity reduces
storage and collection costs by reducing the
number of pickups and/or storage containers
needed.
Drips are minimized during used oil collection
because the oil removal ports allow vacuum
hoses, rather than vacuum assisted wands to be
used to collect used oil from the tank
Steel Drums Low cost
Wide availability.
Convenient for storing small quantities of
used oil.
Little or no maintenance is required once
drums are painted and labeled for holding
used oil.
Easily moved.
Easily inspected for leaks.
Small size allows drums to be located
indoors.
The relatively small quantities of used oil
stored reduce the chance of accidentally
contaminating large quantities of used oil.
Structural integrity is sufficiently in Approximately $2,000 per
question that many local fire marshals have tank. This generally
prohibited their use. includes some equipment,
Only available in 220 to 330 gallon capacities, such as a fill gauge and an
The fill sink design is vulnerable to overflows, internal fire extinguisher.
Fiberglass shells are vulnerable to damage from
vehicle collision, possibly resulting in spills.
Sink covers and face plates are attached to
the fiberglass shells with relatively weak
hardware and can be easily vandalized.
Drips and splatters often occur when the
used oil is removed.
e Large sizes make tanks unwieldy and more
difficult to relocate if a site change is
required.
Some tank fill-hole designs used are
vulnerable to overflows.
Vulnerable to rust and corrosion over the
long term.
« The large volumes of used oil that can be
stored can result in higher disposal costs if
the entire batch of used oil becomes
contaminated with hazardous waste.
From $500 to $6,000 per
tank, depending on
whether the tank is
single-walled or
double-walled, the capacity
of the tank, and associated
equipment (Massachusetts
Water Resources
Authority, 1992;
Washington Citizens for
Recycling Foundation,
1992).
Spills and leaks are difficult to detect,
Frequent and careful monitoring is required.
The large volumes of used oil that can be
stored can result in higher disposal costs if
the entire batch of used oil becomes
contaminated with hazardous waste.
Tank and installation costs are much higher
than for aboveground storage tanks. In
addition, the required leak detection is costly.
Vulnerable to corrosion, especially when
located in areas with high moisture levels in
the soil.
Difficult to relocate if a site change is required.
The costs of cleaning up releases are very high.
Small size is inappropriate for collecting
large volumes of used oil.
Weather protection is needed.
If stored indoors, ventilation is needed.
Vulnerable to spills caused by tipping or
overturning.
Drips and splatters often occur when the
used oil is removed.
Collecting used oil for transportation is
more expensive and labor intensive than
collecting used oil from other containers.
Local fire codes often prevent the use of
steel drums for used oil collection and
storage.
Highest of the storage
options.
55-gallon drums can often
be obtained freeof-charge
from scrap metal dealers
and industrial liquid
transporters. These tanks
must be cleaned before
use, though, to prevent
contamination of the used
oil. Even when purchased,
steel drums are the least
expensive storage option.
Associated costs for drums
include painting and
labeling. ;
Source: Stitzel, 1991 for aboveground tanks and steel drums (unless otherwise noted); Nolan et aL, 1990 and Stitzel, 1991 for underground storage tanks.
38
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2" Collection Pipe with Screw Cap.
Extend to 1" of Bottom.
Consider 2" Evertite with Locking Cap.
2" Vent Pipe
Tank Gauge <
250-Galion Tank.
Sand Min 3" Thick
1/4" Screen to
Prevent Debris from
Contaminating Oil
1 Ft. Sq. x 4" Deep
Lockable
2" Diameter
Collection Pipe
Lockable Drain Dock
Foot Pedal
Impervious Surface Bermed
to Contain Leakage and Spills;
Containment Capacity Equal
to Maximum Volume of Tank.
Drain Acceptable for
Containment Should Be
Plug Type and Not Valve Type.
Figure 6-2. Sample design for an aboveground used oil storage tank (adapted from: U.S. EPA, 1989B).
Size and Storage Capacity-The specific storage needs of the
generator must be considered when choosing a storage de-
vice. Choosing a storage device that is too small will require
the transporter or recycler to make very frequent pick ups,
which is an inefficient process. In addition, a tank or con-
tainer that is too small can negatively affect the recycling
option chosen. For example, a tank that can store 250
gallons or more of used oil is recommended for generators
that burn used oil on site in space heaters. A tank of this
size allows solid contaminants to settle out before the used
oil is burned (Clean Burn, 1992). Choosing a tank that is
too large will waste money because larger tanks tend to cost
more to purchase and install. It is a good idea to contact
the used oil transporter to determine whether any other
collection tank factors (for example, special tank fittings)
apply. In addition, generators using ASTs with a capacity
of 660 gallons or more should familiarize themselves with
the Spill Prevention and Countermeasures (SPCC) regula-
tions described in Appendix D.
Material-Only tanks and containers made of materials
that meet American Petroleum Institute (API) standards for
devices holding flammable and combustible liquids should
be selected (Hegberg et si, 1991). In addition, climates and
site conditions that lead to corrosion affect the type of
material that should be chosen.
Safety-The risk factors at the site, such as susceptibility
to flooding or vehicle collision, should be assessed before
a storage tank or container is selected. A storage option
that minimizes these risks should be chosen.
Durability-As can be seen from Table 6-1, some tanks and
containers are more durable than others. Durability affects
both the potential for leaks, as well as the ultimate cost of
the storage option chosen. To reduce the need to repair and
replace storage devices, 'as well as the resources put into
leak detection and secondary containment, the most dura-
ble tank or container possible should be chosen.
Cost-The cost of the storage device itself, as well as asso-
ciated costs, such as installation, spill and leak detection,
39
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Fill Pipe
Vapor.
Monitor
Figure 6-3. A typical UST (source: U.S. General Accounting Office, 1992).
secondary containment, maintenance, repair, replacement,
and frequency of required pickups, should be considered.
Quite often, choosing a tank or container with lower initial
costs does not minimize storage costs over the long term
because maintenance, repair, and replacement costs are
higher.
Proper Storage Practices
Regardless of the type of storage device chosen, every gen-
erator should follow the same good housekeeping practices
when storing used oil. The following is a list of good house-
keeping practices.
Other materials should never be mixed with used oil.
Substances commonly used by automotive used oil
generators, such as anti-freeze, chlorinated solvents, haz-
ardous solvents, and degreasing agents, can contain haz-
ardous materials. When these substances are mixed with
used oil they can make the used oil a hazardous waste,
which significantly increases management costs and risks
to human health and the environment (Nolan et al.,
1990). Consequendy, separate storage tanks should be
kept for solvents, anti-freeze, or any other liquids that are
used on site and could accidentally be mixed with used
oil. In addition, used oil mixed with nonhazardous sub-
stances, such as water and sand, is more difficult and
expensive to recycle. Consequently, personnel at the fa-
cility should be educated on the need to keep all other
materials from being mixed with used oil.
All aboveground tanks, fill pipes leading to under-
ground tanks, and containers should be dearly labeled
with the words "used oil." The label also can carry a
warning not to add solvents, anti-freeze, paint thinners,
pesticides, or any other substances to the used oil (Clean
Burn, 1993). Figure 6-4 is an example of the type of
warning label that can be used for tanks and fill pipes.
Leaks and spills must be detected as soon as possible to
prevent used oil from being released into the environ-
ment Facilities using ASTs and containers should fre-
quently conduct routine visual inspections for tank/
container decay, severe rusting, other damage, or evi-
dence of oil in surrounding areas. In addition, the
tanks/containers should be kept high enough off the
ground to allow them to be inspected easily (Hegberg et
al., 1991). With USTs, the leak detection and prevention
methods described in Appendix C must be used.
The amount of used oil placed into and removed from the
storage device should be carefully recorded. Recordkeeping
40
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STOP
USED OIL ONLY!
Do Not Add Antifreeze, Gasoline,
Engine Coolant, Pesticides, Paint,
Paint Thinner, Engine Degreasers or
Cleaners, Water, or Any Other Liquid
Besides Used Oil. Do Not Add Sand,
Kitty Litter, Oil Filters, or Any Other
Solid Materials.
Other Liquids and Solid Materials Will
Contaminate the Used Oil and Make It
Difficult or Impossible to Recycle.
Figure 6-4. Label for used oil storage tanks and fill lines
(source: adapted from Clean Burn, 1992).
plays an important role in leak detection for ASTs, USTs,
and containers. If the records of how much used oil is
put into the tank or container do not match the records
of how much is removed, this is a sign that the storage
device is leaking (U.S. EPA, 1989a).
Each storage device should have secondary containment,
or the area around the device should provide enough
secondary containment to hold at least 100% of the
contents of the largest tank or container (with some extra
holding capacity for rain water if the storage area is not
covered). The containment walls should be high enough
and far enough away from the storage devices to catch
spurting leaks from punctures. The base of the contain-
ment area should be sloped so any released used oil can
be easily collected and removed (Hegberg et al., 1991).
Figure 6-5 shows some secondary containment options.
For containment areas that are not covered, a drain or
some other kind of discharge mechanism is needed to
release water that is collected in the containment area
when it rains or snows. Whenever used oil leaks or is
spilled in the containment area, therefore, it must be
properly cleaned up so that it is not released with the
rain (or melted snow) water. If the water looks like it has
oil in it (i.e., the water is shiny at the surface), the water
should not be discharged without being treated.
Storage devices should be equipped with a wide-
mouthed, long-neckecl funnel, which will reduce spills
during filling (Hegberg et al., 1991).
Storage devices should, be equipped with a pressure relief
valve to reduce a build up of pressure, which could cause
leaks (Hegberg et al., 1991).
« Sorbent materials, such as kitty litter and sawdust,
should be kept near the storage device for cleaning up
any spills that occur (Hegberg et al., 1991).
Either regular used oil pickups can be scheduled with
the transporter or recycler, or a representative of the
facility can call for pickups when necessary (Washington
Citizens for Recycling Foundation, 1992). If the used oil
is not picked up regularly, the transporter should be
called to pick up the oil when the tank or container is
75 percent full, so room will still be available to collect
more used oil in the storage device if the transporter
cannot make the pickup right away (Massachusetts Water
Resources Authority, June 1992).
The area around storage devices should be kept neat and
clean (Massachusetts Water Resources Authority, 1992).
A clean appearance emphasizes to personnel and DIYs
visiting the facility that proper handling practices are
important.
Steps To Take If Used Oil Being Stored Has Been Mixed
With a Hazardous Waste
As mentioned throughout this chapter, all possible meas-
ures should be taken to prevent used oil from being
contaminated with hazardous wastes and to keep any con-
taminated used oil from'being introduced into a storage
device with other used oil. If such contamination occurs,
however, proper steps must be taken to have the used oil
removed for disposal or recycling and to decontaminate the
storage device.
A generator that produces 100 kilograms (220 pounds) or
less of hazardous waste a month (or produces or accumulates
1 kilogram [2.2 pounds] or less of an acute hazardous waste)
is considered a conditionally exempt small quantity gener-
ator under RCRA. Consequently, as long as a used oil
41
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=~T^
Tr^FTJq.XV
' "= R-17&M .
v^^lV
DT
Impervious to Oil
X?
Manual Valve
External Liner
Quick Drain
i« ,., Vi^^^
f ',-- ?' -> i.
Vault
To Storm Sewer via
Oil/Water Separator
Dikes, Berms, or Retaining Walls
Double-Walled Tank
Figure 6-5. Options for secondary containment (source: Federal Register, September 23, 1991).
generator produces less than 100 kilograms each month of
characteristically hazardous used oil, solid materials con-
taminated with hazardous used oil, and other hazardous
substances that are not acute hazardous wastes, the gener-
ator is considered a conditionally exempt small quantity
generator under RCRA.
As a conditionally exempt small quantity generator, the
generator:
Cannot accumulate more than 1,000 kilograms of haz-
ardous wastes (or 1 kilogram of an acute hazardous waste)
without losing its status as a conditionally exempt small
quantity generator.
May either treat or dispose of the hazardous waste in an
onsite facility, or ensure that the waste is delivered to an
offsite facility. (Offsite facilities must be in the United
States.) Onsite and offsite facilities must satisfy one of
the following criteria:
- The facility is regulated under RCRA and meets all
relevant RCRA requirements.
- The facility beneficially uses or reuses the waste, or
legitimately recycles or reclaims the waste.
- The facility treats the waste before its is beneficially
used or reused, or recycled or reclaimed.
Must contract an EPA-licensed hauler to transport their
hazardous wastes to an appropriate Subtitle C facility, if
the waste will be shipped off site.
If the generator produces more than 100 kilograms of haz-
ardous waste or 1 kilogram of acute hazardous waste a
month, however, the generator must meet additional RCRA
requirements for handling and disposing of the hazardous
wastes, as discussed in Appendix B. Whether or not the
used oil generator is considered a conditionally exempt
small quantity generator under RCRA, the generator must
still meet the DOT Hazardous Materials Transportation Act
regulations, which are discussed in Appendix E.
Used oil generators can be held liable under CERCLA for
environmental damages caused by onsite mismanagement
of used oil that has been mixed with a hazardous waste.
Because of the hazardous wastes in this used oil, the service
station dealers exemption to CERCLA liability does not
apply. Consequently, the used oil generator also can be held
liable for mismanagement of the used oil by a transporter,
42
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recycler, or disposal facility. Whenever used oil has been
mixed with a hazardous waste, therefore, the used oil gener-
ator should take all possible precautions when choosing a
transporter, recycler, or disposal facility. Choosing an unreli-
able outfit could result in staggering liability costs.
To prevent previous contamination from affecting new
batches of used oil, the storage tank or container that was
holding the contaminated used oil must be decontaminated.
No set procedures exist for decontaminating storage de-
vices, so determinations on how to decontaminate a storage
device should be done on a case-by-case basis. The basic
purpose of decontamination is to ensure that the storage
device no longer contains the hazardous waste..
Burning Used Oil in Space Heaters
Space heater technology has greatly advanced over the last
10 years. Traditionally, most used oil space heaters were
vaporizing units, where the used oil was boiled into a vapor
and the vapor was then burned. Vaporizing units tended to
be messy and to release more emissions to the air than the
new generation of space heaters. Today, most space heaters
are atomizing units (Arner, 1992), which mix the used oil
and air into a fine mist and ignite the mist using a volt
transformer. These units generally burn hotter and cleaner
than the vaporizing units ("The Clean Burn Story: Turning
Waste Oil from an Environmental Liability into a Cost-
Saving Resource").
The largest manufacturer of atomizing space heaters in the
United States sells small space heaters that would be appro-
priate for service stations, quick-lube shops, fleet
operations, DIY collection centers, and retailers. These
space heaters are designed to burn 100% used oil. They
burn an average of 1,750 gallons of used oil a year and sell
for $4,500, including installation. In addition, a tank used
to store used oil and feed it into the space heater can be
purchased for $750 (Arner, 1992).
Space heaters require regular maintenance. In general, a
space heater should be cleaned once in the middle of the
heating season and once at the end of the heating season.
Because used oil can have different contaminant levels,
however, heaters burning highly contaminated used oil
might need more frequent cleaning. Any time 1/4 of an inch
of ash has accumulated in the combustion chamber of the
space heater, cleaning is necessary (Clean Burn, 1992).
When cleaning the space heater, ash should be removed
from wherever it has accumulated, including the com-
bustion chamber and the vent stack. In addition, the
manufacturer's instructions for cleaning the space heater
should be carefully followed.
Before disposal, ash from used-oil fired space heaters must
be tested to determine if it exhibits the characteristics of a
hazardous waste. If the ash tests hazardous, it must be
disposed of in a RCRA Subtitle C facility. If it does not test
hazardous, it can be disposed of in a RCRA Subtitle D
facility.
In addition, storage tanlcs used to hold used oil for burning
in space heaters should be regularly maintained. At least
once a year, water and sludge should be pumped from the
tank and properly disposed of (Clean Burn, 1992). Without
regular maintenance, water and sludge will interfere with
the burning process and could damage the space heater.
Finally, burning used oil that has been mixed with a hazard-
ous waste can damage the space heater and cause emissions
of hazardous materials into the environment (Clean Burn,
1992). Generators should test the used oil or use their
knowledge of how the used oil was generated to determine
if the used oil has been mixed with a hazardous waste before
burning the used oil in a space heater. If there is any doubt
about whether the used oil has been mixed with hazardous waste,
it should be tested before burning!
Responding to Releases of Used Oil to
the Environment
A release of used oil to the environment occurs when a leak
or spill enters soil or water surrounding the storage site.
Spills and leaks that remain on concrete floors in a shop are
not considered releases to the environment (U.S. EPA,
1992c). As has been emphasized throughout this document,
all possible steps should be taken to prevent releases of used oil
to the environment! Even when proper precautions are taken,
however, accidents sometimes happen, and spills or leaks of
used oil can make their way into soil or water.
Under the Used Oil Management Standards, used oil gen-
erators must follow the steps listed below any time a release
occurs.
Stop the Release-All possible actions should be taken to
prevent more used oil from being released to the environ-
ment The actions that are necessary will vary depending on
why the leak or spill is occurring. For example, if the spill
occurs because a 55-gallpn drum has been knocked over,
the drum should be righted to stop the used oil from being
released. If the spill occurs because a valve on the storage
device has been left open, the valve should be closed. If the
43
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leak is a result of a puncture in the tank or container, rags
or similar materials should be used to plug the leak. Finally,
if nothing can be done to stop the release, the used oil
should be transferred into another holding device. All used
oil generators should have a plan to remove used oil from
a leaking tank or container and transfer it to another stor-
age device when necessary (Hegberg et al., 1991).
Contain the Release-Next, efforts should be made to pre-
vent the used oil that has been released from spreading. A
sorbent, such as sawdust, kitty litter, or foam, should be
spread over the spilled used oil. Only sorbent materials that
will not react with used oil should be used (U.S. EPA, 1988).
Clean Up the Release-Depending on the extent of the re-
lease, cleaning up the used oil can be a simple or a compli-
cated task For small spills on the ground, the soil can be
dug up and disposed of. (The soil must be tested to deter-
mine if it exhibits hazardous characteristics, as discussed in
Appendix B.) For larger spills, where puddles of used oil
have formed, vacuum-type machinery can be used to collect
the used oil before the soil is dug up for disposal. Releases
that result in a great deal of soil contamination, or that
contaminate ground water or surface water, are very com-
plicated to dean up. In these cases, professionals should
be contracted to conduct the cleanup (U.S. EPA, 1988).
State contacts listed in Appendix A have information on
professionals who dean up used oil spills. Once several
contractors have been identified, they should be evaluated
to determine which one can give the best service. Other
work performed by the contractors should be examined,
induding site reports for other cleanup jobs. In addition,
dients of eadi contractor can be contacted to see if they
were satisfied with the contractor's work.
Properly Manage the Used Oil That Has Been Cleaned Up-
All leaked or spilled used oil that can be collected during
the cleanup must be managed under the Used Oil Man-
agement Standards, just like any other used oil that has
been generated.
Property Manage the Solid Materials Generated During the Cleanup-
Used oil should first be removed from all sorbent materi-
als, soils, or other solids that have been contaminated with
used oil. The solid materials can be placed in sieve-like
containers to allow the used oil to drip from the solid
materials into a storage device. In addition, the materials
can be compacted to remove the used oil. The removal of
used oil from these solid materials is not complete until
there are no signs of free-flowing used oil. The used oil
that is removed must be managed under the management
standards. In addition, materials contaminated with used
oil that are going to be burned for energy can be managed
in the same manner as the used oil. Contaminated mate-
rials that no longer contain free-flowing used oil and will
not be burned for energy must be tested to determine if
they exhibit the characteristics of a hazardous waste, as
discussed in Appendix B. If they do not test hazardous,
they can be disposed of in a RCRA Subtitle D facility. If
they test hazardous, they must be disposed of in a RCRA
Subtitle C facility.
Remove the Storage Device Irani Service and Repair or Replace It-
Once a leak has occurred, the remaining used oil should
be removed from the storage device and the device should
be examined to determine if the leak can be repaired. If
the leak cannot be repaired, the tank or container must be
replaced. If repair is possible, the repairs should be carefully
conducted so that leaks do not occur from that spot in the
future.
In many cases, generators must also adhere to the Spill
Prevention Control and Countermeasures requirements,
which are discussed in Appendix D, when releases occur.
Releases that occur from most underground storage tanks
are also regulated under Subtitle I of RCRA (40 CFR Part
280), which is discussed in Appendix C.
Finally, as discussed in detail in Chapter 3 and Appendix
C, the used oil generator must follow UST, Clean Water
Act, CERCLA, and TSCA regulatory requirements for re-
porting releases of used oil to the environment, as
appropriate. These requirements are outlined below.
Under the UST requirements in Subtitle I of RCRA (40
CFR Part 280), the state regulatory authority (or EPA
Regional personnel in unauthorized states) must be no-
tified within 24 hours of any leak or spill from an UST
that occurs underground, leaves a visible sheen on a
water surface, or releases 25 gallons or more of used oil.
Under the Clean Water Act (40 CFR Part 110), any release
of used oil must be reported to the National Response
Center if the release causes a sheen on the surface of the
water, violates any water quality standards, or results in a
sludge being deposited beneath the surface of the water
or on the shorelines. The National Response Center can
be contacted at 800424-8802. (In the Washington, DC
metropolitan area, the number is 202-426-2675.)
Under CERCLA (40 CFR Parts 300 to 399), releases to
the environment of used oil that contains reportable
44
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quantities of CERCLA hazardous wastes (such as lead)
also must be reported to the National Response Center
immediately. In addition, the release of used oil contain-
ing 1 pound or more of PCBs must immediately be re-
ported to the National Response Center.
Under the Toxic Substances Control Act (40 CFR Parts
761), any release of used oil containing 50 ppm or more
of PCBs into sewers, drinking water, surface water, graz-
ing land, or vegetable gardens must be reported to the
National Response Center.
If the generator is unsure if a release of used oil should be
reported, the generator should always call the. National Re-
sponse Center and/or the state regulatory authority to be sure.
The most important message with reporting is: if in doubt,
report it!
Planning for Emergencies
Although it is not required under EPA's Used Oil Manage-
ment Standards, service stations, quick-lube shops, fleet
operations, DIY collection centers, and retailers should con-
sider developing emergency pkns. Even when the
requirements in the management standards are carefully
followed, accidents can occur that cause releases of used oil
to the environment. In addition, emergency procedures
would be needed if fires or floods were to occur on site.
Finally, many used oil generators are required under the
SPCC regulations to develop emergency plans.
When a used oil generator develops an emergency plan, the
specific aspects of the generator's operations and site condi-
tions must be considered. Each emergency plan will
therefore be unique. All plans, however, should give step-by-
step procedures that personnel should follow in case of a
fire, flood, explosion, or release of used oil to the environ-
ment (Arner, 1992). The plan should take into account risks
to personnel, potential impacts on surrounding homes or
businesses, the potential for a release to enter ground water
or surface water, the equipment available at the facility, and
the assistance that can' be provided by local police depart-
ments, fire departments, and emergency response teams.
Emergency plans should include the telephone numbers of
local police departments, fire departments, emergency re-
sponse teams, ambulance services, and hospitals. Personnel
should be informed about the telephones and/or radios that
are available on site for use in an emergency. In addition,
personnel should know about other telephones that can be
used in the area if the site telephone or radio is out of
operation. ;
Once the emergency plan has been developed, it should be
periodically reviewed with employees (Convenient Automo-
tive Services Institute, circa 1992a). In addition, employees
should be informed immediately whenever the plan is
changed. Finally, the plan should be kept in a central loca-
tion so that it can easily be referred to in case of emergency.
45
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Chapter 7
Managing and Disposing of
Used Oil Filters
Proper management of used oil from automobile
and truck crankcases includes the proper han-
dling of used oil filters. Oil filters are used to
remove solid contaminants from motor oil, before the oil is
used to lubricate engine parts. The oil is pumped from the
crankcase of an automobile or truck and into the filter,
where it is filtered through a fibrous material (usually pa-
per). The fibers in the filter pick up and hold pieces of dust,
rust, metal, and other contaminants. The oil then flows
through the engine and back into the crankcase. Filtering
out solid contaminants improves the lubricating quality of
the oil.
Every time the oil in an automobile or truck crankcase is
changed, the oil filter must be replaced so that the solid
contaminants from the old oil do not get into the new oil.
When an oil filter is removed, it can contain from 10 to 16
ounces of used oil (Arner, 1992). Considering that over 400
million oil filters are used in the United States every year
(Arner, 1992), a great deal of used oil could be released to
the environment if used oil filters are not managed properly.
As a result of the decision published in the Federal Register
on May 20, 1992, used oil filters are categorically excluded
from the definition of a hazardous waste under RCRA, as
long as the filters:
Are not terne-plated. (Terne is an alloy of tin and lead.
The lead in the terne-plating makes the filters hazardous.)
Have been properly drained of used oil.
Removing Used Oil From Used Oil Filters
Federal regulations require that used oil filters must be hot-
drained to remove residual used oil (U.S. EPA, 1992b). This
means that no matter what draining option is used, the filter
should be removed from a warm engine and drained imme-
diately. Four distinct methods of hot-draining can be used:
Gravity Drailling-When the filter is removed from the en-
gine, it should be placed with its gasket side down in a drain
pan. If the filter has an anti-drain valve, the "dome end" of
the filter should be punctured with a screwdriver (or similar
device) so that the oil can flow freely. The filter should then
be allowed to drain for 12 to 24 hours (Arner, 1992).
Cnishing-The filter is crushed by a mechanical, pneu-
matic, or hydraulic device to squeeze out the used oil and
compact the remaining filter materials (Convenient Auto-
motive Services Institute, circa 1992b). ,
« Disassembly-The filter is separated into its different parts
using a mechanical device. This allows most of the used oil
to be removed from the filter, and the metal, rubber, and
46
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paper parts of the filter to be recycled separately (Fleis-
chaker and Saunders, 1991).
Air Pressure-The filter is placed into a device where air,
pressure forces the used oil out of the filter (Hua, 1992).
The used oil that is drained from the filters should then be
managed properly along with the oil that was drained di-
rectly from the crankcase of the automobile or truck. The
used oil filters themselves can be handled as a solid waste.
The preferred management option for used oil filters is
recycling. As with all of the federal regulations governing
used oil management, states might have more stringent
regulations than the federal government for the manage-
ment and disposal of used oil filters.
Storing Used Oil Filters
Filters should be stored in a covered, rainproof container so
that used oil is not washed from the filters into the sur-
rounding environment. In addition, the container should be
capable of holding any used oil that seeps from the filters
(Convenient Automotive Services Institute, circa 1992b).
Recycling Used Oil Filters
Oil filters are generally made from paper, metal, and rubber.
Two general recycling options exist for used oil filters. Either
the entire filter can be burned for fuel, or the different
components of the used oil filter can be separated and the
scrap metal can be recycled in a metal recycling operation
and the remaining paper and rubber can be burned as fuel
(Maclean, 1991; Smoot, 1991).
Currently, the used oil filter recycling industry is not very
well established in most areas of the country (MacLean,
1991). Consequently, many used oil filter generators might
not have the option of recycling filters at this time. These
used oil filter generators should still remove as much used
oil from the filters as possible, and recycle the used oil.
Used oil filters have value because they can be burned
for fuel and/or the metal components 'can be recycled
(MacLean, 1991). Three types of facilities can recycle used
oil filters. Scrap steel processing or recycling facilities, as well
as steel smelters, can recycle the metal components of the
filter. Although some scrap steel recyclers and steel smelters
will accept whole or crushed used oil filters for recycling,
others will only accept the metal components (Fleischaker
and Saunders, 1991). Finally, used oil filters can be sent to
industrial burners (such as cement kilns) where the entire
filter, or just the paper and/or rubber components, can be
burned for fuel (Convenient Automotive Services Institute,
circa 1992b).
Some of the trade associations and state contacts listed in
Appendix A of this document have information on used oil
filter recycling options in different areas of the country.
When a used oil filter recycling option is identified, the type
of materials the recycler accepts should be determined. If
the recycler has a preference for separated, crushed, or
whole filters, this will affect the decision on which draining
method should be used,
Disposing of Filters
If a recycling option for the used oil filters cannot be identi-
fied, the used oil filters must be disposed of. Although
federal regulations allow nori-terne plated filters that do not
exhibit hazardous waste characteristics to be disposed of in
Subtitle D facilities, some states have more stringent regula-
tions. The state contacts listed in Appendix A can give
information on state regulations on used oil filter disposal.
In addition, they can provide information on the facilities
that are available to accept used oil filters.
If landfilling used oil filters is acceptable in the state where
the generator is located, the generator must identify a land-
fill that is designed and permitted to accept used oil filters.
An alternative would be to identify a properly permitted
solid waste incinerator. If these alternatives are not available,
the used oil filters must: be sent to a hazardous waste dis-
posal facility (Convenient Automotive Services Institute,
circa 1992b). !
47
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Chapter 8
References
40 CFR Parts 100 to 149 (The Clean Water Act Regulations).
40 CFR Parts 190 to 259 (The Resource Conservation and Recovery
Act, Subtitle D, Regulations).
40 CFR Parts 260 to 299 (The Resource Conservation and Recovery
Act, Subtitle C, Regulations).
40 CFR Parts 300 to 399 (The Comprehensive Environmental Re-
sponse, Compensation, and Liability Act Regulations).
40 CFR Parts 700 to 789 (The Toxic Substance Control Act Regula-
tions).
49 CFR Parts 100 to 177 (The Hazardous Materials Transportation
Act Regulations).
49 CFR Parts 178 to 199 (The Hazardous Materials Transportation
Act Regulations).
American Petroleum Institute. 1991. Used oil management in
selected industrialized countries. Discussion Paper #064. Wash-
ington, DC.
Arner, R. 1992. Used oil recycling markets and best management
practices in the United States. Presented to the National Recycling
Congress, Boston, MA (September).
Arner, R. 1988. Used oil recycling: state and local collection pro-
grams. Presented to the 4th International Conference on Urban
Solid Waste Management and Secondary Materials, Washington,
DC (December).
Barrett, S., and D. Nightingale. 1992. Guidelines, laws, and recom-
mendations for siring design, and operation of household used oil
collection facilities. Presented to Puget Sound Suburban Cities
Meeting on Household Used Oil Collection, Sea Tac, WA (May).
Bryant, C, 1989. Slick new oil re-refining process. Resource Recy-
cling. Nov.s36-70.
Byrne, J.P., C.A. Cody, P.J. Doyle, J.S. MacKinnon, A.H. Mayor,
A.M. Reid, S.K. Rosner, and C.J. Talbot, 1989.:Used motor oil
in Massachusetts: a prioritization of end uses based on human
health and environmental risk. Prepared for the Commonwealth
of Massachusetts Department of Environmental Protection by
Tufts University Department of Civil Engineering.
Clean Burn: Multi-Oil Furnaces. 1992. Operator's manual: clean
Burn models CB-90 AH and CB-90-BH with "CB-90-HS" burner.
Clean Burn, Inc., 83 South Groffdale Road, Leola, PA 17540.
The Clean Burn story: turning waste oil from an environmental
liability into a cost-saving resource. Independent Operator Today.
Convenient Automotive Services Institute. 1992. State environ-
mental agency survey used oil & filters. Convenient Automotive
Services Institute, P.O. Box 34595, Bethesda, MD 20827.
Convenient Automotive Services Institute, circa 1992a. Do-it-yourself
oil collection kit: model policies and procedures for quick oil
change centers. Convenient Automotive Services Institute, P.O.
Box 34595, Bethesda, MD 20827.
Convenient Automotive Services Institute, circa 1992b. Used oil
filter generators: model management standards for use by state
and local regulatory agencies. Convenient Automotive Services
Institute, P.O. Box 34595, Bethesda, MD 20827.
Energy and Environmental Research Corporation and Robert H.
Salvesen Associates, Evergreen Oil, Inc. 1988. Guide to oil waste
management alternatives for used oil, oily wastewater, oily sludge,
and other wastes resulting from the use of oil products. Final
Report Prepared for Alternative Technology Section, Toxic Sub-
stances Control Division, California Department of Health Serv-
ices, in cooperation with the U.S. Environmental Protection
Agency.
-------
Fleischaker, M.L, and T.D. Saunders. 1991. Letter communication
from M.L Fleischaker and T.D. Saunders, Counsel for the Filter
Manufacturers Council, to R. Joglekar, Environmental Scientist,
U.S. EPA. November 7. Entered into Docket #F-91-UOLP-FFFFF.
Glenn, J. 1992. The state of garbage in America. BioCycle. May:30-37.
Government Institutes, Inc. 1992. Environmental statutes: 1992
edition. Rockville, MD: Government Institute, Inc
Hegberg, B.A., W.H. Hallenbeck, and G.R. Brenniman. 1991. Used
oil management in Illinois. Chicago, IL- University of Illinois
Center for Solid Waste Management and Research.
Hua, T. 1992. Facsimile communication from T. Hua of Environ Oil
Filtration Mfg., Inc., to R. Joglekar, Environmental Scientist, U.S.
EPA. April 13. Entered into Docket #F-91-UOLP-FFFFF.
MacLean, A. 1991. Letter communication from A. MacLean, Senior
Vice President of Engineering for Purolator Products Company, to
R. Joglekar, Environmental Scientist, U.S. EPA. November 7. En-
tered into Docket #F-91-UOLP-FFFFF.
Massachusetts Water Resources Authority. 1992. Pilot used motor
oil collection project: first year report. Boston, MA.
Mueller Associates, Inc. 1989. Waste oil: reclaiming technology, utili-
zation and disposal. Park Ridge, NJ: Noyes Data Corporation.
National Institute for Petroleum and Energy Research and Robert H.
Salvesen Associates. 1989. Used oil and solvent recycling technol-
ogy transfer manual. Prepared for the Department of the Navy,
Naval Energy and Environmental Support Activity.
Nolan, J.J., C. Harris, and P.O. Cavanaugh. 1990. Used oil: disposal
options, management practices and potential liability, 3rd ed.
Rockville, MD: Government Institutes, Inc.
Smoot, S.D. 1991. Letter from S. Smoot, Environmental Counsel,
Quaker State Minit-Lube, Inc., to R. Joglekar, Environmental Sci-
entist, U.S. EPA. November 7. Entered into Docket #F-91-UOLP-
FFFFF.
State of Connecticut, Department of Environmental Protection.
Guidelines for municipal waste oil collection facilities. Hartford,
CT.
Stitzel, D. 1991. Used oil collection tanks: a comparative analysis.
Prepared for the Washington State Department of Ecology.
U.S. EPA. 1992a. Environmental fact sheet: management standards
issued to control potential risks from recycled used oilno haz-
ardous waste listing. ERA/530-F-92-018. Washington, DC.
U.S. EPA. 1992b. Final listing decision for used oils destined for
disposal. Fed. Reg. 57(98): 21524-21534. May 20.
U.S. EPA. 1992c. Hazardous waste management system; identifica-
tion and listing of hazardous waste; recycled used oil management
standards. Fed. Reg. 57(176):41566-41626. September 10.
U.S. EPA. 1991. Hazardous waste management system; general; iden-
tification and listing of hazardous waste; used oil. Fed. Reg.
56(184):48000-48074. September 23.
U.S. EPA. 1994. Hazardous waste management system; identification
and listing of hazardous waste; recycled used oil management
standards; final rule. Fed, Reg. 59(43):10550-10560. March 4.
U.S. EPA. 1990. Musts forUSTs. EPA/530/USTW008. Washing-
ton, DC.
U.S. EPA. 1989a. Detecting leaks: successful methods step-by-step.
EPA/530-UST-89-012. Washington, DC.
U.S. EPA. 1989b. How to set up a local program to recycle used oil.
EPA/530-SW89-039A. Washington, DC.
U.S. EPA. 1989c. Recycling used oil: for service stations and other
vehicle-service facilities. EPA/530-SW89-039D. Washington, DC.
U.S. EPA. 1988. Oh no! EPA/530/UST-88/004. Washington, DC.
U.S. EPA. 1984a. A risk assessment of waste oil burning in oilers &
space heaters. EPA/530-SW-84-011. Washington, DC.
U.S. EPA. 1984b. Composition and management of used oil gener-
ated in the United States, EPA/530-SW-013. Washington, DC.
Vorhees, P.H. 1992. Perspectives on the generation and management
of used oil in the U.S. in 1991. Presented at the 1992 NORA
Annual Meeting, Scottsdsile, AZ (November).
Washington Citizens for Recycling Foundation. 1992. A guidebook
for implementing curbside and drop-off used motor oil collection
programs. Prepared for the American Petroleum Institute.
49
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Appendix A
Where To Get More Information
everal resources are available for more informa-
tion about used oil management, including
hotlines, trade associations, EPA Regional of-
fices, state used oil contacts, and publications. Many of
these resources are referred to throughout this document
In this appendix, some of the most useful of these sources
of information are described in detail. In addition, tele-
phone numbers and/or addresses are given for the hotlines
and trade associations, as well as EPA Regional Offices and
state contacts. Finally, information is provided on how the
publications can be obtained.
This appendix is meant to give a variety of sources of
additional information on the spectrum of topics covered
throughout this document, rather than be an exhaustive list
of all available materials on used oil management.
Hotlines
The federal government runs a variety of hotlines to assist
the regulated community and the general public in under-
standing environmental regulations. These hotlines can
answer questions about regulations and the associated envi-
ronmental issues, as well as distribute written materials.
EPA's RCRA/Superfund/UST Hotline
EPA's RCRA/Superfund/UST Hotline (commonly re-
ferred to as the RCRA Hotline) was established by EPA to
provide information on all aspects of the Resource Conser-
vation and Recovery Act (RCRA) regulations. The RCRA
Hotline provides information and distributes publications
on solid and hazardous waste issues. The hotline serves
federal, state, and local government offices; private indus-
try; consultants; and the general public.
The RCRA Hotline is an excellent source of information on
EPA's Used Oil Management Standards, as well as solid
waste requirements under Subtitle D of RCRA, and hazard-
ous waste requirements under Subtitle C. In addition, the
hotline can be called for information on the Comprehensive
Environmental Response, Compensation, and Liability Act
(CERCLA) requirements and the Underground Storage
Tank (UST) requirements under Subtitle I of RCRA. Hot-
line personnel are prepared to answer questions on these
subject areas, as well as to take requests for EPA, Office of
Solid Waste publications and make referrals for obtaining
other EPA publications.
The RCRA Hotline can be called on Monday through
Friday, from 8:30 a.m. to 7:30 p.m. (Eastern Standard
Time), except holidays. The national toll-free number is
800-424-9346, or for the hearing impaired, TDD 800-553-
7672. In Washington, DC, the number is 703-412-9810; or
TDD 703412-3323. Information also can be requested by
writing to the following address:
RCRA Information Center
U.S. Environmental Protection Agency
Office of Solid Waste (5305)
401 M Street, SW
Washington, DC 20460
50
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EPA's TSCA Assistance Information Service
Open Monday through Friday, 8:30 a.m. to 5:00 p.m. (East-
ern Standard Time), the TSCA Assistance Information
Service provides information on all aspects of the Toxic
Substances Control Act (TSCA) regulations. Repre-
sentatives from service stations, quick-lube shops, fleet
operations, DIY collection centers, and retailers can call this
information service with questions about the polychlori-
nated biphenyls (PCBs) regulations or other TSCA
provisions. The number is 202-554-1404.
EPA'S ERD Information Line
The Emergency Response Division (ERD) Information Line
provides information on appropriate ways to respond to
releases of potentially hazardous materials to the environ-
ment In particular, this information line can answer
questions on the Spill Control and Countermeasures
(SPCC) regulations and other Oil Pollution Act provisions
under the Clean Water Act The number is 202-260-2342.
DOT'S Hazardous Materials Hotline
The U.S. Department of Transportation's Hazardous Mate-
rials Hotline has information on the Hazardous Materials
Transportation Act regulations, as well as other aspects of
transporting hazardous materials. The hotline can be
reached at 202-366-4488.
National Response Center
The National Response Center was established to record
releases of hazardous substances and other materials that
can harm human health and the environment As discussed
in Chapter 3 and Chapter 6 of this document, different
requirements must be met under the Clean Water Act,
CERCLA, and TSCA for reporting releases of used oil to
the environment When a release of used oil occurs that
must be reported under these regulatory requirements, the
National Response Center should be called immediately.
The National Response Center can be reached 24 hours a
day at 800-424-8802 (or 202-426-2675 in the Washington,
DC metropolitan area).
EPA's Small Business Hotline
The Small Business Hotline helps small businesses comply
with environmental laws and EPA regulations. Repre-
sentatives are available to answer questions, as well as to
refer callers to other sources of information within EPA and
the rest of the federal government. The telephone numbers
for the hotline are 800-368-5888 or 703-557-1938 in the
metropolitan Washington, DC area. Hours are Monday
through Friday, 8:30 a.m. to 5:00 p.m. (Eastern Standard
Time).
Trade Associations
Trade associations are made up of member-companies that
are all involved in the same industry. These member-
companies pay dues to finance the trade association's activi-
ties. The purposes of trade associations are to provide their
membership with information, lobby the government on
issues that are important to their members, and promote the
industry their members are part of. Trade associations are a
good source of information on environmental and other
issues that apply to their members.
American Petroleum Institute
The American Petroleum Institute (API) is made up of
companies in the development, production, and sales of
petroleum products. AH can. be contacted for information
on used oil management, as well as information on the
petroleum industry. In addition, API can provide informa-
tion and technical assistance for the development and
promotion of used oil recycling programs. API's telephone
number is 202-682-8000, and its address is:
American Petroleum Institute
1220 L Street, NW
Washington, DC 20005
Association of Petroleum Rerefiners
The Association of Petroleum Rerefiners (APR) is an inter-
national association of used oil rerefiners and processors, as
well as suppliers of rerefined and processed used oil prod-
ucts. APR maintains information on used oil rerefining and
processing and can be reached by calling 202-639-4490, or
writing:
Association of Petroleum Rerefiners
1915 Eye Street, NW
Suite 600
Washington, DC 2,0006
Convenient Automotive Services Institute
The Convenient Automotive Services Institute (CASI) rep-
resents businesses in the: fast oil change and lubrication
industry. CASI has information on used oil regulations,
proper procedures for managing used oil and used oil
filters, and other aspects of operating quick-lube shops.
51
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CASI's telephone number is 301-897-3191, and its address
is:
Convenient Automotive Services Institute
P.O. Box 34595
Bethesda,MD 20827
Filter Manufacturers Council
The Hlter Manufacturers Council operates a hotline for
generators of used vehicle filters. Hotline operators offer
information concerning state and federal regulations regard-
ing used oil filter management and recycling, as well as
referrals to used oil filter transporters, processors, and recy-
clers in your area. The toll-free number is 800-993-4583, and
the address is:
Filter Manufacturers Council
P.O. Box 13966
Research Triangle Park, NC 27709-3966
Independent Lubricant Manufacturers Association
Members of the Independent Lubricant Manufacturers As-
sociation (ILMA) include blenders of motor oils and
lubricants, base stock suppliers, oil additive manufacturers,
and manufacturers of oil blending equipment. ILMA con-
ducts research programs on motor oil and can be contacted
by calling 202-337-3470, or writing:
Independent Lubricant Manufacturers Association
1055 Thomas Jefferson Street, NW
Suite 302
Washington, DC 20007
National Automotive Dealers Association
The National Automotive Dealers Association (NADA) is
made up of members in the automobile and truck sales
industry. NADA can provide information to automotive
dealers, fleet operators, and others, on the subject of used
oil management. The telephone number for NADA is 703-
821-7040, and the address is:
National Automotive Dealers Association
8400 Westpark Drive
McLean, VA 22102
National Oil Recyclers Association
The National Oil Recyclers Association (NORA) member-
ship includes businesses involved in the processing and
rerefining of used oil. NORA provides information and
technical assistance, handles litigation, and sponsors confer-
ences for its members. NORA is also a source of
information on the issues involved with used oil recycling.
NORA can be contacted at 216-791-7316, or by writing:
National Oil Recyclers Association
129429 Cedar Road
Suite 26
Cleveland, OH 44106-3172
Service Station Dealers Association
The Service Station Dealers Association (SSDA) is a trade
association specifically for service station owners and opera-
tors. SSDA can provide information and technical
assistance to service stations on used oil management, and
other aspects of service station operations. SSDA can be
reached at 703-548-4736, or by writing:
Service Station Dealers Association
499 South Capitol Street, SW
Suite 407
Washington, DC 20003
Waste Oil Heating Manufacturers Association
Manufacturers and distributors of used oil-fired heaters
make up the membership of the Waste Oil Heating Manu-
facturers Association (WOHMA). WOHMA maintains
information on used oil-fired heaters available from their
members, and how to properly use these heaters. The tele-
phone number for WOHMA is 202-457-6074, and the
address is:
Waste Oil Heating Manufacturers Association
2550 M Street, NW
Suite 800
Washington, DC 20037
EPA Regional Contacts
EPA operates 10 Regional Offices throughout the country.
The purposes of the EPA Regional Offices are to provide
information and technical assistance to the states within the
Region, as well as to assist with the implementation of federal
environmental programs and regulations. EPA Regional Of-
fices maintain information on environmental issues and can
be consulted on federal environmental regulations. Specifi-
cally, the EPA Regional Offices can answer questions on the
Used Oil Management Standards, other federal regulations
concerning used oil management practices, and specific used
oil management activities within the Region. Table A-l pro-
vides a list of EPA Regional Offices with their telephone
numbers and addresses, along with the telephone number
and address for EPA Headquarters in Washington, DC.
52
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Table A-l. EPA Offices
401 M Street, SW
Washington, DC 20460
202-260-2090
EPA Region 1
(Connecticut, Massachusetts, Maine, New Hampshire,
Rhode Island, and Vermont)
JFK Federal Building
One Congress Street
Boston, MA 02203
617-565-3420
EPA Region 2
(New Jersey, New York, Puerto Rico, and
the Virgin Islands)
Jacob J. Javitz Federal Building
26 Federal Plaza
New York, NY 10278
212-264-2657
EPA Region 3
(Delaware, the District of Columbia, Maryland, Pennsylvania,
Virginia, and West Virginia)
841 Chestnut Street
Philadelphia, PA 19107
215-597-9800
EPA Region 4
(Alabama, Florida, Georgia, Kentucky, Mississippi, North
Carolina, South Carolina, and Tennessee)
345 Courtland Street, NE
Atlanta, OA 30365
404-347-4727
EPA Region 5
(Illinois, Indiana, Ohio, Michigan, Minnesota, and Wisconsin)
77 West Jackson Boulevard
Chicago, IL 60604-3507
312-353-2000
EPA Region 6
(Arkansas, Louisiana, New Mexico, Oklahoma, and Texas)
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
214-655-6444
EPA Region 7
(Iowa, Kansas, Missouri, and Nebraska)
726 Minnesota Avenue
Kansas City, KS 66101
913-551-7000
EPA Region 8
(Colorado, Montana, North Dakota, South Dakota,
Utah, and Wyoming) i
999 18th Street !
Suite 500 ;
Denver, CO 80202-2405
303-293-1603
EPA Region 9
(Arizona, California, Hawaii., Nevada, American Samoa, Guam,
and the Trust Territories of .the Pacific)
75 Hawthorne Street
San Francisco, CA 94105
415-744-1305
EPA Region 10
(Alaska, Idaho, Oregon, and Washington)
1200 Sixth Avenue
Seattle, WA 98101 ;
206-553-4973
State Used Oil Contacts
As mentioned throughout this document, most states are
responsible for implementing EPA's Used Oil Management
Standards within their jurisdiction. States have the author-
ity to implement more stringent requirements than the
federal government. As a result, the regulation of used oil
management varies from state to state.
The state agencies that can be contacted for more informa-
tion about regulatory requirements for used oil
management are given in Table A-2. These state contacts can
also provide general information about used oil manage-
ment and can usually provide listings of used oil
transporters and recyclers within the area.
Publications
Throughout this document, publications are referenced that
can provide additional information on used oil manage-
ment Some of the most useful of these and other
publications, along with information about how they can be
obtained, are given below.
EPA Publications
EPA has published a variety of documents on used oil
management In addition, EPA contractors have prepared
publications on used oil, and EPA has cooperated with
states and other organisations to develop used oil docu-
ments. Documents published by the EPA Office of Solid
53
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Table A-2. State Used Oil Recycling Contacts
ALABAMA
Land Division
Department of Environmental Management
1751 Congressman W.L Dickinson Drive
Montgomery, AL 36130
205-271-7726
ALASKA
Solid and Hazardous Waste
Department of Environmental
Conservation
410 Willoughby Avenue
Juneau, AK 99801-1795
907-465-5161
ARIZONA
Waste and Water Quality
Department of Environmental Quality
2005 North Central Avenue
Phoenix, AZ 85004
602-207-4140
ARKANSAS
Hazardous Waste Division
Department of Pollution Control and
Ecology
P.O. Box 8913
Little Rock, AR 72219
501-570-2888
CALIFORNIA
Alternative Technology
Department of Toxic Substances Control
P.O. Box 806
Sacramento, CA 95812-0806
916-322-1005
Inquiries on used oil recycling depositories:
Integrated Waste Management Board
8800 Cal Center Drive
Sacramento, CA 95826
916-342-1781 or
800-553-2962 (California only)
COLORADO
Public Assistance Hotline
Hazardous Materials and Waste Management
Department of Health
4300 Cherry Creek Drive South
Denver, CO 80222
303-692-3320
CONNECTICUT
Waste Management Bureau
Department of Environmental Protection
165 Capitol Avenue
Hartford, CT 06106
203-5664869
DELAWARE
Hazardous Waste Management Branch
Department of Natural Resources and
Environmental Control
P.O. Box 1401
Dover, DE 19903
302-739-3689
Inquiries from households:
Delaware Solid Waste Authority
P.O. Box 445
Dover, DE 19901
302-739-5361 or
800404-7080 (Delaware only)
DISTRICT OF COLUMBIA
DC Energy Office
Department of Public Works
613 G Street, NW
Washington, DC 20001
202-727-1800
FLORIDA
Hazardous Waste Management Division
Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL 32399-2400
904-488-0300
GEORGIA
Generator Compliance
Hazardous Waste Management Branch
Department of Natural Resources
Floyd Towers East
205 Butler Street, SE
Atlanta, GA 30334
404-362-2684
HAWAII
Solid and Hazardous Waste Branch
Department of Health
5 Waterfront Plaza, Suite 250
500 Ala Moana Boulevard
Honolulu, HI 96813
808-586-8143 (recycling) or
808-5864227 (disposal)
IDAHO
Permits and Enforcement
Department of Environmental Quality
1410 North Hilton Street
Boise, ID 83720
208-334-5879
ILLINOIS
Disposal Alternatives Unit
Illinois Environmental Protection Agency
2200 Churchill Road
P.O. Box 19276
Springfield, IL 62794-9276
217-524-3300
INDIANA
Hazardous Waste Branch
Department of Environmental
Management
105 South Meridian Street
Indianapolis, IN 46206-6015
317-232-4535
IOWA
Waste Management Division
Department of Natural Resources
Wallace State Office Building
Des Moines, IA 50319
515-281-8263 ;
KANSAS
Solid Waste Section
Department of Health and the
Environment
Forbes Field, Building 740
Topeka, KS 66620
913-296-1667
KENTUCKY
Division of Waste Management
Department of Environmental Protection
14 Reilly Road
Frankfort, KY 40601
502-564-6716
LOUISIANA
Division of Solid Waste
Department of Environmental Quality
P.O. Box 82178
Baton Rouge, LA 70884-2178
504-765-0249
MAINE
Hazardous Material and Solid Waste Control
Environmental Protection Department
State House Station 17
Augusta, ME 04333
207-287-2651
MARYLAND
Oil Control Program
Department of the Environment
2500 Broening Highway
Baltimore, MD 21224
410-631-3442
Inquiries on used oil recycling:
Maryland Environmental Services
2011 Commerce Park Drive
Annapolis, MD 21401
410-974-7282 or 800-473-2925
54
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Table A-2. State Used Oil Recycling Contacts (continued)
MASSACHUSETTS
Division of Hazardous Waste
Department of Environmental Protection
One Winter Street, Seventh Floor
Boston, MA 02108
617-556-1022
Waste Management Division
Department of Natural Resources
P.O. Box 30241
Lansing, MI 48909
517-373-4735 or 517-373-2730
MINNESOTA
Hazardous Waste Program Development
Pollution Control Agency
520 Lafayette Road
StPaul, MN 55155-3898
612-297-8319
MISSISSIPPI
Office of Pollution Control
Department of Environmental Quality
P.O. Box 10385
Jackson, MS 39285-0385
601-961-5377 (disposal) or 601-961-5321
(recycling)
MISSOURI
Hazardous Waste Program
Department of Natural Resources
P.O. Box 176
Jefferson City, MO 65102
314-751-3176 or 800-334-6946
MONTANA
Department of Health &
Environmental Science
Solid and Hazardous Waste Bureau
Cogswell Building,
Helena, MT 59620
406-444-1430
NEBRASKA
Hazardous Waste Section
Department of Environmental Quality
P.O. Box 98922
Lincoln, NE 68509-8922
402-471-4210
NEVADA
Hazardous Waste Hotline
University of Nevada at Reno
702-784-1717 or
800-882-3233 (Nevada only)
Waste Management Bureau
Department of Conservation and
Natural Resources
333 West Nye Lane
Carson City, NV 89710
702-687-5872
NEW HAMPSHIRE
Waste Management Division
Department of Environmental Services
6 Hazen Drive
Concord, NH 03301-6509
603-271-2942
NEW JERSEY
Office of Communications
Solid Waste Management
Department of Environmental Protection
and Energy
CN-414
Trenton, NJ 08625-0414
609-530-8593
NEW MEXICO
Solid Waste Bureau
Environment Department
1190 Saint Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
505-827-2780
NEW YORK
Division of Solid Waste
Department of Environmental
Conservation
50 Wolfe Road, Room 200
Albany, NY 12233-4015
518457-8829
NORTH CAROUNA
Hazardous Waste Section
Department of Environment, Health, and
Natural Resources
P.O. Box 27687
Raleigh, NC 27611
919-733-2178
NORTH DAKOTA
Waste Management Division
Department of Health
1200 Missouri Avenue
P.O. Box 5520
Bismarck, ND 58502-5520
701-221-5166
OHIO
Division of Hazardous Waste Management
Ohio Environmental Protection Agency
1800 Water Mark Drive
Columbus, OH 43266-0149
614-644-2968 or 614-644-2917
OKLAHOMA
Solid Waste Management
Department of Health
1000 Northeast 10th Street
Oklahoma City, OK 73117
405:-271-7160 (recycling) or
405:-271-7114 (disposal)
OREGON
Hazardous and Solid Waste
Quality Division
Department of Environmental Quality
811 Southwest Sixth Avenue
Portland, OR 97204
503-229-5253 (households) or
503-229-6590 (regulations)
PENNSYLVANIA
Waste Minimization and Planning
Department of Environmental Resources
400 Market Street
P.O. Box 8472
Hatrisburg, PA 17105-8472
717:783-6004
RHODE ISLAND
Department of Environmental
Management
83 Park Street
Providence, RI 02903
401-277-3434 (households) or
401-277-2797 (regulations)
SOUTH CAROUNA
Solid Waste, Reduction, and Recycling
Department of Health and
Environmental Control
2600 Bull Street
Columbia, SC 29201
803-734-5195
SOUffl DAKOTA
Office of Waste Management
Department of Environment and
Natural Resources
319 South Coteau
500 East Capitol Avenue
Pierre, SD 57501-5070
605-773-3153
55
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Table A-2. State Used Oil Recycling Contacts (continued)
TENNESSEE
Waste Management Division
Department of Environment and
Conservation
L &. C Tower, Fifth Floor
401 Church Street
Nashville, TN 37243-1535
615-532-0838
TEXAS
Recycling and Waste Minimization Division
Natural Resource Conservation
Commission
P.O. Box 13087
Austin, TX 78711
512-239-6750
UTAH
Division of Solid and Hazardous Waste
Department of Environmental Quality
288 North, 1460 West
P.O. Box 144880
Salt Lake City, UT 84114
801-538^170
VERMONT
Solid Waste Management Division
Department of Environmental
Conservation
Laundry Building
103 South Main Street
Waterbury.VT 05671-0407
802-224-7831
VIRGINIA
Waste Division
Department of Environmental Quality
Monroe Building, llth Floor
101 North 14th Street
Richmond, VA 23219
804-225-2667 or
800-552-3831 (Virginia only)
WASHINGTON
Solid Waste Services
Department of Ecology
P.O. Box 47600
Olympia, WA 98504-7600
206-459-6286 or 206438-7541
WEST VIRGINIA
Hazardous Waste Management Section
Department of Commerce, Labor, and
Environmental Resources
1356 Hansford Street
Charleston, WV 25301
304-558-3370
Inquiries from households:
800-472-8286 (West Virginia only)
WISCONSIN
Solid and Hazardous Waste
Department of Natural Resources
P.O. Box 7921 (SW-3)
Madison, WI 53707-7921
608-266-2111
WYOMING
Solid and Hazardous Waste
Department of Environmental Quality
Herschler Building
122 West 25th Street
Cheyenne, WY 82002
307-777-7162
Waste and Emergency Response can be obtained from the
RCRA Hotline (unless otherwise noted), as discussed ear-
lier in this appendix. Other EPA publications can be ordered
by calling the National Technical Information Service
(NTIS) at 800-553-6847, or the Government Printing Office
(GPO) at 202-783-3238.
Energy and Environmental Research Corporation and
Robert H. Salvesen Associates, Evergreen Oil, Inc. April
1988. Guide to Oil Waste Management Alternatives for
Used Oil, Oily Wastewater, Oily Sludge, and Other Wastes
Resulting from the Use of Oil Products. Final Report. Pre-
pared for Alternative Technology Section, Toxic Sub-
stances Control Division, California Department of
Health Services, in cooperation with the U.S. Environ-
mental Protection Agency. Available through NTIS (re-
quest report No. PB89-224810).
This report presents the results of a study on used oil
management alternatives. The study was conducted for
the California Department of Health Services in coopera-
tion with the U.S. EPA. The report covers used oil
regulations, established and emerging technologies, cur-
rent management practices, economics of used oil, and
environmental impacts of used oil mismanagement The
report focuses on methods of improving the recyclability
of used oil. The report also includes recommendations for
industrial generators on how to best manage used oil.
U.S. EPA, Office of Solid Waste and Emergency Re-
sponse. August 1992. Environmental Fact Sheet: Manage-
ment Standards Issued to Control Potential Risks from
Recycled Used OilNo Hazardous Waste Listing. EPA/530-
F-92-018. Washington, DC.
This 3-page fact sheet provides general background infor-
mation on EPA's Used Oil Management Standards and
explains the specific requirements for service stations and
other generators; processors and rerefiners; transporters,
collectors, and burners; and used oil marketers. In addi-
tion, EPA's decision not to list used oil destined for
recycling as a hazardous waste is discussed.
U.S. EPA, Office of Solid Waste and Emergency Re-
sponse. June 1992. Catalogue of Hazardous and Solid
Waste Publications. 6th Edition. EPA/530-B-92-001.
Washington, DC.
This 240-page catalogue gives detailed listings of docu-
ments published by EPA on hazardous and solid waste
issues. The catalogue includes information on how to
obtain these publications, along with order forms.
56
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U.S. EPA, Office of Solid Waste and Emergency Re-
sponse. May 1992. Environmental Fact Sheet: No Hazard-
ous Waste Listing for Used Oil that Is Being Disposed.
EPA/530-F-92-006. Washington, DC.
This 2-page fact sheet provides the background on EPA's
decision not to list used oil destined for disposal as a
hazardous waste.
U.S. EPA, Office of Solid Waste and Emergency Response.
February 1991. Recycling Used Oil: 10 Steps to Change
Your Oil. EPA/530-SW-89-039C. Washington, DC.
This pamphlet explains how recycling used oil protects
the environment and saves energy. The pamphlet also
provides instructions to DIYs on how to safely change
motor oil.
U.S. EPA, Office of Solid Waste and Emergency Response.
June 1989. Recycling Used Oil: For Service Stations and
Other Vehicle-Service Facilities. EPA/530-SW-89-039D.
Washington, DC.
This pamphlet provides suggestions for businesses on
how to properly manage the used oil they collect and
recycle.
U.S. EPA, Office of Solid Waste and Emergency Response.
May 1989. How to Set Up a Local Program to Recycle Used
Oil. EPA/530-SW-89-039A. Washington, DC.
Designed for local communities, this 41-page document
describes how to set up a program for collecting and
recycling used oil. It explains the importance of local
action and organization and provides specific informa-
tion on how to design and implement a local DIY
collection program.
U.S. EPA, Office of Solid Waste and Emergency Response.
November 1984. Composition and Management of Used
Oil Generated in the United States. EPA/530-SW-84-013.
Washington, DC.
This report characterizes used oil management practices
within the U.S. used oil management system. The report
also discusses the composition of used oil and the types
of contaminants found in different types of used oils.
Possible health and environmental implications of various
used oil management practices are also assessed. This
report is available from NTIS and the order number is
PB85-180297.
U.S. EPA, Office of Underground Storage Tanks. August
1990. Straight Talk On Tanks. EPA/530/UST-90/012.
Washington, DC.
This 30-page booklet provides an overview of the regula-
tory requirements for leak detection for underground
storage tanks (USTs). It also explains specific leak detec-
tion methods and describes special requirements for tank
piping.
U.S. EPA, Office of Underground Storage Tanb. July
1990. Musts for USTs. EPA/530/UST-88/008. Washing-
ton, DC.
This 41-page publication is a summary of the regulations
for USTs. In addition, it provides specific information on
the requirements for maintaining new and existing petro-
leum USTs, correcting problems caused by leaks, closing
USTs, reporting and recordkeeping, and maintaining
chemical USTs. ,
U.S. EPA, Office of Underground Storage Tanks. No-
vember 1989. Detecting Leaks: Successful Methods Step-by-
Step. EPV530/UST-89/012. Washington, DC.
This 215-page handbook provides basic information on
detecting releases from USTs. The handbook contains
information on methods of UST release detection, inven-
tory control, manual tank gauging, tank tightness testing,
automatic tank gauging, vapor monitoring, ground water
monitoring, secondary containment with interstitial
monitoring, and piping release detection methods.
U.S. EPA, Office of Underground Storage Tanks. Decem-
ber 1988. Oh No/ EPA/530/UST-88/004. Washington,
DC.
Designed for service-station owners, this 24-page bro-
chure describes what t;o do in the event of a petroleum
leak, spill, or overfill from aboveground or underground
storage tanks. i
Other Federal Government Publications
Other agencies and departments within the federal govern-
ment have published documents relating to used oil
management In addition, some of the agencies and depart-
ments have cooperated with outside organizations, or hired
contracting firms, to develop materials on used oil. All of
these publications can be obtained through NTIS at 703-
487-4650, or GPO at 202-783-3238.
National Institute for Petroleum and Energy Research
and Robert H. Salvesen Associates. August 1989. Used
Oil and Solvent Recycling Technology Transfer Manual. Pre-
pared for the Department of the Navy, Naval Energy and
Environmental Support Activity.
57
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This manual was prepared to give guidance to Navy per-
sonnel on proper used oil management and recycling
practices. This 216-page manual is divided into two areas:
one on planning and developing used oil recycling pro-
grams and one on the recycling options that are available
for oils and solvents.
U.S. General Accounting Office. May 1992. Hazardous
Materials: Upgrading of Underground Storage Tanks Can Be
Improved to Avoid Costly Cleanups. GAO/NSIAD-92-117.
Washington, DC.
This report examines the Department of Defense's
(DOD) handling of its underground storage tanks. The
report describes the type and number of tanks owned by
DOD and evaluates DOD's efforts to comply with both
federal and state requirements, including efforts to iden-
tify and prevent leaks and spills' and to correct
environmental damage from leaking tanks.
Trade Association Publications
Many of the trade associations listed above develop and
distribute written materials on used oil management. To
obtain a copy of one of the publications listed below, contact
the trade association mentioned in the listing.
American Petroleum Institute. January 1991. Used Oil
Management in Selected Industrialized Countries. Discus-
sion Paper #064. Washington, DC.
This 123-page report examines the national used oil man-
agement systems that have been established in Austria,
Canada, Denmark, Finland, France, Ireland, Italy, Japan,
the Netherlands, New Zealand, Norway, Spain, the
United Kingdom, the United States, and West Germany.
The report examines the various features of these sys-
tems, including taxes and subsidies, restrictions on
over-the-counter sales of lubricants, regional transporta-
tion franchises, collection sites and curbside pickup,
public procurement, and public education. In addition,
the report also includes a discussion of the economics of
used oil.
Convenient Automotive Services Institute, (no date.) Do-
It-Yoimel/ Oil Collection Kit: Model Policies and Procedures
for Quick Oil Change Centers. Bethesda, MD.
This booklet was designed to assist owners and operators
of quick-lube shops to establish DIY collection programs
at their centers. It gives specific guidelines on how to
properly collect, store, and transport used oil.
Convenient Automotive Services Institute, (no date.)
Used Oil Filter Generators: Model Management Standards
for Use by State and Local Regulatory Agencies. Bethesda,
MD.
This 5-page document describes the standards proposed
by CASI for the management of used oil filters by gener-
ators. Topics covered include collection, storage,
recycling, and disposal of used oil filters.
Vorhees, P.H. November 1992. Perspectives on the Genera-
tion and Management of Used Oil in the U.S. in 1991.
Presented at the 1992 NORA Annual Meeting. Novem-
ber 5, 1992. Scottsdale, AZ.
This 14-page paper updates 1988 EPA estimates of the
flow of used oil through the used oil management system.
The paper also explores the factors that have affected the
changes in the used oil management system since 1988.
« Washington Citizens for Recycling Foundation. February
1992. A Guidebook for Implementing Curbside and Drop-
Off Used Motor Oil Collection Programs. Prepared for the
American Petroleum Institute.
This 48-page guidebook is based upon a national survey
of nearly 60 existing curbside and drop-off DIY used oil
collection programs. The guidebook gives information
on how to establish a DIY collection program. Topics
covered include the information required to initiate a
collection program, the different elements involved in
drop-off and curbside collection programs, and roles the
private sector can play. The document also provides an
overview of successful public education strategies, high-
lights model curbside and drop-off programs, and
summarizes existing private sector activity.
Other Publications
Arner, R. October 1992. Used Oil Recycling Markets and
Best Management Practices in the United States. Presented
to the National Recycling Congress. September 15,
1992. Boston, MA.
This paper explores the used oil management system
within the United States, provides information on used
oil recycling technologies, and discusses the environ-
mental impacts of improper used oil management. The
paper also presents best management practices for used
oil generators and collection centers. A copy of this paper
can be obtained from the Northern Virginia Planning
District Commission, 7535 Little River Turnpike, Suite
100, Annandale, VA 22003; telephone: 703-642-0700.
58
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Mueller Associates, Inc. 1989. Waste Oil: Reclaiming
Technology, Utilization and Disposal. Park Ridge, NJ:
Noyes Data Corporation.
This 193-page book describes and assesses the current
status of the used oil industry. The generation, collection,
disposal, and recycling of used oil, and the technology
involved, are discussed in detail. The book also assesses
the problems associated with used oil handling and the
health and safety implications of used oil management. A
copy can be obtained through Noyes Data Corporation,
Mill Road, Park Ridge, NJ 07656.
Nolan, J.J., C. Harris, and P.O. Cavanaugh. December
1990. Used Oil: Disposal Options, Management Practices
and Potential Liability. 3rd Edition. Rockville, MD: Gov-
ernment Institutes, Inc.
This 186-page book explains the market forces affecting
used oil and describes how the recycling system operates.
The book also contains an extensive section on CERCLA
liability and steps that can be taken to avoid liability.
Finally, a summary of the history of the federal govern-
ment's involvement with the used oil issue is provided. A
copy of this book can be obtained by calling Government
Institutes, Inc., at 301-921-2300.
Federal Register
The Federal Register is published daily and includes pro-
posed regulations, responses to comments on proposed
regulations, supporting information on regulatory deci-
sions, and final regulations. The Federal Register is
distributed by GPO, and copies can be obtained by calling
202-783-3238. In addition, Federal Registers relating to used
oil management are available through the RCRA Hotline,
and are listed below.
EPA's Used Oil Management Standards were published
in the Federal Register on September 10, 1992, on pages
4156641626. The citation for this Federal Register is 57
FR 176. These standards were amended in the Federal
Register on March 4, 1994, on pages 10550-10560. The
citation is 59 FR 43.
« EPA has published two technical corrections to the Used
Oil Management Standards in the Federal Register. The
first was published on May 3, 1993, and contains the no
free-flowing used oil requirements for managing solid
materials contaminated with used oil, along with other
topics. The technical correction is on pages 26420-26426
and the citation is 58 FR 83. The second technical cor-
rection was published on June 17,1993, and corrects an
error made in the May 3,1993 technical correction/The
error inadvertently amended the notification require-
ments for used oil handlers. This technical correction is
on pages 33341-33342 and the citation is 58 FR 115.
The Federal Register from May 20, 1992 contains EPA's
decision not to list used oil that is destined for disposal
and most used oil filters as hazardous wastes. The ration-
ale behind these decisions, along with the actual regula-
tory language, are presented on pages 21524-21534. The
citation is 57 FR 98.
EPA's proposed used oil management standards were
published in the Federal Register on September 23, 1991,
on pages 48000-48074. The citation for this Federal Reg-
ister is 56 FR 184.
Code of Federal Regulations
After the final version of a regulation is published in the
Federal Register, the regulation is compiled with regulations
on similar subjects and published in the Code of Federal
Regulations (CFR). EPA's Used Oil Management Standards
are published in 40 CFR Part 260. The CFR is published
annually and distributee! by GPO. Copies can be ordered by
calling 202-783-3238. '
Other CFR citations that relate to used oil management are
listed below.
40 CFR Parts 100 to 149 (The Clean Water Act Regula-
tions).
« 40 CFR Parts 190 to 259 (The Resource Conservation and
Recovery Act, Subtitle D, Regulations).
40 CFR Parts 260 to 299 (The Resource Conservation and
Recovery Act, Subtitle C, Regulations).
I
40 CFR Parts 300 to' 399 (The Comprehensive Environ-
mental Response, Compensation, and Liability Act Regula-
tions).
40 CFR Parts 700 to'789 (The Toxic Substance Control
Act Regulations). :
i
49 CFR Parts 178 to 199 (The Hazardous Materials Trans-
portation Act Regulations).
59
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Appendix. B
Summary of Resource Conservation and
Recovery Act Disposal Requirements
efore used oil or solid materials contaminated
with used oil can be disposed of, they must be
tested to determine if they are a hazardous
waste. The characteristics of a hazardous waste under
RCRA are:
IgnitabilityUsed oil is considered ignitable if it has a flash
point of 140°F or less. Solid materials that have been mixed
with used oil are considered ignitable if they can spontane-
ously catch fire at normal temperatures and pressures, or
friction or the absorption of water causes them to catch fire,
and if this fire burns vigorously enough to be dangerous.
Corrosivity-Used oil is considered corrosive if it corrodes
(or eats away at) steel at a rate of 0.25 inches per year or
greater at a test temperature of 130°F.
Reactivity-Used oil or solid materials that have been con-
taminated with used oil are considered reactive if they are
unstable; react violently, are capable of exploding, or emit
toxic gasses when mixed with water; or are explosive.
Toxictty-Used oil or solid materials contaminated with
used oil exhibit the toxicity characteristic if they exceed the
allowable limits for the toxic chemicals given in Table B-l.
A test method called the Toxicity Characteristic Leaching
Procedure is used to determine the levels and types of toxic
constituents that are present Because used oil rarely exhib-
its the characteristics of ignitability, corrosivity, or reactiv-
ity, the toxicity characteristic is the most important measure
of whether used oil or solids that have been contaminated
with used oil are hazardous wastes.
If used oil or solids that have been contaminated with
used oil are determined to be hazardous under RCRA
standards, they must be handled and disposed of as Sub-
title C wastes. Different standards apply, however,
depending on the quantity of hazardous waste produced
by the generator. The specific requirements for these
different generator types are listed below. These lists of
requirements assume that the generator will send the
wastes off site for treatment or disposal. Although the
RCRA regulations allow generators to treat or dispose of
the hazardous waste in onsite facilities, those facilities are
subject to a variety of Subtitle C requirements, such as
permitting. Most service stations, quick-lube shops, fleet
operations, DIY collection centers, and retailers are there-
fore likely to send their hazardous wastes off site.
Conditionally exempt small quantity generators are facili-
ties that produce 100 kilograms (220 pounds) or less of
hazardous waste a month (or produce or accumulate 1 kilo-
gram [2.2 pounds] or less of an acute hazardous waste. Acute
60
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Table B-i. levels of Contaminants That Cause a Material to Exhibit the Toxicity Characteristic Under RCRA
Contaminant
Arsenic
Barium
Benzene
Cadmium
Carbon tetrachloride
Chlordane
Chlorobenzene
Chloroform
Chromium
o-Cresol
m-Cresol
p-Cresol
Cresol
2,4-D
Maximum
Allowable
Level (mg/L)
5.0
100.0
0.5
1.0
0.5
0.03
100.0
6.0
5.0
200.0a
200.0a
200.03
200.03
10.0
Contaminant
1 ,4-Dichlorobenzene
1,2-Dichlorethane
1 , 1 -Dichloroethylene
2,4-Dinitrotoluene
Endrin
Heptachlor (and its
epoxide)
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Lead
Lindane
Mercury
Methoxychlor
Maximum
Allowable
Level (mg/L)
7.5
0.5
0.7
0.13
0.02
0.008
0.13
0.5
3.0
5.0
0.4
0.2
10.0
i
Contaminant
Methyl ethyl ketone
Nitrobenzene
Pentachlorophenol
Pyridine
Selenium
Silver
Tetrachloroethylene
Toxaphene
!
THchloroethylene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
i
2,4,5-TP (Silvex)
Vinyl Chloride
Maximum
Allowable
Level (mg/L)
200.0
2.0
100.0
5.0
1.0
5.0
0.7
0.5
0.5
400.0
2.0
1.0
0.2
Err j r , . , .. .
200 mg/L
hazardous wastes are fatal to humans in very low doses).
Conditionally exempt small quantity generators must meet
the following requirements:
The generator cannot accumulate more than 1,000 kilo-
grams of hazardous wastes (or 1 kilogram of an acute
hazardous waste) without losing its status as a condition-
ally exempt small quantity generator.
The generator must ensure that the waste is delivered to
an offsite facility (within the United States) that satisfies
one of the following criteria:
- The facility is regulated under RCRA and meets all
relevant RCRA requirements.
- The facility beneficially uses or reuses the waste, or
legitimately recycles or reclaims the waste.
- The facility treats the waste before it is beneficially
used or reused, or recycled or reclaimed.
The generator must contract an EPA-licensed hauler to
transport their hazardous wastes to an appropriate Sub-
title C facility.
Large quantity generators are facilities that produce more
than 1,000 kilograms (2,2.00 pounds) of hazardous waste or
more than 1 kilogram (2.2 pounds) of acute hazardous waste
each month. Large quantity generators must meet the fol-
lowing requirements:
« The generator must obtain an EPA identification num-
ber, and must use a transporter with an EPA identifica-
tion number.
The generator must prepare a manifest that indicates a
facility (and an alternate) to manage the waste. If the
transporter cannot ship the waste to one of those facili-
ties, the generator must choose another facility and put
it on the manifest A representative from the generator,
any transporters handling the waste, and the disposal
facility must sign and keep a copy of the manifest for at
least 3 years. Transporters and disposal facilities cannot
accept wastes without proper manifests.
The generator, as well as the transporter, must meet the
U.S. Department of Transportation's Hazardous Materi-
als Transportation Act packaging and labeling require-
ments (discussed in Appendix E).
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The waste must be properly removed from the generator
site within 90 days.
The generator must prepare a Biennial Report and sub-
mit it to EPA by March 1 of every even numbered year.
This report must include the generator's EPA identifica-
tion number, the EPA identification numbers for all
transporters used, and a detailed description of manage-
ment activities. A copy of this report must be kept for at
least 3 years.
Any generator that exports the waste to another country
for disposal must meet special recordkeeping and report-
ing requirements.
The generator must keep copies of the results of any tests
or analyses conducted.
The waste can only be disposed of in a facility that meets
the stringent Subtitle C requirements.
Small quantity generators are facilities that produce be-
tween 100 and 1,000 kilograms (220 to 2,200 pounds) of
hazardous waste each month. Small quantity generators
must meet most of the same requirements that are listed
above for large quantity generators. The following require-
ments, however, differ for small quantity generators:
The waste must be properly removed from the generator
site within 180 days (or within 270 days if the waste must
be transported for more than 200 miles).
The generator is not required to prepare and submit a
Biennial Report.
Used oil and solid materials that have been contaminated
with used oil that do not test hazardous can be disposed of
as nonhazardous waste under RCRA Subtitle D. Used oil
can be disposed of in a Subtitle D incinerator, while solid
materials contaminated with used oil (with no free-flowing
used oil) can be disposed of in either a Subtitle D landfill
or incinerator. Certain disposal facilities that meet RCRA
Subtitle D requirements, however, do not accept used oil or
materials contaminated with used oil.
Representatives from service stations, quick-lube shops,
fleet operations, DIY collection centers, and retailers that
would like more information on RCRA regulations, includ-
ing the Used Oil Management Standards, should call the
RCRA Hotline. In addition, state contacts and EPA Re-
gional contacts will have information about RCRA
requirements that apply in individual states. The number for
the RCRA Hotline, along with lists of state and EPA Re-
gional contacts, is given in Appendix A.
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Appendix: C
Summary of Underground
Storage Tank Regulations
Although the Underground Storage Tank (UST)
regulations include additional requirements for
tanks holding hazardous substances, only the
requirements that apply to USTs holding used oil are dis-
cussed here. State and local governments can have different
or additional requirements. Owners and operators of USTs
should contact their state regulatory authority to learn the
details of their state UST regulations.
All USTs that store used oil must be in compliance with the
UST requirements, except:
Tanks storing used oil that is burned on site in space
heaters.
Aboveground tanks that are located in underground
areas, such as basements and tunnels, where it is possible
to physically inspect the tank for leaks.
Tanks holding 110 gallons or less.
Emergency spill and overfill tanks.
In order to be in compliance with the UST regulations,
service stations, quick-lube shops, fleet operations, DIY
collection centers, and retailers that store used oil in USTs
must meet the following requirements:
USTs must be installed by properly trained professionals
who follow industry codes. The owner or operator of the
tank must submit a notification form to the state regula-
tory authority to certify that a qualified professional
installed the tank Notification forms are available from
the state.
New USTs (those installed after December 1988) must
be equipped with devices that prevent spills and overfills,
such as spill catchment basins and overfill alarms. Exist-
ing USTs (those installed before December 1988) must
have spill and overfill protection by December 1998.
New tanks and piping must be protected from corrosion.
Existing USTs must have corrosion protection by Decem-
ber 1998. ;
All USTs must use Leak detection methods and be
checked at least once a month to see if they are leaking.
Except for alternate acceptable leak detection methods
described below, one (or a combination) of the following
monthly monitoring methods must be used:
- Automatic tank gauging.
- Monitoring vapors in the soil.
- Monitoring between the layers of double walled tanks
and pipes.
- Ground-water monitoring.
- Other methods approved, by EPA.
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The following are a list of exceptions when alternative
leak detection methods are allowed:
- "With new tanks, a combination of monthly inventory
control and tank tightness testing every 5 years can be
used instead of the monthly monitoring methods
listed above. This alternate leak detection method can
be used for only 10 years after the UST is installed,
after which time one of the monthly monitoring meth-
ods must be used.
- Some small tanks may be able to use manual tank
gauging as a leak detection method, either by itself or
in combination with tank tightness testing.
- For existing USTs that have corrosion protection or
internal tank lining and have devices that prevent
spills or overfills, monthly inventory control com-
bined with tank tightness testing every 5 years can be
used. This method can only be used, however, for 10
years after adding corrosion protection or an internal
lining (or until December 1998, whichever is later).
After 10 years, one of the monthly monitoring meth-
ods must be used.
- For existing USTs that do not have corrosion protec-
tion or internal tank lining and do not have devices
that prevent spills or overfills, monthly inventory con-
trol combined with tank tightness testing every year
can be used. This method is only allowed until De-
cember 1998. After December 1998, the UST (which,
by that time, must have corrosion protection or an
internal tank lining and devices that prevent spills and
overfills) must use either automatic tank gauging or
monitoring for vapors in the soil.
Pressurized pipes must be equipped with devices to auto-
matically shut off or restrict flow, or alarms that indicate
leaks. Pressurized pipes must also be tightness tested for
leaks annually or monitored using one of the following
methods listed for tanks: vapor monitoring, ground-
water monitoring, interstitial monitoring, or other ap-
proved monitoring methods.
The most common suction pipes must either be moni-
tored monthly using one of the monitoring methods
listed above for pressurized piping, or tightness tested
for leaks every 3 years.
A less common but safer suction piping method uses
below-grade piping that is sloped so that the contents of
the pipes will drain into the storage tank if the suction
is released. This suction piping method also has only
one check valve in each suction line that is located di-
rectly below the suction pipe. This suction piping does
not require leak detection.
Owners/operators of USTs must demonstrate their abil-
ity to pay for any environmental damage that could be
caused if their tanks leak. These payments must cover
the costs of cleaning up a site and compensating other
people for bodily injury and property damage.
Owners and operators of USTs must follow proper proce-
dures for reporting and correcting leaks and spills of used
oil. When a spill or leak occurs, the owner/operator of the
UST should:
Stop or contain the leak or spill immediately.
Notify the state regulatory authority of the leak or spill
within 24 hours. All underground leaks, any leaks or spills
that leave a visible sheen on a water surface, and spills and
overfills of 25 gallons or more must be reported.
Identify and mitigate fire, explosion, and vapor hazards.
The local fire department can test for explosive condi-
tions and can help decide how to deal with any danger-
ous vapors or flammable liquids.
Consult state or local government agencies on how to go
about cleaning up a leak or spill. In addition, it may be
useful to contact professional contractors to help deter-
mine the extent of contamination, prepare a cleanup
plan, and clean up the site.
Report all progress and any information collected to the
state regulatory authority no later than 20 days after the
leak or spill.
Investigate damage that has occurred to the environment
and report results of the investigation to the state regu-
latory authority within 45 days of the leak or spill. If
ground-water contamination has occurred, submit a plan
for cleaning up the ground water to the state regulatory
authority.
If repairs are necessary, owners and operators of the tanks
must follow these standards.
Leaking tanks and piping can be repaired by a person
who carefully follows the standard industry codes for
UST repairs. Within 30 days of the repair, the tank must
be tested or inspected to ensure that the repair was
successful. Repaired USTs with cathodic protection must
be tested within 6 months of repair to show that the
cathodic protection is working properly. Records must
be kept for each repair for as long as the UST is kept in
service.
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Damaged metal piping cannot be repaired and must be
replaced. Loose fittings can simply be tightened, how-
ever, if the piping itself is not damaged. Fiberglass piping
can be repaired in accordance with the manufacturer's
instructions or national codes of practice. Within 30
days of the repair, fiberglass piping must be tested to
ensure that the repair was successful.
Owners and operators who decide to discontinue operating
their tanks must follow the proper procedures for UST
closure. USTs can be closed permanently or temporarily. If
a decision has been made to close an UST permanently,
these requirements must be followed:
The state reguktory authority must be notified at least
30 days before closure.
An evaluation must be conducted to determine if leaks
from the UST have damaged the surrounding environ-
ment. If damage has occurred, proper corrective action
for leaks and spills must be taken.
The UST can either be removed or left in the ground.
In either case, the tank must be emptied and cleaned by
removing all liquids, dangerous vapors, and accumulated
sludge. If the UST is left in the ground, it must be filled
with a harmless, chemically inactive solid (like sand) to
prevent it from collapsing.
USTs that will not be used for 3 to 12 months must meet
requirements for temporary closure. In addition, certain
USTs that will not be used for over 12 months can be
temporarily, rather than permanently, closed. These tanks
are:
USTs that meet the requirements for new or upgraded
USTs.
USTs that are granted an extension beyond the 12-
month limit by the state regulatory authority.
USTs that are emptied, cleaned, and filled with an un-
regulated substance, such as water. The state regulatory
authority must be notified of this change. An evaluation
must be conducted to determine if any damage to the
environment was caused while the UST held regulated
substances. If so, proper corrective action for leaks and
spills must be taken.
The requirements for temporary closure are:
For USTs with corrosion protection and leak detection,
continued operation of these systems is required if the
tank still contains used oil. If a leak is found, proper
corrective action must be taken. If the UST is empty,
continued leak detection is not required.
« All lines attached to the UST must be capped, except
the vent line, which must remain open and functioning.
Finally, the following materials must be kept as records to
prove that the UST requirements have been met:
» The previous year's monitoring results for leaks, and the
most recent tightness test.
0 Copies of performance claims provided by leak detection
manufacturers.
» Records of recent maintenance, repair, and calibration of
leak detection equipment
Records showing that the inspections of the corrosion
protection system were carried out by properly trained
professionals.
« Records showing that a repaired or upgraded UST was
properly repaired or upgraded.
For at least 3 years after closing an UST, records of the
site assessment results required for permanent closure.
State regulatory authorities responsible for implementing
the UST regulations have additional information about
particular recordkeeping requirements for each state. The
general rule of thumb for recordkeeping is: When in doubt,
keep it.
Additional information about the UST regulations is avail-
able from the RCRA Hotline, state contacts, and EPA
Regional contacts, which are listed in Appendix A.
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Appendix. D
Summary of Spill Prevention Control
and Countermeasures Requirements
The Spill Prevention Control and Countermeasures
(SPCC) regulations require facilities that handle oil
(and used oil) to develop a plan to prevent dis-
charges into surface water. All racilities handling oil must
comply with the SPCC regulations, except facilities that:
Are located in areas where a release of oil could not be
expected to enter a navigable waterway.
Are subject to the control and authority of the U.S.
Department of Transportation, as defined in the Memo-
randum of Understanding between the Secretary of
Transportation and the Administer of EPA, from
November 24, 1971.
Have an underground storage capacity of 42,000 gallons
or less and have an aboveground storage capacity of
1,320 gallons or less (with no single aboveground con-
tainer having a capacity of more than 660 gallons).
The SPCC requirements that are likely to apply to service
stations, quick-lube shops, fleet operations, DIY collection
centers, and retailers that store used oil are as follows:
The facility must develop a written Spill Prevention Con-
trol and Countermeasures Plan (SPCC Plan).
The SPCC Plan must be reviewed and certified by a
Registered Professional Engineer.
The facility must keep a copy of the SPCC Plan on site
(or at the nearest field office if the facility is not regularly
staffed). The plan must also be available to be reviewed
by EPA Regional Personnel during inspections.
If a release of 1,000 gallons of oil into a navigable water-
way occurs, or if two harmful releases to a navigable
waterway occur in the same year, the facility must submit
a detailed report to the EPA Regional Office and the
appropriate state environmental agency. This report
must include the SPCC Plan, any changes that have been
made to the plan because of the release, general infor-
mation about operations at the facility, and detailed rea-
sons why the release occurred. The EPA Regional Office
will review the SPCC Plan and might require revisions
to the plan.
If equipment at the facility has failed in the past (such
as tank overflows or leaks), the SPCC Plan should in-
clude an estimate of the quantity of oil that could be
released from such a failure in the future, the direction
and rate the used oil would flow, and the potential ef-
fects of the release.
The facility must amend the SPCC Plan whenever a
change in facility design, construction, operation, or
maintenance practices affects the facility's potential to
66
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release oil into a navigable waterway. The amended plan
must be reviewed and certified by a Registered Profes-
sional Engineer.
The facility must be equipped with a system to contain
any releases of oil to prevent their release into a navigable
waterway. Such a containment system could include
dikes, berms, curbing, gutters or other drainage systems,
weirs, booms or other barriers, spill diversion ponds,
retention ponds, and sorbent materials.
Facilities that cannot reasonably prevent a release of oil
into a navigable waterway with containment systems
alone must develop a strong oil spill contingency plan
under 40 CFR Part 109 of the Clean Water Act.
Facilities must use appropriate, equipment and proce-
dures to drain diked areas or catchment basins of storm-
water so that any used oil contained in those areas is not
released to a navigable waterway.
Storage tanks must be made of materials that cannot be
deteriorated by oil and will not be affected by the pres-
sure and temperature the used oil is stored under.
All aboveground storage tanks must be equipped with
secondary containment that is capable of holding more
than the contents of the largest tank in the containment
area.
Buried metallic storage tanks should have corrosion pro-
tection, such as coatings, cathodic protection, or other
effective means. At a minimum, regular pressure testing
should be used to detect leaks.
Partially buried tanks should be avoided unless the bur-
ied portion of the tank is equipped with corrosion
protection.
The condition of aboveground tanks should be peri-
odically tested using hydrostatic testing, visual inspec-
tion, or other means.
As much as possible, tanks should be engineered with
fail-safe methods that avoid spills by preventing overfill-
ing. Such methods could include alarms that signal when
the tank has reached a certain level, or a pump cutoff
device that prevents oil from being pumped into the
tank once the tank has reached a certain level.
If a tank leaks visible quantities of oil, the leak should
be promptly repaired.
Containers storing oil should be located in an area where
leaks or spills will not reach navigable waters and that
provides secondary containment. In addition, the con-
tainers should not be kept in an area that can be flooded.
Buried piping should be coated or cathodically protected
to minimize corrosion. Any exposed sections of buried
piping should be routinely inspected for deterioration. If
deterioration is found in the piping, it should be repaired
as necessary. '
Any piping that is not in service should be capped.
Pipe supports should be properly designed to account
for expansion and contraction of the pipes and to mini-
mize pipe abrasion and corrosion.
Aboveground piping should be periodically inspected
for deterioration, corrosion, or leaks.
Vehicles entering the facility should be warned so that
they do not damage aboveground piping.
The collection of used oil from storage tanks by trans-
porters should follow U.S. Department of Transporta-
tion requirements, as'~, discussed in Appendix E.
Filling or draining of storage tanks should only occur in
areas with secondary containment capable of holding the
used oil held in the largest compartment of the transpor-
tation vehicle.
Some kind of locking or warning system should be pro-
vided to prevent a transportation truck from driving
away without disconnecting from the piping or storage
tank.
The lowest drain and all outlets of the transportation
truck should be inspected for leaks before the truck
collects the used oil, and again before the truck leaves
the site.
The area where used oil is stored or handled should be
fenced in, and entrance gates should be locked or
guarded when the facility is unattended.
Any valves should be locked when the tank is not being
filled or drained.
When it is not in operation, the starter control for all
oil pumps should be locked in the "off' position, or the
starter pump should be kept in a location that is only
accessible to facility personnel.
The facility should have enough lighting to allow a spill
to be detected at night and to minimize the threat of
vandalism.
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Personnel must be properly trained on how to minimize
the risk of spills when using equipment, and how to meet
applicable pollution control laws, rules, and regulations.
One person should be given the responsibility for spill
prevention at the facility, and this person should peri-
odically report to the facility management
Management must periodically be briefed by personnel
on SPCC issues, including how any releases that have
occurred have been handled.
EPA ERD Information Line, described in Appendix A of
this document, has additional information on the SPCC
regulations. >
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Appendix. E
Summary of U.S. DOT Hazardous
Materials Transportation Act
Requirements
^H ^H OT's Hazardous Materials Transportation Act
^^^^^F (HMTA) regulations govern the transportation
H^^ of all hazardous materials. As of 1994, DOT
was in the process of updating these regulations, which may
affect used oil generators in the future. According to the
1994 DOT requirements, used oil must be handled as a
hazardous material if it is a "combustible liquid" (i.e., has a
flash point between 100°F and 200°F), a "flammable liq-
uid" (i.e., has a flash point of 100°F or less), or is destined
for disposal. When transporting used oil that is considered
a hazardous material under DOT's HMTA, the following
requirements must be met:
The generator of the used oil must prepare shipping
papers that describe the contents of the shipment, give
the name of the transporter, and give an emergency re-
sponse telephone number. The generator must also cer-
tify that the material to be shipped and the shipping
papers meet the regulatory requirements.
A manifest must accompany the shipment. This manifest
must be in compliance with RCRA regulations under 40
CFR Part 262, as discussed in Chapter 3. The manifest
must be signed and dated by a person representing the
generator and the original transporter. A copy must also
be given to and signed by any other transporters that
handle the materials, as well as the recycling or disposal
facility that ultimately receives the used oil.
Each shipment of used oil must be accurately labeled
using a system specified in HMTA. The label must give
the proper shipping name for the substance, the identi-
fication number that corresponds with the shipping
name, information about the hazardous nature of the
substances, and any warnings or special requirements
that apply to shipping the substance.
The vehicle containing the used oil must be marked so
as to indicate the contents of the shipment
Information on the actions that should be taken in case
of an emergency should be carried with the shipment.
If a release to the environment occurs and local, state, or
federal authorities determine that the release endangers
public health or the environment, these authorities can
require that the release be cleaned up by the transporter.
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If a release of used oil to the environment is so extreme
that it causes someone to be killed or hospitalized, re-
sults in damages of $50,000 or more, results in an evacu-
ation of the area, or causes a major roadway to be shut
down, it should be reported as soon as possible to DOT
by calling 800-424-8802.
If any release of used oil occurs during transportation,
this should be reported in writing to DOT within 30
days. Reports should include an estimate of the quantity
of used oil released and a copy of the hazardous waste
manifest Reports should be sent in duplicate to: Infor-
mation Systems Manager, DHM-63, Research and Spe-
cial Programs Administration, Department of
Transportation, Washington, DC 29590-0001. (In addi-
tion, used oil transporters must follow Clean Water Act,
CERCLA, and TSCA regulatory requirements for re-
porting releases of used oil to the environment, as dis-
cussed in Chapter 3, Chapter 6, and Appendix D.)
If an accident occurs, people (other than qualified per-
sonnel) should be kept away from the accident, the used
oil should be contained, and the vehicle should be re-
moved from service if it continues to leak.
Transporters must be trained as to the requirements of
HMTA and proper procedures for safely handling the
used oil that is considered hazardous. Drivers must also
be trained in safe driving skills.
The used oil must be packaged in a container approved
by DOT under this regulation. The container must also
be kept under appropriate conditions (for example, it
must be kept at cool enough temperatures and kept cush-
ioned to avoid breakage).
Proper loading and unloading procedures must be used.
(For example, personnel should not smoke during load-
ing and unloading, and the hand brake on the vehicle
should be set)
DOT's Hazardous Materials Hotline, listed in Appendix A
of this document, can be contacted for additional informa-
tion on these regulations, as well as information about
DOT's progress in updating the regulations.
US. Government Priming Office: 1995650-006/22002
70
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