PB2001-103 671
November 2001
1. Used Oil Specifications for Metals: TCLP versus Totals Analysis
Used oil marketers must determine if used oil burnedfor energy recovery meets the
specifications outlined in Table 1 of 40 CFR 279.11. Provided that the marketer
complies with the notification and recordkeeping requirements of Part 279, Subpart H,
used oil meeting the specification levels of Table 1 may be marketed as an on-
specification fuel. The specifications include maximum concentrations for four metals:
arsenic, cadmium, chromium, and lead. Should a used oil marketer use the Toxicity
Characteristic Leaching Procedure (TCLP) to determine whether used oil meets the
specification levels for these metals?
When determining the levels of arsenic, cadmium, chromium, and lead in used oil
that will be burned for energy recovery, the TCLP is not the appropriate test. The TCLP
was developed to simulate leaching in a landfill, addressing the degree of mobility of
waste streams (61 FR 11798, 11809; March 29, 1990). This attribute of the used oil is
irrelevant if the used oil will be burned for energy recovery rather than land disposed.
Instead of a TCLP, a totals analysis should be performed on the used oil. Chapter Two
of "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (SW-846)"
offers guidance on selecting appropriate test methods for specific constituents in different
matrices, such as used oil. For example, Table 2-35 of Chapter Two lists testing options
for various metals, including arsenic, cadmium, chromium, and lead.
FB 14584