T oday’s environmental laws and regulations put the responsibility of tracking used oil and similar waste streams on the user. In fact, when it comes to the streams that are generated in companies operating throughout the United States, all have one thing in common: cradle-to-grave responsibility.
Each state has specific requirements, but the general concept of unreliquished responsibility is a universal theme. Some companies have the luxury of internally processing used oil streams by re-refining them (for example, crude oil refineries). However, most companies must rely on a qualified used oil management company that can handle this stream for them. If the waste stream is improperly handled, the generating company could end up part of a superfund site - a very expensive proposition for any business.
How does a used oil generator assure that the used oil collector is managing the disposal and documentation issues properly? Three words: Do some homework!
Understanding the terminology is a great place to begin. Some common terms that should be clearly understood are:
- Transporter - a company that collects used oil from more than one used oil generator and transports the used oil to a storage/transfer facility.
- Storage facility - also known as a used oil transfer facility - is where used oil is held for more than 24 hours but not longer than 35 days before the used oil is legally recycled.
- Processor - a company, who through chemical or physical means, alters the used oil for the production of fuel oil, lubricants or other used oil-derived products.
The characteristics of the stream and how each state views that stream ultimately determine whether or not the used oil stream is in fact “waste” in the eyes of the law. If it is a waste, it must be treated as such through a company or agency qualified to handle waste streams. If it’s not classified as waste and it is a “recyclable stream”, then it is appropriate to find a company that can handle the used oil and the associated environmental concerns.
Used Oil Is*
Used Oil Is Not
• Synthetic oil — usually derived from coal, shale or polymer-based starting material.
• Engine oil — typically includes gasoline and diesel engine crankcase oils and piston-engine oils for automobiles, trucks, boats, airplanes, locomotives and heavy equipment.
• Transmission fluid
• Refrigeration oil
• Compressor oils
• Metalworking fluids and oils
• Laminating oils
• Industrial hydraulic fluid
• Copper and aluminum wire drawing solution
• Electrical insulating oil
• Industrial process oils
• Oils used as buoyants
* This list does not include all types of used oil.
• Waste oil that is bottom clean-out waste from virgin fuel storage tanks, virgin fuel oil spill cleanups, or other oil wastes that have not actually been used.
• Products such as antifreeze and kerosene
• Vegetable and animal oil, even when used as a lubricant
• Petroleum distillates used as solvents
* Oils that do not meet EPA’s definition of used oil can still pose a threat to the environment when disposed of and could be subject to the RCRA regulations for hazardous waste management.
How to Select an Oil Recycler
How does one select the right oil recycler for his company? There are several factors to consider, such as:
- What kinds of permits/registrations does the supplier have, and are they the right ones? The company’s records need to show that the supplier has the state’s approval. The best way to determine this is to obtain a copy of the supplier’s registrations with the state. If the candidate processor doesn’t have, or cannot find a registration, it is probably not an ideal candidate.
- Is the supplier is a registered transporter, storage facility or processor? At a minimum, the supplier must be registered as a transporter if it is collecting and transporting waste oil.
- Is it a reputable company that is financially stable? If it is a publicly traded company, ask for the most recent 10K Securities and Exchange Commission (SEC) report. Ask for a copy of an internal audit if the company is privately held. The owners of the private company are under no obligation to provide confidential information, but may choose to do so for the right circumstances.
- Request a certificate of insurance showing your company as the certificate holder. If the oil processor does not have adequate insurance, your risk has been magnified.
- What other services can the vendor offer to help manage other items like filters, used coolant and oily water? Single sourcing can help control costs and simplify the process.
- Has the supplier been recently audited by an outside state agency? Is it properly managing any open items (if there are any)? These audits normally produce some correctable items. It’s the serious items that can be a red flag and could later be troublesome.
- Consider these potential issues:
- Has the supplier been cited for not checking for halogen content before picking up used oil?
- Has the supplier held used oil beyond the allowable days?
- Has the supplier moved used oil to questionable end users?
- Are the facilities (trucks, tanks, etc.) clean, organized, and in good shape? If the supplier’s site is clean and well maintained, it usually reflects a healthy attitude on the part of company management and its employees.
- Can the supplier handle the volume and requirements for timely pickup? A well-run company will have a simple system for managing orders that ensures your used oil tank doesn’t get full.
- Does the vendor have a good system for tracking waste streams that it collects? Cradle-to-grave responsibility for the waste stream extends beyond the site where the waste is generated. If a processor abuses the waste stream responsibility, the liability may fall back to the originator of the waste.
- Has the candidate vendor audited its suppliers to make sure that each is meeting minimum standards? For example, is the candidate collection company working with a qualified storage facility and processor?
To answer the preceeding questions, visit the supplier to make sure you’re comfortable with the quality and integrity of the process. How is the used oil recycled? So, where does all the used oil go? The size of the used oil market is impressive: according to both the American Petroleum Institute (API) and a 1998 U.S. Department of Energy study, there is more than a billion gallons of used oil generated in the United States.
Products from the waste stream are resupplied in a variety of uses, as shown in Figure 1.
Figure 1. Applications of Recycled Oil
Each use of used oil has its own requirements and/or specifications. One of the largest uses is burning for energy recovery (for example, in boilers and asphalt plants). Table 2 summarizes some of the specifications used oil must meet in order to be burned for energy recovery.
||5 ppm maximum|
||2 ppm maximum|
||10 ppm maximum|
||100 ppm maximum|
||4,000 ppm maximum|
||<2 ppm maximum|
Table 2. Constituent/Property - Allowable Levels2
State-specific rules can vary, but the federal rules that must be adopted by each state as the minimum requirements are found under Title 40 of the Federal Regulations at Part 279.