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E4.0 Used Oil and Its Storage; Filters and Other Used-oil Contaminated Materials

USED OIL AND ITS STORAGE; FILTERS AND USED-OIL CONTAMINATED MATERIALS

Introduction

Proper used oil management is one of the most important environmental issues facing every vehicle maintenance facility owner and manager. Nearly a 800 million gallons of used motor oil are generated every year in the United States.

Even when compliance with state and federal rules is documented, owners may be subject to significant legal and environmental liabilities for improper off-site handling of used oil by the used-oil transporter/processor.

Used oil is a unique wastestream which, when properly managed, will qualify for a special exemption from federal hazardous waste rules. Some states designate used oil as a hazardous waste (like California) or special waste and have special rules concerning management of used oil. Other states have special requirements for the disposal of used oil filters and other contaminated debris. Used oil processors and treatment facilities may impose stricter rules and policies of their own.

This chapter covers the used oil management standards and other recommended management practices, state variations, used oil storage, recycling options and proper handling and disposal of various debris and wastes contaminated with used oil such as oil filters and absorbents.

RESOURCES: The Final UOMS Rules are here (PDF)

Two-clicks takes you to state used oil regs in your state

The Filter Manufacturers Council maintains information in how to hot-drain and recycle your filters, selecting a recycling company and a directory of filter crushers and recycling companies.

API also has information on used oil recycling http://www.recycleoil.org/

Oil Life Extension (EPA Region 9). This fact sheet describes how a testing program can extend engine oil life and thus lower oil consumption, reduce used oil generation, and decrease operating costs with no risk to your vehicles.

By-Pass Filters. Bypass filters extend oil life through improved filtration. They may also improve engine life and fuel economy.

CalEPA Extended Oil Change Intervals. A recent study provides strong evidence that oil analysis programs, higher quality motor oils, and more efficient filters will protect engines from wear and lead to significant cost savings. Oil analysis helps to determine the optimum oil change frequency and can provide early diagnostics for engine wear.

Used Oil Management Standards

This 30 minute video deals with the used oil management standard with a focus on the used oil generator– for any type of generator. This is for those who need a refresher or a broader understanding of this subject.

 

Note: The following is based on information provided by Doug Greenhaus, Director, Environment, Health and Safety, National Automobile Dealers Association, McLean, VA. (1993)

On August 12, 1992, EPA issued used oil management standards. The regulation affects all used oil generators. In addition, the agency announced it would not list as hazardous waste any used oil that is recycled.

The management standards and the service station exemption were published in The Federal Register on September 10, 1992 and became effective on March 10, 1993. (To our knowledge, all states have adopted the standard.)

Exemption from Superfund Liability

The management standards trigger the so-called “service station” used oil exemption from Superfund liability. Vehicle and equipment maintenance facilities, considered to be “service stations,” are exempt from any Superfund liability for their off-site used oil shipments, so long as they comply with EPA’s management standards and are willing to accept used oil brought in by DIYs. “Service stations” are defined as facilities that derive 50% or more of their revenues from the maintenance of vehicles.

Used Oil Not “Listed” as Hazardous

EPA made its decision not to list recycled used oil based on an analysis of the technical nature of used oil and on its potential threat to the environment. Appropriate management standards were determined to be adequate to address any potential threats to the environment. Listing recycled used oil as hazardous, EPA concluded, would in fact increase the potential for environmental contamination by decreasing the amount of used oil that would be recycled.

Management Standards

All “generators” are treated the same by EPA, regardless of the amount of used oil they manage. EPA’s final “generator” regulations include only the following requirements:

1.    Used oil must be stored in compliance with existing UST or aboveground storage tank (AST) standards or in containers. All storage units must be kept in good condition and must be labeled with the words “used oil.” There are no time limits for the accumulation of used oil.

2.    Releases must be addressed appropriately. Spills and leaks to the environment must be stopped immediately and any used oil that has leaked must be contained and cleaned up. Leaking storage units must be removed from service for repair or replacement. Spills of contaminated used oil and spills of used oil onto surface waters must be reported to the proper authorities.

3.    Used oil shipped off site must be picked up only by transporters with EPA ID numbers. Generators may themselves transport 55 gallons or less of used oil without becoming regulated transporters.

4.    There are no federal tracking or record keeping requirements set out in the regulations. However, it is recommended generators consider keeping logs or other records of their off-site shipments of used oil. Some states do require this and in these cases the used-oil transporter should be providing you with a receipt stating the amount being taken away,

5.    Generators may continue to burn used oil for heat recovery in space heaters under 500,000 British thermal units (Btus)/hour in size as long as they are vented to the atmosphere and as long as only facility-generated and DIY oil is burned. Generators may burn used oil in larger burners or boilers if they comply with certain testing and notification regulations. Used oil may be mixed with diesel fuel for burning in a diesel engine operated by the generator, subject to any engine manufacturer restrictions.

6.    EPA’s definition of used oil includes waste synthetic engine oils. The definition allows generators to mix characteristic hazardous wastes into used oil so long as the resultant mixture lacks the hazardous waste characteristic (i.e., toxicity, ignitability, corrosivity or reactivity). This includes the mixing of mineral spirits into used oil where the mixture has a flash point above 140 degrees Fahrenheit. Listed hazardous wastes must not be mixed into used oil as they will render the entire mixture hazardous.

7.    Used oil contaminated materials such as floorsweep, rags or scrap metals must pass a “no free-flowing” oil test in order to be handled as solid waste. Filters may also be managed as solid waste if they are properly drained, crushed or taken apart to remove any free-flowing oil. Of course, any free-flowing used oil removed from contaminated materials must be properly managed as such.

Note: This concludes the material contributed by Doug Greenhaus, National Automobile Dealers Association, McLean, VA.

All of the above points are discussed in more detail in the following sections.

Recommended Practices

With respect to good used oil management, follow these recommended practices and guidelines:

* Do not dispose of used oil in sewers, drains, waste dumpsters or on the ground, or use as dust or weed control.

* Keep your collection drums covered and labeled, in good condition and secure from vandals and in compliance with local fire codes. Inspect frequently for leaks, corrosion or spillage.

* Label your drums and tanks with “Used Oil Only” or follow state or local labeling and storage requirements.

* Immediately clean up normal spills of used oil with absorbents and properly dispose of the spent materials.

* Used oil filters, absorbents, towels, soils or other materials contaminated with used oil may have special disposal rules in your state. Follow the guidelines in this chapter and determine the requirements in your state.

* Never mix other liquids such as gasoline, antifreeze, listed hazardous wastes or unknown wastes with used oil.

* Use caution when selecting a used oil transporter. See How to Select a Waste Service Firm in Section 1.o.

* Where required, use a transporter who is properly licensed and registered with the state. Generators who transport more than 55 gallons are subject to EPA and DOT rules.

* Consider the advantages of converting used oil USTs to aboveground storage facilities and installing pneumatic, rapid drain/fill systems.

What Is Used Oil?

Used oil generally includes automotive engine oils and other petroleum-based or synthetic lubricating oils and hydraulic fluids as well as cooling, gear and cutting oils which have not been mixed with other characteristic or listed hazardous wastes.

Used oil is exempt from federal rules for classification as a hazardous waste if it is destined for recycling, re-refining, reprocessing or burned-for-energy recovery. Therefore, you should verify your used oil is being sent to a facility which ultimately processes your used oil in one of these approved methods.

Used motor oil contains lead, cadmium, chromium and other metals (from lead in gasoline and from some engine components), as well as benzene and other organic compounds found in petroleum fuels. Currently, lead content of used motor oil normally ranges from about 20 to 40 parts per million (ppm) whether from diesel or unleaded gasoline engines and is dependent on many factors. Normally, used motor oil is much less than 1,000 ppm halogens. Used motor oil is normally an EPA on-spec used oil*.

* A used oil is on-spec if it does not exceed the following limits:

Arsenic 5 ppm

Cadmium 2 ppm

Chromium 10 ppm

Lead 100 ppm

Flash point 100 degrees F min

Total halogens 4,000 ppm

Typically, used motor oils will (should) not exceed the EPA limit of less than 1,000 ppm halogens unless the used oil has been intentionally contaminated with halogenated solvents.

The used oil transporter will conduct an on-site halogen test prior to accepting used oil from a generator to assure the oil is less than 1,000 ppm halogens. If a batch of oil is greater than 1,000 ppm halogens or exceeds the on-spec limits as discussed above, it may not be accepted by your used oil transporter or, if so, it will cost more. If it is accepted, it must be routed through an industrial or utility burner permitted by EPA to burn off-spec used oil.

Mixing Other Materials With Used Oil

No mixing of other materials with used oil should be allowed to occur without consulting with your waste management/oil recycling company and state waste management office. In general,
transmission and hydraulic fluids; petroleum-based, nonhazardous lubricating fluids;
hydraulic, cutting, gear and cooling oils; and synthetic oils are defined as a used oil and may be added to the used engine oil.

The mixing of mineral spirits, brake fluid or used petroleum-based (nonhalogenated) solvents can also acceptable but only under certain conditions. The mixing of these materials with used oil should not, under normal circumstances, substantially change the chemical characteristics of the used oil, especially when added in small quantities. Although this has been a common practice, many companies have made it their policy to not allow mixing of any other materials with used oil to avoid any question of non-compliance. From a management point of view this is the only practical policy.

Never mix gasoline with used oil.

Never mix halogenated (containing chlorinated or fluorinated compounds) solvents with used oil.

Never mix a listed hazardous waste with used oil.

Never mix antifreeze with used oil.

Never mix unknown liquid wastes with used oil.

Transfer of Used Oil and Other Automotive Fluids

Dispensing reels and hoses. Courtesy of GRACO.

The subject of handling and transfer of used oil cannot be fully addressed without viewing the bigger picture of handling and transfer of new oil and other automotive fluids (transmission and brake fluid, antifreeze, windshield wiper fluid, hydraulic fluid, etc.). Where maintenance volume is sufficient, an integrated fluid management system will be beneficial. The advantages of this type of system, powered via air compressor, are:

Delivery of fluids to the vehicle through retracting hoses
Metering of the fluids
Extraction and storage of waste fluids
Minimization of spills
Increasing productivity

used oil under truckOne method commonly used is extraction from the vehicle by gravity into a portable, temporary tank as shown at the left. The used oil can then be drained into an underground tank. Another type of unit, shown at right, allows the used oil to be driven by compressed air into an above ground storage tank, for off-site recycling/energy recovery or onsite energy recovery.

used oil lincoln

Another method is the use of a portable drain container rolled under the vehicle when the vehicle remains on the shop floor. The used oil can then be gravity-drained into an underground tank or vacuumed into an above ground tank. This type of device can also be for draining antifreeze but the equipment must be used for this purpose only and labelled as such. Drainage of used oil from the vehicle into a small container then manually transferring it into a drum or tank using a funnel is also acceptable.

Storage of Used Oil

Federal EPA rules permit storage in covered drums and/or underground or aboveground tanks—either indoors or outdoors. Federal and state rules apply to underground storage of used oil. State and local fire codes regulate the aboveground storage of used oil, although additional environmental rules are becoming more common. Federal AST rules do not apply to tanks of 660 gallons or less. The full spectrum of state environmental rules normally do not apply to ASTs less than 660 gallons.

Used Oil and Other Small Underground Storage Tanks

Two special rules pertain to small underground tanks. USTs having a capacity of 550 gallons or less may use a manual tank gauging method as the sole method of leak detection. For tanks with a capacity of 551 to 2,000 gallons, you may use a manual gauging method in place of an inventory-control method.

Your gauging method must meet the following requirements:

* Liquid level readings are taken before and after a 36-hour period where no liquid is added or removed from the tank.

* Readings are taken twice and averaged both at the beginning and end of the 36-hour period.

*  The method used is capable of measuring the entire depth of the tank and can measure the level to the nearest 1/8 of 1 inch.

Using this method, a leak is suspected where the variation between the beginning and ending measurements exceeds the weekly (one test) or monthly (average of four tests) standards as follows:

Capacity        Weekly test        Monthly average
(gallons)        (one test)        (average of four tests)

550 or less          10 gallons          5 gallons
551 to 1000       13 gallons          7 gallons
1001 to 2000    26 gallons          13 gallons

Another special rule pertains to tanks which are filled by transfers of no more than 25 gallons at any one time; spill and overfill protection is not required to be installed on these tanks.

These special rules pertain to all USTs, including used oil tanks, which meet the above criteria. USTs used to store used oil prior to burning in an on-site space heater, furnace or boiler are exempt from UST regulation. Some states may not grant these exemptions.

Aboveground Used Oil Tanks

The national trend since the 1990’s has been to replace underground used oil tanks with aboveground tanks. Before considering aboveground storage systems, check with the local fire department to determine any special requirements. Consideration must be given to the space the ASTs occupy and the isolation distances from property lines, buildings and combustion sources as required by the fire department. Many fire departments do not allow storage inside a building in quantities more than 55 gallons. Where indoor ASTs are allowed, they need to be vented to the outside.

An optimum time to convert to an aboveground storage system is:

* When the underground tank requires upgrading or replacement in accordance with UST regulations,

* When a release has occurred which requires extensive repair or clean-up, or

* When it is realized that UST leak detection and other requirements are too burdensome.

Special Rules on Used Oil USTs

Spill and overfill prevention are not required for used oil and other tanks which receive no more than 25 gallons at one time. For small tanks of less than 1,000-gallon nominal capacity, leak detection requirements may be met by a manual gauging method in lieu of tightness testing and inventory control.  USTs used for storage of used oil for on-site heating purposes in accordance with EPA regulations are exempt from UST regulation. These rules are discussed in more detail in Chapter 5, Fuel and Liquid Storage Systems.

Recommended UST Operating Practices

Many UST systems are accessed and filled outdoors. This creates a common problem which cannot be easily corrected. Spillage occurs when employees transfer oil to the tank and when used oil transporters empty the tank. Not only does this leave unsightly oil puddles and stains, but may cause a discharge of oil to the stormsewer or adjacent property. Where soil covers the tank, significant soil and groundwater contamination can also occur. Consideration should be given to providing an indoor, remote fill pipe.

Outdoor fill pipes are usually surrounded by a metal casing upon which a steel plate cover is situated. Around the bottom of the casing is the soil which covers the tank. Overfills and spillage in this area contribute to significant oil contamination of the backfill and soil surrounding the tank. One solution to this potential problem is to install overfill protection devices or fill the area with concrete. When transferring oil into the tank, use a hose to insert in the fill pipe to assure no oil is spilled in this area. These actions will substantially reduce future contributions to soil contamination.

Where the tank fill cap is missing or is not watertight, rainwater may enter the tank causing an overflow of oil.  The overflow could then enter a stormsewer or contaminate the soil surrounding the tank or migrate to an adjacent property. Tanks with no caps or nonlocking caps can also result in illegal dumping of hazardous wastes into your tank by “midnight” waste transporters. Provide a locking cap with a light chain. Lock the cap when the tank is unattended.

Note: The following information on Storing Used Oil Correctly and Economically was provided by Alex E. Ralston, P.O.E., President, Petcon, Inc., Jackson, MS.

Storing Used Oil Correctly and Economically

As a consultant and equipment distributor, I have had the opportunity to study designs for the storage of used oil. A common problem I have found is the “over” engineering of the system. Two examples come to mind to illustrate this point.

1.    One system was designed for storing used oil at tire stores for a major tire manufacturer. The tank was a 550-gallon, double-wall steel tank with an electronic overfill alarm and a pump inside the shop, pumping the used oil into the tank, which was located outside the building. The system cost over $7,000, 15 years ago.

2.    Another example features the most expensive system, for a small end user, that I ever recall seeing. This was a design specification for a 500-gallon aboveground used oil tank with secondary containment and a UL 2085 fire-protected rating for insulated aboveground tanks. These design features were combined with an array of bells and whistles.

These are two examples of designing too many features into what could be a much simpler, adequate design to meet aboveground storage tank (AST) regulations for used oil.

AST and UST Regulations: Used oil stored underground is regulated by the Environmental Protection Agency (EPA) Underground Storage Tank (UST) Regulations (40 CFR 280). Aboveground storage of used oil is regulated by federal used oil regulations that became effective March 1993 (40 CFR 260, et al). The local fire department has jurisdiction over both methods of storage.

Federal regulations for storing used oil aboveground require that used oil be stored in containers with no visible leaks, no severe rusting, structural defects of deterioration. Used oil storage tanks must be labeled with the words “used oil.” There is no requirement for secondary containment of aboveground used oil tanks for end users in the federal regulations. Aboveground tanks with a capacity of 660 gallons or more, or two or more tanks with a combined capacity of 1,320 gallons or more, are subject to federal SPCC regulations in addition to the used oil regulations.

Become Familiar with UL Listings: UL 58 is the listing for steel tanks storing flammable or combustible liquids underground. UL 1746 is the standard for external corrosion of USTs storing flammable or combustible liquids. Neither of these tanks are designed for aboveground use. UL 142 is the listing for aboveground steel tanks storing flammable or combustible liquids. UL 2085 is the listing for insulated aboveground tanks.

Know the Regulations: No regulation allows used oil to be stored aboveground in tanks designed for underground use. The use of underground tanks to store used oil aboveground is strictly prohibited by fire codes.

If you intend to store used oil in an UST, used oil tanks are regulated under the EPA’s UST regulations 40 CFR 280. For small tanks with a capacity of less than 1,000 gallons and filled by less than 25 gallons at one time, compliance with the UST regulations can be economical.

USTs filled by no more than 25 gallons at a time are not required to have spill containment or overfill prevention. Tanks with a capacity of 1,000 gallons or less, may use “Manual Tank Gauging” as a means of leak detection, by measuring the tanks once a week and following the correct procedures outlined in 40 CFR 280. When using this method of leak detection, owners are not required to have a precision tightness test performed if the tanks have a capacity of less than 550 gallons, or 551 gallons to 1,000 gallons and have either 48-inch or 64-inch diameters.

Tanks Designed for Economy: One economical design for storing used oil for small shops such as tire stores, quick lubes or garages is to store the used oil in a 550-gallon, UL 142-listed, round, single-wall aboveground bracket tank. Accessories may include: a 5-gallon containment basin on top of the tank to pour the oil, a 4-inch emergency vent, a 2-inch atmospheric vent, an inexpensive gauge to determine the amount of oil in the tank and a 2- to 4-inch fill cap to allow the waste oil hauler to remove the used oil from the tank.

The estimated cost of this equipment is around $900 excluding a dike, installation and any additional requirements by the owner or local authorities.

Usually local equipment distributors are the best source of economical designs. The elaborate systems first mentioned in this article were designed by engineering firms not familiar with this industry.

This article has focused on small end users who store used oil in containers of less than a 660-gallon capacity. Larger tanks are governed by more stringent regulations. In either case, knowing the regulations and applying sound engineering designs to meet those requirements can save the owner of the vehicle maintenance facility money. This common-sense approach to engineering design can be found with engineering and consulting firms familiar with the industry.

Note: This ends the information on Storing Used Oil Correctly and Economically provided by Alex E. Ralston, P.O.E., Petcon, Inc., Jackson, MS.

Drum Storage

Follow these guidelines where used oil is stored in drums outdoors:

* Provide a special storage location. Use a fenced or walled area which is roofed, typically against the building, which can be secured.

* Prevent stormwater and rainfall contact with the drums.

* Provide a concrete or impervious floor with diking which would contain 110% (120% is required in some areas) of the volume of liquid to be stored.

* All drums should be stored with their heads or bungs tightly sealed and labeled “used oil.”

* Indoor and outdoor drum storage areas should be well marked with “No Smoking” signs and signage indicating it is a used oil storage area.

* Adequate spill clean-up materials should be available nearby.

Options for Used Oil Utilization

Nearly all used motor oil generated by vehicle maintenance operations (other than DIY) is recycled in some way. Approximately 90% is burned for energy recovery and the remaining 10% is re-refined.

Off-Site Uses

A used oil management program should also include verification of the destination of your used oil. Your used oil should be destined for:

* Burning for energy recovery (on site or off site)
* Re-refining
*  Reprocessing/recycling/reuse (There are other ways to recycle used oil acceptable to EPA, but these are not commonly practiced.)

The use of used motor oils for road oiling or weed control used to be quite common but is not recommended and is prohibited by many states.

It is extremely important to properly select a used oil transporting firm and verify its ultimate destination. Use the guidelines in Section 1, How to Select a Waste Service Firm.

Even when you are in compliance with used oil regulations, you can be held liable in the future for off-site contamination caused by your used oil or other wastes. Many companies engaged in automotive maintenance are currently partially responsible for legal fees and the costs for site assessment and clean-up of sites caused from improper handling of used oil by waste transporters and recyclers.

On-Site Energy Recovery

cleanburn

Shop used-oil heater. Courtesy of Clean-Burn.

On-site energy recovery with used-oil burners is an excellent option. Used oil burners, designed for burning of used oil in vehicle maintenance shops, are available with state-of-the-art controls that produce a good, clean burn. The burning of used oil in conventional furnaces and space heaters is specifically prohibited by EPA regulation. Typically, you may burn used oil in heaters and other equipment that meet NFPA standards and that are less than 500,000-Btu/hr heating capacity without a special permit. The burning of used oil in EPA-accepted heaters is not allowed in the state of California and several Canadian provinces. At the time of this writing there may be other states and counties that prohibit this.

Units are also available that produce hot water and steam. This can be attractive for car and truck washes.

The burning of used oil in these units reduces the costs for heat (or energy) as well as the costs for off-site transportation. The risk of environmental liability for improper off-site management is also eliminated by using on-site used oil-fired systems. As mentioned previously, USTs used for storing used oil for on-site heating purposes are exempt from federal UST regulation.

Air emissions from burning used oil are insignificant in properly designed and operated units. Tests have shown emissions of hydrocarbons from on-site burners are less than those generated for a new automobile. Even in cases where the facility is located close to residences, businesses and other public places or where the topography or weather conditions may limit dispersion, emissions should not create a nuisance or environmental concern.

Before purchasing a unit, check your state agency for special requirements such as permitting, emission testing or other limitations regarding the use of this equipment. Select a unit from a major manufacturer with a local distributor who can provide a service contract to maintain the unit.  Some materials should not be mixed with motor oil prior to burning to make sure you get a good, clean burn. Never mix other materials in with the used oil unless it is acceptable according to the manufacturer’s recommendations.

The federal EPA has clarified that the burning of used oil in shop heaters will continue to be permissible even if used oil is designated as a regulated hazardous waste in the future. On-site used oil burning in properly designed units remains an excellent option for energy and economically efficient and environmentally sound utilization.

Re-Refining to Produce Re-Refined Oil (RRO)

Re-refining of used oil (processing and producing a high-quality motor lube stock) is also an excellent option for utilization.

For every 1,000 gallons of used oil going into the re-refiner, only about 500 gallons, or 50%, exits as re-refined lube stock, suitable for use in vehicles. The rest is largely bottom liquids and sludges used as fuels and also solids containing high levels of concentrated toxic and hazardous materials. These solids must either be treated and disposed as hazardous waste or, as commonly done, blended into asphalt products.

Used re-refined oil (RRO) at many fleet maintenance locations is returned again and again to the re-refiner. After 1,000 gallons of used oil goes through the re-refining process three times, only 120 gallons (12%) remain as re-refined lubricating oil—the remaining 880 gallons (88%) is lost as fuel and wastes. (Dale Schofield, Canadian Standards Association [CSA] Task Force, 1996.)

Using Re-Refined Oil in Vehicles

Should you use RRO in your vehicles? Re-refined motor oil is the same quality as virgin motor oil. You can be confident of its quality if it carries the API seal of approval as meeting rigid specifications. Vehicle manufacturers also approve of its use. It works as good as virgin product.

You may find RRO costs more than their best price quote on virgin product. It is our conclusion that there are no benefits to using RRO unless it is less costly for you.

Adding Used Oil to Diesel

Federal EPA rules do not specifically disallow adding used motor oil to diesel fuel in mobile and stationary diesel engines, although there are some limitations addressed below. There are two ways to do this:

1. Use of commercially available filtration and blending equipment to add used oil to the stationay storage tank or on-board tanks. With this method, used oil is blended with the diesel fuel in amounts of up to 3%. This method of use is not allowed in California. [ NOTE: On newer engines equipped with catalytic converters, 3% used oil can poison catalysts and decrease life and performance. It is recommended you seek the advice of the engine manufacturer.Also 3% used oil can be very high in sulfur content and could throw your fuel out of spec with EPA’s fuel sulfur limits.Mixing used oil with diesel at about a 3 percent might also increase exhaust emissions and opacity.]

2. The superior method of utilizing used oil and minimizing oil changes is by installation of on-board, continuous filtering/recycling systems. These systems take a very small slip-stream from the oil line and filters it with a high-efficiency filter. It also take a very small slip-stream and adds it to the fuel line for combustion (One unit is designed to deliver a 0.3% blend.) At the same time it adds fresh make-up oil from an oil resevoir. This technology  has very attractive paybacks for high-use diesel engines such as buses and over-the-road trucks by reducing the number of oil changes.

The Internal Revenue Service (IRS) has been enforcing the motor fuel tax and this includes paying taxes on the amount of used oil burned as a motor fuel. Check with your fuel tax accounting advisor for the latest.

Illegal Mixing

Unfortunately, the mixing of used oil with diesel fuel can occur at some truck stops (or their fuel suppliers) where used oil is dumped in the stationary diesel tanks. This is consumer fraud and deception. To make matters worse, it has been the subject of some federal investigations, where toxic materials, such as PCBs, pesticides or other wastes, have also been added intentionally by midnight dumpers. This practice not only can hurt the environment and the engines but can have serious health effects upon those exposed to the exhaust fumes. This practice is clearly a criminal activity. Install locks on all outside fuel and used oil tanks.

Accepting Used Oil From the Public

According to the EPA used oil management standards, maintenance facilities which meet the “service station” definition are exempt from Superfund liability for used oil shipments as long as compliance with the standard is maintained and the facility is willing to accept used oil brought in by DIYs. This may be a misleading “benefit” since enforcement actions and private suits can be brought under a host of other environmental laws or even “common law.”

More and more, retailers of automotive service are providing a service to the DIY oil changers and accepting used oil from them.  In 1990 and 1991, as many as eight major oil companies announced regional and national programs to accept DIY used oil at service stations. Today, many independent service stations, franchised auto parts stores and even farmers’ cooperatives have joined in on accepting used oil from the public, as well as city- and county-sponsored events set up to accept used oil and other household hazardous waste materials.

Clearly, the major used oil environmental concern is the improper disposal of DIY oil. About 30% to 35% of all used motor oil is DIY oil—accounting for over 300 million gallons per year. Prior to 1990, it was estimated only 20% of DIY oil was recycled. According to a 1996 API study of the 342 million gallons of motor oil sold to DIYs, nearly 60% was collected for recycling in 1993. With increasing numbers of available retail locations accepting the DIY oil, this number is expected to increase considerably in the coming years.

In the recent past, there has been considerable concern over the acceptance of used oil from many retailers due to the issue of used oil contamination with other materials. Major used oil recyclers who collect DIY oil have stated contamination (with solvents, pesticides, paint wastes, etc.) is very rarely encountered.

The future status and costs associated with pending federal rules designating the used oil as a hazardous waste have also been a concern with DIY oil collection. With the recent EPA ruling, this dilemma should be resolved. Should federal legislation designate used oil as a hazardous waste, it is likely to stall increasing voluntary acceptance by retailers and service stations.

Many voluntary local and statewide programs exist for the collection of used oil from DIYs. Retailers of oil and automotive service retailers in California, Min-nesota, New Jersey and New York are required to participate in programs for the collection of used oil from the general public.

Acceptance at retail locations is a much-needed service and offers the retailer promotional opportunites to build customer relations and public image. Although there are guidelines and kits available from local, state and commercial recycling programs, here are some guidelines for implementing a customized used oil recycling program:

* Offer special reusable containers in which to return used oil.

* Avoid accepting used oil containers.

* Visually inspect the used oil—do not accept suspicious materials.

* Consider using a separate drum or tank for DIY oil to avoid potential contamination.

*  Have the DIY contributors sign a log with a statement verifying the material is used oil only.

* Post a sign and provide written materials.

* Include your new public service in advertisements.

* Include other environmental efforts in your promotion.

* In addition to retailers accepting used oil, it may be worth considering accepting used oil filters for a small charge.

A complete package on DIY collection is available from the API in Washington, DC, 202-682-8042. For state information, contact the Used Oil Recycling Coordinator given in Appendix A.

Other Used Oil Contaminated Wastes

EPA has determined that nonterne-plated used oil filters and absorbents contaminated with used oil may be handled as a nonhazardous solid waste and discarded into the dumpster for landfill disposal under certain conditions discussed below. There are also operational and economic advantages in utilizing oil filter crushers and/or a total recycling process as explained below.

* Used Oil Filters

As of May 1992, EPA announced that properly drained used oil filters are not subject to hazardous waste rules with the exception of heavy-duty filters manufactured with lead and tin alloys, called terne-plated. Therefore, in most states, drained filters may be landfilled. (With the exception of these terne-plated filters, most testing programs indicate that used oil filters from both gasoline and diesel engines pass the TC rule by a wide margin.)

Over 500 million automotive used oil filters are generated in the United States each year. These filters contain about 24 million gallons of used oil and over 170,000 tons of steel. Most of these used oil filters are disposed in landfills.

What is the best way to manage used oil filters? Should you drain them and toss them in the dumpster, crush them, or recycle them?

Below is an excellent 4-minute video on filter recycling:

Regulatory Considerations

As with any waste material, one must examine how the material is regulated by EPA and by state and local regulations. You must then evaluate available options for proper disposal which meet these requirements.

Regulations—What are the federal EPA requirements concerning the disposal of used oil filters?

Car and light-duty truck filters must first be “properly” drained.  Then they may be disposed as a nonhazardous solid waste—meaning they can be placed in the dumpster—as long as it is permitted under state and local regulations. In some cases, landfill operators prohibit their disposal in landfills.

What does EPA define as “proper” draining of used oil filters?—EPA published this rule on May 20, 1992 at 40 CFR, Part 261.4(b)(13), which states how filters are to be drained:

1)    Puncturing the filter antidrain back valve or the filter dome end and “hot-draining”;

2)    Hot-draining and crushing the filter;

3)    Dismantling and hot-draining; or

4)    Any other equivalent draining method which will remove used oil.

Hot-draining means the oil filter is drained near engine operating temperature and above room temperature. EPA recommends a 12-hour drain time. A filter drain area can be easily constructed by placing a heavy-duty screen or grate or a drain pan on the top of a 55-gallon drum which can receive the drained oil. You can also have the oil drain directly into the used oil tank. Special equipment is also commercially available.

Terne-plated filters must be handled as a hazardous waste or recycled unless testing indicates your terne-plated filters are nonhazardous. Terne-plated filters were normally found on heavy-duty trucks and off-road equipment. The issue of terne-plated filters has largely disappeared. U.S. filter manufacturers have agreed not to manufacture them any longer and, as inventories are depleted, will no longer be part of the wastestream. However, some imported filters might still be terne-plated.

These are the minimum federal requirements. EPA encourages the recycling of each part of the used oil filter including the canister, filter media and plastic parts.

To find out what your specific state and local requirements are for proper disposal and to locate filter transporters, processors and recyclers in your area, contact the Used Oil Filter Hotline at 1-800-99-FILTER (managed by the Filter Manufacturers Association) or contact your state solid waste agency.

Options

Some vehicle maintenance facilities go a step further by crushing their filters prior to landfill disposal. Crushing will significantly reduce the amount of oil retained in the filter and decrease storage volume.

Where filters are prohibited from direct landfilling, they will most likely be processed off site by one of several methods to be accepted by steel producers or to be made suitable for landfilling. In these cases, crushing the filter at the vehicle maintenance facility may be an attractive cost-reduction measure by reducing the volume and the frequency of pickups by the transporter/processor. On the other hand, crushing filters requires some labor and equipment cost. Filter recycling can be environmentally responsible and economical and recycling processes in most areas of the U.S. continue to grow. Some filter recyclers, depending on their processing techniques, will not accept crushed filters.

What Happens to My Filters?

Used oil filters which are destined for off-site processing/recycling are commonly:

*  Shredded, cut open and solvent-washed
* Crushed into low-density pucks
* Crushed into high-density briquettes
* Burned directly in cement kilns or recycled at steel mills
* Prepared for acceptable landfilling

Separated filter media is normally incinerated or landfilled. More and more steel producers are accepting the scrap steel derived from used oil filters. The steel can also be incorporated into construction materials. Plastic parts are recycled or landfilled. Used oil extracted during processing is, of course, handled through the used oil recycling system, commonly destined for use as a fuel.

What Do I Do Now?

* Evaluate your present handling and disposal methods for used oil filters generated at your facility.

* Determine your state and local requirements for used oil filters.

*  Make sure your transporter/processor uses one of the processing methods mentioned above or another acceptable method. Follow cautionary selection procedures as discussed in Section 1, How to Select a Waste Service Firm.

About half of all used filters are now recycled in some way compared to about 0% in 1990. Remember, recycling filters makes sense in many cases; it creates jobs and the filters can be a valuable and useful resource, too.

* Absorbents and Other Materials Containing Used Oil

Knowing the EPA rules concerning used oil and related wastes can save your organization a lot of time and money, and reduce future environmental liability. This section will focus on the following:

•  Spent absorbents and paper wipes containing only used oil
•  Sludge and water from oil-water separators and used-oil tanks
•  Soils contaminated with used oil

These materials can be exempt from federal EPA hazardous waste regulations under certain conditions. Always check with your state used-oil coordinator and your used-oil processing firm for requirements in your area. Some state rules are stricter than the federal requirements.

Spent Absorbents Containing Used Oil

Under federal policies, absorbents used to clean up oil spills or to wipe oily/greasy parts and which contain “free-flowing oil” are considered “used oil”. This includes absorbents made from clay, cellulose, corncobs, and sawdust and paper towels or cloth towels which are to be discarded.  They can be managed under the used-oil management standard rather than the hazardous waste rules. “Free-flowing” oil means the material drips with used oil. If any of the materials contain free-flowing oil and are stored, for example, in a drum, all of the materials can be burned off-site for energy recovery. Therefore, no hazardous waste characterization needs to be performed.

NOTE: Absorbents and wipes not containing “free-flowing” oil (or that are used to pick up other hazardous materials or wastes) are not covered under the used-oil rule. These wastes are subject to hazardous waste characterization, unless you are a federal and state conditionally exempt generator (CEG). A CEG  generates less than 220 pounds of hazardous waste in a calendar month. If you are a CEG, you should be able to place these wastes in the trash disposal bin if allowed by your state.

Follow these recommended practices:

• Use a laundry service for cloth towels and reuse them. Cloth towels sent to launders are not a waste.

• Do not use absorbents where it is unnecessary. Scoop up oil spills with a dust pan and transfer the oil to the used-oil tank. Mop or sponge the residual oil film with a biodegradable detergent containing oleophilic (oil-loving) microbes. Wastewater can be emptied in floor drains connected to an oil-water separator.

• Store used absorbents in covered containers labeled with the words “Used Oil Wastes”, or equivalent.

• If you are disposing of “liquid-free” absorbents and paper wipes in the trash bin, make sure you are a CEG and your state office of solid and hazardous waste allows this practice.

• If you are a small-quantity generator (more than 220 pounds per month of hazardous waste), make sure your absorbents contain some “free-flowing” (dripping) oil. (This allows it to be called “used oil”). Manage them as “used oil” and have them burned for energy recovery through your used-oil processor. Otherwise, you must have them characterized by laboratory analysis or assume they are hazardous and manage them accordingly—unless your state has a different policy.

Absorbents used for clean-up of other spills, such as gasoline, antifreeze or other chemicals, are not covered by this rule and may need to be handled as a hazardous waste (if you are an SQG) in accordance with Section 3.0, Hazardous Waste Management.

As an important note on this topic, even though it may be acceptable to federal, state and local environmental agencies to dispose of these wastes in the dumpster, you need to check your contract with the solid waste contractor. You may find a clause stating “no hazardous or potentially hazardous materials, such as . . .” You may want to get further clarification from the contractor or landfill owner as to what is acceptable. Ask if they expect strict adherence to the contract language and if they can issue you a statement clarifying if they will accept used oil-containing debris.

Another option is the use of high-quality, long-life absorbent materials called blankets, sheets and socks. These can be wrung out, cleaned and dried for reuse (on site or off site). Considerable cost-savings can be realized using this option.

Finally, use of loose absorbent granules has its applications, but there are drawbacks including:

1)    Large waste volumes can be generated, if not controlled;

2)    Waste disposal can be expensive and problematic;

3)    Absorbents used to clean up acid and other chemical spills are of “unknown” characteristic and may not be able to be mixed with granules containing used oil.

4)    They can be messy, especially when they are left on the floor for long periods or when the wind blows them around the shop and out on the pavement.

There are probably better ways to clean up spills than current methods used in your shop. Take this opportunity to review your spill control procedures and clean-up and disposal costs. You may be able to make great improvements, reduce waste absorbent volume and save money.

Historical Note:

Due to concerns of the impact of dirty rags, towels and wipes on the environment, including air emissions and possible effects on workers who may be exposed to hazardous materials contained in the rags, EPA proposed a rule in the 90s that never came about (fortunately) . Preliminary language to the rag rule targeted 13 hazardous solvents: 2-nitropropane; nitrobenzene; methyl ethyl ketone; methyl isobutyl ketone; methylene chloride; pyridine; benzene; cresols (o,m,p); carbon tetrachloride; chlorobenzene; 1,1,2-trichloroethane; tetrachloroethylene; and trichloroethylene.

Under the proposed rule, if a towel is “dry” (containing less than 5 grams of solvent) it can be sent to landfills or industrial laundries. But, even a dry towel can’t be sent to a landfill if it contains one of the 13 targeted solvents, meaning incineration will be needed. Wet towels cannot be sent to landfills. The proposed rule also would have addressed requirements pertaining to the containers in which wet towels must be shipped, how to remove free liquids from towels, and the role of hand wringing and centrifuges. As mentioned, the rule has never come about.

Sludge, Oily Water and Soils

Sludge from used oil tanks is defined by EPA as “used oil”. This allows it to be handled as used oil as long as it is burned off-site for energy recovery and has never been mixed with a hazardous waste. This holds true even if the sludge exhibits a toxicity characteristic such as lead, cadmium, chromium or benzene. However, you must meet all of the requirements of the used-oil management standard to obtain this exclusion.

Sludge and oil from oil/water separators (OWS) are considered “used oil” if they are transported by and to a used-oil processor which is permitted under the Clean Water Act. These wastes are excluded from hazardous waste regulation. Some states may not allow this. Oil collected from the OWS can also be collected and burned in a used-oil heater.

Oily wastewater from OWS cleanout is also considered “used oil”. The wastewater should be placed back into the OWS, eliminating additional charges from your service firm. Your used oil processor should also be able to arrange proper treatment. Make sure the OWS is filled with water after the clean-out. See OWS cleanout guidelines below.

Contaminated oily water from used-oil tanks should be acceptable to your used oil recycling firms for an additional charge. They should be able to provide separation and treatment.

Soils contaminated with used oil might meet the definition of a hazardous waste. State rules for disposal of petroleum-contaminated soils vary widely. There is a special, federal deferral from hazardous waste regulation for contaminated debris found during underground storage tank clean-ups. It covers materials having any one of 25 toxicity characteristics, such as benzene, toluene or xylene. This deferral covers the empty tank and materials outside the tank, such as soil, groundwater, surface water, piping, and debris such as rocks, stumps and grass.

*Used Shock Absorbers and Struts
Trash or Recycle?

There are no federal or state regulations in existence that are specific to the disposal or recycling of shock absorbers or struts. This article will examine what might be considered “best management practices” for disposal of these used vehicle parts.

The simplest and most practical methods for disposal of used shocks and struts, are determined to be:

1) Landfilling with other non-hazardous solid waste. (If your area uses solid waste incinerators, scrap metal is separated prior to incineration and either landfilled or recycled according to the operator’s operating practices.)

2) Recycling as scrap metal under conditions described below.

How these “best management practices” were determined is the subject of the rest of the section.

Are These Materials Hazardous by EPA Definition?

Clearly, these wastes can be assumed to be non-hazardous according to EPA definition. Neither the oil nor the steel would be considered hazardous. In the case of nitrogen-pressurized shocks and struts, the nitrogen is an inert, non-hazardous gas and EPA does not define containers as hazardous solely because they are pressurized.

Can They Be Landfilled?

Since these materials contain oil, the question arises whether or not they can be legally landfilled.

Historical Note: In the late 90s. state regulators were queried in the states of California, Indiana and Wisconsin. California and Indiana said these materials can be directly landfilled. Indiana said this issue has never been raised before. Wisconsin has a 1990 law banning  materials that contain oil except in “minimal quantities” and where the oil has been removed to the maximum extent possible. However, the law does not define “minimal quantity.” A December 1999 letter from the Wisconsin Department of Natural Resources said the law will be left to the courts to ferret out. In the meantime, it stated, vehicle service providers could be at risk of violating the landfill ban and be responsible for contamination resulting from disposal of oil-containing materials.

You have the option to manage used-oil-containing wastes under the used oil management standards or under solid/hazardous waste regulations. In the case of shocks and struts, we conclude these materials are non-hazardous solid wastes and are acceptable for landfilling.

Most of today’s landfills are environmentally safe. About 70% are built to strict EPA design standards making it nearly impossible for soil or groundwater contamination to occur. With the high volume of toxic household products accepted by landfills, shock absorbers and struts represent, at most, a negligible environmental impact.

Can These Materials Be Recycled?

At the manufacturing facilities, defective units are recycled by:

1. Drilling a hole to relieve the pressure
2. Cutting with a band saw to remove the oil
3. Recycling the oil as used oil and,
4. Recycling the metal as scrap metal.

In a vehicle maintenance facility, where much smaller quantities of these units are generated, this treatment scenario is unnecessary and impractical. It also presents safety hazards.

Since the units contain oil, must used shocks and struts which are to be recycled be managed under the used-oil management standard?

To answer this question, one must review a 1994 letter and opinion of the EPA Director of Characteristic and Assessment. It must be emphasized that this is only an opinion, and there will be many opinions on this issue, but it is an opinion based on federal regulations. This means all states must be at least as stringent.

The July 11, 1994 letter to a Minnesota appliance recycler regards the status of appliances that contain oil (i.e. household refrigerator compressors, in this case). The letter states that an appliance (the same opinion can made for shocks and struts) that contains non-hazardous oil must be drained of used oil prior to transport to a recycling facility. If not, it must be managed under the used oil management standard. (According to this letter then, somewhere along the line, it is required to drain the oil and manage it as used oil. In addition, these used-oil collection facilities which store used oil in quantities of 55 gallons or more must have an EPA I.D. number (or state equivalent) and are subject to other requirements.

Does the end processor drain the oil and manage it as used oil? Probably not. They most likely shred it with other scrap. As a result, the oil can burn during shredding, spill on the ground or contaminate the unrecyclable “fluff’ which will be landfilled.

Scrap metal dealers will accept used shocks and struts for recycling. However, given the unknown and commonly illegal operating practices at scrap yards and end processors, is this a good practice? It can be if you are satisfied that all parties involved meet used-oil management standards—but this is almost unverifiable.

Conclusion

Although there is a potential for violating used-oil management standards and off-site contamination when recycling shocks and struts, we conclude that landfilling or recycling are both good options for managing these wastes.

As always, it is best to check with your state used-oil coordinator or local solid waste agency for specific requirements or policies in your area.

Minimization of Used Oil and Related Debris

In all vehicle maintenance activities, oil-contaminated debris can be reduced by:

* Minimizing spills

* Using absorbents and rags to maximum useful life

* Minimizing small leaks from vehicles and equipment through proper maintenance or replacement of seals, gaskets and fittings

*  Installing drip pans or absorbent pads under leaking vehicles, equipment and machinery

* Providing diking or secondary containment around used oil storage drums and containers

In fleet operations, increase engine oil life and reduce oil consumption and used oil filter generation by:

* Specifying a long-life or synthetic oil

* Using advanced filtration technology

* Installing centrifugal oil cleaning technology on heavy-duty diesel engines

* Using life-extending oil additives

* Using an engine oil analysis service for heavy-duty engines (See Fact Sheet at the end of the chapter)

* Extending filter life by installing and monitoring a pressure-drop device (many filters are discarded before useful life is over)

* Considering the use of reusable lifetime filters

How Fleets Can Reduce Oil Consumption, Used Oil and Filters

For the retailer of automotive services, the owner/operator has little control over used oil and filter wastes (you get whatever comes in). But for vehicle fleet operations that service their own vehicles, it is a totally different story. Here are some useful tips:

1)    Motor oil does not wear out; it gets dirty (suspended and dissolved solids–including metals), and it can build up other chem-
ical contaminants (sulfur, organic constituents of fuel and fuel combustion by-products).

2)    You can extend oil life by exceeding OEM oil-change intervals (on cars, estimates of up to double oil-change intervals have shown no effect on engine life/performance, depending on driving conditions.)

3)    You can extend the life of the oil filter by about twice or more, and it can be monitored by a pressure-drop device to determine when to change it. (Good fleet maintenance managers know this.)

4)    Use of long-lasting or lifetime oil filters reduce or eliminate filter wastes, filter expense and disposal costs.

5)    Relatively simple and inexpensive by-pass filtration systems can be installed to obtain drain intervals of over 200,000 to 400,000 miles.

6)    Advanced on-board oil treatment systems can extend drain intervals even more. Two systems, which have been in use worldwide for more than 15 years, can potentially allow a truck to run up to 1 million miles without an oil change.

RESOURCES: The Final UOMS Rules are here (PDF)

Two-clicks takes you to state used oil regs in your state

The Filter Manufacturers Council maintains information in how to hot-drain and recycle your filters, selecting a recycling company and a directory of filter crushers and recycling companies.

API also has information on used oil recycling http://www.recycleoil.org/

Oil Life Extension (EPA Region 9). This fact sheet describes how a testing program can extend engine oil life and thus lower oil consumption, reduce used oil generation, and decrease operating costs with no risk to your vehicles.

By-Pass Filters. Bypass filters extend oil life through improved filtration. They may also improve engine life and fuel economy.

CalEPA Extended Oil Change Intervals. A recent study provides strong evidence that oil analysis programs, higher quality motor oils, and more efficient filters will protect engines from wear and lead to significant cost savings. Oil analysis helps to determine the optimum oil change frequency and can provide early diagnostics for engine wear.

 

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