USED OIL SEGREGATION AND STORAGE

Revision Date: 11/03    The information in the data sheet does not change. This data sheet will not be updated.
Process Code: Navy/Marines: IND-025-99; Air Force: HW01; Army: N/A
Usage List: Navy: High; Marines: High; Army: High; Air Force: High
Alternative For: N/A
Compliance Impact: Medium
Applicable EPCRA Targeted Constituents and CAS Numbers: N/A


Overview: Proper segregation and storage of used petroleum, oils, and lubricants (POLs) is necessary to promote recycling. Required segregation is normally dictated by the waste oil transporter so that waste oils are consistent with the intended use. Proper storage is the same, regardless of the degree of segregation. Generally, the goal of proper storage is to eliminate water and dirt contamination of the waste POL prior to off-site shipment.

Based upon a review of Title 40 Code of Federal Regulations (CFR) Part 279, "Used Oil Management Standards," Subpart A, "Definitions," used oil is defined as any oil refined from crude oil or any synthetic oil that has been used and, as a result of its use, is contaminated by physical or chemical impurities. "Subpart B, ‘Applicability’, states mixtures of used oil and any hazardous waste listed in subpart D of 40 CFR part 261, or hazardous waste that solely exhibits a hazardous characteristic in subpart C of 40 CFR part 261 if the resultant mixture exhibits the hazardous characteristic, require regulation as a hazardous waste under 40 CFR parts 260 through 266 268, 270,and 124, rather than as used oil under 40 CFR part 279."

Generally, testing of used oil to determine if it is hazardous waste is not required. Title 40 CFR 279, "Used Oil Management Standards" states that used oil is subject to this regulation regardless of whether it exhibits characteristics of a hazardous waste. If it is suspected that the used oil has been mixed with a hazardous waste, it should be tested using the following methods in accordance with 40 CFR, Parts 261 and 279. Measured values should be compared to those presented in 40 CFR 261.

  • Environmental Protection Agency (EPA) Method 1311, "Toxicity Characteristic Leaching Procedure (TCLP)" (40 CFR 261.24);
  • EPA Method 1010 Pensky Martens Closed Cup (PMCC) Method, or EPA Method 1020;
  • Setaflash Closed Cup (SCC) Method - "Flash Point" (40 CFR 261.21);
  • EPA Method 1110, "Corrosivity (pH)" (40 CFR 261.22);
  • EPA Method 9040 or 9041, "Reactivity" (40 CFR 261.23); and
  • EPA Method 8010, "Halogenated Volatile Organics."

Appropriate precautions should be taken to store used oils in a manner that prevents other non-used oil products from being added. In this event, any or all of the above tests will not be required. Used oil is presumed to be a hazardous waste when it contains more than 1,000 parts per million (ppm) total halogens, subject to rebuttal as outlined in 40 CFR 279.

Assuming the oil meets the criteria of used oil rather than a hazardous waste, it is regulated under 40 CFR 279 and 40 CFR 279.1. "Definitions" defines the following terms:

Used Oil Collection Center: "...means any site or facility that is registered/licensed/permitted/recognized by a state/county/municipal government to manage used oil and accepts/aggregates and stores used oil collected from used oil generators regulated under subpart C of this part who bring used oil to the collection center in shipments of no more than 55 gallons under the provisions of subpart 279.24. Used oil collection centers may also accept used oil from household do-it-yourselfers."

Used Oil Aggregation Point: "...means any site or facility that accepts, aggregates, and/or stores used oil collected only from other used oil generation sites owned or operated by the owner or operator of the aggregation point, from which used oil is transported to the aggregation point in shipments of no more than 55 gallons. Used oil aggregation points may also accept used oil from household do-it-yourselfers."

40 CFR 279, Subpart D - "Standards for Used Oil Collection Centers and Aggregation Points" requires both the used oil collection center and the aggregation point to comply with the requirements of 40 CFR 279, Subpart C, "Standards for Used Oil Generators." The essential difference between a used oil aggregation point and a collection center is the aggregation point can accept oil only from used oil generation sites owned or operated by the owner or operator of the aggregation point and there is no requirement for state, county, or municipal registry, licensing, permitting, or recognition. In both cases, shipment, acceptance, and transport of used oil is limited to 55 gallons or less. There is no limitation on the amount of used oil that may be accumulated at the collection center or the aggregation point.

40 CFR 279, Subpart C, "Standards for Used Oil Generators," requires used oil to be stored in tanks, containers, or units subject to regulation under 40 CFR 264, "Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal (TSD) Facilities," and 40 CFR 265, "Interim Status Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities". Subpart C, "Standards for Used Oil Generators, states that containers and above ground tanks and fill pipes into underground storage tanks used to store used oil at generator facilities must be labeled or marked clearly with the words ‘Used Oil’." Further, used oil generators are subject to applicable Spill Prevention, Control and Countermeasures (SPCC) plan requirements (Title 40 CFR 112). Used oil stored in underground storage tanks is also subject to the applicable regulatory requirements of Title 40 CFR 280, "Technical Standards and Corrective Action Requirements for Owners and Operators of Underground Storage Tanks (USTs)".

In addition to federal requirements, state regulations should be carefully reviewed to ensure all applicable requirements are met.

The most effective method of minimizing contamination is to segregate the used oil from possible contaminants such as non-petroleum oils, solvents, and antifreeze. This segregation can be accomplished by providing separate, labeled containers for the collection of waste solvents, synthetic oils, glycol, and other materials. Physical separation of the processes using materials that contaminate oil can be helpful in solving the problem.


Compliance Benefit: Segregating used oil promotes a decrease in the amount of hazardous waste on site due to the fact that any used oil which has been contaminated from hazardous waste exposure may need to be classified as a hazardous waste and managed accordingly. The decrease in hazardous waste may help a facility reduce their generator status and lessen their regulatory burden (i.e., recordkeeping, reporting, inspections, transportation, accumulation time, emergency prevention and preparedness, emergency response) under RCRA, 40 CFR 262. A decrease in hazardous waste may also help a facility to meet the goals of the Pollution Prevention Act (42 USC 13101-13109) and Executive Order (EO) 13148, Greening the Government Through Leadership in Environmental Management. In addition, segregation generally allows the used oil to fall under the less stringent regulations of 40 CFR 279.

The compliance benefits listed here are only meant to be used as general guidelines and are not meant to be strictly interpreted. Actual compliance benefits will vary depending on the factors involved, e.g., the amount of workload involved.


Materials Compatibility: Material compatibility concerns exist with non-petroleum-based POLs, solvents, fuels (some), and non-POLs such as antifreeze. For example, the following materials normally should not be mixed with used oils:
  • Non-petroleum based hydraulic fluids
  • Solvents
  • Parts cleaners
  • Gasoline (MO gas or Motor Gasoline)
  • Antifreeze
  • Methanol
  • Water

Waste diesel fuel and jet fuels JP-4 and JP-8 may be acceptable for mixing depending upon the ultimate use of the used oil. For example, if used oil is destined for energy recovery, waste diesel fuel and jet fuels JP-4 and JP-8 may be acceptable for mixing. For additional information, refer to Pollution Prevention Opportunity Data sheet 6-I-2, On-Site Recycling of Used Oil.

With regard to used refrigerant oil, users should refer to 40 CFR Part 279.10, "Applicability," paragraph (b)(ii), "Rebuttal presumption for used oil". This paragraph states that used oil containing greater than 1,000 ppm total halogens is presumed to be a hazardous waste under the assumption the oil was mixed with halogenated hazardous waste. Users may rebut this presumption by demonstrating the used oil does not contain hazardous waste. If a user can document the used oil was not mixed with chlorinated hazardous wastes (e.g., document the oil is, in fact used refrigerant oil), the oil does not need to be managed as a hazardous waste, as long as the total halogens do not exceed 4,000 ppm and the used oil is recycled. In order to keep accurate records of the source of the oil, the used refrigerant oil should be kept separate from other types of used oils. Most used refrigerant oils do exhibit greater than 1,000 ppm total halogens. However, if the analytical results of the used refrigerant oil indicate it contains less than 1,000 ppm total halogens, the used refrigerant oil can be mixed with other types of used oils destined for energy recovery. If the total halogen level in the oil is variable, the oil must be analyzed each time it is removed from a refrigeration unit before mixing it with other types of oil. Keeping the used refrigerant oil separate from other types of used oil will ensure compliance with the regulations and preclude the rebuttable presumption requirements. Related topics and additional information are available in data sheets 6-I-2 and 6-I-5.


Safety and Health: Safety and health concerns regarding waste oils are minimal. However, safety precautions should be exercised when handling synthetic aircraft oils containing tricresyl phosphate, which is toxic by ingestion and skin adsorption. Care should also be taken when working with hot oils or managing oils/mixtures that exhibit the hazardous characteristic of ignitability.

Consult your local industrial health specialist, your local health and safety personnel, and the appropriate MSDS prior to implementing this technology.


Benefits: Proper used oil segregation and storage helps:
  • Ensure the marketability of used oil.
  • Ensure compliance with applicable regulations.
  • Generators avoid the high cost of disposing of oil as hazardous waste.


Disadvantages: None.


Economic Analysis: The economic advantage of segregating used oil is based on the payback associated with the recycling. Economics are usually favorable for off-site recycling of used oil. Specific economic analysis should be performed on a case-by-case basis since handling charges/reimbursements differ among used oil transporters, processors, and marketers. However, in general, cost savings should be realized due to the reduction of hazardous and/or non-hazardous waste disposal fees and future liability. Recyclers of used oil may be found in the Yellow Pages listed under Oils-Waste.

Based on communication with hydraulic fluid recyclers, the cost for off-site recycling of petroleum-based hydraulic fluid ranges from a reimbursement of $0.37 per gallon to a cost of $0.15 to $0.68 per gallon. These prices vary due to the quantity of hydraulic fluid generated at a site (the greater the oil, the lower the price per unit recycled).

Assumptions:

  • 400 gallons of waste hydraulic fluid a month is generated (200 gallons hazardous waste, 200 gallons non-hazardous waste).
  • Used hydraulic fluid is subject to the Used Oil regulations in 40 CFR 279.
  • 25 hours annual labor for storage, paperwork, and arranging delivery for recycling hydraulic fluid.
  • 40 hours annual labor for storage, paperwork (manifest) and arranging delivery for disposal as a hazardous waste.
  • Hazardous waste is disposed through DRMO at a cost of $0.84/gallon.
  • Labor rate: $30/hr.
  • Used hydraulic fluid is recycled using a contractor for $0.42/gallon.
  • According to the Dallas Air Force Regional Environmental Office, a non-hazardous waste disposal cost would in all probability not be significantly different than the cost for hazardous waste disposal.

Table 1. Annual Cost Comparison for Recycling or Disposal of Used Hydraulic Fluid

 

Recycling

Disposal

Capital and Installation Costs

$0

$0

Operational Costs:

   

Labor

$750

$1,200

Hazardous Waste Disposal

$0

$2,016

Non-Hazardous Waste Disposal

$0

$2,016

Recycling

$2,016

$0

Transportation

$0

$0

Total Operational Costs

$2,766

$5,232

Total Income:

$0

$0

Annual Benefit:

- $2,766

-$5,232

Economic Analysis Summary:

  • Annual Savings for Recycling: $2,466
  • Capital Cost for Diversion Equipment/Process: $0
  • Payback Period for Investment in Equipment/Process: Immediate

Click Here to view an Active Spreadsheet for this Economic Analysis and Enter Your Own Values. To return from the Active Spreadsheet, click the Back arrow in the Tool Bar.


NSN/MSDS:
Product NSN Unit Size Cost MSDS*
Waste Oil Storage Tk. 5430-01-384-8091 500 liter $3,375.61  
Waste Oil Storage Tk. 5430-01-384-8108 1000 liter $3,758.11  
Waste Oil Storage Tk. 5430-01-384-8132 1500 liter $4,083.21  
Waste Oil Storage Tk. 5430-01-384-8192 2500 liter $5,114.06  

*There are multiple MSDSs for most NSNs. The MSDS (if shown above) is only meant to serve as an example. To return from the MSDS, click the Back arrow on the Tool Bar.


Approving Authority: Appropriate authority for making process changes should always be sought and obtained prior to procuring or implementing any of the technologies identified herein.



Points of Contact: For more information

Vendors: This is not meant to be a complete list, as there may be other suppliers of this type of equipment.

National Concrete Products
P.O. Box F
Greenwood, DE   19950
Phone: (302) 349-5528 
FAX: (302) 349-9435


Related Links: None


Sources: Mr. Ronald Jahns, Air Force Regional Environmental Office, Dallas, December 1999.
Mr. Dale Fox, Air Force Regional Environmental Office, San Francisco, November 1999.
Mr Michael Viggiano, Naval Facilities Engineering Service Center, January 1999.
Mr. Dell Fox, Air Force Regional Environmental Office, San Francisco, January 1999.
58 Federal Register (FR) 26425, "Final Rule; Technical Amendments and Corrections," Environmental Protection Agency (EPA) Standards for Managing Used Oil, US EPA, 3 May 1993, including the clarification of issues discussed in the preamble.
Title 40 Code of Federal Regulations Part 279, "EPA Standards for Managing Used Oil," US EPA, 10 Sept. 1992, amended at 58 FR 26425, 3 May 1993 and 58 FR 33342, 17 June 1993.
Guide to Used Oil Regulations, Thompson Publishing Group, 1992.
Air Force Occupational Safety and Health Standard (AFOSH) Standard 127-43, "Flammable and Combustible Liquids," 21 September 1980.
National Fire Protection Code (NFPA) 30, "Flammable Liquids Code," [PF 0425]
Technical Order (T.O.) 42B-1-23, "Management of Recoverable and Waste Liquid Petroleum Products."