June/July 1997 June/July 1997by Usman Valiante
Across Ontario, in garages, automotive repair facilities, industrial locations and greenhouses, burning used motor oil for space heating is a growing practice. In the winter of 1996 about 10-million litres of used oil was burned in Ontario at over 600 locations. At the current rate of 155 Certificates of Approval a year by the Ontario Ministry of Environment and Energy (MOEE), the winter of 1997 will see an additional 2.5-million litres of used oil sent up in smoke in communities across Ontario.
Used oil space heaters are essentially regular oil heaters that are slightly modified to burn less volatile and more viscous motor oils. Though modified, these heaters operate without pollution controls. As a result, metal emissions, greenhouse gases and precursor emissions to smog and acid rain are discharged from these units uncontrolled. Unfortunately, this frequently occurs in densely populated urban neighborhoods.
Air emissions associated with burning used oil result from the chemical constituents in the oil itself. After hundreds of hours of engine operation, a portion of the additives in motor oil break down. Additives include both inorganic and organic compounds of chlorine, sulfur, phosphorus, bromine, nitrogen, and metals such as zinc, magnesium, barium, and lead as well as aromatic organics such as napthalenes and phenols. In addition, both combustion by-products, and metals from engine wear and tear contaminate the oil, thereby reducing its effectiveness as a coolant, lubricant and compression sealant. It is interesting to note that pollution control devices installed on many modern internal combustion engines operate by concentrating by-products of engine operation directly in the crankcase oil. Once drained from the engine, these concentrated pollutants can be easily removed from the used oil through the various stages of dehydration, fuel stripping, lubricating oil separation and hydro-finishing--commonly referred to as oil re-refining. However, when burned in space heaters, contaminants in the used oil are discharged (in various forms) into the atmosphere rendering millions of dollars worth of automotive pollution control equipment redundant.
To quantify and contrast the emissions of typical "in-compliance" used oil heater in Ontario with furnaces burning a "clean" fuel such as natural gas, a comparative emissions model was prepared on behalf of Safety-Kleen Canada Inc. The emissions associated with one winter's operation of 413 used oil heaters in the Southern Ontario Corridor and the equivalent heat output in natural gas is provided in Table 1.
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| |||||
| 413 typical new, atomizing type, used oil fired space heaters | 413 typical natural gas fired space heaters
(< 300,000 Btu) |
Number of times the emissions: used oil vs. natural gas | Avoided emissions: using natural gas instead of used oil | ||
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| |||||
| Emissions in grams /1000 hr of use (approximately 1 winter of operation) | |||||
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| SOx/SO2 | 2.3 x 107 | 2.9 x 104 | 795 | 23.4 | tonnes |
| NOx | 6 x 106 | 4.6 x 106 | 1.3 | 1.4 | tonnes |
| CO | 7.9 x 105 | 2.0 x 106 | 0.4 | -1.2 | tonnes |
| PM | 1.6 x 107 | 5.5 x 105 | 30 | 15.9 | tonnes |
| CO2 | 8.2 x 109 | 5.9 x 109 | 1.4 | 2,349.4 | tonnes |
| VOC | 3.7 x 105 | 5.4 x 105 | 0.7 | -165.5 | kg |
| Arsenic | 541.0 | 11.3 | 48 | 0.5 | kg |
| Chromium | 7.1 x 103 | 54.0 | 132 | 7.1 | kg |
| Cobalt | 122.9 | 5.9 | 21 | 0.1 | kg |
| Lead | 6.2 x 104 | 13.3 | 4,628 | 61.6 | kg |
| Manganese | 1.4 x 105 | 18.7 | 7,439 | 139.2 | kg |
| Nickel | 2.2 x 103 | 177.3 | 12 | 2.0 | kg |
| Zinc | 2.2 x 106 | 46.7 | 46,659 | 2.2 | tonnes |
In addition to emissions associated with pollution from uncontrolled combustion, used oil heaters burn an infinitely reusable commodity that is high in value-added chemical and energy content. Used motor oil does not wear out and re-refining effectively removes contaminants, yielding lubricating oil equivalent in quality to oil refined from crude oil. Re-refining and reuse of used oil realizes significant life-cycle reductions in materials intensity, energy use, and air and water emissions. In the Southern Ontario corridor alone, re-refining yields an emissions offset of an estimated 128,000 tonnes CO2 equivalent.
A major portion of the energy and emissions reductions result from the elimination of the crude oil exploration and extraction phase of the oil life-cycle. While collection of used oil from generators does require energy, it is estimated that overall, re-refining lubricating oil from used oil consumes two-thirds less energy than refining from crude oil. Though refining crude oil and re-refining used oil both generate petroleum by-products (fuels, asphalt extenders etc.), re-refining is inherently less materials intensive--to refine a litre of lubricating oil requires an average of 67 litres of crude oil versus an average of only 1.6 litres of used oil.
Disincentives
The practice of burning used oil has increased dramatically since 1992, the year in which the waste derived fuel regulation (Regulation 347 General Waste Management - Waste Derived Fuel Sites) was amended. One of the objectives of the amendment was to ensure that northern generators without access to used oil collection were given an option for managing their used oil. Inadvertently, the amendment opened up the use of used oil heaters to all of Ontario and as a result, there are now about 413 used oil heater sites (some with more than one used oil heater) in the Southern Ontario corridor--an area bounded in the north by a line extending from Grand Bend in the west to Arnprior in the east.
The practice of burning used oil for space heat is driven by cost--burning of used oil allows used oil generators to avoid the cost of used oil collection and the cost of purchasing clean fuels. As with many resource allocation issues, the false economy of burning used oil results from several market aberrations.
Lubricating oil is the most valuable fraction of a barrel of crude oil and retains its value even after use. However, to a used oil generator, used oil is nothing more than a costly waste. With the prospect of free disposal and reduced heating costs, burning used oil is very attractive to the used oil generator even though it squanders the true value of the oil. One solution is to provide generators with an economic incentive to seek used oil collection. Economic instruments such as deposits put a value on used oil and thereby provide used oil generators with an incentive to channel their used oil for proper management.
Each time used oil is collected and re-refined it is taxed. Ideally, measures that reduce the consumption of non-renewable resources, reduce environmental impact, and drive value-added economic activity should be encouraged, not taxed. Eliminating taxes on the collection of used oil and sale of re-refined oil would create further economic incentives for generators to have their oil recovered and would also help in changing patterns of consumption from virgin to re-refined oil.
While emissions associated with burning of used oil can either be directly measured or estimated, the impacts of those emissions are difficult to quantify in terms of cost. Though much work has been done to attach a "cost" to environmental discharges, it remains difficult to achieve consensus on these costs and public policy makers are often left addressing what is subjectively "acceptable" and what is not.
Remedies
While it is difficult to modify the current sales tax regime, it is possible to address the value generators place on used oil and their willingness to seek oil recovery and re-refining as a environmentally preferable management practice. Private sector and public policy directions in encouraging oil recovery and re-refining include:
Voluntary producer responsibility through used oil stewardship and recovery programs that include the use of measures such as: deposits on motor oil, used oil recovery rebates, consumer user fees to cover the cost of used oil collection (these user fees are already charged by many garages), and expanded used oil recovery services in Northern Ontario.
Establishing a preferred hierarchy for used oil management. Proper management may be defined by this hierarchy: re-refining (which encompasses reuse and recycling) as the preferred environmental option, burning in a pollution controlled technology (e.g. in a cement kiln) for heat recovery as a secondary option, and pollution uncontrolled burning for space heat as a "method-of-last-resort" to be used only in situations where recovery of used-oil for proper management is either unavailable or prohibitively expensive (as in the far North). Provincially promulgated as a backdrop regulation and guidelines, this hierarchy could provide a framework for municipalities to control the burning of used oil (as discussed below).
Creating provisions for municipal operating licenses and fees for used oil heaters. Currently municipalities cannot license or ban used oil furnaces because an existing provincial regulation (Regulation 347) already addresses the issue of waste derived fuel. Amending Regulation 347 could allow municipalities to determine whether proposed or existing used oil furnaces meet the conditions of the provincial backdrop regulation and the specific concerns of the municipality. Municipal control of used oil burning would, in effect, create a flexible, geographically specific regulation which addresses the concerns of used oil generators in Ontario's far North.
Creating provisions for the sun-setting of existing Certifications of Approval for used oil heaters based on the availability and economic accessibility of preferred used oil management options.
Current policy directions
Recently, the MOEE responded to requests from used oil generators to streamline the approvals process and reduce compliance costs with Regulation 347 (estimated to be between $150 and $500 a year per site) by referring the issue of used oil burning to the Ministry of Consumer and Commercial Relations' (MCCR) Fuel Safety Branch. In turn, MCCR has directed the Canadian Standards Association (CSA) to undertake a process by which the operation and performance of used oil furnaces is to be "standardized." Since used oil heaters are manufactured without pollution controls, and the high cost of pollution control equipment eliminates the cost advantages of used oil heaters, it is not clear what aspects of furnace performance the CSA's standardization process will address.
As a preferred environmental strategy, used oil collectors and re-refiners must make used oil management convenient, accessible, and cost-effective. In partnership with business, public policy must support generators, collectors, and re-refiners in their efforts to take responsibility for used oil. Working in harmony with other MOEE initiatives (such as the proposed Smog Plan), an equitable used oil policy will reduce subsidies from the environment and will protect the health of communities in which used oil is generated.
Usman Valiante is a consultant with General Science Works in Toronto, Ontario.
© Southam Inc., 1999. All rights reserved.