ON-SITE RECYCLING OF USED OIL

Revision Date: 12/00
Process Code: Navy/Marines: ID-25-99; Air Force: HW01; Army: N/A
Usage: Navy:Medium; Marines:Medium; Army:Medium; Air Force:Low
Compliance Impact: Medium
Alternative for: Off-Site Disposal/Off-Site Recycling
Applicable EPCRA Targeted Constituents: N/A


Overview:

It is possible to recycle used lubricating oils generated from fluid changeouts of internal combustion engines in tactical service (MIL-L-2104) and in administrative service (MIL-L-46152), steam turbine and gear oil (MIL-L-17331), marine diesel service (MIL-L-9000), petroleum-based 90W and 140W gear lube oil (MIL-L-2105), and vacuum and compressor oils.

On-site recycling options for used lubricating oil are typically limited to energy recovery such as diesel fuel supplementation and burning as a boiler fuel supplement. Based upon a study performed at Red River Army Depot in 1993, oil could not be successfully reconditioned on site for reuse due to heavy metal contamination. In addition, re-additizing of treated oils by on-site processors is generally not recommended.

Diesel Fuel Supplementation
The criteria that must be used in electing on-site recycling options involves the volume of used lubricating oil generated annually. Diesel fuel on-site use includes the volume of diesel fuel used (40,000 gal/yr is required to burn 2,000 gallons of used diesel lubricating oil at a 5 percent mixture ratio), volume of diesel lubricating oil generated, diesel engine warranty, and activity policy.

Boiler Fuel
Used lubricating oils from internal combustion engines, steam turbine and gear oil, petroleum-based gear lube oil, and mechanical pump oils can be dewatered and filtered for use as a supplement to No. 6 burner fuel or used to fuel dedicated waste oil burners. To burn these used oils in a boiler, may require a permit from the state that defines the source of the fuel. The boiler must be of a special design to burn used oil and must meet federal containment limits. Technically, the Navy can burn used lubricating oil, but in practice it is not done.

Burning used lube oil as a supplement to No. 6 fuel oil will increase boiler maintenance costs. Although burning used oil as a burner fuel supplement is cost-effective, if the blend of No. 6 oil with used lube oil exceeds 50 percent, the maintenance costs will increase.

When considering burning used oil in boilers at military installations, users should coordinate with the installation Civil Engineer, Public Works officer or equivalent authority. Acceptable oil types (e.g. synthetic, petroleum-based, etc.) air emission concerns, and regulatory permit requirements should be determined. Also, users should consider the regulatory requirements of Title 40 Code of Federal Regulations (CFR) Part 279, Subpart G, "Standards for Used Oil Burners Who Burn Off-Specification Used Oil for Energy Recovery". These requirements impose restrictions on burning and specify procedures for notification, rebuttable presumption, storage, tracking, and notices.

Vendors, such as Black Gold, manufacture dedicated waste oil burners that are designed to burn high carbon content waste crankcase oils, lubricating oils, automatic transmission fluids, and No. 2 heating oils. Black Gold offers turnkey systems that include everything but the fuel.


Compliance Benefit:

Recycling of used oil may allow the used oil to fall under the less stringent regulations of 40 CFR 279 as opposed to the hazardous waste regulations in 40 CFR 260 through 268. In addition, under 40 CFR 261.5 generators who recycle their used oil and manage it under 40 CFR 279 do not have to count the used oil in their monthly totals of hazardous waste generated. The decrease in the quantity of hazardous waste generated monthly may help a facility reduce their generator status and lessen the degree of regulatory requirements (i.e., recordkeeping, reporting, inspections, transportation, accumulation time, emergency prevention and preparedness, emergency response) applicable with under RCRA, 40 CFR 262. Recycling also helps facilities meet the requirements of waste reduction under RCRA, 40 CFR 262, Appendix. Recycling used oil on site generally requires a facility to store large quantities of used oil. Development and implementation of a Spill, Prevention, Control and Countermeasure Plan is required under 40 CFR 112 for facilities that store certain amounts of oil on site. In addition, the burning of used oil on site may require an air permit.

The compliance benefits listed here are only meant to be used as a general guideline 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:

The six types of lubricating oil listed (L-2104, L-17331, L-46152, L-9000, and L-2105) can and should be combined for efficiency and economy of collection. Do not mix or blend low-flash hydrocarbons with used lubricating oil. It is permissible to collect hydraulic oils (H-5605 and H-17672B) with lubricating oils provided neither are being recycled for their original use, and provided they are not contaminated with halogens.

These oils should be accumulated by the generator in clean, well-labeled, and color-coded drums. (Drums should be labeled with the words "Used Oil.") When the drum is full, the generator should complete a standard 1348-1 manifest form and request Public Works or another appropriate activity to transfer the drum to the central storage facility.

When storing used lubricating and gear oils for on-site energy recovery, users should consider the requirements of 40 CFR 279.22, "Used oil storage," which include storing used oil only in tanks, containers, or units subject to regulation under 40 CFR 264 or 265. Storage should be achieved in clean 55-gallon labeled drums, bowsers, buffaloes, above-ground tanks, or railroad tank cars. If drums are used, they should be covered so that water does not collect on top of the drum and possibly contaminate the contents. Storage containers should be placed in an area that is bermed or diked to contain spills and prevent them from reaching groundwater.


Safety and Health:

Care should be taken when handling lubricating oils. Proper personal protective equipment is recommended. Safety precautions should be exercised when handling synthetic aircraft oils containing tricresyl phosphate, which is toxic by ingestion and skin adsorption. Consult your local health and safety personnel for specific precautions.


Benefits:

Potential benefits of on-site energy recovery of used oil are as follows:

  • Reduced waste oil disposal
  • Reduced diesel fuel and fuel oil purchases


Disadvantages:
  • Activities that are not users of diesel fuel or No. 6 burner fuel may not realize an economic benefit


Economic Analysis:

Diesel Fuel Supplement
Racor Industries, Inc., Modesto, California, provides a unit designed specifically for processing used lube oil for use as a diesel fuel supplement. If permanently installed, it is generally used in conjunction with a fuel reservoir or tank. It automatically blends used crankcase oil with diesel fuel. It also filters, recycles, and transfers diesel fuel and has its own waste oil holding tank and oil injection system.

The basic equipment costs of recycling used lubricating oil as a diesel fuel supplement are $8,500 to $10,000, and the total capital investment ranges from $57,000 to $80,000. These costs assume that a storage tank for the diesel fuel exists. The total capital investment includes installation materials and labor, training, and start-up materials costs. Payback period of these initial investment costs can be achieved in less than the estimated 10-year life of the equipment.

A brief summary of the costs of recycling used lube oil as a diesel fuel supplement follows:

Annual volume of used lube oil, gal:

2,000

Annual volume of diesel fuel required to meet the 1:20 dilution factor, gal:

40,000

Estimated value of diesel fuel per gallon:

$1.00

Standard or basic equipment costs:

$8,500

Total capital investment costs:

$57,000

Savings Investment Ratio (SIR):

1.543

Net Uniform Annual Savings (NUAS):

$5,022

Investment payback period, years:

5.3

Waste Oil Burners
Material and installation costs for a 200,000 BTU/Hr. (1.4 gallons per hour of waste fuel) waste oil burner is estimated to be $9,500. The waste oil burner will require a 2,000-gallon, above-ground tank to store the waste oil, at an estimated cost of $8,000. Total installed cost allowing for training and SPCC preparation (update) is estimated to be $18,700. Assuming a status quo disposal cost of $0.75 per gallon for oil, the payback period is approximately 3.5 year.

A brief summary of the costs of recycling used lube oil as a diesel fuel supplement follows:

Volume of used lube oil to be consumed (6,050 gallons in 6 months at 24 hours/day):

1.4 gal/hr

Waste oil furnace and vent installed:

$9,500

2,000 gallon storage tank installed:

$8,000

Training and SPCC preparation:

$1,200

Energy value of waste oil (per year) (7,600 Therms/year):

$3,200

Waste oil disposal cost (status quo):

$0.75/gal

Increased labor for waste oil handling:

$975/yr

Payback period:

3.5 years

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Approving Authority:

Approval is controlled locally and should be implemented only after engineering approval has been granted. Major claimant approval is not required.

Air Force approval is controlled locally and should be implemented only after coordination with the installation environmental function. The installation environmental management activities should ensure local, state and Federal regulation are followed.


NSN/MSDS:
Product NSN Unit Size Cost MSDS*
None Identified $  

*There are multiple MSDSs for most NSNs.
The MSDS (if shown above) is only meant to serve as an example.


Points of Contact: Air Force:
Dale Fox
San Francisco REO: HQAFCEE/CCR-S
333 Market Street
Suite 625
San Francisco, CA 94105-2196
Phone: (415) 977-8881

Atlanta REO: HQAFCEE/CCR-A
60 Forsyth Street SW
Suite 8M80
Atlanta, GA 30303-3416
Phone: (404) 562-4205

Mr. Dave Elliott
Small Engine Engineer
San Antonio Air Logistics Center
San Antonio, TX
Phone: (210) 925-6537
DSN: 945-6537

Mr. Gerald Doddington
Headquarters Air Force Civil Engineer Support Agency
DSN: 523-6343


  Navy:
Mr. Peter Fanning
Waste Oil Burners
Naval Facilities Engineering Service Center
1100 23rd Ave.
Code 24
Port Hueneme, CA 93043-4370
Phone: (805) 982-3564


Vendors: RACOR
Parker Hannifin Corporation
RACOR Division
P.O. Box 3208
3400 Finch Road
Modesto,  CA   95353
Phone: (800) 344-3286 

  Black Gold Corp.
Suite 344
240 Great Circle Road
Nashville,  TN   37228
Phone: (615) 251-0680 
or (800) 351-0643
FAX: (615) 251-0682
URL: http://www.blackgoldcorp.com
Service: Waste Oil Burners

  ECONO HEAT, Inc.
5714 East 1st Avenue
Spokane,  WA   99212
Phone: (509) 534-1022 
or (800) 255-1363
Service: Manufacturer of Omni Waste Oil Heaters

Sources:

Mr. Dale Fox, San Francisco REO, November 1999.



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