Offsite recyclers of hydraulic fluids process waste fluid into re-refined usable products. The primary benefits of recycling hydraulic fluids include reduction of the amount of waste disposed at a facility and the possible allowance of this material to be managed under less stringent regulatory requirements. One facility, the Naval Air Station in North Island CA, reported that they recycle 90% of the waste hydraulic fluid generated on-site, leaving only 10% to be disposed as hazardous waste.

In order to implement an off-site recycling program successfully, the program costs must be less than the disposal costs. Numerous companies with varying charges and fees for waste fluid pickup perform Offsite recycling of hydraulic fluids. Some recycling companies may charge to pick up hydraulic fluid while others will remove it free of charge. In addition, some recycling companies may reimburse facilities for their waste hydraulic fluid.

Used oil is defined under 40 CFR 279.1 as "any oil that has been refined from crude oil, or any synthetic oil that has been used and as a result of such use is contaminated by physical and chemical impurities." Under the definition, hydraulic fluid can be managed in the same manner as used oil. Generators who are considering an off-site recycling program for used oil should refer to Title 40 Code of Federal Regulations (CFR) Part 279 "Standards for the Management of Used Oil" for specific regulatory guidance. If the off-site recycling program includes burning used oil for energy recovery, generators should pay particular attention to the provisions of 40 CFR 279.11, "Used Oil Specifications". Used oil to be burned for energy recovery which does not exceed the specifications for arsenic, cadmium, chromium, lead, flash point, and total halogens is not subject to most requirements of 40 CFR Part 279. Table 1 at 40 CFR 279.11 provides the following limits:

• Arsenic: 5 parts per million (ppm) maximum
• Cadmium: 2 ppm maximum
• Chromium: 10 ppm maximum
• Lead: 100 ppm maximum
• Flash Point: 100 degrees Fahrenheit minimum
• Total Halogens: 4,000 ppm maximum

Recycling of used oil may allow the fluid 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 that recycle their used oil and manage it under 40 CFR 279 do not have to count the used oil into 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 their regulatory burden (i.e. recordkeeping, reporting, inspections, transportation, accumulation time, emergency prevention and preparedness, emergency response) under RCRA, 40 CFR 262. Recycling also helps facilities meet the requirements of waste reduction under RCRA, 40 CFR 262, Appendix.

EPA presumes that all used oils are recyclable and, therefore, must be managed in accordance with 40 CFR Part 279. If the used oil is to be disposed on-site or sent off-site for disposal, the generator must then, as with any other solid waste, determine if the used oil exhibits any hazardous characteristic. If the used oil to be disposed is determined to be a characteristically hazardous waste, it then must be managed in accordance with applicable requirements of 40 CFR Parts 260 through 266, 268, 270, and 124. If the used oil to be disposed were determined to be a non-hazardous waste, it then would be managed in accordance with applicable requirements of 40 CFR 257 and 258.

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.

• Reduces the volume of hazardous and/or non-hazardous waste requiring disposal
• Some recyclers of used oil and hydraulic fluids may pay for the material, further reducing disposal costs

• Used oil containing greater than 1,000 ppm total halogens is presumed to be a hazardous waste under the rebuttable presumption provided under 40 CFR 279.10(b)(1)

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.

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). Recyclers of petroleum based hydraulic fluid may be found in the Yellow Pages listed under Oils-Waste.

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
• 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

Annual Cost Comparison for Recycling or Disposal of Used Hydraulic Fluid

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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 regulations are followed.