Refining of waste oils allows the materials to be reused in similar applications to those for which they were originally produced (e.g. reused as motor oil). As such, refining of waste oil represents a higher level of recycling than methods to recover the energy value of the waste petroleum. Currently, the EPA has identified four facilities that solely refine used oil.

Under this method, the waste oil generator contracts with an oil refiner or intermediate broker for disposal of waste oil. The broker/refiner will not normally accept less than full tanker truckloads of waste petroleum, oils, and lubricants (POL); therefore, on-site storage and accumulation will be necessary until sufficient quantities are generated. One advantage to this method is that all POLs can normally be combined into a single tank, including engine oils, hydraulic fluids, gear lubricants, transmission oil. According to the Dallas Air Force Regional Environmental Office, prior to entering into a contract for re-refining of used oil, generators should review available records maintained by the appropriate regulatory agency pertaining to the compliance history of the used oil processor/re-refiner. In addition, regulatory guidance regarding proper labeling and storage requirements should be considered. Used oil may only be stored in tanks, containers, or units subject to regulation under 40 CFR 264 and 265. Also, containers must be in good condition, not leaking, and labeled with the words "Used Oil." 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."

Recycling of used oil (i.e., off-site refining) 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 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 amount of regulatory burden (e.g. recordkeeping, reporting, inspections, transportation, accumulation time, emergency prevention and preparedness, emergency response) they are required to comply with under RCRA, 40 CFR 262. Off-site refining also helps facilities meet the requirements of waste reduction under RCRA, 40 CFR 262, Appendix. Off-site refining of used oil generally requires a facility to store large quantities of used oil on site. A Spill, Prevention, Control and Countermeasure Plan is required to be developed and implemented under 40 CFR 112 for facilities that store certain amounts of oil on site.

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.

Care must be taken when handling hot waste oils. Proper personal protective equipment is recommended. Special safety precautions should be exercised when handling synthetic oils containing tricresyl phosphate, which is toxic by ingestion and skin absorption. Consult your local industrial health specialist, local health and safety personnel, and the appropriate product Material Safety Data Sheet (MSDS) for specific safe handling procedures concerning waste oil materials.

• Refining of used oil is a more environmentally acceptable alternative than most other options
• Reduces the volume of hazardous and/or non-hazardous waste requiring disposal

• Used oil stored on-site is subject to the regulatory requirements contained in 40 CFR 279.22. These requirements include release response actions and clean-up steps in the event of a release.

Safety Kleen reports that they will accept truck load quantities of waste oil charging $0.11 to $0.15 per gallon at the generator's site. The Defense Reutilization and Marketing Office at Imperial Beach, CA will dispose of used oil at a cost of $0.84 per gallon.

Assumptions:

• 200 gallons of waste oil a month is generated
• Used oil is subject to the Used Oil regulations in 40 CFR
• 25 hours annual labor for storage, paperwork, and arranging delivery for refining used oil
• 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 oil is refined using Safety Kleen for $0.13/gallon

Annual Cost Comparison for Refining or Disposal of Used Oil.

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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.