Off-site heat recovery is the most common disposal method for used oil in the United States. Processors of used oil typically collect automotive and industrial oil, process it to remove water and sediment, and offer the used oil for sale for use as a fuel blender in industrial fuel burners. Some fuel processors may use the blended fuel on site in their own boilers and industrial furnaces.

Off-site heat recovery is facilitated by waste oil processors who collect, process, burn, or offer for sale the processed oil as specification fuel. Processing is a physical/chemical process that may include: 1) blending with virgin petroleum, 2) blending to meet fuel specifications, 3) filtration to remove sediment and/or water, 4) simple distillation to remove water, and 5) physical/chemical separation. The specification fuel is then burned or sold to industrial facilities to be burned for energy recovery.

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." 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 (e.g. off-site heat recovery) 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 in their monthly totals of hazardous waste generated. By decreasing the quantity of hazardous waste generated monthly, facilities can reduce their generator status and correspondingly reduce their regulatory burden (e.g. recordkeeping, reporting, inspections, transportation, accumulation time, emergency prevention and preparedness, emergency response) under RCRA, 40 CFR 262. Off-site heat recovery 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.

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.

• Reduces the volume of hazardous and/or non-hazardous waste requiring disposal
• An abundance of used oil transporters and processors exist
• Some recyclers of used oil 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 heat recovery of waste oil. Specific economic analyses should be performed on a case-by-case basis, since handling charges differ from one oil transporter/processor to another.

The Defense Reutilization and Marketing Service (DRMS) manages the disposal of hazardous property for DOD activities. Hazardous property is handled according to the same priorities as other property: reutilization within DOD, transfer to other federal agencies, donations to qualified state and nonprofit organizations, and sale to the public including recyclers. Hazardous property that cannot be reused or sold is disposed via commercial service contracts that must comply with applicable federal, state and local environmental laws and regulations.

Safety Kleen reports that they will accept truckload quantities of waste oil at a cost of $0.11 to $0.15 per gallon at the generator's site. The Defense Reutilization and Marketing Office at Imperial Beach, CA reports that hazardous waste is disposed of 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/hour
• 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.