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Re: Virgin Oil Waste: Used Oil Waste: Followup



Ric and Graham:

I am consolidating a response to the questions posed in your messages,
regarding statistical and environmental  data on used/virgin oils.  Some of the
figures on waste generation rates, etc. are extrapolations.  For example, for the
transportation sector, some state estimates were based on state vehicle
registry data (on the number of vehicles) and the frequency of oil changes. 

Regarding Grahams's question whether the info I provided contains anything
on the fate of virgin oil.  I would say that the info is deficient on the environmental
fate of virgin oil.  However, I have a document that describes the universe of,
and waste generating activities of, crude oil and petroleum product
distribution/processing facilities: "Estimates Of Waste Generation For
Petroleum Crude Oil And Petroleum Crude Oil And Petroleum Products
Distribution And Wholesale Systems" (November 13, 1987); Prepared for: U.S.
Environmental Protection Agency, Office of Solid Waste; 401 M Street, S.W.,
Washington, D.C. 20460, by: Midwest Research Institute (MRI); 425 Volker
Boulevard, Kansas City, MO 64110-2299.  Although dated, this document
provides figures on the quantity of crude/petroleum oil transported, generated,
and processed by facilities/transporters, as well as the types, composition,
sources, and quantities of wastes generated from these sources.

The U.S. EPA has several empirical documents or studies on file attesting to
the hazardous of used oil mismanagement and its adverse consequences in
the environment.  The citings include reports/data on road oiling, adulteration,
improper storage (at used oil processors, rerefiners, underground storage
tanks, etc.), and Superfund cites. The U.S. EPA has determined that many of
the sites on the National Priority List (NPL) involve mismanagement or storage
of used oil ("Summary Descriptions of Sixty-Three "Used Oil" Superfund Sites.
Final Draft, U.S. EPA, May 1992).  I believe details on these cites are in the U.S.
EPA Docket: F-92-UO2F-FFFFF (also see September 10, 1992 Federal
Register, Vol. 57, No., 176).  There also are several reported incidents for
RCRA facilities (see above Docket). 

The U.S. EPA announced a prohibition in using used oil to suppress fugitive
dust (accept for certain conditions) in the September 10, 1992 Final Rule,
based on incident reports and the fear that misuse/application of used oil in
road oiling will result in run-off into, and contamination of ,surface waters.  I think
many of us know about the incident at Times Beach, Missouri in 1982, in which
a contractor unfortunately applied dioxin-contaminated used oil to road
surfaces throughout a wide area, resulting in millions of dollars of damage. The
town is still unoccupied today.

For those of used who are interested, there is a report on using used oil a
space heaters: "Used Oil Analysis and Waste Oil Furnace Emission Study
(EPA-456/R-95-001, April 1995) ; co-sponsored by the Vermont Agency of
Natural Resources and  U.S. EPA (Office of Air Quality Planning and
Standards, Research Triangle Park, N.C. 27711).

The U.S. EPA issued a "Notice of Potential Risk" document February 1984. 
This was primarily intended as a chemical advisory to service station workers
to inform them of the results of a study sponsored by The American Petroleum
Institute (at the Kettering Laboratory, University of Cincinnati), and to
recommend on safe handling practices.   Basically, the study indicated that
laboratory mice exposed to commercial engine lubrication oils under specified
conditions developed skin cancer.  They cautioned that this was just one study
but that the results found in mice could also happen in humans.   The U.S.  EPA,
TSCA Hotline, may also have  toxicity information on used oil.

The U.S. EPA developed the used oil regulations to facilitate the recycling of
used oil.   This is one of the primary reasons why they decided not to list used
oil as hazardous waste.   The requirement to characterize used oil to ensure
that it has not been mixed with hazardous waste, and to determine its
specification (on/off), as a condition for its eligibility to be safely recycle, was
an important provision developed by U.S. EPA  to minimize or discourage
contamination. 

Today, about 70% of the used oil from commercial operations is recycled,
primarily by burning to recovery its energy. There is currently a push to channel
larger portions of used oil into the rerefining sector.  The used oil rerefining
industry went through a period or recession, and many dropped out of the
picture.  With the introduction of new rerefining/processing technologies that
have reduced some of the waste problems that historically plagued the
industry, there appears to be a resurgence in rerefining used oil into lubricating
products.

The management and recycling of used oil from DIYs or households has
historically been a problem.  This is due, in part, to adulteration and the fear by
collectors, handlers, and processors, that they will be held liable for
possessing such tainted oils.   Many states have, or are, developing DIY used
oil collection programs, in cooperation with local government, business, and
private organizations.  Many of the owners/operators of service stations, etc,
that collect DIY oil have disclaimers as a condition to accepting the used oil. 
Many experienced operators can gauge whether the oil they receive has been
contaminated by noting its color, phase separation, smell, etc. 

As far as comprehensive, detailed studies on the fate, distribution, and
partitioning of used/virgin oil in the environment, I suggest contacting academia
( research studies, thesis, dissertations, etc), or perusing the Internet.

I apologize to the P2Tech viewers for taking up their valuable time.

Art Coleman, Ohio EPA
Division of Hazardous Waste Management
P.O. Box 1049
Columbus, Ohio 43216-1049
(614) 644-2968
Fax: (614) 728-1245 or (614) 644-2329
art_coleman@central.epa.ohio.gov