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Re: Virgin Oil Waste: Used Oil Waste: Followup

> Art Coleman wrote:
> 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

Many thanks, Art. This is very valuable from the perspective of my
country (South Africa) where attempts are currently being made to have
used oil management set up on a proper footing. 

Does anyone out there know of any university-based studies that might
throw further light on the environmental fate and impact of discarded
lube oil?

The part about the non-hazardous status of used lube oil in the US that
I find difficult to understand is how that discourages its adulteration.

Do operating or environmental performance guidelines of some sort exist
for the different re-refining techniques that are available? Can anyone
help point me in their direction?

Your help is greatly appreciated.

Graham Noble
261 Brook Street
South Africa
Tel: +27 12 362-0102
Fax: +27 12 362-2607