Recycling Used Oil in New Jersey Sondra Flite Flite, , Sondra Principal Environmental Specialist Principal Environmental Specialist NJ Department of Environmental NJ Department of Environmental Protection Protection www.state.nj.us/dep/dshw www.state.nj.us/dep/dshw 2008 2008
Topics: Topics: Where are the used oil regs regs? ? Where are the used oil What’ ’s a used oil and what isn s a used oil and what isn’ ’t? t? What How about mixtures of oil and HW? How about mixtures of oil and HW? What’ ’s this s this rebuttable rebuttable presumption that I What presumption that I keep hearing about? keep hearing about? What are the used oil specs good for? What are the used oil specs good for? What are my responsibilities as a generator? What are my responsibilities as a generator? Can I burn oil in my shop? Can I burn oil in my shop? Can I move and consolidate my oil? Can I move and consolidate my oil? What are the other categories of handler? What are the other categories of handler? FAQs FAQs
Feel like you’re reading a foreign language? Used oil is regulated at 40 CFR 279 and NJAC 7:26A-6. Generators should read NJAC 7:26A-6.1-6.5. Get a free non-judicial copy from DEP, Or consultant copies, often affordable and conveniently bound, Or the official copy, with case law notes, from Westlaw, at 1-800-808-9378.
Designed to leave oil outside HW program. Unlike UW, UO is not presumed to be HW. It is presumed to be destined for recycling until you dispose of it or ship it to disposal. It doesn’t count toward your HW totals. It may be: Generated during: cutting oil, lube oil changes, hydraulic oil , cleanups, compressor oil. inventory cleanout. New Jersey classifies UO as Class D Recyclable Material; lesser requirements than HW.
It can be unused! It can be unused! USEPA says it’ ’s any oil refined from s any oil refined from USEPA says it crude oil or any synthetic oil that has crude oil or any synthetic oil that has been used and, as a result of such use, been used and, as a result of such use, is comtaminated comtaminated. . is NJDEP adds that it may also be unused NJDEP adds that it may also be unused oil that is contaminated, or that is oil that is contaminated, or that is determined to be a solid waste by the determined to be a solid waste by the generator. generator. That means you can include oil that you That means you can include oil that you simply don’ ’t intend to use. t intend to use. simply don
NJAC 7:26A-6.1 Applicability This tells you what we want to regulate, and what we want to leave out: What’ ’s s in in? ? What Refined, Coal, Shale, Polymers (Synthetics). Refined, Coal, Shale, Polymers (Synthetics). Used oil mixed with CESQG waste. Not best practice! Not best practice! Used oil mixed with CESQG waste. Used oil mixed with products (fuel). Used oil mixed with products (fuel). Any oil you drain off solids. Any oil you drain off solids. The solids themselves, if they contain “ “free flowing free flowing The solids themselves, if they contain oil” oil ” (rags, filters). (rags, filters). Oil that is only a D waste. Oil that is only a D waste.
Drained materials (filters): Solid waste or Drained materials (filters): Solid waste or What’s out? scrap metal. Recycling is best practice. Recycling is best practice. scrap metal. Wastewater w/ minimal oil; see clean water Wastewater w/ minimal oil; see clean water act (and your POTW). act (and your POTW). PCBs oils: see 40 C.F.R. 761.20(e). PCBs oils: see 40 C.F.R. 761.20(e). Anything you dispose of: solid or HW. Anything you dispose of: solid or HW. And these Reclaimed materials (re- -refined oil), refined oil), Reclaimed materials (re products: Re- -refining bottoms used in asphalt, refining bottoms used in asphalt, Re Your diesel crankase crankase oil and diesel fuel Your diesel oil and diesel fuel mixed on site to 5% for your own your own mixed on site to 5% for vehicles. vehicles. All are Product! And… Corn oil! Corn oil! It moves to It moves to recycling as a product. recycling as a product.
Not bad so far, but read on: D Characteristic Oil is a used oil. (Crankcase oil with lead) D Characteristic Oil is a used oil. (Crankcase oil with lead) Oil mixed with a listed waste (261.31, 32, 33, 38) is a HW HW Oil mixed with a listed waste (261.31, 32, 33, 38) is a (for instance, U228). (Solvents) (for instance, U228). (Solvents) But “ “D D” ” oil mixed with “ “D D” ” HW, so that the resultant mix But oil mixed with HW, so that the resultant mix doesn’ ’t exhibit t exhibit any any characteristic, is still used oil. doesn characteristic, is still used oil. Non- -” ”D D” ” code used oil mixed with “ “D D” ” HW so that the so that the Non code used oil mixed with HW resultant mix doesn’ ’t exhibit t exhibit any any characteristic is still used resultant mix doesn characteristic is still used oil. Check with your destination facility! oil. Check with your destination facility! And if if “ “D D” ” code oil is mixed with D001- -only waste, and the only waste, and the And code oil is mixed with D001 resultant mix is not D001 but fails for another another resultant mix is not D001 but fails for characteristic, it it’ ’s still a used oil s still a used oil . . (This allows allows ignitables ignitables characteristic, (This (mineral spirits) back into fuel blending.) (mineral spirits) back into fuel blending.) Used oil mixed with CESQG waste is Used Oil. Check first! Check first! Used oil mixed with CESQG waste is Used Oil. Best practice is not to mix!
The dreaded rebuttable presumption! (To keep you from mixing non-oils into used oil.) Oil with 1,000+ ppm ppm total halogens is presumed presumed to be to be Oil with 1,000+ total halogens is adulterated with a HW solvent. adulterated with a HW solvent. You can rebut this presumption with testing or knowledge of You can rebut this presumption with testing or knowledge of origin (MSDSs MSDSs) (Chlorinated ) (Chlorinated paraffins paraffins, CESQG waste , CESQG waste (not (not origin ( best practice), salt water!) , salt water!) May raise your costs. May raise your costs. best practice) Cutting oil moved by tolling agreements is exempt. Cutting oil moved by tolling agreements is exempt. CFCs reclamation are exempt. Keep separate! CFCs reclamation are exempt. Keep separate!
NJAC 7:26A-6.2 Used Oil Fuel Specification If you can prove your used oil meets Arsenic …… ≤ ≤ 5 5 ppm ppm Arsenic …… Lead ……… ……… ≤ ≤ 100 ppm ppm Lead 100 specs, it may be sold as product, for any Cadmium… ….. .. ≤ ≤ 2 2 ppm ppm Cadmium fuel purpose. But you can’t. Flash point.. ≥ ≥ 100 100° °F F Flash point.. Don’t confuse this with the Rebuttable Chromium… … ≤ ≤ 10 10 ppm ppm Chromium Presumption ! Halogens… … ≤ ≤ 1,000 ppm ppm* * Halogens 1,000 Pretend you never saw it. *USEPA allows *USEPA allows 4000ppm. 4000ppm. 7:26A-6.3 Prohibitions Surface impoundments or waste piles, Surface impoundments or waste piles, Burning off- -spec oil in commercial boilers spec oil in commercial boilers Burning off Burning on- -spec oil in a home/institution/ spec oil in a home/institution/ Burning on unapproved space heater, unapproved space heater, Use for dust suppression. Use for dust suppression. Oil is not asphalt! Oil is not asphalt!
7:26A-6.4 Generators: 6.4(a) Who are they? They are sites sites , not people that: , not people that: They are not not: : They are They are Remove oil, DIYs, , Remove oil, DIYs Ship it to disposal or recycling, Diesel Crankcase Ship it to disposal or recycling, Diesel Crankcase blenders, blenders, Spill it. Spill it. Farmers who generate Farmers who generate <25g/mo. <25g/mo. 6.4(b) What’ ’s not allowed? s not allowed? 6.4(b) What Transporting other people’ ’s oil s oil Transporting other people Disposing Disposing Refining or burning or marketing to others Refining or burning or marketing to others 6.4 (c) Liability 6.4 (c) Liability You’ ’re responsible for contamination in re responsible for contamination in You the oil you ship off site. the oil you ship off site.
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