DSHW-2024-008886

Standards for Used Oil Generators (R315-15-2)
David Wheeler, Environmental Scientist
[phone]
[e-mail]
What is a used oil generator?
Official Definition: A used oil generator is any person, by site,
whose act or process produces used oil or whose act first causes used
oil to become subject to regulation.
Simplified Translation: Someone who creates used oil.
Clarification (Limited Exceptions):

1. Household "do-it-yourselfers"
-and-
2.Small farmers (generate an average of 25 gallons per month or less
of used oil from vehicles or machinery used on the farm in a calendar
year)
are ONLY subject to the prohibitions of R315-15-1.3 and cleanup
requirements of R315-15-9.
Common examples of used oil
generators
Vehicle mechanic and oil lube shops
Farms with lots of farm machinery
Fleet maintenance shops
Machining/metal cutting facilities
Used metalworking fluids and oils are used oil
Places that drain electrical equipment like transformers
Automotive scrap yards
Mixing used oil with
hazardous waste
With limited exceptions, mixing used oil with hazardous waste produces a
mixture of hazardous waste. This is discussed in R315-15-1.1(b) of the rules.
$ $ $ This usually increases the cost of disposal, often dramatically. $ $ $
(The oil goes from being a recyclable commodity to a waste which must be
properly disposed).
Don’t mix used oil with hazardous waste, antifreeze, water, etc.
It tends to make it more expensive to recycle/dispose
The rebuttable presumption for used oil
Historically, used oil has often been mixed with a particular type
of hazardous waste: chlorinated solvents.
So EPA makes the presumption that any used oil tested to have a
total halogen concentration of 1000 parts per million (ppm) has
been mixed with chlorinated solvents (hazardous waste). That
makes that mixture of oil and solvent hazardous waste.
Science Fact: chlorine is a type of chemical (element) called a halogen
The rebuttable presumption for used oil
(cont.)
BUT, the EPA also recognized that sometimes chlorine and other
halogens can get into the used oil in other ways than mixing with
chlorinated solvents.
Therefore, they allow the generator to present evidence to rebut
the presumption of hazardous waste mixing. If the generator can
prove that there is an “innocent” explanation for those halogens in
the used oil, that oil mixture will go back to being regulated as
used oil (NOT Hazardous Waste).
An example of a successful rebuttal of the presumption of
hazardous waste mixing – salt production machinery used oil.
Note that the generator
must get approval from the
Division that they agree with
the rebual claim. Such
claims are often proven with
laboratory analysis to see if
there are chlorinated
solvents in the used oil.
(Remember that non-
hazardous waste used oil
containing over 4000 ppm
halogens is regulated as
o-specification used oil.)Salt contains mineral chlorine which is not
regulated as a hazardous waste.
Used Oil Storage:
SPCC
Used oil storage is subject to all applicable Spill Prevention, Control and
Countermeasures (SPCC) rules, 40 CFR 112, in addition to the requirements of
the generator rules (R315-15-2). SPCC is a federally-administered program.
Used Oil Storage:
R315-15-2.3(a) through(c)
Generators must also comply with the following used oil storage regulations.
In general, used oil must be stored in containers and tanks (units) that are:
1.Proper type.
2.Good condition.
3.Kept closed.
4.Managed to prevent releases.
5.Labeled with the words "Used Oil".
1.Proper type. Used oil generators shall not store used oil in units other than
tanks, containers, or units subject to regulation under R315-264 and R315-265.
NOT proper used oil storage containers.
NOT proper used oil storage container.
2.Good condition. Those units must be in good condition (not severely rusting,
deteriorating, etc.) and not leaking.
NOT in good condition.
Not leaking.
Leak from a pipe seal near boom
of a very large tank. Concerning.
Used oil leaking from a pump and hoses.
3.Kept closed. Tanks and containers for storage of used oil must be closed
during storage except when adding or removing used oil. (i.e. Loading ports should
be capped, draining racks/funnels should have either caps or valves, drums should be
lidded with closed bung holes)
NOT properly closed.
Open drain rack with no means of closing the opening (even when not draining).
NOT properly closed.Properly closed.
Properly closed drain rack with a lid.
4.Managed to prevent releases. Tanks and containers shall be managed to
prevent releases of used oil to the environment.
Overfilled (and likely improperly closed) drums stored outside in weather.
Precariously stacked (teetering on the edge of a bank overlooking a pond!).
Spills on the ground.
Spills on the ground, etc, etc.
5.Labeled with the words “Used Oil.” Containers and aboveground tanks used to store
used oil at generator facilities shall be labeled or marked clearly with the words "Used Oil". Fill pipes
used to transfer used oil into underground storage tanks at generator facilities shall be labeled or
marked clearly with the words "Used Oil."
It doesn’t have to be fancy...
Response to releases
R315-15-2.3(d)
Upon detection of a release
of used oil to the
environment, the generator
shall comply with
Emergency Controls
section of the Rules
(R315-15-9).
[We’ll go over those rules
in detail in the next
presentation.]
What can generators do with
their used oil?
1.Heat their facility under the on-site burning provisions of R315-15-2.4.
2.Arrange for a permitted transporter to pick it up.
3.Self-transport it under the provisions of R315-15-2.5(a) or (b).
(= Self-transportation of small amounts to approved collection centers or
aggregation points owned by the generator.)
Remember! A generator may not sell or give away their used oil to
another generator for burning unless that oil has been certified to be
on-specification by a Utah-registered used oil marketer.
On-site burning
R315-15-2.4
On-site burners shall comply with R315-15-6 and, if
applicable, shall obtain an Air Quality permit.
On-site burning (cont.)
Generators may burn used oil in used oil-fired space heaters without a used
oil permit provided that:
(1) The heater burns only used oil that the owner or operator generates;
(2) The heater is designed to have a maximum capacity of not more than
a half million Btu per hour;
(3) The combustion gases from the heater are vented to the outside
ambient air;
(4) The generator has knowledge that the used oil has not been mixed
with hazardous waste; and
(5) The used oil is being legitimately burned to utilize its energy
content.
NO! Yes
Remember, used oil is defined very broadly.
For an excellent table with examples of what is and is not used oil, visit
the EPA website called “What is Used Oil?” at:
https://www.epa.gov/hw/reference-table-question-what-used-oil
Questions?