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Robert Arner, Solid Waste Program Manager
Northern Virginia Planning District Commission
Annandale, VA
INTRODUCTION
Used oil can become a serious problem or a valuable resource depending how it is managed. Simply reflecting on the fact that one oil change contains four quarts which, when improperly disposed of, can ruin one million gallons of fresh water, thus adversely impacting fish and plant life.
Roughly 45 million people who change their own oil, the so called do-it-yourselfers (DIYs), are a major source of improper disposal of used oil. It is estimated that between 193 to 400 million gallons of used oil are released into the environment each year in this manner.
DO-IT-YOURSELF GENERATORS
The most significant types of used oil disposition comes from the very small generator or the so called do-it-yourselfers (DIYs). The DIY is an individual who removes used oil from a motor vehicle, utility engine or farm equipment that he or she owns and operates. There are roughly 45 million Americans—from blue collar workers to affluent car buffs—who change oil from their own vehicles. Often, however, other types of small quantity generators are not included this category, making a precise accounting of this activity difficult. DIYs are, however, the major source of improper disposal of used oil (e.g., pouring or throwing out used oil). It is estimated that between 193 to 400 million gallons of used oil are released into the environment each year in this manner.
A recent National Used Oil Collection study contracted by the American Petroleum Institute 1994 found that 230 million gallons of used oil were collected by both private and public sector from just 204 million gallons in 1993. The majority of the oil collected from DIYers – about 165 million gallons, or 89% – is still burned for energy recovery, and 8% is used in other non-automotive applications (i.e., phosphate mining) and 3% is re-refined into new motor oil.
Consumer market trends also explain why DIY oil is a concern for industry and government. In 1961, service stations accounted for about 70% of all sales of lubricating oil for passenger cars. In the late 1980s, retail outlets commanded this market, with DIYs purchasing roughly 60% of all lubricating oil sold. Many retailers sell oil at a loss to draw customers into their stores to purchase other merchandise. Today, the number of DIYs are decreasing because of the convenience, low cost, and abundance of the quick lube shops. However, proper disposal of DIY used oil is still a concern.
COLLECTION METHODS
Drop-off
Many communities have enacted collection programs where residents drop off used oil for recycling. Some states require retailers to either post signs informing the public where to drop off used oil or require businesses selling used oil to collect DIY-generated used oil. The recent National Used Oil Collection study conducted for the American Petroleum Institute identified 2,927 government operated facilities in 29 states and D.C. collected 18 million gallons used oil in 1994 while 10.5 million gallons were collected in 1993. In 29 states, API counted nearly 8,000 private sector used oil collection locations. Chief Auto found that accepting DIY used oil at its stores increased sales of other automotive purchases.
To increase the number of public and private used oil collection centers, many states have adopted the American Petroleum Institute (API) Model Bill or components of it. This bill establishes a state used oil fund which is designed to provide grant funding for cities and towns that wish to establish used oil drop-off or curbside collection programs. The bill also requires that the state establish a 1-800 number to provide information to residents about used oil recycling. Other requirements include posting signs to inform the public about the 1-800 number and the need for proper collection and recycling of used motor oil. The bill also reimburses any used oil collection center for the cost associated with contaminated used oil resulting when other hazardous fluids are improperly mixed in with used oil. Texas (2 cents a quart) and South Carolina (2 cents a quart) tax retailers that sell oil and divert the funds into a grant program for local DIY programs. Other states such as New York and Massachusetts require service stations that sell oil to accept DIY used oil.
Curbside
Another method of collecting used oil is at the curb. Drop off collection programs for used oil often lack the higher participation rates attained through the convenience of curbside collection programs. In 1993, 116 Oregon communities collected 312,000 gallons of DIY oil at the curb, while drop-off collection accounted for 281,000 gallons (this does not include service station or quick lubes operations). Also in 1993, California collected 700,000 gallons at the curb (collected along with residential rubbish and/or recyclables) through 70 programs serving 3.6 million people. In a 1995, 57 California communities offer curbside collection of used oil in conjunction with their recycling programs. A demonstration program was funded for 18 jurisdictions to provide curbside collection serving about 2.5 million people. These counties report a substantial increase in the amount of used oil collected compared to the amount brought to collection events in a given year. Curbside collection is taken a step further in Mill Valley, California, where residents can call private haulers to request pick-up of their used oil.
In Vermont, the Central Vermont Regional Planning Commission conducted an 11 month pilot program to assess the feasibility of collecting used oil with regular curb trash pick-up. Because of the success of this program, which began in the spring of 1993, the trash removal company continues the current used oil collection service and has expanded the program to include the entire Central Vermont residential customer service base.
The American Petroleum Institute has published an excellent how-to manual, A Guidebook for Implementing Curbside and Drop-off Used Motor Oil Collection Programs (February 1992) which provides useful free information. Write to: American Petroleum Institute, 1220 L Street, NW, Washington, DC, 20005; or call: 202-682-8000.
Recent Market Research
The Valvoline Oil Company recently conducted a study on the DIY market and concluded that the number of DIYs is decreasing. More people are having their oil changed by an automotive service center. In 1988, the DIYs accounted for 68.5% of the market; however, it is projected in 1998 that the percentage of DIYs will fall to 53%. Examining the behavior of people who have a shop change their oil, the so-called installers, also shows a decrease in DIYs. In 1984, installers accounted for only 28% of the market; by 1994, their numbers have increased to nearly 40%. Moreover, the percentage of installers are projected to increase to 45% in 1998.5
Although DIYs may be decreasing, they still play a significant part in used oil impacting the environment because two thirds of used oil is not collected for recycling. `
Overview of State Studies and Programs
Over the past few years, several states have begun to promote a used oil recycling program to reduce the amount of used oil improperly disposed of in the environment. Through these studies, the states have gathered information about their DIYs and their disposal practices.
California
The California Oil Recycling Enhancement Act of 1992 was created in response to the decline of public collection sites and the need to manage a large volume of used oil. As of the end of October 1995 there are 1,494 certified collection centers in California. In the six months from January to June 1995, the Integrated Waste Management Board estimated total oil sales of 109 million gallons of which about 61% was recycled and over 23 million gallons of used oil unaccounted. A multi-million dollar used oil block and opportunity grants program is being administer by the Integrated Waste Management Board, promoting curbside collection, not for profit drop-off sites, and state certified collection centers, as well as local government and statewide education and informational efforts. The program is funded by a (4 cents a quart) fee on lubricating oil. Grants are available to local government as an incentive to recycle. Grants are available to local governments to maintain existing programs (up to $10 million per year) and to set up or expand collection programs (about $ 5 million per year).
DIYs in California reflect the national trend in Valvoline's research. DIYs in California tend to be young and less educated, have lower incomes, and live in
rural areas. However, a 1994 survey revealed that used oil education must also be targeted towards the non English speaking residents—almost 20% of California DIYs speak Spanish as a primary language. In addition, the improper disposal rate of used oil was found to be high among non English speaking people.
Another aspect of convenience—reducing the mess involved with oil changes—is a significant factor: according to the survey, providing spill-proof containers would also increase used oil recycling.
South Carolina
In May 1992, a South Carolina law went into effect that makes it illegal to dispose of used motor oil in municipal landfills. The South Carolina Used Oil Partnership implemented a used oil education campaign to inform the public about the new law. A year later the Institute of Public Affairs at the University of South Carolina conducted a survey to assess the success of the campaign and to understand the behavior of the DIYs.7
Again, this survey's findings were consistent with the Valvoline national study: more people are having their oil changed by a mechanic. Of those surveyed, 62.5% have it installed, while others change their own oil or have a family member do it. Also, more men (36.2%) change their oil than women (15.1%). In addition, those who did not dispose of used motor oil at an approved collection center generally were people under 45 who have a lower education than average, and who have below average family incomes.
The survey results show that the public needs to be better educated about the used oil recycling law. Although more than 60% of those who changed their car's motor oil recycle the oil at an approved collection center, almost one third do not dispose of their oil this way.
Minnesota
Since 1977, Minnesota law has required retailers to post signs indicating nearby locations that will collect used oil. In 1987, Minnesota legislation banned the disposal of used oil in landfills and the ground. However, the system set up to deal with DIY used oil is voluntary. Service stations, auto dealers, petroleum marketers, public works garages and other facilities collect used oil from the public on a voluntary basis. These facilities are not required to perform this service. Currently, Minnesota now has 1,016 private used oil collection sites. However, they are not located statewide; some areas of the state do not have collection sites.
The Minnesota Pollution Control Agency completed a survey of DIY used oil in August 1993. A similar study was done in 1987 by the research firm, Natural Resources Research Institute (NRRI), which is the basis for comparison.
Although the Minnesota survey did not cover all aspects of the Valvoline survey, similar questions revealed the same results. First, Minnesota DIYs are decreasing. Only 45% of the population are DIYs compared to 58% in 1987. Second, the total amount of DIY used oil is decreasing. Currently 775,000 gallons per year of DIY oil is improperly managed as opposed to 4,655,000 gallons per year in 1987.
Again, convenience is an important component of a successful used oil collection program. Unfortunately, some Minnesota counties do not even have one collection center. The counties with greater population counts have more collection centers than the less populated counties. A quarter of DIY respondents feel the location of collection sites is inconvenient. In addition, about 8% of DIYs feel that there are no collection sites near enough for them to use. The survey indicates that most DIYs would prefer to take their used oil to any motor oil retailer and many would like to take used oil to government public works facilities and retailers that voluntarily accept DIY used oil. Curbside collection of used oil is not seen as more convenient to Minnesota's residents. DIYs would prefer to drop off used oil at service and non-service retail businesses and government garages over curbside collection.
Texas
Based upon passenger car motor oil sales, Texas is the second largest generator of used motor oil in the nation. Recognizing the need to encourage the collection and recycling of this used motor oil, Texas passed a law banning the disposal of used oil in a landfill and making it illegal to dump used oil or use it for dust suppression or weed abatement. The law requires registration and reporting of persons involved in the transportation, marketing, or recycling of used oil.
Funded by a two cents per quart fee on the sale of new oil, the bill provides for a grant and public education component enabling local governments to promote used oil recycling by providing collection opportunities to their citizens through state funded programs, such as drop-off centers or curb-side recycling programs.
Additionally, the law encourages appropriate businesses and governmental agencies to serve as public used oil collection centers by providing a limitation of liability for registered collection centers and a reimbursement fund to compensate a registered collection center for cost associated with the proper disposal of used oil contaminated by used by accepted from the public. As of September 1, 1991, more than 1500 businesses and local governments have registered as public used oil collection centers under the state's used oil collection program.
Florida
In 1988, the Florida Petroleum Council provided $2.5 million for a statewide public awareness campaign on used oil disposal. A post-campaign survey showed that billboards proved to be a highly effective tool for reaching the general public, and that school curriculum programs were well received by teachers (in fact, the school materials are still in use).
Pennsylvania
In Pennsylvania, DIYs dispose of 11 million gallons of used oil each year. Of this DIY used oil, 1.5 million gallons are recycled, but the other 9.5 million gallons are dumped in sewers, on the ground or in the trash Pennsylvania has set up used oil collection sites around the state at service stations, garages, and fire stations. Currently, Pennsylvania has 900 used oil collection sites. Pennsylvania has a used oil campaign where participating service stations display a Recycle Oil symbol. In addition, the state also has a Recycling Hotline that will inform citizens of local used oil recycling sites and provide information on used oil recycling.
OIL FILTERS
Not only does a portion of used oil come from oil filters, but oil filter sales are a way of determining the number of oil changes performed. Approximately 400 million oil filters are produced annually in the U.S., which includes original equipment and after market installation in passenger cars, light trucks and heavy duty applications. Approximately 75% of all used oil filters are currently disposed of in landfills. Recycling all oil filters generated in 1994 would result in the recovery of an estimated 161,500 tons of steel and 17.8 million gallons of oil.
Properly disposing of oil filters can be a problem, especially for DIYs. Oil filters are a hidden source of used oil. An undrained oil filter can contain from one half pint (8 oz., e.g., compact car) to a full quart (64 oz., e.g., heavy duty truck) of used oil. A popular selling oil filter (14% of market sales) has a capacity of 23 ounces but after hot draining for 12 hours retains 3.5 ounces of used oil. However, a properly drained oil filter will contain one to eight ounces of residual oil. Realizing that 45% of passenger car filter sales are to DIYs, oil filters contain a significant part of DIY used oil. Unfortunately, many DIY used oil recycling programs do not accommodate filter recycling. Only 1% to 2% of DIY generated oil filters are estimated to be recycled. Many automotive service centers have been slow to recover filters since it may be too expensive and the filter recycling market is underdeveloped.
Oil from oil filters needs to be incorporated into current state used oil programs to decrease the volume of used oil entering the environment. Collection sites that already collect used oil may explore the collection of used oil filters. These sites include public drop-off centers, gasoline service stations, auto service centers, quick lubes, and government facility locations. Interestingly, some localities have curbside collection of oil filters along with their recycling programs such as:
Austin, Texas; Babylon, NY; Chino, CA; and Deer Park, Texas. Recently, Arkansas set up a used oil and oil filter recycling pilot drop off program in several northeast Arkansas counties. Through this program, Nucor-Yamato Steel, located in Blytheville, Arkansas, has agreed to accept the oil filters to manufacture new steel products. The State of South Carolina is also developing a program to recover DIY generated oil filters. The state is providing grant funding to counties to expand their oil collection program to include filters.
Some states have enacted regulation on used oil filter disposal that exceed federal requirements. Both California and Rhode Island consider used oil and used filters a hazardous waste unless recycled, compacted and/or shredded. The states of Texas and Minnesota ban landfill disposal of used oil filters from businesses and DIYs. Several other states impose additional requirements on draining procedures for oil filters, or testing requirements prior to disposal.
CONCLUSIONS
Of the 1.35 billion gallons of used oil Americans generate annually, an estimated 60 percent, or 850 million gallons, are reclaimed. Of this, 90 percent is recovered as a fuel supplement. A small percent is re-refining oil back into a lubricant should be encouraged as much as possible.
Re-refining used oil back into a lubricant needs the support of government procurement to assist this technology in a time where the oil market has been depressed. This industry is quite active in all parts of the world except in the U.S. because of numerous factors, including the low cost we pay for oil. Any "buy recycled" campaign should include the purchasing of re-refined motor oil.
Re-refining—represent the best attempts to return used oil to its original state. The second two technologies—direct burning and reprocessing—transform used oil into an alternative fuel as its end market.
Reprocessing used oil or cleaning used oil to be used as industrial fuel plays a valuable role in marketing this petroleum by-product. Strong management standards are important to ensure that the necessary pollution controls are in place to test, and properly dispose of the waste materials, and to lessen toxic emissions to the air basin.
Burning used oil without reprocessing plays an important role for certain types of generators, primarily those who do not have access to other methods. Like reprocessing, this technology requires strict management standards in disposing of the ash and in ensuring proper emission controls. Also, other hazardous wastes associated with the specific generators' activities should be strictly manifested and accounted for. The burning of hazardous waste in this sector can cause serious health and safety problems.
The draining and recycling of used oil filters is another area which requires public and government support. Every motor vehicle administration in the U.S. could, at a minimum, promote that DIYs drain their oil filter before disposal. This could also be promoted on every oil filter sold.
The opportunities to develop on-site, closed-loop, recycling technologies can not be over-stressed as demonstrated with industrial used oils. Reclaiming oil for re-use on site is a very attractive prospect since transportation costs and the possibility of increased spills are severely curtailed.
There are many used oil technologies that differ in how they reclaim used oil. No matter what technology is used, one important market must be changed. Roughly 20 percent of all the total used oil generated is generated by the DIY oil change market. Of this, nearly 80 percent does not become marketed and is "lost" in the environment. This represents half of all the used oil discarded. Public education is crucial to further create greater incentives and awareness of used oil recycling. Further, private/public cooperative efforts may prevent used oil from being disposed. This offers numerous marketing opportunities to abate a serious environmental problem.
USED OIL REFERENCES
The most important sources consulted during the preparation of this paper are listed below.
Arner, Robert
• "Safe Recycling of Used Oil," Biocycle, September 1995.
• "What Oil Changers in America Are Doing With Their Used Oil," Waste Age, April 1995.
• "Separating the Steel from the Oil," Biocycle, January, 1995.
• "Re-refining in 1994: Converting Used Oil Back into a Lubricant," Biocycle and Lubricants World, June 1994.
• "Curbside Recycling of Used Oil," Resource Recycling, September 1991.
• "State and Local Used Oil Programs," Resource Recycling, May 1989.
• "Used Oil Markets and Best Management Practices in the United States," to the National Recycling Congress on September 15, in Boston, MA.
• "How to Set Up a Local Used Oil Recycling Program" (Co-author), and
assisted in the development of numerous newsletters and brochures on used oil recovery, US EPA 1988.
Managing Used Motor Oil, (625/R-94/010) Environmental Protection Agency, Center for Environmental Research Information, Document Center, 26 West Martin Luther Drive, Cincinnati, OH 45268. (513) 569-7582.
FEDERAL REGISTER NOTICE
Environmental Protection Agency Management System; Identification and Listing of Hazardous Waste; Recycled Used Oil Management Standards; Final Rule, September 10, 1992.
Environmental Protection Agency Management Standards Issued to Control Potential Risks from Recycled Used Oil - No Hazardous Waste Listing, August 13, 1992, EP/530-F-92-018.
Cost and Economic Impact Screening Analysis for the 1991 Used Oil Proposal, Regulatory Analysis Branch, Office of Solid Waste, U.S. Environmental Protection Agency, August 14, 1991.
Environmental Protection Agency Proposed Rule, Hazardous Waste Management System; Identification and Listing of Hazardous Waste; Used Oil; Supplemental Notice of Proposed Rulemaking, 56 Federal Register 48000, September 23, 1991.
OTHER STUDIES
An Innovative Graduate Thesis Evaluates Used Oil End Uses, "The Environmental Challenge of 1990's," Proceeding of the International Conference on Pollution Prevention, USEPA/600/9-90/039, September 1990, p. 643-651).
Market Facts, Inc., Analysis of Potential Used Oil Recovery from Individuals, Office of Industrial Conservation, July 1981.
INDUSTRY STUDIES
The American Petroleum Institute, A Guidebook for Implementing Curbside and Drop-off Used Motor Oil Collection Programs by Washington Citizens for Recycling Foundation (February 1992).
Nolan, J., et al., Used Oil: Disposal Options, Management Practices and Potential Liability, Government Institutes, March 1990.
Also various references from the National Oil Recyclers Association, Ms. Kitty McWilliams, Executive Director, 2266 Bellefield Ave. Cleveland, OH 44106, (216) 791-7316.
METHODS TO RECAPTURE USED OIL
Recommended Guidelines for Used Oil Collection Centers
Operating Procedures:
1. The owner or operator of the collection facility should ensure that all containment devices, including tank pipes and containers used for collection or storage, are inspected (at least once a week, month, etc.). The tank should also be inspected (weekly, monthly) to avoid malfunctions, operation error and/or leaks. You may wish to also accept used oil filters.
2. Each designated collection facility should have the accumulated oil picked up by a registered used oil transporter on a regular basis. A list of registered transporters should be available from your state regulatory officials.
3. Any accumulation of water in the tank should occasionally be drained off and properly disposed of. Inquire with the local environmental regulatory agency about proper disposal.
4. The collection facility operator should inspect the tank gauge and record the oil level daily.
5. The facility should be attended at all times, or provided with after hours security to minimize the possibility of unauthorized access, vandalism, or any unplanned sudden release of used oil into the environment.
6. Each designated facility should post and maintain a durable and legible sign readily visible in an appropriate place which indicates that the facility is a used oil collection facility site and also indicates the hours that the facility will be open.
7. The collection facility should not charge a fee to persons making deposits.
8. All tanks must be locked except during filling and emptying.
9. Road access to the collection area should be convenient. Access should be limited to those times that an attendant is on duty.
10. A record keeping system should be set up and maintained to keep account of the dates, volume of used oil received and transported off site, the transporter's name, and the oil's final destination.
11. Routine cleanup and replacement of absorbent material under the tank should be performed monthly.
12. Trash cans should be available for the disposal of empty containers.
13. A plan containing emergency procedures should be prepared and retained on site which describes the actions facility personnel should take in response to vandalism, theft, fires, explosions or any unplanned release of used oil on the ground which would threaten human health and the environment. The plan must contain the names, addresses and phone numbers of the local police, fire departments and local emergency response teams to coordinate emergency services in a time of need. The plan containing emergency procedures should be located within the office of each of these groups.
14. Finally, you may want to consider periodic testing of the used oil with a chlorine/halogen detection kit for used oil to monitor whether the oil is being contaminated by household hazardous waste. Also check with the used oil transporter who may have some sort of halogen detection device.
(Guidelines adapted from Florida's Department of Environmental Regulations Guidelines for Collection Centers.)
SUGGESTIONS FOR PROMOTING A USED OIL RECYCLING PROGRAM
1. Determine the number of retailers.
2. Determine the number of service stations.
3. Determine the volume of used oil which is generated, collected and recycled by all program participants within the community.
4. Determine the volume of new oil purchased by public agencies in the community, the volume of used oil generated, and the volume recovered. From these figures, estimate the revenues brought into the area through used oil recycling.
5. Send letters to retailers encouraging them to post a point-of-purchase sticker—or sign—urging recycling of used oil.
6. Send letters to service stations or auto repair centers requesting they act as used oil collection centers; find out which stations are full service; include a return postcard and specific date to respond by. Also indicate that all employees should be aware of the program.
7. Develop a list of Used Oil Collection Centers and participating service stations.
8. Ask Used Oil Collection Centers for current volume of oil generated at the station and percent donated by do-it-yourself oil changers; ask them to keep a record of volumes of oil brought in after signing up as a collection center.
9. Develop a system to monitor each Used Oil Collection Center's data; conduct follow-ups after a given period of time to record program successes and failures.
10. Generate a press release announcing the used oil program and the number and location of collection centers; this can be arranged through your local press centers.
11. Conduct a press event featuring a popular individual in the community and use visual aids to attract media attention (e.g., oil change by mayor; baseball mascot featured in event, etc.).
12. Arrange for a week-long public awareness campaign, which can be launched by the press event; arrange for all profits from oil sales to go to local charities; advertise this fact.
13. Seek cooperation between local used oil industry members, service station associations located within the community and local service groups.
14. Distribute television/radio public service announcements to local stations after initial on-site visits with participating managers.
15. Investigate and research the possibility of the curbside collection of used oil. Your local hauler/recycler may be willing to participate if you can provide good background information and show how this has worked in other communities (such as Sunnyvale, California).
DETERMINING THE AMOUNT OF USED OIL COLLECTION CENTERS
The number and capacity of the used oil collection centers in any given area is determined by the population size of the municipality they will serve so that they can efficiently handle the anticipated amount of used oil generated by do-it-yourself oil changers. A suggested minimum number of used oil collection facilities for a given community population is:
l. Zero, if the population is less than 3,500;
2. One, if the population is at least 3,500 but less than 25,000;
3. Two, if the population is at least 25,000 but less than 100,000; and
4. Three, if the population is at least 100,000 plus an additional facility for each additional 100,000 of population.13
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