Frequent Questions

Would a facility conducting oil/water separation, where the oil would be removed and eventually taken from the site as used oil fuel, be considered a used oil processor?

Processing is defined as chemical or physical operations designed to produce from used oil, or to make used oil more amenable for production of, fuel oils, lubricants, or other used oil-derived product. Processing includes, but is not limited to: blending used oil with virgin petroleum products, blending used oils to meet the fuel specification, filtration, simple distillation, chemical or physical separation, and re-refining (40 CFR §279.1).

Oil/water separation is not processing unless the recovered oil is burned for energy recovery (Memo, Weddle to Van Schepen; November 1, 1993 (RCRA Online #11792)). The following memos provide additional clarification on oil/water separation in regards to used oil processing:

Memo, Denit to Hunter; October 7, 1993 (RCRA Online #11783)
Memo, Shapiro to Lindgren; March 22, 1994 (RCRA Online #11818)

These memoranda are available in the RCRA Online database at the following URL: https://yosemite.epa.gov/osw/rcra.nsf/how+to+use?OpenForm 

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