Many asset managers need a better understanding of how to obtain the maximum value for their used oil—perhaps most importantly—in an environmentally sustainable manner. In their presentation in Scottsdale, Environmental Management Systems personnel shared current and proposed used oil regulatory changes, recycling options for different types of used oils, how to prevent future environmental liability exposure and how changing market trends for crude oil affects used oil pricing. The Role the EPA will play in the Management of your Used Oil The discussion opened with background information on the Environmental Protection Agency (EPA) and why the agency was created. The standards for used oil were discussed with an emphasis on used oil generators and how easily one’s used oil can become contaminated—resulting in the used oil becoming hazardous waste. Once the oil becomes a hazardous waste, it has changed from being an asset into a liability. The audience was then presented with Table 1 from 40CFR 279 Standards for Generators of Used Oil. This table illustrates levels of contaminants that if exceeded, will render the used oil “off-specification.” Should the used oil be determined to be “off-specification” this could further reduce the value. There was a brief overview of the Toxic Substance Control Act (TSCA) and its use authorizations pertaining to PCBs, the proposed TSCA rule changes and the timeline for these changes. Used Oil Recycling Next began a review of the varieties of oil that are commonly recycled. Motor oil, hydraulic oil, machine and cutting oils, turbine oils, and dielectric oil are the most common. It is important to have segregation and management practices in place for different oils; most importantly oils with varying PCB concentrations should not be intermingled. Motor and hydraulic oils have multiple recycling outlets and can be burned for energy recovery. However, silicone oil, which is primarily utilized in electrical transformers in sensitive areas, has very limited recycling options and can’t be burned for energy recovery due to the non-flammable characteristics of the oil. Then, the conversation dealt with managing oil that has been contaminated with PCBs. The two contamination ranges (2-49 ppm of PCB and greater than 50 ppm of PCB) can be dealt with in a similar fashion, however, only TSCA-permitted facilities are able to accept oil with a PCB concentration greater than 50 ppm. Environmental Liability and Due Diligence through Auditing There is significant potential liability that could befall a company in regards to the EPA’s Superfund law. The various categories of Superfund liability, how that liability is triggered, what a potentially responsible party could be responsible for financially, and the different classes of Superfund liable parties were discussed. In order to protect themselves from this liability, companies that generate used oil can take several protective measures. One important step is the performance of due diligence by auditing the used oil transportation company, looking for transit insurance coverage, driver logs and pre and post-trip inspection forms as a way to protect themselves EMS, Inc., custom designed manifold tanker backs up to an oil recycling tank farm 9 ASSET 2.0 Vol. 2: 2012 from environmental contamination liability over state and local roads. The second protective measure that was relayed was to audit the used oil processing facility. During this audit, auditors were instructed to look for a Phase I environmental audit report and any Notices of Violations. Following these measures will help protect the used oil generator from costly environmental contamination liability. Oil Market Pricing Supply and demand are not the only things that influence oil pricing. Although the U.S. is the third largest producer of crude oil in the world, we consume roughly 9.5 million barrels of oil per day more than we produce. The key factors that influence the price of oil include production, supply, global inventories, financial markets, demand, the spot market, and new technology/renewable resources. But other factors also affect oil prices such as natural disasters and global unrest, distance, equipment costs, taxes, weak U.S. dollar, Department of Toxic Substances Control (DTSC) guidelines, quality and weight of oil and investor demand.