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EXCLUSIONS FROM REGULATION AS HAZARDOUS WASTEOne presentation in a series that briefly explains the Federal exclusions from full regulation for certain materials under the Resource Conservation and Recovery Act (RCRA).

40 CFR 261.4(b)(13)

This presentation: 40 CFR 261.4(b)(13):Used Oil Filters

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PRESENTED BY:

Daniels Training Services815.821.1550www.DanielsTraining.comInfo@DanielsTraining.com

A different kind of training.

40 CFR 261.4(b)(13)

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40 CFR 261.4(b)

• Paragraph ‘b’ of section 261.4 identifies 17 solid wastes excluded from regulation as a hazardous waste.

40 CFR 261.4(b)(13)

Solid Waste

Hazardous Waste

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Used Oil Filters

“In order to promote the recycling and recovery

of metals and other products from used oil filters, EPA exempted used oil filters that have been properly drained to remove the used oil.”

40 CFR 261.4(b)(13)

2011 RCRA Orientation Manual

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“The following solid wastes are not hazardous wastes for the purpose of this part…”

• Oil filters that are:• Used• Not terne plated.• Not mixed with listed hazardous waste.• F-codes• K-codes• P- & U-codes

40 CFR 261.4(b)(13)

And…

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Have been gravity hot-drained using one of the following methods:

1. Puncturing the filter anti-drain back valve or the filter dome end & hot-draining.

• Puncturing can be with any tool that will allow air to evacuate the remaining oil from the filter.

40 CFR 261.4(b)(13)

www.OilFilterDrainSystems.com

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Have been gravity hot-drained using one of the following methods:2. Hot-draining &

crushing.• Filter is crushed by a

mechanical, pneumatic, or hydraulic device to squeeze out the used oil & compact the remaining filter material.

40 CFR 261.4(b)(13)

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Have been gravity hot-drained using one of the following methods:

3. Dismantling & hot-draining.

• Filter is separated into its different parts using a mechanical device.

40 CFR 261.4(b)(13)

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Have been gravity hot-drained using one of the following methods:4. Any other equivalent

hot-draining method that will remove used oil.

• e.g. Air pressure forces used oil out of the filter.

40 CFR 261.4(b)(13)

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More to Consider (1)…

• What are terne-plated oil filters?• An alloy of tin & lead.• Uncommon in most highway vehicles since ‘92.• More common in heavy equipment.• Coated with an alloy of lead & tin.

• Toxic hazardous waste for lead (D008).• If recycled as scrap metal, they are exempt from most of the hazardous waste regulations.

40 CFR 261.4(b)(13)

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More to Consider (2)…

• “Hot draining” means draining oil close to or at engine temperature.

• Check with your State as it may not recognize this Federal exclusion or have more strict requirements.

40 CFR 261.4(b)(13)

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40 CFR 261.4(b)(13) Verbatim:

(b)Solid wastes which are not hazardous wastes. The following solid wastes are not hazardous wastes:…• (13) Non-terne plated used oil filters that are not mixed with

wastes listed in subpart D of this part if these oil filters have been gravity hot-drained using one of the following methods:

• (i) Puncturing the filter anti-drain back valve or the filter dome end and hot-draining;

• (ii) Hot-draining and crushing;• (iii) Dismantling and hot-draining; or• (iv) Any other equivalent hot-draining method that will

remove used oil.

40 CFR 261.4(b)(13)

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Got Questions About RCRA or HazMat Transportation?

I provide:

Annual RCRA Training for Hazardous Waste Personnel

And

Triennial HazMat Employee Training

Public Seminar or Onsite Training

Daniels Training Services815.821.1550Info@DanielsTraining.comwww.DanielsTraining.com

40 CFR 261.4(b)(13)