The following used oil recycling Superfund sites represent a mere subset of the messes created by companies that once claimed to manage it properly:
- AA Oil, Beede Waste Oil
- Bridgeport Rental & Oil Services
- Cramer and Maurer (Oil Pit) And Neff Oil
- Dixie Oil Processors, Inc.
- Dubose Oil Products Co.
- Gautier Oil Co., Inc.
- Gold Coast Oil Corp.
- Golden Oil Truck Supply
- Harbor Oil Inc.
- Imperial Oil Co., Inc./Champion Chemicals
- Intermountain Waste Oil Refinery
- Laskin/Poplar Oil Co., Liquid Gold Oil Corp.
- Louisiana Oil Recycle & Reuse
- Murphy's Waste Oil Service
- Old Inger Oil Refinery
- P. And W. Waste Oil
- Peak Oil Co./Bay Drum Co.
- Pure Earth Recycling
- Purity Oil Sales, Inc.
- R & H Oil/Tropicana Energy
- Reclamation Oil Company
- Rocket Oil Site
- St. Croix Waste Oil Services, Inc.
- Swope Oil & Chemical Co.
- T.C. Waste Oil Facility Inc.
- Tri-City Oil Conservationist, Inc.
- US Oil Recovery
- York Oil Co.
Fifteen of those sites are still listed with the Environmental Protection Agency as “construction not complete/sites not ready for anticipated use”:
- AA Oil (Indiana)
- Beede Waste Oil (New Hampshire)
- Bridgeport Rental & Oil Services (New Jersey)
- Cramer & Mauer/Neff Oil (Florida)
- Gautier Oil Co. (Mississippi)
- Golden Oil Truck Supply (California)
- Louisiana Oil Recycle & Reuse (Louisiana)
- P&W Waste Oil (North Carolina)
- R&H Oil/Tropicana Energy (Texas)
- Reclamation Oil (Michigan)
- Rocket Oil Site (Ohio)
- t. Croix Waste Oil Services (St. Croix)
- TC Waste Oil (St. Croix)
- US Oil Recovery (Texas)
That means the final cleanup bills are yet to come due.
Of that group, Beede Waste Oil was the most epic, combined failure of the recycling industry and the state and federal regulators who were supposed to enforce the law against them over their decades of operation. Mom & Pop fast lube owners ended up on the top 10 list of potentially responsible parties alongside Exxon Mobil to cover the $48 million to $60 million cleanup. Beede Waste Oil ceased operations in 1992, which meant the federal Service Station Dealer Exemption couldn’t be used. Unfortunately, Beede’s cautionary tale did not spur regulators to inspect used oil recyclers more often nor did it discourage all recyclers from cutting corners.
Successor Liability Still Happens
If you think most of the used oil Superfund sites sound old and, therefore, can’t impact current automotive facilities, think again. The Superfund law may have been the catalyst for creating the “polluter pays” concept, but it was never limited to actual bad actors. Superfund liability can be inadvertently purchased and pose a successor liability threat for decades. For instance, the U.S. attorney for the Southern District of Indiana made a $1.37 million settlement for the AA Oil site cleanup with major used oil generators Ford Motor Company, Arconic, and Navastar just last year. That particular site stopped recycling used oil by 1990, which means Arconic and Navastar were held liable for their predecessor companies’ transportation of used oil to AA Oil some 35 years later. Automotive service facility sales should cover this issue.
21st Century Used Oil Superfund Sites Still Happen
Pure Earth Recycling Superfund Site (New Jersey) operated with waste oil contamination until 2012. Cleanup activities have been ongoing since that time. EPA proposed an approximately $1.5 million settlement for cleanup costs in February 2025. P&W Waste Oil (North Carolina) is another recycling facility that operated with waste oil contamination including PCBs until 2012. A federal judge in Raleigh, North Carolina, held the company liable for $21.373 million in cleanup costs experienced by an offsite third party and also gave the owner prison time/probation. But there seems to be no public record of payment, reimbursement of onsite cleanup costs, or verification that the site has undergone cleanup. It would be highly unusual if automotive service facilities were not among the PRPs identified for both sites.
US Oil Recovery (TX) operated with oily waste contamination until 2010. So far, the site has only been stabilized from causing off-site contamination, and the costs exceed $5 million. The study under development to choose an appropriate remedy has not yet been published. The site PRP Group has already sued hundreds of PRPs for contribution including fast lube operators, dealerships, and many independent used oil transporters who may yet provide information on additional automotive service provider generators of used oil that went to the site.
The Service Station Dealer Exemption
One of the rare exemptions to Superfund liability, the Service Station Dealer Exemption or “SSDE” applies to used oil sent for recycling via licensed used oil transporter on or after March 8, 1993. Automotive service facilities like fast lubes qualify as “service station dealers” under this exemption, but in order to actually receive it certain requirements must be met: (1) demonstrated willingness to accept DIYer used oil from the public; (2) compliance with all applicable used oil management standards, which includes the federal SPCC regulation for aboveground storage of oil; and (3) no mixing of other hazardous substances with used oil. As described above, Superfund liability for offsite, third party used oil pollution typically caused by used oil recyclers remains a threat, which means meeting the qualifications for the SSDE remains critical.
