JNjEO STq~~S ~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Q WASHINGTON, D.C. 20460



# DEC -1 2010

OFFICE OF SOLIDWASTEAND EMERGENCYRESPONSE 

### The Honorable Russell D . Feingold United States Senate Washington, D

.C. 20510 Dear Senator Feingold: Thank you for your letter of October 15, 2010, regarding the U.S. Environmental Protection Agency's (EPA) rulemaking on the recycling of used oil and the possible ramifications it may have on small businesses. EPA issued a proposed rule on June 4, 2010, to identify which non-hazardous secondary materials (NHSM) are considered solid waste when burned in combustion units. The proposal was issued in conjunction with three Clean Air Act (CAA) proposed rules: Area Source Industrial, Commercial, and Institutional Boilers; Standardsfor Hazardous Air Pollutantsfor Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters; and Commercial and Industrial Solid Waste Incineration Units. 

### Underthe NHSM

proposal, ifa non-hazardous secondary material is not a solidwaste under the Resource Conservation and Recovery Act (RCRA), and is burned in a combustion unit, then the combustion unit that burns that material would be subject to the applicable CAAsection 112 requirements. On the other hand, ifthe non-hazardous secondary material is considered a "solid waste," then the combustion unit that burns the material would be subject to the CAA 129 requirements. Used oil is one ofthe many non-hazardous materials discussed in the NHSM proposal . The preamble to the proposed rule specifically discussed used oil that meets the on-specification criteria under the 40 CFR Part 279standards for the management ofused oil, and the offspecification used oil that does not meet those standards. Under the proposal, on-specification used oil is considered to be a traditional fuel . Traditional fuels are those fuels that have been historically managed as valuable fuel products rather than being managed as waste materials, and are not considered to be solidwastes under the proposed rule. On-specification used oil can thus be used in any combustion unitthat uses traditional fuel oil . Off-specification used oil is considered to be a solidwaste and can only be combusted in units meeting CAAsection 129 standards for solidwaste incinerators. This would provide an additional measure of control to address the higher level ofcontaminants that could be present in off-specification used oil . Offspecification used oil that is processed into on-specification used oil, however, would not be considered a solidwaste. I appreciate your constituent's concerns andwill ensure that his comments are carefully considered as the rule is developed.

Internet Address (URL) 0 http://www .epa.gov Recycled/Recyclable e Printed with Vegetable Oil Based Inks on 100%Postconsumer, Process Chlorine Free Recycled Paper

### I am enclosing a material characterization paper that provides additional background information on used oil . Our web site also provides information about the proposed rule: http://www

.epa .gov/epawaste/nonhaz/define/index. htm . Again, thank you for your letter. Ifyou have further questions, please contact me or your staffmay contact Raquel Snyder, in EPA's Office ofCongressional and Intergovernmental Relations, at (202) 564-9586.

Mathy gtaslaus Assistant ministrator EnclosureMaterials Characterization Paper In Support ofthe Proposed Rulemaking: Identification of Nonhazardous Secondary Materials That Are Solid Waste - Used Oil March 18, 2010 

### 1. Definition ofUsed Oil EPA defines used oil as any oil that has been refined fromcrude oil, or any synthetic oil, that has been used and as a result ofsuch use is contaminated by physical or chemical impurities .l EPA's criteria for used oil : " Origin: Used oil must have been refined fromcrude oil or made fromsynthetic materials (i .e., derived fromcoal, shale, or polymers) . Examples of crude-oil derived oils and synthetic oils are motor oil, mineral oil, laminating surface agents, and metal working oils. Thus, animal and vegetable oils are not included. Bottom clean-out fromvirgin fuel oil storage tanks or virgin oil recovered froma spill, as well as products solely used as cleaning agents or for their solvent properties, and certain petroleum-derived products such as antifreeze and kerosene are also not included.

2 . Use: The oil must have been used as a lubricant, coolant, heat (non-contact) transfer fluid, hydraulic fluid, heat transfer fluid or for a similar use. Lubricants include, but are not limited to, used motor oil, metal working lubricants, and emulsions. An example ofa hydraulic fluid is transmission fluid. Heat transfer fluids can be materials such as coolants, heating media, refrigeration oils, and electrical insulation oils. Authorized states or regions determine what is considered a "similar use" on a site-specific basis according to whether the material is used and managed in a manner consistent with Part 279 (e.g., used as a buoyant) . 

### Contaminants: The used oil must be contaminated by physical (e.g., high water content, metal shavings, or dirt) or chemical (e.g., lead, halogens, solvents or other hazardous constituents) impurities as a result ofuse. Annual Quantities of Used Oil Generated and Used (1) Sectors that Generate Used Oil : " According to EPA, generators of used oil include "businesses that handle used oil through commercial or industrial operations or fromthe maintenance of vehicles and equipment ." Examples include: 1 See 40 CRF 279

.1 for the specific definition. Z EPA's regulatory definition of used oil generators does not include 1) farmers who produce less than an average of 25 gallons of used oil per month and 2) individuals who generate used oil through the maintenance of their personal vehicles and equipment. Although EPA's regulatory definition does not include these groups, the data included in this document reflect used oil generated by all entities that generate this material .Used Oil 

### o Automotive repair shops o Vehicle service stations o Fleets o Grocery stores o Metal working industries o Energy industry 

### o Boat marinas (EPA 2008b) Exhibit 1 lists the NAICS codes ofthe major sectors that generate used oil . Exhibit 1 : NAICS Codes or Used Oil Generators NAICS NAICSTitle 111' Cro

p p roduction 221 Electric services 221 Electric and other services combined 324Z Petroleumand coal p roducts 332, 333` S

p ecial industry machine 333 Metal working industries 333,336 2 Construction machine and eq ui pment 421Z Scrap and waste materials 445' Groce ry stores 484, 488, 492, 493, 562Z Motor frei g ht transportation and warehousing 713' Boat marinas 811' Automotive rep air sho ps 811' Fleets 811' Vehicle service stations 814' Private households 562' Waste Management and Remediation Services Sources: 1 . Description of sectors fromEPA2008b; NAICS identified fromU.S. Census Bureau 2007. 2. EPA2005b. (2) Quantities of Used Oil Generated: Exhibit 2 summarizes the annual generation and management of used oil . As indicated in the exhibit, an estimated 70 percent of used oil is either used as a fuel (i .e., burned for energy recovery) or re-refined into lubricating oil . However, depending upon the year, estimates indicate that as much as 90 percent of all collected used oil is burned for energy recovery, leaving 10 percent or less to be rerefined into lubricating oil (Svizzero 2008) . 

### (3) Trends in Generation: The data sources consulted for this document do not include information on the trend in the generation of used oil . A2006report fromthe Department of Energy indicates,Used Oil 

### however, that the volume of oil changed by consumers themselves (e.g., households and owners/operators of commercial vehicles) declined from60 percent of total oil changes in 1997 to 45 percent in 2005 (DOE 2006, p. 5-2) . This shift in practice may have helped increase the recycling rate for used oil . During the 1997-2005 period, the recycling rate for used oil generated by service stations increased from66 percent in 1997 to almost 100percent (DOE 2006, p. 5-2) . Exhibit 2: Overviewo Annual Generation and Use

Annual Annual Annual Quantity Disposed i Total Quantity Quantity of in Landfills or Annual Quantity Quantity Commodity Generated Used as Fuel Im proper Locations Re-refined Stockpiled Used Oil 1 .37 billion 780million 426million gallons 165 million gallons unknown

gallons gallons Sources:

. Data are fromUnited States Department of Energy 2006, .5-1 . 

### 3 . Uses of Used Oil 

### (1) Combustion Uses: " Use as feedstock at petroleumrefinery " Use as an alternative fuel (EPA 2008b) For the purposes of regulating used oil burned for energy recovery, EPA makes a distinction between on-spec used oil and off-spec used oil based upon a finding that only certain contaminants in used oil pose a significant threat to human health or the environment. As a result, EPA has established maximumconcentration limits for these constituents of concern, as summarized in Exhibit 3.3 Ifthe used oil is shown not to exceed any allowable level, it is on-spec and can be burned in any combustion device. Otherwise, it is considered off-specification. Published data on the distribution between on-spec and off-spec used oil nation-wide was not readily available, but an industry source estimates that roughly 20 percent of the used oil generated in the U.S. is off-spec (Harris 2009) . In addition, data on used oil generated in Florida indicate that an estimated 110,308,107 gallons of used oil and oily waste were managed in Florida in 2005. Of this, 56,569,512 gallons (51 .3 percent) were recycled as follows: 

### 41,386,124 gallons (73.2 percent) were marketed as an on-spec used oil fuel 1,775,815 gallons (3.1 percent) were burned as an off-spec used oil fuel

3 The limits are set such that the emissions resulting from the burning of used oil containing these contaminants, at or below established "on-spec" limits, will pose no more threat to human health or the environment than the emissions resulting fromthe burning ofvirgin oil or diesel (68 FR 44662, July 30, 2003) .Used Oil 13,407,573 gallons (23.7 percent) were marketed for other industrial uses (e.g. phosphate beneficiation) (FL DEP 2006) Averaging the industry source and the Florida data, we estimate that approximately 77 percent of the used oil generated and used each year is on-spec and 23 percent is off-spec. 

### Exhibit 3: Criteria or On-S eci tcation UsedOil Property Allowable Level Arsenic 5 m maximum Cadmium 2 m maximum Chromium 10 m maximum Lead 100 m maximum Total Halogens 4,000 m maximum' Flashpoint 100° F minimum Source: EPA2001 Notes: 1 . Used oil containing m ore than 1,000 ppm

total halogens is presumed to be a hazardous waste under the rebuttable presumption provided under §279.10(b)(1) . Such used oil is subject to subpart Hof part 266rather than part 279 when burned for energy recovery unless the presum p tion ofmixing can be successfull y rebutted. Although approximately 23 percent of the used oil generated in the U.S. is off-spec, a lower portion of off-spec used oil burned as a fuel is off-spec because off-spec used oil is often blended into on-spec by used oil processors. Industry sources indicate that between 5 and 15 percent of the used oil sold or burned by used oil processors in the U.S. is off-spec.4 In addition, the Florida data referenced above suggest that approximately 4 percent of the used oil marketed and burned in Florida is off-spec.s Averaging the available values, we estimate that 8.2 percent of used oil sold or burned by used oil processors is off-spec.6,7

4 Harris, 2009 estimates that off-spec used oil makes up approximately 15 percent of the used oil market, while Briggs, 2009 estimates that this figure is approximately 5 to 6 percent. 5 We derived this value by dividing the 1 .7 million gallons of used oil burned as off-spec by the 43.1 million gallons ofused oil burned as fuel (on-spec and off-spec combined) . `' This estimate is the average of the 15 percent value fromHarris (2009), the midpoint of the 5 to 6percent range provided by Briggs (2009), and the 4 percent value fromFlorida DEP (2006). 7 Briggs (2009) indicates that used oil burners sometimes use off-spec used oil as a fuel .Used Oil 

### As shown in Exhibit 4, asphalt plants are the largest users ofused oil as fuel, followed by space heaters and industrial boilers. It is likely that asphalt plants use on-spec used oil adhering to the criteria noted in Exhibit 3 above. Exhibit 4

: Users of UsedOil

Source: DOE 2006, p. 5-2. 

### Aportion ofthe used oil burned for energy recovery in the U .S. is reflected in the combustor survey database developed by EPA for the 2009 proposal of the Commercial and Industrial Solid Waste Incinerator (CISWI) standards and the Industrial Boilers Maximum Achievable Control Technology (MACT) standards. According to this database, the units surveyed by EPAfor these standards annually combust 34million gallons of used oil (EPA 2009) .8 (2) Non-Combustion Used Oil Uses: Used oil may be re-used if it is processed or regenerated (EPA 2008b) . (3) Quantities of Used Oil Landfilled: Approximately 426 millions gallons of used oil are landfilled or improperly disposed annually (DOE 2006) . (4) Quantities of Used Oil Stockpiled/stored: Readily available data sources on used oil do not suggest that this material is stockpiled or stored (for long periods of time) $ Although we report used oil quantities from the combustor database in gallons, the database includes material quantities expressed in terms of heating values (Btu) . To express this information in terms of gallons, we assumed that used oil has a heating value of 140,000 Btu per gallon, consistent with the estimate in EPA 2008b. Also, we note that much of the used oil burned by combustion units included in the database may be reported as (virgin) fuel oil rather than as used oil . That is, the use ofused oil may be underreported in the combustordatabase.Used Oil in large quantities. This is because its value as a fuel or product leads to its prompt use. 

### 4 . Management and Combustion Processesfor Used Oil (1) Types of Units Combusting Used Oil : 

### Facilities burn both on-specification and off-specification used oil . However, offspec used oil may only be burned in specified combustion devices (EPA 2008) : " Industrial furnaces as defined in 40 Code of Federal Regulation (CFR) §260.10 and §279.61(a)

. Industrial boilers as defined in 40 CFR §260.20 that are located at facilities that are engaged in a manufacturing process where substances are transformed into newproducts. 

### " Utility boilers as defined in 40 CFR §260.20 that are used to produce electric power, steam, heated or cooled air, or other gases or fluids for sale. " Used oil-fired space heaters provided that the burner meets the provisions of 40 CFR§279.23. " Hazardous waste incinerators subject to regulation under 40 CFR parts 264 and 265, subpart O

. 

### (2) Supply/Processing Chain for Used Oil : The Standards for the Management of Used Oil in the Code of Federal Regulations define processing as "chemical or physical operations designed to produce fromused 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 rerefining" (40 CFR279.50(a)) . 

### (3) Processing Used Oil for Fuel Applications: Used oil is generated from many different sources and then consolidated at key collection points (e.g., commercial and industrial operations, automotive repair shops, branch collection networks, and fleets) through well-established channels before being shipped to processing facilities and end users. Based on communications with used oil recyclers and marketers, the steps to process used oil for use as a fuel are as follows: 

### " Test the oil to determine whether it's on-spec or off-spec. The recyclers and marketers who we contacted indicated that nearly all used oil is on-spec (Blackburn 2009) . " Remove as much water and other liquids fromthe oil as possible by allowing the water to settle to the bottom, or also by using solvents to remove water (and sometimes antifreeze) . " Filter out metal scraps and other larger particles using screens. The filtering can be done when the oil is collected, or in the burner when the oil is added (Saunders 2008 and Blackburn 2008) .Used Oil



### 5 . The filtering and water extraction processes described above are standard practice in the industry. That is, most used oil goes through these processing steps prior to being used as a fuel . In addition to the processing steps outlined above, processors typically store used oil in tanks, allowing oil to separate fromother liquids and settle to the bottomof the tank. These steps allowprocessors to provide users with relatively high-quality used oils (Saunders 2008 and Blackburn 2008, 2009) . 

### Estimated counts of the entities involved in the various stages of used oil processing and use include the following: " 379 used oil transporters and transfer facilities " 150 used oil processors and re-refiners " 750 burners of off-specification used oil " 340used oil fuel marketers (Office of Management and Budget 2005, p. 52) (4) State Status of Used Oil use as Fuel : Based on a reviewof information fromthe 2006 Beneficial Use Survey conducted by the Association of State and Territorial Solid Waste Management Officials (ASTSWMO), none of the 34 states responding to the survey reported that they had given used oil a beneficial use designation as a fuel (ASTSWMO 2007, p.B-38-39) . States typically regulate used oil practices under federal used oil management standards (EPA 2008c) .9 This may include establishing programs to encourage appropriate use of used oil . For example, DOE indicates that 24 states have enacted purchasing programpreferences to stimulate the demand for used oil (DOE 6-3 to 6- 4) . Used Oil Composition andImpacts 

### (1) Composition of Used Oil " 140,000 Btu per gallon" (EPA 2008b) " A2003 study by Dominguez-Rosado and Pichtel indicates that used motor oil has the following metals concentrations: o Zinc: 838 mg/kg o Lead: 110 mg/kg o Cadmium

: 9.4 mg/kg o Barium

: 4,100mg/kg 

### o Chromium

: Not detected (Dominguez-Rosada and Pichtel 2003)

9 As of September 30 2008, 31 states have received federal authorization for the Recycled Used Oil Management Standards and an additional 10 states have adopted the Standards. 1° The heat input of used oil on a Btu per pound basis depends on the density ofthe used oil . Assuming a density of 7 pounds per gallon (Mississippi DEQ, 2007), the 140,000 Btu per gallon estimates translates to 20,000 Btu per pound.Used Oil 

### Used oil often contains approximately 2 to 5 percent additives (DOE 2006, p. 9- 14) . Exhibit 5 summarizes the most common of these additives. In addition to these additives, used oil may include a number of physical and chemical contaminants, including metals, dirt, and solvents (EPA, 2008a) . Exhibit 5

: CommonAdditives Found in Used Oil Purpose ofAdditive Additives Anticorrosion Zinc dithio hos hates, metal henolates, fat acids and amines A_ntifoamant Silicone pol y mers, organic copolymers Antiodorant Perfumes, essential oils Antioxidant Zinc dithio hos hates, hindered phenols. Aromatic amines, sul hurized p henols Antiwear Additive Chlorinated waxes, alkyl phosphites and phosphates, lead napthenate, metal triborates, metal and ashless dithio hos hates Color Stabilizer Aromatic amine com pounds Corrosion Inhibitor Metal dithiophosphates, metal dithicarbamates, metal sulfonates, thiadiazoles, and sulfurized te enes Detergent Alkyl sulfonates, phosphonates, alkyl phenates, alkyl phenolates, alkyl carbox lates, and alk

yl substituted salic lates Dispersant Alk lsuccinimides, alk Isuccinic esters Emulsifier Fatty a cids, fatty amides, and fatty alcohols Extreme Pressure Additives Alkyl sulfides, polysulfides, sulfurized fatty oils, alkyl phosphites and phosphates, metal and ashless dithiophosphates and carboxylates, metal dithiocarbamates, and metal triborates Friction Modifier Organic fatty acids. Lard oil . Phosphorous based com pounds Metal Deactivator Metal Deactivator Organic complexes containing nitrogen and sulfur amines, sul hides and p

hosphates Pour p oint depressant Alk lated naphthalene and henolic p ol ymers, ol methac lates Rust Inhibitor Metal alkylsulfonates, alkylamines, alkyl amine phosphates, alkenylsuccinic acids, fatty acids, alk l henol ethox lates, and acid p hosp hate esters Seal Swell A

g ent Or anic Organic phosphates aromatic hydrocarbons Tackiness A

gent Pol acr lates and ol butenes Viscosity Pol y mers ofolefins, methac lates, di-enes or alk lated s renes Sources: DOE 2006, Table 9and EPA2005a, A ppendix C-2

. 

### (2) Impact Information " Cost Impacts: The cost impact associated with consuming used oil as a fuel depends on both the value of the fuel that it displaces and the cost of processing used oil . The Department of Energy reports that the market value of used oil is approximately 65 to 75 percent of the price of No. 6 fuel oil (DOE 2006, p. 4-4), but it is unclear whether this estimate applies to processed or unprocessed used oil . At October 2008 fuel prices, the 65 to 75 percent estimate suggests that the value of used oil is approximately $1 .14 to $1 .31 per gallon. 11 In addition, in terms of the economic benefit realized by facilities that sell their used oil, a used oil recycler in Idaho indicates that the price paid by oil recyclers for unprocessed used oil varies depending on the quantity and frequency of sale (Blackburn 2008) . " This is based on a price of $1 .75 pergallon for No. 6fuel oil (DOE 2008).Used Oil At current oil prices, used oil recyclers pay between $0.60 and $1 .07 per gallon for used oil (Blackburn 2008) . Used oil marketers must also bear the costs of testing to determine whether oil is on-specification or off-specification. The results of an EPA survey of used oil marketers indicate an average facility annual cost of testing of $3,462 (EPA 1998) . " Emissions Impacts of Used Oil as a Fuel : To characterize the potential environmental impacts and benefits associated with the use of used oil as an alternative fuel, we identified comparative emissions information for used oil and for the fuels it typically replaces: distillate fuel oil and residual fuel oil . More specifically, we obtained information on the emissions associated with the combustion of each of these fuels and the emissions associated with cradle-togate processing of the virgin fuel oil, impacts that would be avoided by burning used oil as an alternative. Exhibit 6 belowsummarizes this information. Note that this analysis does not include the emissions associated with the preparation of used oil for combustion, and may therefore overstate the relative air emissions reductions associated with using this alternative fuel . However, the majority of the upstream impacts of used oil are the result of the generation of the primary product associated with the oil ; the processing required to prepare used oil for combustion is limited. Additionally, since not all contaminants in used oil cause health or environmental risk, maximumconcentration limits can be set such that used oil burned with concentrations at or belowthe limits will not create risk. These concentration limits define the difference between on-spec and off-spec used oil . 

### Exhibit 6 shows that the principal benefits of combustion of used oil are associated with upstreamproduction offsets and include substantial reductions of NO, CO, and COZ emissions. In terms of combustion-specific emissions, use of used oil results in notably lower NOXemissions, in particular when compared to residual fuel oil . On the other hand, particulate matter and lead emissions may be substantially higher than virgin fuel oil, depending on the concentrations ofthose compounds in the used oil . Note that other uses for used oil may be environmentally preferable to combustion (e.g., recovery and reuse as a lubricant) but this analysis examines only combustion uses.Used Oil

Exhibit 6

: Emission Factorsfor Used Oil andAlternatives

Used Oil Distillate Fuel Oil Residual Fuel Oil Combustion Combustion Pollutant Combustion Combustion plus U p stream Combustion plus U pstream -------------------------------- Lb./MMBtu --------------------------- Criteria Pollutants PM2 .5 - - - - - PM 10 0 .162 - 0 .190 0

.011 0

.011 0

.093 0

.093 PM, unspecified 0 .203 - 0 .238 - 0 .012 - 0 .012 NOx 0 .131 0

.173 0

.234 0

.367 0

.428 VOCs - 0 .001 0

.363 0.002 0.367 sox 0 .051 - 1 .014 0 .209 0

.394 1 .593 1 .781 CO 0 .034 0

.036 0

.082 0.033 0.079 Pb 1 .79x10-3-2.16x10-3 4.60x10~6 5.61x10-6 5.80x10"5 5.90x10~5 H - 1 .58x10"6 1 .77x10"6 8.67x10~6 8.85x10-6 Greenhouse Gases C02 151 .7 161 .2 180 .1 173.3 192.5 CH4 - 3.7410~4 0 .030 0

.007 0

.036 NZO - - 2.O1x10-5 - 2.07x10-5 MTCO,E/MMBtu 0 .069 0

.073 0

.082 0

.079 0

.088 Sources: Distillate fuel oil and residual fuel oil emissions fromFranklin Associates 1998. Used oil emissions fromEPA 1995, VermontAgency of Natural Resources 1996, and Colorado Department of Public Health and Environment. Notes : -" signifies data not available; may equal zero. Heating value of used oil assumedto be 145 MMBtu/1000 gal . The emission information presented in this table is derived fromLife Cycle Inventory (LCI) data, as compiled by Franklin Associates. LCI data identifies and quantifies resource inputs, energy requirements, and releases to the air, water, and land for each step in the manufacture ofa product or process, fromthe extraction of the raw materials to ultimate disposal . The LCI can be used to identify those systemcomponents or life cycle steps that are the main contributors to environmental burdens such as energy use, solid waste, and atmospheric andwaterborne emissions. Uncertainty in an LCI is dueto the cumulative effects of input uncertainties and data variability. There are several life cycle inventory databases available in the U .S. and Europe. Forthis paper, we applied the most readily available LCI database that was most consistent with the materials and uses examined. These LCI data rely on systemboundaries as defined by Franklin Associates, as described in the documentation forthis database, available at: http ://www .pre.nl/download/manuals/DatabaseManualFranklinUS98 .pdf.Used Oil

References 40 CFR279.50(a) Association of State and Territorial Solid Waste Management Officials (ASTSWMO)

. 2007, 2006 Beneficial Use StudyReport, November 2007. Blackburn, Randy. 2008. Commercial Fuel Recycling, LLC, Idaho, personal communication, September 25, 2008 and November 20, 2008. Blackburn, Randy. 2009. Commercial Fuel Recycling, LLC, Idaho, personal communication, April 24, 2009. Briggs, William

. 2009. ORRCO, personal communication, August 24, 2009. Colorado Department of Public Health and Environment. 2008, "A Guideto Hazardous Waste and Air Requirements for Used Oil Space Heaters", accessed on August 29, 2008 at http://www

.cdphe.state.co.us/ap/sbap/sbap useoilheaters.pdf . Dominguez-Rosado, Elena and John Pichtel . 2003, "Chemical Characterization ofFresh, Used, and Weathered Motor Oil Via GC/MS, NMR, and FTIR Techniques," Proceedings oftheIndiana Academy of Sciences, Vol . 12, No. 2, 2003, pages 109-116 . Florida Department of Environmental Protection. 2006, "Florida's Used Oil Recycling Program : 21 S" Annual Report," March 2006. Franklin Associates. 1998, "Franklin US LCI 98 Library" . Harris, Christopher. 2009. Association of Responsible Recyclers, General Counsel, personal communication, August 21, 2009. Mississippi Department of Environmental Quality. 2007. "Material Density and Volume Conversion,"

http://www

.deq.state.ms.us/MDEQ .nsf/page/Recycling MaterialDensityandVolumeConversion?OpenDocu ment . Saunders, Brandon. 2008. Polar Refrigerant Technologies, New Hampshire, personal communication, September 25, 2008. Svizzero, Michael . 2008. U.S. Environmental Protection Agency, personal communication, citing American PetroleumInstitute data, October 22, 2008. United States Census Bureau. 2007. "2007 NAICS Definitions" . United States Department of Energy (DOE) . 2006, "Used Oil Re-refining StudytoAddress Energy Policy Actof 2005 Section 1838" . United Stated Department of Energy (DOE) . 2008, "Short-TermEnergy Outlook," November 12, 2008. United States Environmental Protection Agency (EPA). 1995, "AP-42, Fifth Edition, CompilationofAir Pollutant Emission Factors, Volume 1 : Stationary Point and Area Sources" . United States Environmental Protection Agency (EPA). 1998, "Supporting Statement For Renewal of ICR(#1286) ; Used Oil Management Standards Record Keeping and Reporting Requirements," accessed April 27, 2009 at http ://www

.epa.gov/waste/conserve/materials/usedoil/support htm . United States Environmental Protection Agency (EPA) . 2001, "RCRA, Superfund &EPCRACall Center Training 11Used Oil Module Introduction to Used Oil," October 2001 . United States Environmental Protection Agency (EPA) . 2005a, "Guidance and Summary of Information Regarding the RCRA Used Oil Rebuttal Assumption," March 2005. United States Environmental Protection Agency (EPA) . 2005b, "Supporting Statement for Information Collection Request Number 1286.07Used Oil Management Standards Recordkeeping and Reporting Requirements," November 10, 2005. United States Environmental Protection Agency (EPA) . 2008a, "Code of Federal Regulations: Standards for the Management of Used Oil", accessed August 28, 2008 at http ://www .gpoaccess.eov/index.html . United States Environmental Protection Agency (EPA) . 2008b, "Managing Used Oil : Advice for Small Businesses", accessed August 19, 2008 at http://www .epa.gov/epaoswer/hazwaste/usedoil/usedoil .htm . United States Environmental Protection Agency (EPA) . 2008c, "Authorization Status by Rule", accessed December 2, 2008 at http ://www

.epa.gov/epawaste/laws-regs/state/stats/authall .pdf. United States Environmental Protection Agency (EPA)

. 2009, Combustorsurvey database in supportof the 2009 proposal of the Commercial and Industrial Solid Waste Incinerator (CISWI) standards and the Industrial Boilers Maximum

Achievable Control Technology (MACT) standards, April 2009. United States Office of Management and Budget (OMB) . 2005, "Supporting Statementfor Information Collection Request Number 1286.07 Used Oil Management Standards Recordkeeping and Reporting Requirements" . Vermont Agency of Natural Resources. 1996, "Vermont Used Oil Analysis and Waste Oil Furnace Emissions Study", accessed on August 29, 2008 at http://www .epa.gov/ttn/catc/dir-1/w oilacr.pdf.