JNjEO ~ STq ~~S 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Q WASHINGTON, D .C . 20460 

DEC -1 2010 

OFFICE OF 

SOLID WASTE AND 

EMERGENCY RESPONSE 

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; 

Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and 

Institutional Boilers and Process Heaters; and Commercial and Industrial Solid Waste 

Incineration Units. 

Under the NHSM proposal, if a non-hazardous secondary material is not a solid waste 

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 CAA section 

112 requirements . On the other hand, if the 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 of the 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 279 standards for the management of used 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 solid wastes under the proposed rule . On-specification used oil can thus 

be used in any combustion unit that uses traditional fuel oil. Off-specification used oil is 

considered to be a solid waste and can only be combusted in units meeting CAA section 129 

standards for solid waste incinerators . This would provide an additional measure of control to 

address the higher level of contaminants 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 solid waste. I appreciate your constituent's concerns and will 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 . If you have further questions, please contact me or 

your staff may contact Raquel Snyder, in EPA's Office of Congressional and Intergovernmental 

Relations, at (202) 564-9586. 

Mathy gtaslaus 

Assistant ministrator 

Enclosure 
Materials Characterization Paper 

In Support of the 

Proposed Rulemaking: 

Identification of Nonhazardous Secondary Materials That Are Solid Waste - Used Oil 

March 18, 2010 

1. Definition of Used Oil 

EPA defines used oil as any oil that has been refined from crude oil, or any synthetic oil, that has 

been used and as a result of such use is contaminated by physical or chemical impurities .l 

EPA's criteria for used oil : 

" Origin : Used oil must have been refined from crude oil or made from synthetic materials 

(i .e ., derived from coal, 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 from virgin fuel 

oil storage tanks or virgin oil recovered from a 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 of a 

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 of use. 

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 from the 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 of the major sectors that generate used oil . 

Exhibit 1: NAICS Codes or Used Oil Generators 

NAICS NAICS Title 

111' Crop production 

221 Electric services 

221 Electric and other services combined 

324Z Petroleum and coal products 

332, 333` Special industry machine 

333 Metal working industries 

333,336 2 Construction machine and equi pment 

421Z Scrap and waste materials 

445' Grocery stores 

484, 488, 492, 493, 562Z Motor frei ght transportation and warehousin g 

713' Boat marinas 

811' Automotive re pair shops 

811' Fleets 

811' Vehicle service stations 

814' Private households 

562' Waste Management and Remediation Services 

Sources: 

1 . Description of sectors from EPA 2008b; NAICS identified from U.S . Census 

Bureau 2007. 

2 . EPA 2005b. 

(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. A 2006 report from the 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 from 60 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 from 66 

percent in 1997 to almost 100 percent (DOE 2006, p. 5-2) . 

Exhibit 2: Overview o 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 Impro per Locations Re-refined Stockpiled 

Used Oil 1 .37 billion 780 million 426 million gallons 165 million gallons unknown 

gallons gallons 

Sources: 

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

3. Uses of Used Oil 

(1) Combustion Uses: 

" Use as feedstock at petroleum refinery 

" 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 maximum concentration limits for 

these constituents of concern, as summarized in Exhibit 3 .3 If the 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 from the burning of virgin 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 Used Oil 

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' 

Flash point 100° F minimum 

Source: 

EPA 2001 

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 H of part 

266 rather than part 279 when burned for energy recovery unless the 

presumption of mixing can be successfully 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 of used oil burned as fuel (on-spec and off-spec combined). 

`' This estimate is the average of the 15 percent value from Harris (2009), the midpoint of the 5 to 6 percent 

range provided by Briggs (2009), and the 4 percent value from Florida 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 of used 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 Used Oil 

Source : DOE 2006, p. 5-2. 

A portion of the 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 

EPA for these standards annually combust 34 million 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 of used oil may be underreported in the combustor database . 
Used Oil 

in large quantities. This is because its value as a fuel or product leads to its prompt 

use. 

4. Management and Combustion Processes for 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 new products. 

" 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 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 rerefining" (40 CFR 279 .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 from the 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 from other liquids and settle to the bottom of the 

tank. These steps allow processors 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 

" 340 used oil fuel marketers (Office of Management and Budget 2005, p . 52) 

(4) State Status of Used Oil use as Fuel : 

Based on a review of information from the 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 program preferences to stimulate the demand for used oil (DOE 6-3 to 6-

4) . 

Used Oil Composition and Impacts 

(1) Composition of Used Oil 

" 140,000 Btu per gallon" (EPA 2008b) 

" A 2003 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: 4,100 mg/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 of the 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: Common Additives Found in Used Oil 

Purpose of Additive Additives 

Anticorrosion Zinc dithio hos hates, metal henolates, fat acids and amines 

A_ntifoamant Silicone polymers, or ganic co polymers 

Antiodorant Perfumes, essential oils 

Antioxidant Zinc dithio hos hates, hindered phenols . Aromatic amines, sul hurized phenols 

Antiwear Additive Chlorinated waxes, alkyl phosphites and phosphates, lead napthenate, metal 

triborates, metal and ashless dithio hos hates 

Color Stabilizer Aromatic amine compounds 

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 alkyl substituted salic lates 

Dispersant Alk lsuccinimides, alk Isuccinic esters 

Emulsifier Fatty acids, 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 compounds 

Metal Deactivator Metal Deactivator Organic complexes containing nitrogen and sulfur amines, 

sul hides and phosphates 

Pour point de pressant Alk lated naphthalene and henolic pol ymers, ol methac lates 

Rust Inhibitor Metal alkylsulfonates, alkylamines, alkyl amine phosphates, alkenylsuccinic acids, 

fatty acids, alk l henol ethox lates, and acid phosphate esters 

Seal Swell Agent Or anic Organic phosphates aromatic hydrocarbons 

Tackiness Agent Pol acr lates and ol butenes 

Viscosity Polymers of olefins, methac lates, di-enes or alk lated s renes 

Sources : 

DOE 2006, Table 9 and EPA 2005a, Appendix 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 per gallon for No. 6 fuel 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 below summarizes 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, maximum concentration limits can be set such that 

used oil burned with concentrations at or below the 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 upstream production 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 NOX emissions, 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 of those 

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 Factors for Used Oil and Alternatives 

Used Oil Distillate Fuel Oil Residual Fuel Oil 

Combustion Combustion Pollutant Combustion Combustion plus Upstream Combustion plus Upstream 

-------------------------------- 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 from Franklin Associates 1998 . 

Used oil emissions from EPA 1995, Vermont Agency 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 assumed to be 145 MMBtu/1000 gal. 

The emission information presented in this table is derived from Life 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 of a product or process, from the extraction of the raw materials 

to ultimate disposal . The LCI can be used to identify those system components or life cycle steps that are the main 

contributors to environmental burdens such as energy use, solid waste, and atmospheric and waterborne emissions. 

Uncertainty in an LCI is due to the cumulative effects of input uncertainties and data variability. 

There are several life cycle inventory databases available in the U.S . and Europe. For this paper, we applied the 

most readily available LCI database that was most consistent with the materials and uses examined . These LCI data 

rely on system boundaries as defined by Franklin Associates, as described in the documentation for this database, 

available at : http ://www .pre .nl/download/manuals/DatabaseManualFranklinUS98 .pdf. 
Used Oil 

References 

40 CFR 279.50(a) 

Association of State and Territorial Solid Waste Management Officials (ASTSWMO). 2007, 2006 Beneficial Use 

Study Report, 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 Guide to 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 of Fresh, Used, and Weathered 

Motor Oil Via GC/MS, NMR, and FTIR Techniques," Proceedings of the Indiana 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 

Petroleum Institute data, October 22, 2008. 

United States Census Bureau . 2007. "2007 NAICS Definitions" . 

United States Department of Energy (DOE). 2006, "Used Oil Re-refining Study to Address Energy Policy Act of 

2005 Section 1838" . 

United Stated Department of Energy (DOE). 2008, "Short-Term Energy Outlook," November 12, 2008 . 

United States Environmental Protection Agency (EPA). 1995, "AP-42, Fifth Edition, Compilation of Air 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 & EPCRA Call Center Training 

11 
Used 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 1286.07 Used 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, Combustor survey database in support of 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 Statement for 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.