United States Environmental Protection Agency Solid Waste and Emergency Response (OS-305) EPA/530-SW-91-071 Fall 1991 SEPA Used Oil Recycling EPA Revisits Used Oil Management Standards and Listing In This Issue • EPA Revisits .Used Oil Management * Standards and .'.Listing M Mobil-izing Recycling Forces ^ • Amoco ".Strives for Oil - Recovery •'State Contacts , on Used Oil ^Recycling • Education + "Publicity = '•Recycling •^Straight from ,'the Crankcase *t •""EPA Promotes |Used Oi! Recycling The U.S. Environmental Protection Agency (EPA) is in the process of determining the most practical methods for managing used oil to protect human health and the environment while encouraging recycling of this valuable re- source. Those who are involved in used oil management have been concerned about a possible change in the regulatory status of used oil from a nonhazardous to a hazardous waste. Hazardous wastes are stringently regulated under the Resource Conservation and Recovery Act (RCRA). Many fear that a hazardous waste designation would make it difficult to develop collection systems for Do- It-Yourselfer plY) used oil. On September 23,1991, EPA issued a notice in the Federal Register that requested com- ments on the latest data bearing on whether to add used oil to the list of wastes determined to be hazardous under RCRA. The notice also proposed alternative standards for used oil management. These issues may have impli- cations for service station dealers and others involved in DIY used oil recycling. This notice expanded and clarified a 1985 proposal re- garding used oil. (The public comment period on the September notice ended November 7, 1991.) The proposed management options are ba- sic "housekeeping" guidelines designed to mitigate the effects of improper d isposal, stor- age, and recycling of used oil. If promulgated, they would apply to all handlers of used oil, including generators, transporters, recyclers, marketers, burners, and disposal facilities. They would require used oil generators and collectors of DIY-generated used oil (e.g., service stations) to: • Inspect for and clean up any spills or leaks associated with storage and transportation of recycled used oil. • Keep records on the used oil's origin, trans- portation, and destination. • Report all used oil recycling and disposal activities. The 1985 notice proposed exempting small quantity generators (those who generate less than 300 gallons of used oil per month) from the most substantive of the management standards if they recycle used oil. The new proposal presented two potential alternatives for public comment. The first option would be to remove the distinction between large and small quantity generators. All generators would be treated equally as described above. This option would eliminate the need for measuring quantities of used oil collected and stored each month. It also would alleviate the concern that genera tors could be bumped into a more stringent regulatory category if they collect DIY-generated used oil. The result is essentially a system whereby all used oil is collected, recycled, and managed in an environ- mentally sound manner, thus reducing haz- ards to human health and the environment. This first option also would exempt service station dealers from liability under the Compre- hensive Environmental Response, Compensation, and Liability Act (CERCLA), or "Superfund," the federal laio governing the cleanup of hazardous waste, if they comply with the management stand- ards and accept DIY-generated used oil. This ex- emption could be beneficial to dealers because CERCLA liability can mean unex- pected one-time costs for spill remediation, whereas the costs associated with the man- agement standards are for preventive actions and therefore are more predictable and amenable to advance planning. Used Oil Recycling is printed on recycled paper. (Continued on page 4) ------- Focus on Corporate America Jn 2990, hoo major oil companies, Amoco Oil Company and Mobil Corporation, started pilot used oil collectionl programs at many of their service stations. Since their beginning, these programs have expanded greatly,\ providing Do-it-yourselfers (DIYs) with convenient recycling depots in many communities across the nation.} Both Amoco's and Mobil's used oil collection programs operate on three guiding principles: (1) DIYs can bring theirl used oil to any participating service station free of charge, (2) no purchase is necessary, and (3) both Amoco and Mobill service stations accept all used motor oil regardless of the brand. Moreover, station attendants bear responsibility fort handling the used oil once it is brought in and for pouring it into receptacles for pickup. Both companies limit thel amount of oil a person can return to 5 gallons per trip, and DIYs at Mobil must sign a register certifying that the oill they are recycling is not contaminated. Amoco and Mobil ask DIYs to deliver their used oil in clean plastic containers! with caps (such as milk jugs or plastic oil bottles) for easy handling. The efforts of both Amoco Oil Company andl Mobil Corporation show that effective management ofDIY used oil is not only an important environmental goal, but\ increasingly a reality. Mobil-izing Recycling Forces In October 1990, Mobil Corporation began its used oil acceptance program with a pilot pro- gram involving stations in Florida and metropolitan Washington, DC. A national adver- tising campaign helped spread the word about the pilot program. The campaign featured a 7-second spot at the end of the company's motor oil television commercials that strongly urged motorists to return their used oil at designated recovery sites. According to Carl Gerster, Mobil Corporation spokesperson for the program, two concerns prompted Mobil to start the program. One, Mobil saw a chance to address a serious en- vironmental problem in an inexpensive, but effective manner. Also, the corporation wanted to be proactive and show that private industry could solve a problem without further government regulations. Gerster has been traveling throughout the United States promoting Mobil's used oil program in different regions of the nation. He conducts informative, educational sessions with independent dealers and provides technical assistance in es- tablishing a collection system. Through these sessions, Mobil is striving to incorporate the used oil recycling program direct- ly into its existing framework. Many full-service Mobil sta- tions—those that provide comprehensive automobile service—already recycle used oil from car repairs and oil chan- ges; the new program increases the amount of used oil gathered and turned over to state-licensed collectors. Gerster said that some service stations have reported 20 to 30 percent increases in the amount of used oil turned in per month since the pro- gram began. Thus far there have been no incidents of used oil contamina- tion, and overall, the program is running smoothly. The sole problem encountered by some Mobil dealers so far is the dropoff of oil after business hours when there are no attendants present. By the end of the third quarter of 1991, over 850 Mobil stations were accepting used oil for recycling. Although the program is voluntary for independent Mobil dealers and distributors, most of them have welcomed the additional flow of potential customers represented by the par- ticipating DIYs. "It's a win-win situation: win for the environ- ment and additional sales opportunities for the dealer," Gerster said. "We've had good success. The people bringing their oil in are happy to do it." Amoco Strives for Oil Recovery Amoco Oil Company launched a pilot collec- tion program in April 1990, that involved 34 full facility service stations in Illinois. Due to the success of the pilot at these service sta- tions, the company extended the program to hundreds of more stations in Florida, as well as the metropolitan areas of Chicago, St. Louis, and Washington, DC / Baltimore, by the end of 1990. In designing its used oil recycling program, Amoco was primarily motivated by a desire to provide consumers with a place to take used oil, according to Terri Mohsenzadeh, spokesperson for Amoco's program. "We wanted to show that a large corporation, without [government] regulations, can act and help solve this problem," Mohsenzadeh said. The collection program constitutes an important part of Amoco's company-wide environmental action policy. A significant key to the overall success of used oil recycling programs is that consumers want to do the right thing environmentally. Amoco currently has plans to expand its program, al- though details have not yet been announced. Although no exact figures are available on the amount of used oil col- lected, Mohsenzadeh asserted that the program's success is clearly demonstrated by the public praise and positive com- ment the company has received, as well as by the high participation rate of Amoco dealers. About 75 percent of independent Amoco dealers equipped with used oil storage tanks have chosen to undergo a brief training period and establish a collection site at their station. In addition, many states have invited the company to set up the collection program in their cities and towns. Amoco reports only two incidents of contaminated oil, one of which was the fault of service station attendants. Most of the difficulties experienced by Amoco during the implementation process have come from complying with ------- STATE CONTACTS ON USED OIL RECYCLING The following list contains EP A's most recent directory of state used oil recycling contacts. Contacts, if your name, address, or phone number is incorrect or if there are others who should be included on the list, please inform Charles Franklin (OS-305), Office of Solid Waste, 401M Street SW., Washington, DC 20460, (202) 260-4646. (Updated July 30,1991) Alabama Ms. Christina Shirley Pollution Control Specialist Hazardous Waste Branch Dept. of Environmental Management 1751 Congressman W.L. Dickinson Dr. Montgomery, AL 36130 205-271-7746 Ms. Janet Graham Project ROSE Coordinator P.O. Box 870203 Tuscaloosa, AL 35487-0203 205-348-1735 Alaska Mrjefflngells Mr. Dave Wigglesworth Dept. of Environmental Conservation Haz. and Solid Waste Management Div. P.O. Box O Juneau, AK 99811 907-465-2671 Arizona Ms. Michelle Diaz Administrative Asst. Dept. of En vironmental Quality Solid Waste Unit 2005 North Central Ave. G-200 Phoenix, AZ 85004 602-257-2349 Arkansas Ms. Jane Schwartz Dept. of Pollution Control & Ecology Solid Waste Division 8001 National Drive Little Rock, AR 72219 501-562-6633 California Mr. Ken Hughes I Integrated Waste Management Board 8800 Cal Center Drive ', Sacramento, CA 95826 ' 916-255-2347 Mr. Lief Peterson Dept. of Toxic Substances Control Alternative Technology Section P.O. Box 942732 Sacramento, CA 94234-7320 916-324-1807 Colorado Dept. of Health Public Assistance Haz. Materials and Waste MgmL Div. 4210 East llth Ave. Denver, CO 80220 303-331-4400 Connecticut Mr. Charles Zieminski Dept. of Environmental Protection State Office Building 165 Capitol Ave. Hartford, CT 06106 203-566-4633 800-842-2220 Delaware Mr. John Posdon Division of Facilities Management Energy Office P.O. Box 1401 Dover, DE 19903 302-739-5644 800-282-8616 District of Columbia Ms. Michelle Fowler D.C. Dept. of Energy Office of Recycling 65 K Street, ME Washington, DC 20002 : 202-727-5856 Florida Ms. Betsy Galocy Dept. of Environmental Regulation Solid & Hazardous Waste Section Twin Towers Office Building 2600 Blair Store Road, Room 479 Tallahassee, FL 32399-2400 904-488-0300 Georgia Ms. Pam Thomas Environmental Protection Division Dept. of Natural Resources Floyd Towers East Room 1154 205 Butler Street, SE Atlanta,GA 30334 404-656-0772 Hawaii Ms. Arlene Kabei Branch Chief Solid & Hazardous Waste Department of Health 500 Ala Moana Blvd, Suite250 Honolulu, HI 96813 808-548-6455 Idaho Mr. Jerome Jankowski Dept. of Health & Welfare 450 West State Street 3rd Floor Boise, ID 83720 208-334-5855 .Illinois Mr. James Mergen Environmental Protection Agency 2200 Churchill Road P.O. Box 19276 i Springfield, IL 62794-9276 217-782-8700 Indiana Mr. James Hunt Dept. of Environmental Management 105 South Meridian Street Indianapolis, IN 46206 317-2324535 Iowa Mr. Scott Cahail Dept. of Natural Resources 900 East Grand Des Moines, IA 50319 515-281-8263 Kansas Mr. Sam Sunderraj Dept. of Health & Environment Solid Waste Division Building 740, Forbes Field Topeka, KS 66520 913-296-1609 Kentucky Mr. Charles Peters Dept. of Environmental Protection Natural Resources & Environmental Protection Cabinet ISReillyRoad Frankfort, KY 40601 502-564-6716 Louisiana Mr. Tom Patterson Dept. of En vironmental Quality Hazardous Waste Divison P.O. Box 82178 Baton Rouge, LA 70884-2178 504-765-0246 Maine Mr. Richard Kasalis Dept. of Environmental Protection State House Station #17 Augusta, ME 04333 207-289-2651 Maryland Ms. Debbie Wagner Maryland Environmental Services 2020 Industrial Drive Annapolis, MD 21401 301-974-7254 800-482-9188 Massachusetts Ms. Cynthia Bellamy Division of Solid & Hazardous Waste Dept. of Environmental Quality Eng. One Winter Street, 5th Floor Boston, MA 02108 617-292-5848 Michigan Ms. Mindy Koch Dept. of Natural Resources Waste Management Division Resource Recovery Section P.O. Box 30241 Lansing, MI 48909 517-3354090 Minnesota Mr. LaAllan Estrem Office of Waste Management 1350 Energy Lane, Suite 201 St. Paul, MN 55108 612-649-5750 Mr. Patrick Carey Minnesota Pollution Control Agency 520 Lafayette Road St. Paul, MN 55155-3898 612-297-8320 800-652-9747 ------- Mississippi Mr. David Lee Office of Pollution Control Dept. of Environmental Quality P.O. Box 10385 Jackson, MS 39289-0385 601-961-5377 Missouri Ms.JuncSullens Hazardous Waste Section Waste Management Program Dept. of Natural Resources P.O. Box 176 Jefferson City, MO 65102 314-751-3176 800-334-6946 Montana Mr. Bill Potts Solid Waste Management Bureau Dept. of Health ft Environmental Sciences Cogswell Building, Room B-201 Helena, MT 59620 •106-144-1430 Nebraska Mr. Gene Hanlon Dopt. of Economic Development County-City Building 555 South 10th Street Lincoln, NB 68508 402-171-7043 Nevada Mr. Curtis Frame! Ms. Harriet Schallcr Office of Community Service Capital Complex Carson City, NV 89710 702-687-4908 New Hampshire Mr. Michael Wimsatt Waste Management Division Dept. of Environmental Services HiMllh & Welfare Building 6 Hazcn Drive Conconl.NH 03301 603-271-2942 New Jersey Ms. Ellen Bourton Office of Recycling Dopt. of Environmental Protection CN-414 850 BoarTavern Road Trenton, NJ 08625-0414 609-530-4001 Now Mexico Mr. George Beaumont Solid Waste Bureau Environmental Department P.O. Box 26110 Santa Fe, NM 87502 505-827-2775 Now York Mr. Kenneth Brczncr Dcpl. of Environmental Conservation Hunters Point Plaza 4740 21st Street Long bland, NY 11101 718-482-4996 North Carolina Mr. Paul Crissman Dept. of Environment, Health & Natural Resources Hazardous Waste Section P.O. Box 27587 Raleigh, NC 27611 919-733-0692 Ms. Maxi May Southeast Waste Exchange University of North Carolina at Charlotte Charlotte, NC 28223 704-547-2307 North Dakota Mr. Curtis Erickson Division of Waste Management Dept. of Health 1200 Missouri Avenue P.O. Box 5520 Bismarck, ND 58502-5520 701-221-5166 i Ohio Mr. ArtCoIeman ' Environmental Protection Agency 1800 Water Mark Dr. Columbus, OH 43266-0149 614-644-2956 ' Oklahoma ' Mr. Bryce Hulsuy Solid Waste Management Service Dept. of Health P.O. Box 53551 Oklahoma City, OK 73152 405-271-7193 Oregon Mr. Peter Spendeour Dept. of Environmental Quality 811 SW 6th Avenue Portland, OR 97204 503-229-5253 800-452-4011 (In-State Only) Pennsylvania Mr. Bill LaCour Dept. of Environmental Resources Box 2063 : Hamsburg, PA 17105-2063 717-787-7382 Rhode Island Mr. Eugene Pepper Dept. of Environmental Management 83 Park Street Providence, RI 02903 401-277-3434 South Carolina Mr. Robert Fairy • Dept. of Health & Environmental Control 2600 Bull Street Columbia, SC 29201 803-734-5915 South Dakota Ms. Kerry Jacobson Dept. of Water & Natural Resources Office of Waste Management Programs 319 S. Coteau c/o 500 East Capital Pierre, SD 57501 605-773-3153 Tennessee Mr. Mike Apple State of Tennessee Dept. of Health & Environment Division of Solid Waste Management 701 Broadway, 4th Floor Nashville, TN 37247-3530 (615) 741-3424 Texas Mr. Ken Zarker Texas Water Commission Hazardous & Solid Waste Division P.O. Box 13087, Capitol Station Austin, TX 78711 512-463-7751 512-463-7761 Utah Ms. Sandy Hunt Division of Oil, Gas and Mining 355 West North Temple 3Triad Center, Suite 350 Salt Lake City, UT 84180-1203 801-538-5340 Vermont Mr. Gary Gulka Agency of Environmental Conservation 103 South Main Street Waterbury, VT 05671-0404 802-244-8702 Virginia Ms. Susan Thomas Division of Energy 2201 West Broad Street Richmond, VA 23220 804-367-0928 800-552-3831 Washington Mr. Steve Barrett Department of Ecology Mail Stop PV-11 Olympia,WA 98504-8711 206-459-6286 West Virginia Mr. Dale Moncer Community Development Office Dept. of Natural Resources Fuels & Energy Office 1204 Kanawhas Blvd. 2nd Floor Charleston, WV 25301 304-348-6350 Wisconsin Mr. Paul Koziar Dept. of Natural Resources Bureau of Solid & Hazardous Waste Management P.O. Box 7921SW-3 Madison, WI 53707-7921 608-266-5741 608-267-9388-Direct Wyoming Mr. Carl Anderson Solid Waste Management Program Dept. of Environmental Quality Henschler Building 122 West 25th Street Cheyenne, WY 82002 307-777-7752 ------- :ensing procedures, which in some states are more cumber- >me than in others. Mohsenzadeh points to the positive consumer response to e program as an indication that improper used oil disposal in be checked effectively. She believes that a significant key the overall success of the program is that consumers want do the right thing environmentally. Education + Publicity = Recycling ; Both Amoco and Mobil have undertaken stroiiig educational efforts to complement the collection coi}i- i ponent of their programs. These corporations Relieve that education is necessary to inform the public about tljie risks associated with improper oil disposal 'and instill 'environmentally sound disposal practices in individuals. In fact, the majority of costs incurred by Mobil and Amoco in implementing their used oil collection programs have stemmed from educational efforts. j Amoco has aired television public service an- nouncements, printed pamphlets, and published fijll page newspaper ads in those areas where the AmoCo ^collection program operates. In September 1991, Molj>il plans to resume its television advertising campaign, which the company broadcast in 1990 at theistart of its collection program. In addition, Mobil has published 4n "Environmental Awareness" brochure that explains the proper methods of used oil disposal. ! ! , Carl Gerster of Mobil Corporation remarked that, in : Europe, returning used oil has become a standard prac- tice for DIYs, while in the United States, onlyllO percent ,of DIY used motor oil is properly collected and sent cjff for recycling. Gerster believes that a dynamic edu- cational campaign and convenient collection locations iare ways to make recycling a habit as it is in Europe arid to address the problems of improperly managed used oil. Straight from the Crankcase • Pennzoil Company sponsored the reprinting and distribution of over 20,000 copies of EPA's pamphlet, Recycling Used Oil: 10 Steps to Change Your Oil (EPA/530-SW-89-039C), to encourage used oil recycling efforts. • AAA Potomac, a division of the American Automobile Association, distributed 1,200 copies of another EPA pamphlet, Recycling Used Oil: What Can You Do? (EPA/530-SW-89-039B), to AAA's seven service centers in the metropolitan Washington, DC, area in an effort to increase recycling of used oil generated by DIYs. : I • . In addition, EPA published a third pamphlet in the series, Recycling Used Oil: For Service Stations and Other Vehicle-Service Facilities (EPA/530-SW-89- 039D), and a manual, How to Set Up a Local Program to Recycle Used OH (EPA/530-SW-89-039A). EPA encourages the copying and distribution of all the above publications. To obtain free copies, call EPA's RCRA/Superfund Hotline at (800) 424-9346 Monday through Friday, 8:30 a.m. to 7:30 p.m. EST. For the hearing impaired, call TDD (800) 553-7672. Locally, call (703) 920-9810, or TDD (703) 486-3223. You may also write to: RCRA Information Center (OS-305), U.S. Environmental Protection Agency, 401 M Street, SW., Washington, DC 20460. ------- (Continued from page 1) ,, • , The second option outlined in the recent proposal would be to use storage capacity as the distinguishing characteristic between small and large quantity generators. Under this sec- ond option, generators with total aboveground storage capac- ity of less than 1,320 gallons or underground storage capacity of less than 110 gallons would be considered small generators and exempt from the used oil management standards if they recycle the used oil they generate. Generators must document that they are recycling the oil on site or that they have a contract with a recycling firm. This option would allow small businesses to accumulate enough used oil to meet minimum requirements for pickup set by used oil collectors. It also would require less recordkeeping for small businesses and make determination of compliance easier for inspectors. In addition to the options on alternative management standards, EPA presented new data that will be used in deter- mining whether to list used oil as a hazardous waste. In 1986, EPA decided not to designate used oil that is being recycled as a hazardous waste due to the potential stigma that might be attached to a hazardous waste listing, which could discourage recycling and consequently result in increased incidences of improper disposal. In 1988, this decision was challenged, and a court ruling required EPA to base its listing determination solely on technical criteria. In light of the new data in the notice, EPA presented three listing options for comment: listing all, some, or no used oils. Regardless of the listing decision, DIY used oil collectors will not be liable under RCRA, because DIY used oil is a household waste and RCRA Joes not apply to this type of waste. In addition, regardless of the listing decision, EPA proposed that the management standards discussed in the notice apply to all used oils. EPA's proposal was based on the view that all used oils can pose some degree of risk to human health and the environment when mismanaged, and thus need to be subject to some type of management standards, two options for which were presented in the notice. For a copy of the September 23,1991, Fedei-al Register notice (docket number F-91-UOLP- FFFFF), call EPA's RCRA/Superfund Hotline at (800) 424-9346. For the hearing impaired, call TDD (800) 553-7672. Locally, call (703) 920-9810, or TDD (703) 486-3223. You may also write to: RCRA Docket Information Center (OS-305) U.S. Environmental Protection Agency 401 M Street, SW. Washington, DC 20460 Also, if you want to be included on the Used, Oil Recycling mailing list, please write to the above address. EPA Promotes jUsed Oil Recycling ! ' I j EPA's proposal also: identified and requested porh- ments on five possible; approachesjfor promoting the collection and recycling of DIY-generated used ojl and the maximum recycling of non-DlY ysed oil: | • Used oil generators and lube oil retailers may be required to accept DIY used oil for recycling and to post signs indicating that they accept this oil. They may also have to check DIYJgen- erated oil for evidence of mixing and maintain collection containers in compliance with |stor- age standards. . I | •'! ; i • Used oil recycles and rerefiners may b|e re- quired to collectJDIY used oil jhrough progjraniis organized through the community or municipal- ity, or with civic organization?. They may jhave to check the oil f ar evidence c-f mixing and [keep records of annual quantities'of DIY-genefated oil accepted. Tpey may also pave to report the disposition of D^Y-generatedjused oil. | '• , i • • Oil producers nhay be requited to recycle, or arrange for the recycling of, specific quantities of DIY used oil. They may hajve to register with EPA, report anrjually on whether projected re- cycling targets were met, apd provide docu- mentation to support compliance. j • ! '. • • Lube oil producers may havp to meet a man- datory recycling ratio established annually by EPA. For example, producers^ could recycljethe used oil themsjelves, purchase rerefin^d oil from rerefiners: or processors, or purchase "used oil recycl ng credits" from rerefine;rs or processors af a price set b|y market fo'rces. Each credit cou d equal a unjt of used oil recy- cled; producers would need to acquire enjough credits to meet the established recycling ratio. • A system may be created inj which customers would pay a deposit 6n certain quantities of oil purchased. The deposit could be redeemed when the used oil is returned for recycling. EPA plans to analyze comments, study the above and other approaches,! and then m^y propose ope or more options for further public comment. | The mention of publications, products, or organiza- tions in this newsletter does not constitute endorse- ment or approval for use by the U.S. Environmental Protection Agency. ------- |