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)
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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
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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
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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
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: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.
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