United States
                        Environmental Protection
Solid Waste and
Emergency Response
                                                                          Fall 1991
SEPA       Used  Oil   Recycling
                        EPA Revisits  Used Oil Management
                        Standards and  Listing
In This Issue
• EPA Revisits
  .Used Oil
 * Standards and
M Mobil-izing
  Forces ^
• Amoco
 ".Strives for Oil
 - Recovery
•'State Contacts
 , on Used Oil
• Education +
 "Publicity =
•^Straight from
 ,'the Crankcase
•""EPA Promotes
 |Used Oi!
                             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,

                         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
                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

   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

 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)
 Ms. Christina Shirley
 Pollution Control Specialist
 Hazardous Waste Branch
 Dept. of Environmental Management
 1751 Congressman W.L. Dickinson Dr.
 Montgomery, AL 36130

 Ms. Janet Graham
 Project ROSE Coordinator
 P.O. Box 870203
 Tuscaloosa, AL 35487-0203

 Mr. Dave Wigglesworth
 Dept. of Environmental Conservation
 Haz. and  Solid Waste Management Div.
 P.O. Box O
 Juneau, AK 99811

 Ms. Michelle Diaz
 Administrative Asst.
 Dept. of En vironmental Quality
 Solid Waste Unit
 2005 North Central Ave. G-200
 Phoenix, AZ 85004

 Ms. Jane Schwartz
 Dept. of Pollution Control & Ecology
 Solid Waste Division
 8001 National Drive
 Little Rock, AR 72219

 Mr. Ken Hughes          I
 Integrated Waste Management Board
 8800 Cal Center Drive     ',
 Sacramento, CA 95826     '

 Mr. Lief Peterson
 Dept. of Toxic Substances Control
 Alternative Technology Section
 P.O. Box 942732
 Sacramento, CA 94234-7320

 Dept. of Health
 Public Assistance
 Haz. Materials and Waste MgmL Div.
 4210 East llth Ave.
 Denver, CO 80220

 Mr. Charles Zieminski
Dept. of Environmental Protection
State Office Building
 165 Capitol Ave.
Hartford, CT  06106
 Mr. John Posdon
 Division of Facilities Management
 Energy Office
 P.O. Box 1401
 Dover, DE 19903

 District of Columbia
 Ms. Michelle Fowler
 D.C. Dept. of Energy
 Office of Recycling
 65 K Street, ME
 Washington, DC 20002      :

 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

 Ms. Pam Thomas
 Environmental Protection Division
 Dept. of Natural Resources
 Floyd Towers East Room 1154
 205 Butler Street, SE
 Atlanta,GA 30334

 Ms. Arlene Kabei
 Branch Chief Solid & Hazardous Waste
 Department of Health
 500 Ala Moana Blvd, Suite250
 Honolulu, HI  96813

 Mr. Jerome Jankowski
 Dept. of Health & Welfare
 450 West State Street
 3rd Floor
 Boise, ID 83720

 Mr. James Mergen
 Environmental Protection Agency
 2200 Churchill Road
 P.O. Box 19276             i
 Springfield, IL 62794-9276

 Mr. James Hunt
 Dept. of Environmental Management
 105 South Meridian Street
 Indianapolis, IN 46206

 Mr. Scott Cahail
Dept. of Natural Resources
900 East Grand
Des Moines, IA 50319
 Mr. Sam Sunderraj
 Dept. of Health & Environment
 Solid Waste Division
 Building 740, Forbes Field
 Topeka, KS 66520

 Mr. Charles Peters
 Dept. of Environmental Protection
 Natural Resources & Environmental
 Protection Cabinet
 Frankfort, KY 40601

 Mr. Tom Patterson
 Dept. of En vironmental Quality
 Hazardous Waste Divison
 P.O. Box 82178
 Baton Rouge, LA 70884-2178

 Mr. Richard Kasalis
 Dept. of Environmental Protection
 State House Station #17
 Augusta, ME 04333

 Ms. Debbie Wagner
 Maryland Environmental Services
 2020 Industrial Drive
 Annapolis, MD 21401

 Ms. Cynthia Bellamy
 Division of Solid & Hazardous Waste
 Dept. of Environmental Quality Eng.
 One Winter Street, 5th Floor
 Boston, MA 02108

 Ms. Mindy Koch
 Dept. of Natural Resources
 Waste Management Division
 Resource Recovery Section
 P.O. Box 30241
 Lansing, MI 48909

 Mr. LaAllan Estrem
 Office of Waste Management
 1350 Energy Lane, Suite 201
St. Paul, MN 55108

Mr. Patrick Carey
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155-3898

Mr. David Lee
Office of Pollution Control
Dept. of Environmental Quality
P.O. Box 10385
Jackson, MS 39289-0385

Hazardous Waste Section
Waste Management Program
Dept. of Natural Resources
P.O. Box 176
Jefferson City, MO 65102

Mr. Bill Potts
Solid Waste Management Bureau
Dept. of Health ft Environmental Sciences
Cogswell Building, Room B-201
Helena, MT 59620

Mr. Gene Hanlon
Dopt. of Economic Development
County-City Building
555 South 10th Street
Lincoln, NB 68508

Mr. Curtis Frame!
Ms. Harriet Schallcr
Office of Community Service
Capital Complex
Carson City, NV 89710

New Hampshire
Mr. Michael Wimsatt
Waste Management Division
Dept. of Environmental Services
HiMllh & Welfare Building
6 Hazcn Drive
Conconl.NH 03301

New Jersey
Ms. Ellen Bourton
Office of Recycling
Dopt. of Environmental Protection
850 BoarTavern Road
Trenton, NJ 08625-0414

Now Mexico
Mr. George Beaumont
Solid Waste Bureau
Environmental Department
P.O. Box 26110
Santa Fe, NM 87502

Now York
Mr. Kenneth Brczncr
Dcpl. of Environmental Conservation
Hunters Point Plaza
4740 21st Street
Long bland, NY 11101
North Carolina
Mr. Paul Crissman
Dept. of Environment, Health & Natural Resources
Hazardous Waste Section
P.O. Box 27587
Raleigh, NC  27611

Ms. Maxi May
Southeast Waste Exchange
University of North Carolina at Charlotte
Charlotte, NC 28223

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

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

Mr. Peter Spendeour
Dept. of Environmental Quality
811 SW 6th Avenue
Portland, OR 97204
800-452-4011 (In-State Only)

Mr. Bill LaCour
Dept. of Environmental Resources
Box 2063         :
Hamsburg, PA 17105-2063

Rhode Island
Mr. Eugene Pepper
Dept. of Environmental Management
83 Park Street
Providence, RI 02903

South Carolina
Mr. Robert Fairy  •
Dept. of Health & Environmental Control
2600 Bull Street
Columbia, SC 29201

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
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

Mr. Ken Zarker
Texas Water Commission
Hazardous & Solid Waste Division
P.O. Box 13087, Capitol Station
Austin, TX 78711

Ms. Sandy Hunt
Division of Oil, Gas and Mining
355 West North Temple
3Triad Center, Suite 350
Salt Lake City, UT 84180-1203

Mr. Gary Gulka
Agency of Environmental Conservation
103 South Main Street
Waterbury, VT  05671-0404

Ms. Susan Thomas
Division of Energy
2201 West Broad Street
Richmond, VA  23220

Mr. Steve Barrett
Department of Ecology
Mail Stop PV-11
Olympia,WA 98504-8711

West Virginia
Mr. Dale Moncer
Community Development Office
Dept. of Natural Resources
Fuels & Energy Office
1204 Kanawhas Blvd.
2nd Floor
Charleston, WV 25301

Mr. Paul Koziar
Dept. of Natural Resources
Bureau of Solid & Hazardous Waste Management
P.O. Box 7921SW-3
Madison, WI 53707-7921

Mr. Carl Anderson
Solid Waste Management Program
Dept. of Environmental Quality
Henschler Building
122 West 25th Street
Cheyenne, WY 82002

: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.           :
                               •  . 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 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.