PB-237 618

                             DISTRIBUTED BY:
                             National Technical Information Service
                             U. S. DEPARTMENT  OF  COMMERCE

1. Report No.
PB   237   618
. Title and Subtitle
  Part  I:   Federal Research on  Waste Oil from Automobiles
                                                  5. Report Date
                                                   October, 1973
  Peter  M.  Cukor, Michael John  Keaton, Gregory Wilcox
                                                  6. Performing Organization Kept.
 Performing Organization Name and Address
  Teknekron, Inc. and The Institute of Public Administration
  2118  Milvia Street
  Berkeley, California   94704               7 '  '
                                                  10. Project/T.slc/Work Unit No.
                                                  11. Contract/Grant No.
                                                    EPA Contract No:
2. Sponsoring Organization Name and Address
                                                  13. Type of Report 8t Period
                                                     Final 1 year
 5. Supplementary Notes
6. Abstracts
                                          a    W-«W-                            .y ,
   A summary of  Federal Research .concerning waste  oil from automobiles.  J- '
   Contains an annotated bibliography  of publications concerning waste
   oil disposal. "
17. Key Words and Document Analysis.  17o. Descriptors

   Secondary Oil Recovery, Economic Analysis
17b. Identifiers/Open-Ended Terms

   Waste oil re-refining, recycling, re-refining industry analysis
 I7e. COSAT! Field/Group
18. Availability Statement
                                       19.. Security Class (This
                                                           „  ^
                                                           20. Security Class (This
             21. No. o.f Page*
                                THIS FORM MAY BE REPRODUCED




                   OF WASTE OIL RECOVERY
  Part I:   Federal  Research on Waste 011 from Automobiles
           This report (SW-90c.l) was written by
Teknekron, Inc., arid The Institute of Public Administration
               under contract no. 68-01-1806


This report has been reviewed by the U.S. Environmental Protection Agency.
Its publication does not signify that the contents necessarily reflect the
views and policies of the U.S. Environmental Protection Agency, nor does
mention of commercial products constitute endorsement or recommendation
for use by the U.S. Government.

An environmental protection publication  (SW-90c.l) 1n the solid waste
management series.

The report A Technical and Economic Study of Waste 011
Recovery, prepared by Teknekron, Inc. and The Institute
of Public Administration under EPA Contract 68-01-1806,
has been published 1n three separate volumes under the
following titles:

A Technical and Economic Study of Waste Oil Recovery  -
Part I:  federal Research on Waste Oil From Automobiles

A Technical and Economic Study of Haste Oil Recovery  -
Part II;  An  Investigation of Dispersed Sources of Used
Crankcase Oils

A Technical and Economic Study of Haste 011 Recovery  -
Part III:  Economic,  Technical and InstltuttonaT
Barriers to Waste Oil Recovery
                                 Preceding page blank

                            TABLE OF CONTENTS
     1.1   Introduction	1
     1.2  Summary	,	1
3.0  CONGRESS	......	9
     3.1   Statutes	9
     3.2  Bills	9
     3.3  General Accounting Office	10
     5.1  Background	.	13
     5.2  Projects	14
     6.1  Interest and Background	»	21
     6.2  Organization and Personnel	21
     6.3  Present Programs	<	.23
     6.4  In-House Research and Past Studies...	...28
     7.1  Background	31
     7.2  Interest.	31
     7.3  Present Program	33
     7.4  Organization and  Key Personnel	33
     8.1  Background	.35
     8.2  Interest	? 35
     8.3  Projects	36
     8.4  Organization and  Key Personnel	36
     9.1  Background and  Interest	37
     9.2  Projects.	37
     9.3  Organization and  Key Personnel	38


                     TABLE OF CONTENTS  (continued)
      10.1   Background		39
      10.2   Interests			39
      10.3   Projects	,	39
      10.4   Organization and Key Personnel	40
      11.1   Background		41
      11.2   Interest	43
      11.3   Projects	 .43
      11.4  Key Personnel —	43
APPENDIX A:  Section 104(m) of the Federal Hater Pollution Control
             Act Amendments of 1972.	59
APPENDIX B:  National 011 Recycling Act	61
APPENDIX C:  Annotated Bibliography of Publications Concerning
             Waste 011 Disposal	79

                      1.0 INTRODUCTION AND SUMMARY
1.1  Introduction

     As with many other problems of national  Importance, concern over the
environmental effects of the disposal  of used automotive crankcase oil  has
spawned a variety of research projects 1n a number of agencies of the feder-
al government.  In addition to the obvious participation of the Environmen-
tal Protection Agency, the Departments of Defense, Interior, Commerce and
Treasury, the General. Services Administration, the Federal  Trade Commission,
the Postal Service, the White Mouse and the Congress have all been involved
to a significant degree in efforts concerned with finding solutions to the
waste oil disposal problem.  Unfortunately, there 1s little coordination of
these efforts amongst the agencies involved and even within an agency there
is a tendency for inadequate communication regarding ongoing research acti-
vities.  It  is apparent that time and money could be utilized more efficient-
ly if those  concerned with research on waste oil disposal could be made aware
of the scope and direction of similar projects 1n the various branches of
the government.

     This report seeks to achieve this goal by Identifying and describing
in some detail current and recent federal Investigations related to the waste
oil problem.  By drawing together disparate strands of  Information concerning
waste oil research programs, 1t 1s possible both to avoid duplication of ef-
fort and to  guide future strategy.  Through extensive conversations with pro-
ject officers and contractors, a 11st of federal research programs concerned
with the disposition of waste oil from automobiles has  been  compiled.  A
summary of  these efforts 1s  presented 1n Table 1.

     Appendix C to this report consists of an annotated  bibliography covering
a  very wide  range of publications which have resulted from  federal research
efforts on  used oil disposal.   In addition,  the  bibliography contains refer-
ences  to a  number of reports prepared by organizations  outside  of  the federal
government.   Information contained in these  reports  bears directly on current
studies being carried  out  by federal agencies.   By  providing abstracts of
relevant publications,  it  is possible to locate  and  analyze efforts  already
performed upon whose results broad federal policy concerning waste lube  oil
disposal and future  research programs can  be based.
 1.2  Summary

      The material in this report is summarized in Table 1.   Two sets of con-
 clusions can be drawn by examining the entries in the table - one by reading
 down the columns and the other by reading across the rows.   The columns, which
 represent different functional cuts at the waste oil problem, show that three
 elements have received little attention by Interested federal agencies.   First,

there has been little research on the environmental Impacts of various  Kaste
oil disposal practices.  EPA has been the sole supporter of work In tills
area, and even Its projects have received a relatively lea level of funding.
Data on this element of the waste oil problem 1s crucial because knowledge
of the environmental damages resulting from waste oil disposal permits  the
determination of the cost- effectiveness of research directed at this par-
ticular pollutant.

     Second, federal research efforts have failed to analyze the economics
of today's re-refining Industry.  Although there has been no lack Of economic
evaluation of new re- refining technology, no study of the existing Industry
as an economic system has been made.  Obviously, any federal efforts to en-
courage recycling of waste oil cannot be effective with such an overview.
Part III of the present stufy provides the first quantitative snatysls  of the
economics of the re-refining lij&stry GS It
     Thirdly, little or no effort has been directed toward the establishment
of an overall national policy on waste oil -- both fno pollution control re-
source conservation viewpoints.  Two modest EPA studios are the only fodoral
efforts now being made In this area.  It Is hoped that this analysis of federal
waste oil  research activities may be a beginning step in developing a rational
and  coordinated  federal policy on the dlspostton of this valuable resource.

     Reading across the rows shows the activities of the many federal agencies
with an Interest in waste oil disposal.  The Defense Department and the En-
vironmental Protection Agency are the leaders 1n research on this Issue.  The
Military's Involvement has resulted both from Its role as the nation's largest
consumer of lube oil and producer of waste oil, and frtcn Us responsibility for
establishing quality specifications for and for actual procurement of lube oils
required by all  federal agencies.  Several other federal agencies are also
Involved because they, too, are  large customers of lube oil.  Thase groups In-
clude the  General Services Administration, the Department of Agriculture and
the  Postal Service.  The  Involvement of several other agencies  has baen related
to their normal  functions, such  as the Treasury Department, which has interpreted
the  excise tax  liability  of buyers and producers of lube oil and the Federal
Trade Commission, which  1s now reconsidering the labelling requlrentants for re-
refined oils.   Agencies which  have the potential to become major participants
 1n forming new policies on waste oil, such as the Department of Cicpiarce and tha
National  Science Foundation,  have also revlewsd  problems related to  the disposal
and  recovery of waste  oils.
    "A Technical and Economic Study of Haste 011 Recovery - Part III: An Analysis
    of Economic, Technical and Institutional Barriers to Haste 011 Recovery;"
    Teknekron, Inc.; EPA Contract Mo. 68-01-1806; October 1973.

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                             2.0  WHITE HOUSE
     Just after Us creation 1n 1970*, the White House Council  on Environmental
Quality (CEQ) put together an inter-agency task force to study  the need for new
federal policy on waste oil disposal.  However, the CEQ staff shelved the Is-
sue following a preliminary evaluation of the expected problems and probable
benefits.  Since that time CEQ has done very little on waste oil and has no
plans to revive the issue in the near future.

     CEQ was discouraged from developing new waste oil policy for two reasons:
product quality and environmental Impact.  In the area of product quality, it
could not get adequate technical data on the quality of re-refined lube oil,
and the data that was available appeared to show that re-refined oil was fre-
quently inferior.  In particular, the complete removal of additives from waste
oil seemed to be extremely difficult.  As for environmental impact, CEQ could
not get any evidence that current waste oil disposal practices  were causing
significant damage.  With damages unclear and no promising alternative use for
waste oil, 1t was felt that compared to other pollutants waste oil did not merit
the effort required to deal with it.

     Although the CEQ task force effort was scrapped, the  investigation resulted
in a CEQ request to the Defense Department to look  into the use and possible
procurement of reprocessed lube oil.  This request  eventually  led to a proposal
by the Defense Supply Agency to conduct a major study of re-refined o1lz.

     Staff responsibility  for  the Issue of waste oil disposal  has shifted
several  times since CEQ's  creation.  William MatuszesM was the staff  assis-
tant in  charge when the 1970 inter-agency task force was active.  The  FTC,
GSA, Bureau of Mines, Treasury Department, and EPA  were Included  1n the dis-
cussions.  Responsibility  was  then  shifted to  Eric Zausner and recently  to
Steffen  Plehn, who now has responsibility for  the files developed during  CEQ's
past waste oil  investigations.   Last fall, Plehn made a brief  review of devel-
opments  in the  field, but  decided that  the situation  had not changed enough  to
warrant  renewed  CEQ  interest.  The  product quality  and  environmental Impact
issues continue  to be seen as  major obstacles.

                              3.0  CONGRESS
     Congress 1s the source of much of the Increasing Interest 1n waste oil.
It has mandated a thorough EPA study of waste oil  and has raised many of the
Issues and new policy Ideas now being widely considered.   In addition, the
General Accounting Office recently began a survey of waste oil disposal prac-
tices at federal facilities.

3.1  Statutes3
     The most Important recent enactment concerning research on waste oil
was the passage last fall of amendments to the Federal Water Pollution Con-
trol Act2*.  Section 104(m) directs EPA to study waste oil:  present disposal
practices, biological impacts, and future possibilities for  use.  Preliminary
results of EPA's study were reported last AprilS and final results are requir-
ed by April 15, 1974.

     The waste oil study provision was written Into the law largely at the
insistence of Sen. J. Caleb Boggs (R-Del.) who had been concerned with the
issue since 19676.  However, Sen. Boggs was not returned to the Senate in
the 1972 election, and the Senate lost Its leading proponent of improved waste
oil disposal practices.

3.2  Bills
      In the House,, Congressman Charles A. Vanik (D-Ohio) has led the crusade
on waste oil but so far has failed to get his proposals enacted.  This year
he introduced a comprehensive bill, the "National Oil Recycling Act", to con-
trol  waste oil pollution and conserve resources.'  A major provision of the
bill  would reform the excise tax treatment of lubricating oils by abolishing
the current tax exemption  enjoyed by virgin lube oil that is not used in high-
way vehicles.  The bill would also change the labeling requirements for re-
refined oil imposed by the Federal Trade Commission, prohibit oil companies
from  restricting  their  service  stations from  selling recycled oil,  encourage
Federal procurement of recycled oil, and force all lube oil retailers to pro-
vide  disposal facilities and to sell only in returnable containers.8

      Many of the provisions in Vanik's bill are similar to provisions in other
bills either now pending in Congress or introduced in the past.  Bills to  re-
form  the excise tax treatment of lube oils were introduced in the Senate this
                                            Preceding page blank

year by Senator Strom Thurmond (R-S.C.)9 and 1n the House by Congressman Joseph
P. Vigorlto (D-Pa.)10.  These measures would allow re-refiners to be exempted
from payment of excise taxes on virgin oil that they buy to blend with their
re-refined oil".  A bill to exempt lube oil, that meets certain performance
specifications, from burdensome FTC labeling regulations was Introduced by Sen.
Boggs in 1968*2.  NO action was taken.

3.3  General Accounting Office

                                                                        i .•
     The General Accounting Office (GAO), an agency of the U. S. Congress, be-
gan an exploratory survey of waste oil disposal by federal facilities 1n July
1973.  Some  $25,000 will be spent to conduct, and analyze the results of, staff
visits to federal facilities In a specific region of the country.  The objec*-
tive is to evaluate the need for a broader national study which would result in
a  formal report  to Congress.  The survey will attempt to determine what 1s cur-
rently being done with waste oil and whether preferable disposal alternatives
exist.  The results of the  survey should be available by October, and a de-
cision on a full-scale,nation-wide review 1s expected soon thereafter.

     The GAO survey grew out of the agency's past review of  EPA's implementation
of the Solid Waste Disposal Act.  Recent  Interest 1n energy  supplies and oil
imports led GAO  to consider an examination of waste lube oil.  The  project was
undertaken on  GAO's own  Initiative and  not at the direction  of Congress.

      For administrative  reasons, the work will  be directed from  the GAO Seattle
regional office.  Field  Investigations  will  be  limited  to two states, Washing-
ton and Oregon,  and to three federal  agencies,  Defense,  Postal Service, and
General Services Administration.  However,  since the survey  1s meant  to be
exploratory, other agencies and states  may  be  Included  1f the problem or  poten-
tial  solutions appear to be outside the original boundaries. Of the  200  man
days alloted to the project,  150 will be spent  In  Seattle and 50 for  the  pro-
ject review  1n Washington,  D.  C.

      J.  Kevin  Donohue,  an Audit Manager 1n  the Resource and  Economic  Develop-
ment Division  of GAO, has overall  responsibility  for the waste  oil  disposal
 survey.   John  McNamara 1n the Seattle regional  office  Is the project  officer.

                         4.0  DEPARTMENT OF COMMERCE
     The Commerce Department's National  Bureau of Standards (NBS)  was once
active on the issue of waste oil  re-refining but has done nothing  on the
topic in the recent past and plans no action in the future.  Twice in the last
six years, there have been tentative plans to have NBS test the quality of re-
refined oils, but neither attempt went past the talking stage,   IwS  no  longer
has the facilities nor expertise to evaluate the quality of lubricating oils.

     NBS published a letter circular in August 1950 entitled "Re-Refining Used
Crankcase Oil"13.  Tne three-page report concluded that the quality of re-refined
oil depends upon the quality of new oils from which it is obtained, the extent
of deterioration, and the re-refining process.  It admitted that NBS did not
have adequate test data to support any statement on the relative performance
of new and re-refined oils.  The Automotive Section of NBS was abolished in
the early 1950's and the Fuel Section in 1960.

     In 1967, as a result of hearings on waste oil that year  , Senators Magnuson,
Muskie, and Boggs wrote to the Department of Commerce (DOC) asking that NBS
perform quality  tests on re-refined oil.  DOC requested $300,000 for the task
but the request was rejected by the Bureau of the Budget.

     In 1970 the Federal Trade Commission (FTC) queried NBS on the quality of
re-refined oil.  The  FTC had promised to reconsider its labeling" restrictions
in  the light of new data on product quality during its participation in a CEQ
waste oil task force11*.  NBS told the FTC at that time that it wa"s unable to
supply any information.

                        5.0  DEPARTMENT OF DEFENSE
     The Defense Department has sponsored two major waste oil  studies.
The first is a Defense Supply Agency program to search for ways to Increase
federal purchases of products made from used oil.   The second  is a series of
plans for the Navy Supply Systems Command for disposal of oily wastes at Naval
facilities.  In addition, the Army Materiel Command and the Air Force are pur-
suing small independent studies of waste oil as a fuel.

5.1  Background

     The military's waste oil policies have a strong influence on all other
federal agencies and on much of the private market.  The Defense Department
(DOD)  is the nation's largest and most careful buyer of vehicle lube oil and
its largest producer of waste oil.  Its specifications for lube oil quality
are followed by many state,  local, and commercial fleet maintenance facilities.

     Even more important, the General Services Adm1n1stration(GSA) has dele-
gated  authority to  the Defense Supply Agency  (DSA) to procure fuel and lubri-
cants  for  the entire federal government*".

     The military's great influence in the  lube oil field has meant that its
views  have  a major  impact -- and  it has taken a very dim view of the quality
of re-refined oil.  DSA  buys lube oil for the military and other federal
agencies according  to specifications written  by the Army Materiel Command's
Coating  and Chemical Laboratory  at Aberdeen Proving Ground in Maryland.
These  specifications exclude the use of  previously used materials such as
re-refined  oils on  the grounds that there  is  no reliable  information on  the
quality  of  such oils*7.  According to DSA,  the small,  independent firms  which
typically  engage  in oil  re-refining do not  have the financial capability to
support  the kind  of laboratory and other testing  needed  to provide essential
data on  quality and consistency.

     DSA believes that  the  quality  of re-refined  stocks  may be  affected  by two
factors:   treatment method  and waste oil composition.  As for treatment  method,
there  is concern  that the  acid frequently  used to remove contaminants may
also remove naturally present  inhibitors and lubricating components.  Re-
refiners  dispute this  opinion but  have  not been  able to show convincing data
to  the  contrary.

     The variation in the  source of  used oil  presents an even tougher problem.
Vehicle  lube  oils are currently  procured for the government only after  they
 have passed an  extensive series  of  qualifying engine  tests costing between
                                     13       Preceding page blank

$10,000 and $80,000.   Once an oil  1s qualified,  the supplier is  required  by
contract not to change his additive package, his refining method,  or his
source of crude oil.   Of course re-refiners who  get their waste  oil  from  ser-
vice stations and other scattered sources have little control  over the quality
of their feedstock and have no hope of entering  into such a contract.   DSA
believes that most of the re-refiners could not  afford even one  set of quali-
fying tests, let alone a set of tests for each new batch of re-refined oil

5.2  Projects

     DSA, as the central purchaser of military supplies, 1s mainly concerned
about the quality and cost of new lube products, while the Individual services
are more concerned with how to dispose of their waste oils without running
afoul of pollution regulations.

     (1)  Products from Waste 011:  DSA

     In September of 1972, DSA Issued Its proposal for a research effort on
waste oil disposal, "Waste 011 Recycling Study"i°.  The proposal and a back-
ground report were prepared at the request of Deputy Assistant Secretary of
Defense for Health and Environment, John A. Busterud.  Although Busterud re-
portedly liked the proposal, he left to join the Council on Environmental
Quality before any action could be taken.  The proposal then went to the
Department of the Army for evaluation in early 1973, but has not yet been
either approved or disapproved.

     The proposal makes the following recommendations:

      -  Take steps to acquaint members of the re-refining  Industry with
various  petroleum products procured  by the  government that are not restricted
to virgin  base stocks.

      -   Initiate  research to determine the  physical  characteristics  of waste
oil  generated  by  vehicles operating  on unleaded  gasoline and  low-ash  oil;
choose  a military Installation to  demonstrate the  feasibility of  utilizing
the crankcase  drainings as a  heating fuel.

      -   Start  a  study  to  develop  specifications  for an  automotive lubricating
oil  containing available  re-refined  stocks.

       DSA  itself  proposed to  do  the  first  task  and has  already  contacted
lube oil re-refiners.   On the other  hand,  the DSA  proposal gives, the U.  S.
Army Materiel  Command  (USAMC)  the primary  responsibility for  the  remaining
two tasks  because the  USAMC  has  both the final  authority to write motor
oil  specifications  and the  laboratory facilities to do  the necessary technical
work.   Although  the proposed  DSA study tasks have  not been formally approved

and assiqned, the USAMC has begun preliminary work on the project under its
general research authority in this area.

     The first task recommendation, procurement of unrestricted re-refined
products, is thouqht to be a short term way of assisting the beleagured re-
refining industry.  DSA points out that of the 210 lube products handled by
the Defense Fuel Supply Center (DFSC), about 200 do not prohibit the use of
re-refined materials.  The DSA suggests that the re-refiners'  lack of knowledge
of quality requirements and procurement procedures may be a problem and that
a single education program is the answer.  Nevertheless, DSA also acknowledges
that nearly half of the volume of lube oils procured by DFSC are restricted
to virgin stock.  Therefore such procurement cannot be a long-term solution
to waste oil problems however much it may assist individual re-refiners.

     The second task recommendation, an investigation of non-metallic waste
oils,  is an attempt to evaluate the use of waste oil as fuel from the stand-
point  of expected changes  in oil composition over the next few years.  DSA
suggests that planned environmental restrictions on lead in gasoline and
likely environmental restrictions on metallic additives to lube oil will
produce ashless oil that can be burned without causing air pollution.  The
DSA proposal recommends that performance of lead-free gasoline and low ash
content lube oils be demonstrated at a  particular military installation,
that the resulting waste oil be blended with fuel oil, and that the emissions
and burner operation of the mixture be monitored.

     The last task recommendation, development of military specifications  for
re-refined lube oils,  is the most difficult and DSA  has requested extra re-
sources to carry  it out.   The  proposal  calls for a three-year  effort,  three
full-time personnel5 and an additional  $150,000 per year for laboratory sup-
port and engine testing.

      In carrying  out the study,  DSA plans  to  identify all  re-refiners  and  col-
lect re-refined base stock samples from their USAMC  laboratory analysis.   The
analysis is  to  determine the  physical characteristics and  quality variations
of re-refined oils  now  on  the  market.   The variations  in batches resulting from
different waste oil  sources,  treatment  methods, and  seasonal changes will  be
of special  interest.   It  is  proposed  that  the  Bureau of  Mines  help  in  the work.
Once allowable  parameters  for  re-refined  oils'  are established, the  USAMC  will
attempt to  develop  simple  laboratory  tests for monitoring  lube oil  character-
 istics so  that  consistency can be assured.   Appropriate  additive  packages will
be combined  with  the re-refined st.ocks  and performance  will  be measured with
a series of  engine  tests.   If  100 percent re-refined oils  are  found to be un-
qualifiable,  the  USAMC will  test various  blends  of virgin  oil  and  re-refined
oil  until a  qualifying mixture can be specified.   Finally, it  is  proposed that
a military  installation demonstrate  the performance of the newly specified oils
 over  a 12-month trial  period.

      Mr.  Harry  Ammlunq, Director of  the USAMC1s  Coating and Chemical  Laboratory
 in Aberdeen,  Maryland,  would  have overall  responsibility for the parts of the

DSA project involving fuel tests of ashless waste oil  and specifications for
re-refined oil.   Mr.  Charles F.  Schwartz and Mr,  E.  LePera of Aberdeen would
have the chief operational responsibility.   Mr.  Jan  B. Reltman, of DSA's Field
Support Division, drafted the original  DSA  proposal  with the assistance of Dr.
John A. Krynitsky of the Defense Fuel Supply Center's  Office of Technical Ser-

     (2)  Waste Oil as Fuel:  AMC Coating and Chemical Laboratory

     The Army Materiel Command has its own  ongoing project involving waste
oil disposal.  Since September 1972, the USAMC's Coating and Chemical Labor-
atory has burned 40,000 gallons of waste oil as fuel using a 5% - 10% blend
with No. 2 virgin fuel oil  The project is  a small, informal one requiring
no funds.  Stack emissions have been measured before and after introduction
of waste oil.  Although no numerical data has been released as a result of
the test, USAMC has found neither excessive emissions nor boiler fouling.
Staff from nearby Edgewood Arsenal are helping to monitor emissions.  The
USAMC is now considering a recommendation that other Army Installations use
this method of disposal.

     The USAMC's study of waste oil as fuel began largely as the result of
an order in 1972 from the USAMC's Troop Support Division which banned ground
dumping, Including the use of waste oil for dust control.  Disposal was limit-
ed either to selling, paying for collection, or burning.  Open burning is not
allowed and there have not been enough Incinerators to destroy the waste oil.
Moreover, in many areas re-refiners could not readily be found to collect it.
As a  result, waste oil has been collecting at Army posts, camps, and stations
across  the country.

      In an attempt to control the unwanted stockpiling  of waste oil, USAMC
has  informed all Army facilities of  the location of nearby re-refiners.   If
this  proves  inadequate, USAMC plans  to meet with the  Association of  Petroleum
  e-  efiners  to see what can  be done  to  increase collection services.   In  the
meantime, the Army has collected data on waste oil  types, quantities, and lo-
cations at  its installations, but has not analyzed  the  information.   It  is
hoping  that  the  USAMC tests  of waste oil for fuel will  provide a way to  re-
duce its  increasing  waste oil stockpiles.

      (3)  Elimination of  Waste Oil  Generation:  USAMC Army Fuels and
          Lubricants Laboratory

      The  Army Materiel Command  1s  trying yet another  solution  for  waste oil
disposal  problems:   non-generation.  The USAMC's Army Fuels  and  Lubricants
Laboratory  in San  Antonio,  Texas,  1s running  tests  to determine  the feasibil-
ity  of eliminating automobile oil  changes  entirely.   The project is costing
in the neighborhood  of  $50,000  and  will  be  completed  by the  end  of 1973.
The  first  phase, lab tests,  were begun  early  this year  and have  been comple-
ted.   The second phase,  "fleet  testing", will  start in  fall  1973.   In  this
phase,  military  jeeps will  be driven 20,000 miles with  sealed  crankcases.

     The Army's rationale for the program is that the deterioration  of  lube
oil can theoretically be counterbalanced by the quality,  frequency,  and
amounts of make-up oil added to replace the old lube oil  burned in the  engine.
If enough fresh, high quality lube oil  can be put 1n the  crankcase to dilute
the dirty used oil, then the overall  quality of the lubricant can be kept at
an acceptable level.  However, the only way to provide enough room for  the
amounts of new oil required 1s to Increase the burning of oil 1n the engine ~
contrary to the usual objective of decreasing engine oil  burning.  The  Army
estimates that an average engine 1n good condition and using clean fuels would
need to burn up about a quart of oil  every 1100 miles to  allow enough new oil
to be added.  It warns, however, that under more typical  conditions, the burn
rate would have to be higher since service station fuel 1s not particularly
clean and fuel contaminants are a major cause of lube oil deterioration.

     The Army Fuels and Lubricants Laboratory argues that the automobile en-
gine may be an excellent incinerator for used lube oil.  Since the Army feels
that the most practical use of waste oil may be as fuel anyway, 1t reasons
that expensive handling can be eliminated by recovering the fuel value
within the automobile engine.  An attempt will be made to compare the air
pollution and other environmental Impacts of this burning method with other
more conventional methods.  The Army Laboratory will also investigate what
this approach  implies for engine design and wasteful increased burning  of
fresh new oil.

     The project  leader  is Sidney Lestz, Manager of the Laboratory's Fuels and
Lubricants  Engineering Section.  Roy D. Quillian directs the Laboratory and
reports to  Harry  L. Ammlung, Director  of the Army's Coating and Chemical
Laboratory  in  Aberdeen,  Maryland.  The USAMC's Fuels and Lubricants Laboratory
uses facilities owned by the Southwest Research  Institute.

      (4)  Disposal  of Oily Wastes:  Navy

      In March  1972,  the  Research and Development Branch  of  the Naval Supply
Systems Command  (NASUP)  let  a  contract for  $275,000  to Esso Research and
Engineering Company to develop plans for disposal of  all oily  wastes at nine
major  Navy  terminal  complexes^,  including  Marine Corps  facilities.  Used  motor
vehicle  lubricants  are  included,  but represent only  a  small  percentage of  total
Navy  oily wastes.   NASUP estimates that with the Esso plan,98% of oily waste
will  be  reclaimed as  fuel20,  the  remaining  2%  going  to landfill.  All  research
is now completed  and  reports were  due  in  by June 25,  1973.   The Navy hopes
to receive  an appropriation  in fiscal  1975 for construction funds to implement
the plans.

      At  each of the nine locations,Esso1s  scope of  work  required these tasks:

      -  An  estimation of the quantity, quality and  location of all  oily
wastes,  both ashore and  afloat.

      -  Explicit consideration of a  wide range of solutions and designation
 of the most cost-effective.


     -  Design of an implementable area-wide system for collection,  proces-
sing and sale of oily waste for fuel.

     -  Finding ways to have private industry solve the problem,  or  short
of that, to have other government agencies cooperate;  as a  last resort the
Navy would go into the disposal  business by itself.

     Although the plans have all been completed and many have been submit-
ted for approval, revisions will be needed to take Into account recently an-
nounced base closings, such as the operations shift from Long Beach  to San
Diego.  It is not anticipated that the revisions will  significantly  retard
Implementation since the adjustments will be relatively minor and can be made
while reviews are proceeding.

     The impetus for the Navy oily waste program goes back to 1970.   In June
of that year Congress passed the Water Pollution Control Act calling for a
cessation of oil dumping at sea.  In a November NATO meeting, the U. S.  in-
troduced, and won, a resolution that by mid-decade all NATO nations should ach-
ieve a complete halt of international discharges Into the sea.  The only alter-
native was development of extensive shore facilities to dispose of the oil.

     The federal project officer for the Esso study 1s Donald H. Jermain of
NASUP's Research and Development Branch.  Commander Joseph  D'Em1d1o,  Director
of  the Navy's Environmental  Protection  Division,  has  overall  responsibility
for  Navy waste disposal  activities.

      (5)  Waste Oil as Fuel:  A1r Force

     The Air  Force  has awarded  two waste oil research contracts to Esso
Research and  Engineering Company.  The first contract is for $39,000 and
calls  for Esso to perform a paper study of alternative techniques that the
Air  Force might use in disposing of waste petroleum, oils, and lubricants
(POL's)21.  The study  is to be  completed by the end of October and the final
report released soon thereafter.  The second contract is for $41,000 and
provides  for  actual field testing of one of the alternative techniques being
analyzed  in  the first  contract:  use of  POL's as fuel".   It  1s to be  com-
pleted by the end of August  1973.

      The  objective  of  the first study 1s  to  Identify  alternative  POL dis-
posal  techniques  and  to  recommend criteria  that Air Force  installations,  in
different circumstances, can  use 1n  choosing among these techniques.   The
criteria  will  include  the amounts and kinds  of  POl's  generated,  nearness  of
the installation  to purchasers, local air quality  and so forth.   The  Air
Force has  some data on the  kinds and amounts of  POL's generated  at  its bases
and  has supplied  the  information to  Esso.   Esso will  analyze  this data
along with  available  disposal  technology and make  specific recommendations  on
optimal  disposal  approaches  at  specific facilities.   Esso  has a  general  pre-
ference for fuel  uses  but  project supervisors  feel that their technical  review
 is capable  of catching any  biases in this direction.

     The objective of the second study is to test the feasibility of burn-
ing POL's as fuel, blended either with fuel  oil  or natural  pas.   Both heavy
and light POL's are to be tested, but waste crankcase oil  has been excluded
from the experiments on the grounds that there is already  sufficient experi-
mental data on its use as fuel.  Solvents, contaminated fuels, and synthetic
aircraft oils will be the primary focus.  The short-term nature of the study
will not allow burner fouling or air pollution to be studied extensively.
Instead, blending ratios, fuel concentrations, and similar process variables
will be examined.

     The two contracts are being monitored by the Air Force Weapons Laboratory
at Kirtland Air Force Base, New Mexico.  Kirtland has service-wide responsi-
bility for environmental engineering and research development.  Lt. Ronald
H. Kroop, an environmental engineer in the Environics Branch of the Laboratory,
is the project officer for both studies.

     At Air Force Headquarters in Washington, Col. Herbert I. Bell, Chief of
the Air Force Environmental Protection Group, has overall  responsibility for
supervising waste oil disposal research and policy development.  Col. John
Thompson, an environmental engineer, has the chief staff responsibility.
The second Esso contract on fuel uses came as a direct request from this group.

     Air Force Headquarters indicates that waste  oil  is currently  building  up
at the service's  bases because opportunities for  disposal have diminished.
Waste oil disposal  practices  vary widely from base to base,  but  none  presently
participate in any  "closed-loop" re-refining system.  Some of the  oil 1s  still
being used for dust control.   Headquarters  is doubtful that  either fuel use
or fuel recycling  to lube  oil  will  provide  a long-term solution  to waste  oil
disposal.   Instead,  it believes  that  reprocessing of  waste oil to  other petro-
leum  products, such as the diesel  fuel  produced  by NORCO23,  is the best solu-
tion.   Futhermore,  it believes  that the  Air Force should be  part of  a much
larger  national  system of  waste  oil collection and reprocessing.

6.1  Interest and Background

     The Environmental Protection Agency (EPA) is the most active*organiza-
tion in the federal government's search for solutions to the waste oil
problem.  EPA's interest is motivated by three concerns:

     -  Pollutioncaused by waste oil disposal

        Most of the waste oil generated in this country is dumped
        either in sewers or on the ground, and both methods cause
        severe water pollution.  On the other hand, incineration
        or use as a fuel is likely to cause significant air pollution.

     -  Pollution caused by waste oil treatment

        Re-refininq of waste oil and other treatment techniques
        result in ground and water pollution from acid  sludges,
        spent clay, and other process residuals.  Air pollution
        by noxious odors can also be a problem.

     -  Resource conservation

        Dwindling  petroleum reserves and higher  petroleum explora-
        tion costs make dead-end disposal of waste oil  an   increasingly
        short-sighted approach.

     EPA's interest in waste oil has been both broadened and  focused  by  recent
 amendments to  the  Federal  Water  Pollution Control Act24.  The agency  is  called
 upon to report to  Congress within eighteen months on  a  variety of waste  oil
 issues.   Several of these  issues have  not been emphasized  in  past EPA re-
 search, and a  number  of projects have  recently been funded  to yield the
 required  information.

 6.2 Organization  and Personnel

     The  Office  of the Administrator has  assigned  the Office of  Research and
 Development  (OR&D) the job of  formulating  EPA waste  oil policy,  producing
 the waste oil  study mandated by Congress  and  of  coordinating the additional
 EPA research  needed  to  produce the  study  report.  Kurt .Jakobson  of  the Office
 of Environmental  Engineering will gather  and  evaluate data required by Wate>r
                                      21      Preceding page blank

Pollutions Act, Section 104(m), subparagraph A, the generation,  nature,  col-
lection, disposal, and uses of waste oil.  Dr. David Nyquist of the Office
of Environmental Sciences will provide the Information required  by subpara-
qraph B, long-term, chronic biological effects of waste oil in the environ-
ment.  John A.Jaksch of the Implementation Research Division is  responsible
for subparagraph C on markets, federal procurement, and economic and legal

     Since other EPA units have an Interest, and expertise, 1n waste oil pro-
blems, a working group has been formed to coordinate their Inputs.  In addi-
tion to the previously mentioned officials, the working group membership
includes Dr. Peter Lederman of OR&D's National Environmental Research Center
in Cincinnati; Thomas D. Clark of the Office of Solid Waste Management Pro-
grams; Cheryl Wasserman of the Office of Planning and Evaluation; Richard Hess
and Donald Walters of the Office of A1r and Water Progrems; Kenneth Woodcock
and Henry Stetlna of the Office of Enforcement and General Counsel; and William
Holmberg of the Office of Regional Liaison.  Jakobson 1s chairman of the work-
ing group.

     EPA's National Environmental Research Center in Cincinnati (NERC)  is a
technical arm of  the Office of Research and Development and has funded  tech-
nical studies of  waste oil reclamation processes for several years.  Dr. Peter
Lederman, Director of the Center's Edison Water Quality Research  Laboratory
in New  Jersey  is  supervising  these activities.  He will contribute  to the
working group  1n  the area of  waste oil generation and collection, and in the
area of re-refining and  fuel  oil technology.   Leo McCarthy, also  of the Edison
Lab, will report  on the  biological effects of  waste oil burning.

     The  Office of Solid Waste Management Programs' Division  of Resource Re-
covery  has  an  interest  in waste oil as a resource  that can be recycled.  Dr.
John H. Skinner,  Chief  of  the Division's Resource  Recovery Analysis Branch,
assigned  Thomas D. Clark to  supervise projects dealing with this  Issue.

     The  Office of Planning  and Evaluation  is  interested  in waste oil from
the  viewpoint  of  policy development and prospective  legislation.  Ms. Cheryl
Wasserman,  a member of  the working group* works in the Policy Planning  Divi-

     The  Office of A1r  and Water  Programs'  Division  of 011 and  Hazardous
Materials,under Kenneth E. Biglane,has an  Interest in waste oil  as  a  poten-
 tial water pollutant.   Richard Hess  1s responsible for developing regulations,
and  operating  programs, to prevent  and mitigate the effects of  oil  spills.
 Donald  Walters, in the Office of  Air  Programs, will  advise the  working  group
on the  air pollution  effects of waste oil  burning.

      The Office of Enforcement and  General  Counsel  1s to  comment on pos-
 sible  enforcement actions that would  result from any new  legislation recom-
mended.  It will  also assist 1n the Interpretations of any existing legis-
 lation  that regulates waste  oils.   Kenneth Woodcock 1s assisted 1n this

responsibility by Henry Stetina who will interpret state and local  waste
oil laws for the working group.

     William Holmberg, Office  of  Regional  Liaison, will review the work-
ing group's work and study recommendations  from the perspective of  EPA's
regional offices to ensure that plans are administratively feasible.

6.3  Present Programs

     EPA has stepped up its research efforts on waste oil and changed its
focus in response to Congress's call for an EPA report.  EPA has shifted its
efforts from basic technical studies to practical evaluations of alternative
comprehensive disposal strategies.  In the past the agency has emphasized
development of pollution-free disposal and treatment processes, whereas pre-
sently waste oil economics and federal policy options have become major con-

     Most of EPA's research projects are being pursued under contracts let
by the Office of Research and Development.   The present study, however, is
funded by the Office of Solid Waste Management Programs.  The other EPA
research projects are discussed below.

      (1)  Technology for Reprocessing to Fuel and Diesel Oil:  NORCO

          EPA's  biggest investment  in development of waste oil technology
has  been the NORCO study.   In  1969  the  National Oil Recovery Corporation
(NORCO), a  small company in Bayonne, New Jersey,, received a $338,000  grant
from  EPA to develop a  low  pollution process for turning waste oil  into
useful  petroleum products other than lube oils, particularly low sulfur
heating oil and  diesel  fuel.   The project was completed in  1971 and produced
a  report entitled, "Conversion of Crankcase Waste Oil  Into Useful  Products"25.
Soon afterward,  EPA gave $352,000 more  to NORCO for further research, this
time in the form of a  two-year contract26.

      Although NORCO scored  some successes In the Initial research  project,  a
number  of problems remained.   The vacuum distillation  process  being evaluated
produced No. 2 and No.  4 fuel  oils  that were low in sulfur and metals.   It
also produced some marketable  lube stocks.  Some experts, however, regard
the  technology as relatively antiquated2?„  The method avoided the use of
acid and therefore eliminated  the need  for acid  sludge disposals but  not all
disposal problems were  solved.  Residual metals  proved particularly hard to
get  rid of.  When the  grant expired, NORCO predicted  that new  and  added
equipment developed with the aid  of continued EPA  funding would result in
90 percent  recovery of waste oil  at lower cost without creating residual
waste problems.

      EPA  has  specified the following tasks  in  its current contract:

      -  Develop a  treatment process unit to remove suspended colloidal and
dissolved  organic  and metallic compounds either from the feedstock prior to


processing or from the products after processing 1n order to upgrade product
quality.  Higher level (No. 1 and No. 2) burner fuel 1s sought.

     -  Design and develop specifications for a bottom's Incinerator or develop
product outlets for the high metals content bottoms In order to preclude the
discharge into the environment of these toxic materials.

     -  Conduct studies to determine the quality of products produced.

     -  Conduct various plant runs to obtain systems design and operating

     In all,  three different re-refining approaches are being evaluated:
straight vacuum distillation, solvent extraction followed by distillation,
and  hydrotreating.

     The NORCO project is  being carried out under  the  supervision of  EPA's
Edison  Water  Quality  Laboratory, a division of  the National Environmental
Research Center  1n Cincinnati.  Richard Keppler, a research and development
representative in EPA's Region  I  office  (Boston), is  the project officer.
The  contract  is  to be completed by the  end of January  1974.

      (2)   Systems for Collection and Reprocessing  to Fuel 011:  MES

      In June  1972, EPA granted  the Maryland Environmental Service  (MES)
 $140,000  for  development  of  a comprehensive collection and  treatment  plan
 to solve  the  state's  waste oil  problems.  Maryland contributed  $50,000  of
 its  own funds and contracted with Environmental Quality System,  Inc.  (EQSI)
 of Rockville, Maryland,  to perform most of the  research.   In July  1973,
 EPA  made  an additional  $42,000  grant to MES to  find out how to  get  rid  of
 solid  residuals  1n  bottoms.  MES will contribute about $8,000 of its  own

      Once plans  are  completed,  MES will consider several  options.   It may
 attempt to interest  private  industry in an  area-wide  franchise  or  it  may
 itself build a pilot waste oil  processing plant.  Such a plant  would  require
 about  $1  million in  state funds and  federal  assistance.  In any case, MES
 hopes  to  implement  the collection  part  of the plan as soon as  possible.

      The  original  grant proposal  to EPA28  lists the following  objectives:
      -  Perform a state of the art review and analysis of existing techno-
 logy for reclaiming, reprocessing,  and  re-refining waste oils.

      -  Provide a management program for collection and handling of waste
 oil.  The program should specify the number of trucks, the collection net-
 work, pickup and delivery scheduling and storage  points.

      -  Provide a preliminary financing plan with alternative methods of


financing and management.

     -  Perform preliminary engineering and prepare plans and specifications
for the waste oil recovery system 1n the State of Maryland, such that detail-
ed plans and specifications may be finalized and construction may proceed

     By December 1972, EQSI had spent more than $40,000, completed the re-
search for the first objective, and released a report, "Maste Oil Recovery
Practices, State of the Art81.

     Although the Maryland system 1s to study production of both lube oils
and heating fuel, MES has decided to emphasize fuel oil production from waste
oil rather than lube oil re-refining.  An earlier Maryland report, "Used 011s,
A Waste or a Resource?"^? favored the recycling approach but for several rea-
sons MES, in 1972, decided against the approach.  First, MES felt that it
could not easily assure a demand for lube oil products for the state buys
fuel oil for its buildings but has no motor pools to provide a market for
automobile lube oils.  Second, MES realized that the wider latitude in
acceptability of fuel oil quality would reduce the need to control feedstocks
and therefore would be likely to result in more oil being reprocessed and
less being dumped in the environment.  Third, the still unresolved technical
problems involved in producing lube oil made it appear advisable to begin
with the easier task of making fuel oil.  Finally, MES hoped to avoid con-
flicts with  lube oil producers by settling for a product that they felt would
pose less competition as the fuel oil produced will be only a small percen-
tage of total fuel oil presently purchased.

     Dr. Peter Lederman, Director of NERC's Edison Water Quality Research
Laboratory,  is the Federal Project Officer for the Maryland Studies.
Michael T. Long, Chief of Administrative Services, has monitored waste oil
research for the MES but his responsibilities have recently been taken over
by  J. Carl Uhrmacher, MES Baltimore  Regional Engineer.  All system plans are
expected  by  the  end of September  1 973, and the bottoms research is expected
to  be completed  by the end of  1974.

      (3)  Blending Waste Oil for Fuel:  GCA

      In April  1972, the GCA  Corporation, under a  $29,500 contract with  EPA,
began an  exploration  of the  economic and technical feasibility  of using
waste automobile oil  for firing municipal  incinerators^0.  Then in May  1973,
EPA let a $50,000 contract to  GCA for  a  study of  the  technical,  economic,
and environmental issues raised by  using waste oil as  a  blended fuel  oil,
particularly in  steam power  plants^!.

      GCA's  report of  its first contract  study concluded  that  the physical
and combustion properties  of automotive  waste oils make them  quite  suitable
as  an auxiliary  fuel  in municipal  incinerators^.  Using waste  oil  in this
way was  found  to reduce combustible air  pollutants and excessive residue

that result from wet or low heat-value refuse.

     In reaching these conclusions, GCA reviewed  the physical  and  chemical
properties of waste oU to determine Us suitability as  a fuel  oil.   It used
a combustion model of a refuse bed to estimate the quantities  of waste oil
needed, and evaluated alternative techniques for  Injecting the waste oil  Into
the incinerator.  It also assessed monitoring and control techniques, stor-
age and fuel systems, capital  and operating costs.  A1r  pollution  Impacts
were examined, but only lead concentrations around the Incinerator were

     The second GCA contract -- on power plant fuel oil  — calls for a report
on these issues:

     -  Collection and analysis of Information on potential Industrial de-
mand, especially by steam power plants, for blended waste oil.

     -  Estimates of downtime and repair costs connected with use of different
grades of  pretreated waste oil 1n varying proportions with ordinary fuel oil
of varying grades.

     -  Estimates of the profitability of pretreatment operations under
varying assumptions as to Input prices, output prices, and type of treatment.

     -  The  effect of  environmental restrictions on the economics and tech-
nology of  pretreatment operations and power plants.

     Richard Keppler was the  EPA project officer  for the first GCA contract
and  Dr. John A. Jaksch, an operations research analyst in  the Office of
Research  and Development,  is  the project officer  for the second GCA contract.
The  report from the  first contract was  released  1n  February 1973 and the re-
port from the second  is due the end of  January 1974.

      (4)   Systems  for  Collection and  Reprocessing to Lube  Oil:  Teknekron

      In March 1973,  EPA  let a $58,000 contract to Teknekron,  Inc. of
 Berkeley,  California  for  a  project  entitled,  "A  Technical  and  Economic Study
 of Waste  Oil Recovery"33.   Teknekron   and  its subcontractor, the Institute
 of Public Administration,  will  Investigate the feasibility of  setting  up
 "closed  loop" oil  disposal  and  reprocurement systems, with special attention
 to opportunities at federal facilities.

      According to the scope of work, Teknekron and IPA  will:

      -  Report on current federal waste oil research programs and provide
 a waste oil disposal bibliography.

      -  Investigate dispersed generation of waste oil  as a result of back-
 yard, user-performed oil changes.

     -  Describe and evaluate the Internal  economics of the wfistgroll  re-
refining Industry.

     -  Investigate the feasibility of establishing a "closed-loop" recycling
system that could be demonstrated at a federal Installation.

     The Teknekron project Is being supervised by Thomas D. Clark of EPA's
Office of Solid Waste Management Programs.   The study is to last six months,
and the final report 1s scheduled to be completed by the end of Pecember.

     (5)  Waste Oil Generation and the Technology, Economics, and
          Environmental Impacts of Re-Ref1n1ng:  Recon Systems

     In June 1973, EPA let a $40,000 contract to Recon Systems, Inc. and
Response Analysis Corporation for a joint effort to develop additional
Information on waste oil recycl1ng34.  The firms have two major objectives:
1) to describe and evaluate waste oil re-ref1n1ng processes and their
environmental impacts and 2) to measure the magnitude of the waste oil
problem by developing a material balance survey program for selected major
waste oil generation areas.  Response Analysis  Corporation will have a
major role in developing the survey program.

     According to the contract's statement of work, the study will Include
four  primary tasks:

      1.  An assessment of current waste oil disposal techniques and
         all potential refining and re-refining processes  for all  types
         of waste oils.  This  1s to Include Information on feedstocks,
         products,  processes,  environmental Impacts, and economics.

      2.  A technical assessment of waste oil  processes with recommendations
         for further work.

      3.  An  environmental assessment  of waste discharges from the  waste  oil
         processes  examined,  taking  into account  aesthetic damages and local,
         state,  and federal  regulations.

      4.  A preliminary material  balance national  survey  program for major
         generation areas.   The  survey is  to  include the types, quantities,
         sources, and disposal practices for  waste oil  generated.   Besides
         the survey plan, a  "best" material balance is to  be described.

     The Recon  study is  being  supervised by Leo McCarthy of EPA's  Edison
Water Quality Laboratory.  The study  is to be completed  by mid-October and
the final report released soon thereafter.  It is anticipated that impleme-
tatlon of the national survey  developed and tested under this contract may
require further  expenditures  for contract  research.

      (6)  Federal Policy on  Waste  Oil:  ELI


       The Environmental  Law Institute (ELI)  of  Washington, D.C., began a
ten-month EPA research contract in July 1973  on  the  legal  aspects of  incen-t
tiveapproaches to pollution control^.  Some  part, possibly about half, of
the $60,500 allotted to the entire effort will be focused  on  the specific
problem of federal policies to control waste  oil.

     The scope of work requires:

     -  A comparative analysis of waste oil  policies of industrial  nations.

     -  A summary and evaluation of statutes, regulations, pending  legis-
lation, and proposals 1n subject areas related to waste oil.

     -  The identification and evaluation of broad  alternative legal  approaches
to waste oil problems.

     -  A detailed description of the more feasible approaches, including
the groundwork for statutory language.

     Dr. Fred H. Able will be the EPA project officer.  The Final  Report is
due in July 1974, but 1t is hoped that most of the findings will  be available
for inclusion in  EPA's waste oil report to Congress in April  1974.

6.4   In-House Research and Past Studies

      Part of the  waste oil study mandated by Congress  is  to deal with the
long-term,  chronic biological effects  of waste oil, and EPA has initiated
in-house experimental research  to provide the needed data.  Testing of the
effects of  waste  oil on aquatic life  will be carried out  at two locations.
Research on freshwater life will  take place at  EPA's Natural Water Quality
Laboratory  in Duluth, Minnesota,  and  research on salt  water life at  EPA's
National Marine Water Quality Laboratory  in Narragansett, Rhode Island.

      The research projects will measure the  impacts of waste oil, crude oil,
and refined oils.  Although the entire project  is to  last one  year,  from
July  1973  to  June 1974,  the first half of the study will  be devoted  entirely
to waste oil.  This  1s so  that  the  results will  be  ready  by January  1974
and available for inclusion 1n  the  EPA waste  oil report to Congress.

      Each  of  the  National  Water Quality  Labs  will devote  about $40,000 to
biological  waste  oil  research  1n  fiscal  1974.              \

      Steven F.  Hedtke, a  research aquatic biologist at the Duluth  Lab, will
supervise  freshwater tests, while Stanley Heggre at the Narragansett Lab
will  supervise  marine tests.   Both report to Dr. David Nyquist of  EPA's
Office of  Environmental  Sciences  1n Washington, D'.C.

     Several  past EPA studies have dealt with ground disposal  of waste oil.
In October of 1972 the EPA's Edison Research Laboratory investigated  the
runoff from dirt roads treated with waste oil to suppress  dust".  The study
indicated that some 70 percent of the oil leaves the roadway on dust   parti-
cles or in water runoff.  Almost all the remaining 30 percent volatilizes
and is biodeqraded.

     In addition, in December 1972 EPA completed a study of disposal  of oily
waste by soil cultivation^'.  The experiment in Deer Park, Texas, used soil
microorganisms in an effort to determine how fast waste oil would decompose
in landfill areas.  At prevailing local soil and climate conditions,  it was
found that about one half pound of oil per cubic foot of soil would decompose
each month without fertilizers.

     In 1967, the Federal Water Pollution Control Administration funded
a waste oil project, a demonstration of the caustic-base re-refining  process38.
The objective was to demonstrate a process for eliminating water pollution
by waste oil re-refining plants.  The project showed that the operating
problems would not be much different than with the more typical atid-clay
treatments and that sludge disposal would still be a major difficulty.

                      7.0  FEDERAL  TRADE  COMMISSION
     The Federal  Trade Commission (FTC)  will  soon consider softening  the
burdensome labeling requirements it has  placed on waste oil  products.   FTC
staff are preparing recommendations to be presented to the full  Commission
by December 1973 on the use of the word  "recycled" in product labels.

7.1  Background

     In 1958, the FTC ruled that the sale of reclaimed or re-refined
lubricating oil without an indication of previous use was misleading  and
deceptive.  It ordered that "any lubricating oil...composed in whole  or
in part of oil which has been reclaimed or in any manner processed from
previously used oil be labeled with a clear and conspicuous statement to
that effect on the container."3"

     In an attempt to comply with the FTC order, the Double Eagle Refining
Co., one of the respondents^, submitted label samples which included state-
ments on the  side of the container that the oil had been "scientifically
RE-REFINED from previously used oil".  The FTC approved this method of
compliance in I960, but in 1961 rescinded its approval because the state-
ment of prior use was on the side rather than on  the front of the container.
The  hearing examiner supported  the re-refiner's position, but in 1964 the
Commission overruled his decision and ordered that the statement be "on the
front panels  of the container".4*

     In addition to requiring front  labeling, the FTC  in  the same year also
promulgated a Trade Regulation  Rule  requiring a  statement of "previous use"
and  also  restricting  the use of the  word "re-refined".   It prohibited the
use  of  the term  "re-refined"  to describe "previously used lube oil unless
the  physical  and chemical  contaminants  acquired  through  previous use had been
removed by the refining process".42

     Although there are no satisfactory estimates of  the impact of the  FTC
orders,  some  observers feel  that it  has been  a major  cause of the progres-
sive collapse of the  re-refining industry and,  in turn,  of  increasing  en-
vironmental oil  pollution.43  others have argued  that  the entire  area of
consumer  response  to  terms like "recycled"  is unknown.44

7.2   Interest

     The  FTC's interest  in reconsidering its  waste oil  labeling  rules

                                     31       Preceding page  blank

steins largely from the impact of the National  Environmental  Policy Act of
1969 (NEPA).   NEPA requires all  federal  agencies to report,  and take into
account, the environmental  impacts of major actions.   NEPA of course only
applies to future major trade decisions  with significant environmental
consequences.  In an effort to rationalize and systematize the FTC's new
environmental responsibilities,  the staff has  initiated an effort to come
up with general recommendations  for changes in policy, particularly in the
area of recycling of waste materials.  The staff has decided, moreover, that
the development of such policies calls for a reconsideration of past label-
ing rulings for previously used  lube oil — although not actually required
by NEPA.

     NEPA will expand the FTC's waste oil concerns in at least two direc-
tions:  product quality and environmental impact.  In its earlier labeling
decisions, the FTC argued that product quality and performance was not the
issue in its charges of deceptive trade.^5  The Commission felt that man-
datory  labeling could be completely justified on the basis that oonsumers
are known to prefer new oil and tend to mistake reprocessed  oil for new
oil unless it  is clearly labeled as reprocessed.^  NEPA, however, requires
the FTC to consider all alternatives including product quality.  The Commis-
sion must consider whether the environmental damage from disposal alternatives
to reuse, e.g. dumping, may be too high a price to pay for its labeling rules.
Although the rule deals with traditional deception and takes cognizance of
apparent consumer preferences, it may also lead misinformed consumers  to
reject  high  quality recycled oil.  With potential markets constricted  in this
way, re-refining  is likely to be replaced by other more damaging waste oil
disposal practices.  The actual quality of recycled oil, rather than  its or-
igin, this becomes a crucial factor  in a NEPA-required balance of costs and

     As for  environmental  impact, NEPA will require the FTC  to predict both
the  abatement  or  creation  of pollution and the  consumption or conservation
of  resources  resulting from  rulings  on recycled  products.  Both these tasks
and  the assessment of  product quality require technical expertise that is  in
short  supply at  the FTC.   The Commission staff  will of necessity rely heavi-
 ly  on  technical  assistance from other federal agencies.

      NEPA  has  affected the FTC's  interest  in waste oil in yet another  way
through its  creation  of  the  Council  on  Environmental  Quality (CFQ).   FTC
participated during early  1970  in CEQ's  task  force on waste  oil disposal.4'
Although  the CEQ effort  did  not result  in  any major  federal  policy  change,
the FTC agreed at the time to reconsider  its  recycled oil labeling  require-
ments  should it appear that  the oil  could  equal  the quality  of acceptable
virgin  oil.48  However,  a  check by  the  FTC of several  federal  aqencies,  in-
cluding the  Bureau  of Mines,  reinforced  its  past finding  that reprocessed
oil  was inferior.

7.3  Present Program

     FTC staff members are now preparing recommendations  for  changes   in  .
labeling of products made from used materials,  including  reprocessed  oil.

     In December 1972, the staff prepared a draft of a proposed guide for
the use of the word "recycled" in product labels.  The guide  would attempt
to restrict use of this designation to products which perform at least as
well as comparable products made from virgin material.  Issues still  to be
resolved include:  the conditions under which labeling should be imposed,
the location of labels showing past use, the information  to be provided on
the label, the percentage of used material needed to qualify a product as
"recycled", and the use of similar words such as "recyclable",  "reusable",
and  "refillable".

     Since the FTC draft was prepared, the Commission has received comments
from interested agencies, including EPA, Bureau of Mines, CEQ, and 6SA,
and also from consumer groups, Congressional committees,  and marketing
experts.  FTC's staff plans to have a final draft and a report before the
full Commission between September and December 1973.  Nevertheless, even
with immediate favorable action it is unlikely that the new labeling rule
would be in effect before mid-1974.

     Several problems threaten to slow action on the prooosed changes.
Considerable time and manpower will be required  to conform with NF.PA report-
ing requirements.  Only one FTC employee has been assigned to the project
and  he has not been able to devote full time to this effort.  Further", since
the quality of recycled oil is still  in dispute,  the FTC may decide  against
permitting  the use of the word "recycled"  on the label.  Finally, the release
of  EPA's  definitive report  to  Congress  on  waste  oil  due  in April  1974, may
cause  the FTC to delay the  decision  on  labeling  requirements.

7.4  Organization  and  Key Personnel

     Recommendations  for  changes  in  FTC  policy on  recycled materials
are being  carried  out  in  the  Bureau  of  Consumer  Protection under  the
direction  of  William Dixon, Assistant Director of Rules  and  Guides.
Raymond Rhine is  the attorney in  charge of the project to  consider
"recycling"  labels.

     The General  Services Administration (GSA) has recently taken .a re-
newed interest in waste lube oil  as a potentially saleable or recyclable
commodity.  It has completed a survey of waste oil generated by GSA
vehicles and is expecting to eventually extend the survey to the entire
Federal Government.
8.1  Background

     GSA operates about 65,000 motor vehicles, the largest fleet after
the Postal Service and the Defense Department.  In contrast to these agencies,
however, most of the servicing of GSA vehicles is done by service stations
under government contract, and it is doubtful that the waste lube oils gen-
erated by them can be claimed by the U. S. Government.  Of the 98 motor pools
run by GSA, the great majority use such contracts.  Moreover, many auto-
mobiles are leased by GSA and the drainings from such vehicles are even
less likely to be legitimately claimed as Federal property.

     Although GSA currently purchases no products made from used lube oil,
the agency is active in a number of programs to procure supplies made
from other used materials.  The Federal Supply Service has set standards
for the amount of post consumer paper waste included in 77 paper products
it procures.  Government toilet paper, for example, contains 50 percent
recycled  paper.  GSA also reclaims platinum and silver from sparkplugs used
in aircraft and heavy military vehicles.  The silver and platinum is
supplied  back to sparkplug manufacturers as raw material.

8.2   Interest
      Although  GSA  is  the  government's central  purchaser for most goods,
 the agency has delegated  the  responsibility  for  procurement of  lube oils
 to the Defense Supply Agency  (DSA).   Its  interest  in waste oil  is  there-
 fore not in possible  purchases  of  waste oil  products such as  re-refined
 lube oils.  Rather,  it would  like  to find ways to  turn disposal of waste  oil
 from a debit to a  credit  item.   Recent  fuel  shortages have made GSA partic-
 ularly interested  in  the  possibility of using  waste oil as a  blended  fuel

      GSA would be  willing to  subsidize  improved  waste oil reclamation
 through a special  government  purchase program  for  waste oil products  but
                                     35     Preceding page blank

it is restricted by its legal mandate to purchase products of a given quality
at least cost.  The agency would need special  Congressional authorization
and funds  to support such a subsidy.  This approach has a precedent in the
new federal statute on noise pollution.50  This law allows GSA to pay 125%
of normal retail price cost for products that have received a low noise
certification from EPA.
8.3  Projects

     In June 1973, GSA completed a small survey of the generation of waste
oil from those of its vehicles serviced at the agency's own facilities.  No
special funds were committed to the project.  Questionnaires were sent
out to GSA motor pools by the Federal Supply Service's Office of Motor
Equipment, Transportation, and Public Utilities.  Data from the survey is
still being interpreted and reviewed.

     Information collected in the survey included:

     -  Number of vehicles in each fleet

     -  Number of vehicles serviced in-house

     -  Quantity of waste oil generated in-house over six months

     -  Method of waste oil storage

     -  Method of disposal

     -   Estimated cost of disposal

     -   Income from waste oil sales

 8.4 Organization and Key Personnel
      Andrew Kauders, Executive Director for Environmental  Affairs,  has
 the overall responsibility for GSA environmental  programs.  His office has
 agency-wide responsibility to monitor environmental  programs,  ensure
 compliance with environmental legislation, and initiate new environmental
 projects.  William S. Eckert, Director of the Federal  Supply Service's
 Property Rehabilitation Division, designed the waste oil survey and has
 overall responsibility for the rehabilitation, reclamation and recycling
 of Federally-owned property.  Mr. Eckert is assisted in the waste oil
 survey by Mr. Michael Dee, Assistant Director.

                      9.0  DEPARTMENT OF  THE  INTERIOR
     The Interior Department's Bureau of Mines  1s currently carrying out
the first steps of a major technical  study of processes to re-refine waste
oil.  It is hoping to get increased funding 1n the next several  years so
that it can proceed with full-scale engine testing.   A report on progress
to date is expected in the next few months.
9.1  Background and Interest

     The Bureau of Mines' Interest 1n the waste oil problem stems from Its
long experience with petroleum refining problems and from the opportuni-
ties offered by the Bureau's large testing laboratories.

     Consistent with these interests, the Bureau believes that two major
obstacles must be overcome before used oil can be successfully re-refined in-
to  lube oil.  First, the technology of the re-refiner must be upgraded to
produce a lube oil that meets requirements of modern automobile engines and
military specifications.  Second, the re-refiner must ge given a greater
profit incentive to process the large amounts of used oil presently being
dumped or disposed of in damaging ways.  In this connection, the Bureau has
come out in support of the legislation offered by Congressman Vantk to en-
courage oil recycling.^l

     Although some observers have questioned whether re-refining technology
is  at the heart of the waste oil problem, Bureau of Mines studies have shown
that present re-refining processes produce oil that has  lost much of its
lubricity and oxidation  stability.  Therefore, there does appear to be room
for improvement in this  area.

9.2 Projects

     The Bureau of Mines is proceeding with  the  initial  laboratory work
described  in  its April  1972 proposal,  "An  Issue  Paper About...Waste Oil
Recycling."   The proposal calls for  an extensive $1:5 million  five-year
research effort to develop and demonstrate methods  of waste oil  re-refining.
The project  is to use the technical  facilities at  the Bureau's Bartlesville
Energy Research Center  in Oklahoma.  The Bureau  received $125,000  in
fiscal 1973  for laboratory work,  but this was  only a  little more than  half
the amount requested  in  the Bureau's proposal  for  the first year of opera-
tions. 52   Large scale pilot testing  of processes and  engine testing of pro-

ducts were not granted funds.  The Bureau has asked for $350,000 for fiscal
1974 but expects to receive about the same amount as In fiscal  1973.

     Even before the Bureau of Mines began this specific project, 1t had
looked into related Issues.  It had collected samples of waste oil  and
examined the contaminants, particularly wear metals.  Some samples of re-
cycled oils from existing re-refiners were also collected and analyzed using
bench scale tests.

     The Bureau's present program objective 1s the development of an effi-
cient method for reclaiming waste lubricating oils.  The objective is to be
met through performance of the following tasks:

     -  Bench-Scale Quality Evaluation Tests.  Improvements will be sought
in some of the tests and in methods for categorizing the quality of lube

     -  Bench-Scale Refining Operations.  Three re-refining techniques are
to be evaluated 1n the laboratory:acTd extraction, caustic-based extraction,
and solvent extraction.

     -  Pilot-Scale Operations.  The most effective processing technique will
be demonstrated 1n a pilot plant.

     -  Engine Testing.  The re-refined  lube oil  products will be put through
the full  sequence of engine  tests needed to demonstrate quality.

     The  Bureau has been able  to  proceed with  the proposed evaluation of add
and caustic-based extraction,  but has  not been able to  test the  propane sol-
vent method because Information from Industrial users  has been  Inadequate.53
The Bartlesville  Center  has  evaluated  commercially available processes and
has used  crankcase oil from  Its own automobile fleet as a feedstock.

     The  Bureau of Mines  Indicates  that  1t  has found a  particular  solvent
extraction process that  has  good  prospects  of  meeting  the need  for  improved
technology.   It  1s presently engaged in  testing  the quality of  products made
with  the  process,  and  has  been reluctant to divulge technical data  before
tests  are completed.

9.3   Organization and  Key Personnel

      Mr.  Richard  M. Goodlng, a petroleum chemist in the Bureau's Washington
area  office and  C.  C.  Ward,  Research Supervisor  at the Bartlesvllle facility,
are  the Bureau's  staff chiefly responsible  for waste oil  studies.

                           10.0  POSTAL SERVICE
     The Postal Service is the Federal  Government's greatest non-military
generator of used automotive lube oils.  It has long-standing general  guide-
lines for non-pollution disposal  of waste oil8  but has no plans for further
study or policy changes in this area.

10.1  Background

     The Postal Service's 100,000 vehicles produce an estimated 650,000
gallons of used oil each year.  Most of the oil is collected at the Service's
311 Vehicle Maintenance Facilities (VMF's).  More than two-thirds of these
facilities service between 300 and 1400 vehicles and store used oil 1n under-
ground tanks until it can be sold or given away.  Smaller VMp's  store oil 1n
55 gallon drums until it is picked up, and very small facilities use
commercial service stations.

     Postal Service Methods Handbook M2, "Vehicle Maintenance Facilities",
sets guidelines for the disposal of used oil.  Although the guidelines were
once mandatory, decentralization within the Service has given local managers
the final decision.54  The guidelines  simply provide that VMF's enter Into
local annual contracts with companies  who will pick up the waste oil.  The
Postal Service believes that since most of the scavengers appear not to be
re-refiners, the oil collected is eventually used for fuel.55

10.2   Interests

     The  Postal  Service would  like to  get  rid  of  its waste oil at  the least
possible  cost  consistent with  protection of the environment.  Although most
VMF's  at  one time  were able .to sell waste  oil, almost all now must arrange
to  give  it  away  and  sometimes  they must  pay to have  it collected.   The Postal
Service  is  certain that none  of  its facilities arbitrarily dump waste oil,
but beyond  this  there  appears  to be little hard data  on  the  generation,
distribution,  or ultimate disposition  of used  vehicle oils.   In part, this
is  a reflection  of thorough decentralization  in the  Postal  Service.

10.3   Projects

     Currently there are  no  Postal  Service projects  on waste oil  and  none
are being planned.  However,  the Central Regional Office (Chicago) recently


considered the offer of a local  re-refiner to reprocess  vehicle  oil  for re-
use by delivery vehicles.  Although the price offered would  be cheaper  than
virgin lube oils, the Postal  Service 1s worried about the quality of the oil.
It does not question the technical  feasibility of re-refining but 1s doubtful
that the Service could adequately police the Integrity of the re-refiners.
The stakes in terms of possible engine damage are high,  and  the  Postal  Service
sees it as unlikely that it could colltct damages if the re-refined oil should
cause problems.

     The Postal Service, like GSA, buys gasoline and oil through Defense
Supply Agency (DSA) contracts.  These Invariably specify lube oil made  only
from virgin crude.  However, the Postal Service 1s not prevented by these
contracts from participation In "closed-loop" systems like the one offered
by the Chicago re-refiner.

10.4  Organization and Key Personnel

   Mr. Carl Myers, the Director of the Office of Fleet Maintenance,
Bureau of Customer Services, 1s responsible for setting waste oil guidelines
in the Postal Service.  Merton Culver, Fleet Maintenance Management Officer,
has major operational responsibility.

                     11.0  DEPARTMENT OF THE TREASURY
     The Treasury Department Interprets statutes that Impose excise taxes
on lube oil.   Although Treasury has expressed disapproval  of the tax loop-
holes for Industrial lube oils which Congress enacted 1n 1965,  1t has no plans
to request statutory changes.  Nor does the department have any plans to
reconsider Its 1965 tax decisions that were unfavorable to the  re-refining

11.1  Background

     Before 1965, the Treasury Department taxed lubricating oil fiiade
from crude  petroleum at a rate of 6$ per gallon.  Re-refined or reclaimed
oil was exempt on the grounds that this excise tax had already  been paid when
the oil was new.  Typically, however, re-feffners would not market 100%
recycled oil but would blend it 1n some ratio with virgin oil 1n order to
meet certain viscosity requirements.  Since the excise tax had  to be paid
on the new oil used for such blending, a gallon of the re-refiners' product
was subject to taxation.  The amount of the tax was proportional to the vol-
ume of virgin oil used in blending.  Nevertheless, the blended  oil itself
was not  subject to  tax.5°  The 6
     In sum, waste oil  re-refiners kept their tax advantage on automobile
lube oils but lost 1t on all other lube oils.  Purchasers have to pay the
excise tax Initially 1f they buy virgin lube oil, but can get the tax refund-
ed by the federal government at the end of the year by showing that the oil
was not used 1n highway vehicles.  This gives virgin lube oil used Industrial-
ly the same tax exempt status previously enjoyed only by re-refined oil.59

     Several questions about the tax liability Of blended oils remained
after the Excise Tax Reduction Act was passed.  Since most of the re-refiners'
lube products are blended, these questions were particularly Important to
the Industry.  Nevertheless* Treasury Department rulings have all been against
the Interests of the re-refiners or re-refining.

     The Issues were:

     1)  Are re-refiners exempt from paying  the excise tax, I.e. do they de-
serve a refund as an off-highway user when they buy virgin oil to blend with
their re-refined oil?

     2)  Are the off-highway purchasers of blended re-refined lube oil due a
Treasury payment for that part of the oil bought which 1s virgin lube oil and
carries the excise tax?

     3)  Is lube oil manufactured from a mixture of virgin crude oil and used
oil subject to the 64  excise tax  even though the law  exempts  previously  used
oil from the tax?

     The Treasury Department decided that re-refiners do not  qualify as  an
off-highway user and therefore are  Ineligible for a  tax rebate on virgin oil
they buy for blending.60 Re-refiners who blend, for  example,  1n a 50-50
ratio must  pass  on the 6$ tax to their customers.  I.e., at 34 a gallon.  This
would not be a serious problem  1f customers  could  1n  turn  collect from Treas-
ury either  a 64  a gallon payment or at least a 3<  a  gallon payment to cover
the excise  tax carried by the new oil mixed  1n with  the  re-refined oil.  Un-
fortunately for  the  re-refiners,  Treasury also ruled  that  industrial buyers
of blended  recycled  lube oil could  not collect a refund  since the product
they  purchased was  not taxable.**  THe" effect was  that  blended re-refined
oil not only  has lost  Us 34 a  gallon  tax advantage,  it  is now 34 more  ex-
pensive relative to  virgin  ollbecause all  opportunities  to  get a Treasury
excise  tax  refund are  lost  1n  the blending  operation.  The non-highway  user
pays  no excise tax  for virgin oil,  but continues to pay 34 a gallon  tax  on
blended oil.

      Finally, Treasury ruled  that the Introduction of used oil into  the pro-
cess  of refining virgin crude  oil did  not thereby  make the product "a mere
blend  or mixture"  and  exempt  1t from  the excise tax as  a blended oil  using
re-refined  oils.62

11.2  Interest

     The Treasury Department would be happy to repeal the cumbersome lube
oil tax refund provision.  However, this preference comes out of a desire
for simplicity 1n the tax code rather than concern for the re-ref1n1ng In-
dustry or the environment.  Treasury feels that the re-reflnlng Industry 1s
basically a dying Industry and that special tax concessions will be In-

     The Treasury Department suggested to the Association of Petroleum Re-
Refiners (APR) that their customers might be allowed a refund 1f the re-
refiners would report the exact percentage of virgin oil 1n their blended
lube oil.  Treasury found APR Industries unwilling to disclose the amount
of virgin taxed oil used and nothing came of Us suggestion.

11.3  Projects

     No activity on lube oil taxation 1s planned or recommended fey Treasury.

11.4  Key Personnel

     John Copeland  in Treasury's  Tax Policy Division  is  responsible for  over-
seeing  excise taxes on lube oils.

                    12.0  DEPARTMENT OF TRANSPORTATION
     The Department of Transportation (DOT) cooperated with the Department
of Interior to publish 1n February  1968, "011 Pollution", a special  study
requested by President Johnson.  The report covered the general topic of
water pollution by oil and other hazardous substances but emphasized  major
Industrial sources and spills.  It did, however, briefly mention the  problem
of waste oils from service stations, the first time auto lube wastes  were
recognized by the Federal Government as a significant source of pollution.

     DOT currently has an active Coast Guard program to prevent and control
oil spills on navigable waters.  However, the agency 1s not doing anything
1n the area of waste oil from motor vehicles.
                                      45     Preceding page blank

                     13.0  DEPARTMENT OF  AGRICULTURE
     The U.S.  Department of Agriculture (USDA)  has  no waste oil  research
projects at present, nor are any planned.   However, the department operates
and maintains  the federal government's fourth largest vehicle fleet,  30,000
units, ranging from cars to large trucks.

     The Forest Service manages USDA's largest fleet, some 13,600 vehicles,
and operates 500 pieces of construction equipment.   The Soil Conservation
Service operates about 11,000 vehicles, the Animal/Plant Health  Inspection
Service, 2,400, and the Agriculture Research Service, 2,700.  Pick-up trucks
are the backbone of all USDA fleets.  They account for almost 26,000 of the
30,000 total.

     Nearly all the maintenance of USDA vehicles 1s carried out  by commercial
service facilities.  Only the Forest Service services any of its own vehicles
and even the Forest Service uses commercial servicing for three  .quarters of
its vehicles.   Fleet managers report that when the Forest Service changes
oil in Its own vehicles during repair or yearly preventative maintenance,
1t uses the same commercially available scavenger pick-up services used by
service stations.  Only when construction equipment is used in remote areas
1s 1t likely that waste oil will be dumped on the ground.  Although the crank-
cases of such vehicles are relatively large, few vehicles are ever serviced
at any one location at the same time, hence 1t is expected that the small
volumes of waste oil dumped on the ground can be naturally degraded without
environmental damage.

     There are currently  no department-wide guidelines on waste oil disposal
procedures except a general requirement that vehicles be serviced safely
1n accordance with manufacturers' specifications.

      K.H. Boyer, Assistant Director for Telecommunication, Transportation,
and  Physical  Security  (Office of Plant and Operations), has responsibility
for  department  policy  on  maintenance  and management  of USDA vehicles.   Oliver
Broadway has  chief  responsibility for vehicle maintenance within  the  Forest
                                     47      Preceding page blank

                    14.0  NATIONAL SCIENCE FOUNDATION
     The National Science Foundation (NSF) has no current research 1n waste
lube oil disposal and has no plans to allocate funds to such research.  How-
ever, NSF 1s carrying on studies 1n related areas and has Interests and an
organizational framework which could easily encompass waste oil  research.

     NSF 1s funding studies 1n the field of waste management strategies,
an activity carried on in NSF's Division of Environmental Systems and
Resources.  This 1s one of the operating divisions of the Applied Research
Directorate.  The Applied Research Directorate 1n turn 1s the unit set up
to administer the RANN program (Research Applied to National Needs), a
major NSF effort to support practical research with a significant rear-
term  benefit to the nation.
     Edward H. Bryan is a program manager for Regional Environmental Systems
within the Division of Environmental Systems and Resources.  Waste management
strategies are his particular concern.
Preceding page blank

Teknekron, Inc. and The Institute of Public Adminis-
tration wishes to acknowledge the Resource Recovery
Division, Office of Solid Waste Management Programs,
U.S. Environmental Protection Agency, for support of
this study.  In particular we are grateful to Dr.
John H. Skinner, Acting Deputy Director, Resource
Recovery Division and to the Project Officers, Messrs.
Thomas D. Clark and Laurence B. McEwen for their
guidance and assistance in the performance of this
                         si     Preceding page blank

1.  Under the National  Environmental  Policy Act of 1969,  signed  January  1,  1970.

2.  See p. 14.

3.  For tax laws on waste oil re-ref1n1nq, see Section 2.10,  "Treasury Depart-
    ment" .

4.  "Federal Water Pollution Control  Act Amendments of 1972", PL 92-500,33
    USC 1151, 86 Stat.  816, October 18, 1972.  See Appendix A for full

5.  "Waste 011 Study, Preliminary Report to Congress", April, 1973.

6.  Sen.  Boggs chaired an entire day of waste oil hearings on June 9, 1967,
    before the Subcommittee on A1r and Water Pollution of the Senate Public
    Works Committee (p.261 of Water Pollution - 1967, Part I)

7.  HR 5902,  Introduced March 20, 1973; referred to Ways and  Means Committee.
    Remarks, March 14, 1973  (Congressional Record E1543).  This 1s an Iden-
    tical bill to the one Vanlk Introduced June 14, 1972; remarks, June 14,
    1972  (Congressional Record E6208).  Vanlk had Introduced  earlier, less
    sophisticated legislation to reform lube oil excise taxes on December 2,
    1971, (HR 12015) and on January 18. 1972  (HR 12433).

8.  See Appendix B for full  language.

9.  S 409,  Introduced Jan. 16, 1973,  Identical  to a bill  Thurmond  Introduced
    March 21, 1972.  Remarks, March 21, 1972 (Congressional Record S4314).

10. HR 4421,  introduced Feb.  20, 1973.  This bill and  the  Thurmond bill are
    Identical to the bill Vanlk first Introduced  1n January   1972.

11. The  current Vanik  bill,  in contrast,  would  abolish the excise tax exemp-
    tion  on  off-highway virgin lube oil,  rather than  extend  1t  to purchases
    by re-refiners.
12. S  3890,  introduced July  26, 1968  by   Sen.  Boqgs,  co-sponsored by Sens.
    Muskie  and  Randolf,  referred to the Commerce  Committee.

13. LC-990,  superseding  LC-360.

14. See  footnote #4.
                                      53      Preceding page blank

15.  See FTC,  p.  33.

16.  About 2 percent  of all  lube and industrial  oils  and  qreases  sold annually
    in the U.S.  are  procured by the federal  government.  Most  of these  pro-
    ducts are centrally purchased for all  federal  agencies  by  the Defense
    Supply Aqency through its Defense Fuel  Supply  Center (DFSC).   During fis-
    cal 1971, DFSC procured 23,900,000 gallons  of  motor  oils.

17,  "Waste Oil Recycling Study", DSA, September 1972,  p.  1.  MIL-L-46152
    (engine oil) requires virgin oil regardless of the performance of
    competing re-refined oil.

18.  DSA, Cameron Station, Alexandria, VA.  22314, contact:   Jan Reitman, Field
    Support Division.                                              ;

19.  San Diego, Norfolk, Pearl Harbor, Puget Sound, Oakland, Long leach, Guam,
    Jacksonville and Charleston.  Facilities in these areas account for about
    90% of the Navy fuel handled.

20.  The Navy originally intended to look for "new  products" to use oily wastes
    as raw material.  After contacting major oil companies  and universities
    with strong petroleum Interests, the idea was  dismissed as a waste  of  time.

21, "POL Disposal Techniques"  , U.S. Air Force Contract No. F29601-73-C-0047,
    with Esso Research and Engineering, Linden, New Jersey, January 23, 1973.

22. "Reuse of Waste POL's", U.S. Air Force Contract No.  F29601-73-C-0101,
    with Esso Research and Engineering Company, Linden,  New Jersey, May 1, 1973.

23. For explanation of EPA's NORCO  project, see Section 6.0, p.  23.

24. See note #4,   p. 53 and Appendix A.

25. National Oil Recovery Corporation, March 1971, Project #15080 DBO, EPA
    Water Quality Office.

26. "Recycling  Waste  Oils Into Direct  Fuels and  Other Petroleum  Products",
    EPA Contract No.  68-01-0177, March 7, 1972.

27. American  Petroleum  Institute,  "Waste 011 Roundup....No. 1",  p.5.

28. "Oil  Recovery Program",  December 7, 1971.

29. Wilfred  H.  Shield,  Jr.,  Chief,  Solid Waste Services*, Maryland  Environmental
    Service,  and  Walter  A.  Miles,  Head, Monitoring  and  Surveillance Section,
    Division  of Solid Waste Management, Maryland  Department of  Mental  Hygiene.
    April  1971.

30. "Study of Waste Auto Lubricants as  Incinerator  Fuel",  EPA Contract No.
    68-01-0186, with  GCA Corporation,  Bedford, Massachusetts, April 19, 1972.


31. "A Study of the Economic, Technical, and Environmental  Factors  Affecting
    Reuse of Waste 011 as a Blended Fuel 011", EPA Contract No.  68-01-1859,
    May 17, 1973.

32. "Study of Waste Automotive Lubricating 011 as an Auxiliary Fuel to Improve
    the Municipal Incinerator Combustion Process", by 6CA Corporation, Bedford,
    Massachusetts, February 1973.

33. "Technical and Economic Study of Waste 011 Recovery", EPA contract
    No. 68-01-1806, with Teknekron, Inc., Berkeley, California, March 26,

34. "Develop Information on Waste Oil Recycling", EPA Contract No.  68-01-1870,
    with Recon Systems, Inc., Princeton, New Jersey, June 18, 1973.

35. "The Legal Aspects of  Incentive Approaches to Pollution Control", EPA
    Contract No. 68-01-2203, Washington, D.C., June 28, 1973.

36. Freestone, F.J.,  "Runoff of Oils from Rural Roads Treated to Suppress
    Dust",  EPA Report 0EPA-R2-72-054, October 1972.

37. "Oily Waste  Disposal by  Soil Cultivation Process", EPA-R2-72-110*
    December  1972.

38. "Final  Progress Report on Water Pollution  Control  Demonstration Grant
    No.  WPD-174-01-67" by  Villanova University.

39. 54 FTC  1026-1034, Sayler Refining Co.,  Inc.  et  al., and  54 FTC  1035-1042,
    Frank A.  Kerran et al., doing business as  Double Eagle  Refining  Co.,
    February  14, 1958.

40. The FTC has  ruled on  16  lube oil  labeling  cases, of which 6 have ended
     in appelate  court decisions, Including  54 FTC 1035-1042.

41. 66 FTC  1039-1068, Double Eagle Lubricants,  Inc.,  et  al., October 22,
     1964.   The  opinion does  not  require a  statement of "previous use" rather
    than "re-refined" as  some  reports of FTC  lube oil  actions  have asserted.
     (See "Waste Oil  Practice,  State of  the Art", EQSI.)  The ruling does,
  .   however,  expand  on  the 1958  order by prohibiting re-refiners from repre-
     senting that their  lube  oil  "composed  1n whole or 1n part  of oil that has
     been manufactured,  reprocessed, or  re-refined from oil that has been
     previously used  for  lubricating purposes, has been manufactured from oil
     that has not been previously used".  Since, if the lube oil were composed
     only in part of  used oil,  it would  be manufactured from oil that had not
     been previously  used, the ruling appears to prevent  re-refineHes from
    making truthful  statements about virgin stock used in these.products,
     e.g. in blending.  Although this issue has never been brought  before the
     Commission, FTC  staff have told industry representatives that  they would

    support requests to Indicate blending on product labels.

42. Deceptive Advertising and Labellnq of Previously Used Lubricating 011,
    16 CFR 406.5, 29 F.R. 11650o  August 14, 1964.   The term "re-refined"
    is not entirely prohibited under this regulation.  However, the Commission
    restricted its use because 1t found that the term could be misleading.
    To some consumers 1t might Imply a virgin oil which had been refined more
    than once.  Even when put on notice that the oil had been previously used,
    many consumers would be led to believe that the oil had been restored  to its
    original condition by a complete refining process.

43. "The labeling requirement knocked the bottom out of the re-refined oil
    market...because the label suggested low quality, consumers assumed it
    to be an inferior product, the demand for used oil consequently dropped
    sharply; the re-refiners and reprocessors had tb lower their manufactur-
    ing costs so they could still make a profit."  Wilfred H. Shields, Walter
    A. Miles, "Used 011s:  A Waste or a Resource", April 1971, p. 9.

44. Edward F. Morrison, Staff Assistant to Congressman Charles A. Vanlk

45. "The complaint does not question the quality of respondent's oil",
    66 FTC  1039.

46. 16 CFR 406.2(a).  This view was upheld by the U.S. Court of Appeals,
    10th Circuit, in approving the FTC's cease and desist order, frank A.
    Kerran v. Federal Trade Commission. 265 F2d 246  (1959).

47. See p. 32.

48. Although  the  FTC argued that quality was not an  issue  in its original
    used oil  labeling orders, during  Its considerations  it was persuaded by
    technical evidence  that much of the lube oil made  from used oil was
    indeed  inferior.

49. Under  Section 7  of  the Vanlk oil  recycling bm,  HR  5902,  all  recycled
    oils,  defined as oils  identical or superior  to  new oil  Intended for the
    same  purpose, would carry the  label "Recycled Oil",  and  EPA would  set
    regulations  requiring  container labels  that  advise the purchaser  to re-
    cycle  the oil or dispose  of 1t  1n an otherwise  proper  manner.   See
    Appendix B.

50. Noise  Control Act  of 1972,  enacted October 27,  1972.

51.   See  p.  37.

52. $228,000 was requested for  the first  fiscal  year.

53. Specifically, information from the  Institute Francais  du Petrole (IFP).

54.  The guidelines will  soon be republlshed to reflect their  non-mandatory
    nature.  The title and number are not yet determined.

55.  A preliminary investigation of this supposition indicates that waste oil
    may frequently be used for space heating fuel  in small  industries,  or, 1n
    the warmer climates of the nation, may be sold for re-refining feedstocks.

56.  26 CFR 48.4091-2 (b)(11-111), "Manufacturers  on whom taxes are Imposed
    do not include "any person who merely cleans,  renovates,  or refines used
    or waste lubricating oil, or any person who merely blends or mixes  one or
    more taxable oils with used or waste lubricating oil that has been  cleaned,
    renovated, or refined."  Section 314.40(d)(3)  of Treasury Regulation 44.

57. Amendments to the Internal Revenue Code, 1954, PL 89-44,  June 21, 1965.

58. By adding a new Section 6424 to the Internal Revenue Code of 1954.

59. Although the tax changes were damaging to re-refiners, it appears that
    Congress did not intentionally set out to burden the industry.  Instead,
    the Administration and Congress were 1n a mood to cut taxes 1n 1965.
    President Johnson's bill would have repealed all excise taxes on lube
    oils.  The House agreed to drop the tax on off-highway use on the grounds
    that 1) the Highway Trust Fund was 1n  special  need of more revenue and 2)
    that some tax advantage was  needed to  keep the re-refining industry
    alive.  The Senate disagreed with both the President and House and kept
    the full lube tax, arguing that 1t was needed  by the re-refiners.  The
    House  views prevailed  in conference committee  with, It 1s reported, very
    little or no  pressure  from competing virgin oil producers or  Industrial
    users.  Senate  Report  No. 324, p. 26,  June 14, 1965 and  House Report  No.
    433, p. 21, May 28,  1965.

60. Rev. Rul. 68-108.

61. Rev. Rul. 68-108.   It is  customary tax code theory that  if a  taxable  good
     1s used  in  making  another  taxable good,  the initial tax  is forgiven.   In
     this case,  however,  no tax  1s  paid on the second  good, i.e.  blended  re-
     refined  lube  oil,  and so  the first tax,  I.e.  on  virgin lube  oil  for  blend-
     Ing, was  not  forgiven.

 62.  Rev.  Rul.  57-204.   This decision 1s  not strictly an anti-re-refiners  de-
     cision although it may be an ant1-re-ref1n1ng decision.   It  1s anticipated
     that a decision that allowed an exemption would have  spurred the major oil
     refiners  to Include some used oil 1n their crude oil  processing 1n order
     to escape the excise tax on lube oil  products.  This  might have resulted
     in greater  recycling of waste oil -  though how much is uncertain since
     the volume  percentage in the final  product from waste oil would have been
     minute.   It 1s more certain that such an exemption would thereby lose
     their  tax edge in the highway market 1n addition to losing 1t in the off-
     highway industrial  market.

63. Stat. 823, PL 92-500, October 18, 1972.

                               APPENDIX  A

     "(m) (1)  The Administrator shall, in an effort to prevent degradation
of the environment from the disposal of waste oil, conduct a study of (A)
the generation of used engine, machine, cooling, and similar waste oil,
including quantities generated, the nature and quality of such oil, present
collecting methods and disposal practices, and alternate uses of such oil;
(B) the long-term, chronic biological effects of the disposal of such waste
oil; and (C) the potential market for such oils, including the economic and
legal factors relating to the sale of products made from such oils, the level
of subsidy, if any, needed to encourage the purchase by public and private
nonprofit agencies of products from such oil, and the practicability of
Federal procurement, on a priority basis, of products made from such oil.  In
conducting such study, the Administrator shall consult with affected indus-
tries and other persons.

"(2)  The Administrator shall report the preliminary results of such study
to Congress within six months after the date of enactment of the Federal Water
Pollution Control Act Amendments of 1972, and shall submit a final report to
Congress within 18 months after such date of enactment."

        APPENDIX  B
             61      Preceding page blank

                      MARCH 20,1973
Mr. VANIK introduced the following bill; which was referred to the Committee
                     on Wnys and Means
                    A  BILL
To  provide for the recycling of used oil and for other purposes.
 1      Be it enacted bfl the. Senate and House of Reprcsenta-
 2  twcA of the United Slates of America in Congress assembled,
 3  Thnt this Act may he  cited  ns the "National Oil Recycling
 4  Acl".
 5                        PURPOSES
 6      $K(\ '2. Congress finds that hundreds  of millions of gal-
 7  Ions of nsed oil  are hcing wasted each j'car, and are heing
 8  disjioscd of in ways which pollute the waters, air,  and land
 9  of (he United States. For the purposes of—
10           (1) protecting the health and welfare of the people
11      of the United Slates;
                          63     Preceding page blank

 1           (2)  restoring, preserving,  and enhancing  the Ka-
 li       (ion's environment; and
 '.'>           (3)  conserving  oil for  the  national defense; Con-
 4       gress declares that to the greatest extent  possible consist-
 ")       cn(  with  (his Act and other Federal law, used  oil shall
 <>       be recycled.
 7                         DKPINITION.S
 8       SKC. .'». For 1 he purposes of this Act—
 9           (1)  the term "used oil" means  nil oil  which has
10       through use been contaminated b)* physical or chemical
11       impurities which have  not been  removed by  subsequent
12      re-refining or other processing;
13          (2)  the term "recycled oil" means used oil which
14       has been re-refined  or otherwise  processed  to  remove
l-r)      the physical and chemical contaminants acquired through
Hi      use, which by itself or when blended with  new oil  or
17      additives is substantially identical or superior to new oil
18      intended for the snme purposes;
19          (3)  the  tcnn  "new oil" means nil  oil  which has
20      been refined from virgin oil and may or may  not contain
21      additives, but has  never been  used. The  term "new
22      oil" does not  include "used oil" and  "recycled oil"  de-
23      fined in subsections 3(1) and 3(2);
24           (4) the term "lubricating oil" means all oil rcgard-
25      less of origin,  which-


1               (A) is  suitable  for use as a lubricant,  or
2               (B) hj sold for use as  a lubricant;
3           (5)  the term "hydraulic oil" means all oil  which
4       is used  primarily  to transmit  power or pressure,  but
•r>       which mny  also serve lubricating  and other functions;
^           (0)  the term "cutting oil" means all  oil which  is
?       used primarily in cut-ting, milling,  and machining oper-
^       ations  (including forging,  drawing,  rolling,  shearing,
9       punching, and  stamping),  but which may  also serve
W       lubricating and other functions;
11            (7) tbe term "fuel oil" means  all  oil  which has
^      been refined, re-refined, or otherwise processed for the
!•''      purpose of being burned to'produce heat;
3 I           (8) the term "automotive  oil"  means  all oil,  in-
13      eluding lubricating oil and hydraulic oil, which  is used
1<>      in automobiles,  trucks,  buses, motorcycles,  and all other
17      motor vehicles which travel on roads and highways;
38      .     (J))  the lerm ''industrial oil'' means all oil exclusive
11'       of virgin oil. fuel oil, oils used for cooking and medicinal
20       purposes, and automobile oil. Industrial oil includes, hut
21       is not limited to, lubricating oil,  hydraulic oil. and  cut-
2*2       ting oil when such  oils  are not automotive oils;
2:1            (10)   the term  "used  oil collector"  means any  per-
24       son who controls a system which functions to  retrieve


1      or collect used oil for sale  or  transfer to oil  recycling

-      facilities,-or for other methods of disposal;

X           (11) the term "used oil recycler" means any person

4      who re-refines or otherwise processes used oil to remove

5      its physical and chemical contaminants.

6                       TAX PROVISIONS

7      SKC. 4.  (a)  The Internal Revenue Code of 1954, Sub-.

8   part B—Lubricating Oil, is amended to rend as follows:


10       "There  is  hereby   imposed on lubricating,  hydraulic,

11   and cutting  oils  (other  than  recycled oils) which are sold

12   in the United States by the manufacturer or producer a tax

l;'  of 6 cents per gallon,  to be paid by the manufacturer or

^  producer.

ir>  "SEC. 4092. DEFINITIONS.


^  TUKKRS.—For the purposes of this snbpart, a  vendee who

^  has purchased lubricating, hydraulic, or cutting oils  free of

19  tax under section 4093  shall be considered the manufacturer

20  or producer of such oils.

21      " (b) LUBRICATING OIL.—The  term 'lubricating oil'

22  means all oil regardless of origin, which—

"'**           " (1) is suitable for use as a lubricant, or

             " (2) is sold for use as a lubricant.

2;)       " (c) HYDRAULIC  OIL.—The term 'hydraulic oil' means


I  all oil which is used primarily to transmit power or pressure,

2  hut which may also  servo  luhricating and other functions.

3      "(d)  CUTTING OIL.—The term 'cutting oil' means all

4  oil  which is used primarily  in cutting, milling, and maehin-

5  ing operations  (including forging, drawing, rolling, shear-

6  ing, punching,  and  stamping), hut  which may also serve

7  luhricating and other functions.

8       "(c)  RECYCLED OIL.—The  term 'recycled oil' means

9   used oil  which has hcen re-refined  or otherwise processed

10   to  remove the physical and chemical contaminants acquired

11   through use,  which hy itself or when hlendud with new oil

12  or additives is  substantially identical or superior to new oil

13  intended for  the same  purposes.


15      "Under  regulations prescribed hy the Secretary or his

16  delegate,  no  tax shall he imposed under this suhpart upon

17  lubricating, hydraulic,  or  cutting  oils  sold  to a manufao-

18  hirer or producer of such  oils for resale hy him."

19       (b)  Section  4094  of the Internal  Revenue Code of

20   H)f>4  (Suhpart 15—Lubricating Oil, cross reference) is herc-

21   by repealed.

22       (c)  Section  6424  of the Internal  Revenue Code of

23   H'54  (providing ofT-highway users of lubricating oils with
•_>4   a tax refund of 6 cents per gallon)  is hereby repealed.


-      Sue. f>. All Federal officials shall act within their author?
3  ity to encourage the use of recycled oil. Such action includes*
4  hut is not limited to—
 ">            (1)  procuring  recycled  automotive and industrial
 f>       oils for all military and nonmilitary Federal uses, when?
 7       ever such recycled oils are available at prices competitive
 8       with those of new oil produced for the same purposes;
 9            (2)  requiring all persons contracting with the Fed*
W       eral Government to use recycled  oil in performing such
U       contracts, whenever recycled oils are available at prices
12      competitive with those of new oil produced for the same.
!•*      purposes;
H           (3) f educating the Government and private sectors*
15      of  the economy as  to the merits of  recycled oil, and
 1(>      (he need, for  its use  in  order to  reduce the drain  on
 17      the Nation's oil reserves and minimize the disposal of,
 •18      used oil in  ways harmful to the  environment;
 19            (4) - where necessary,  assisting  and  encouraging-
 20       the development of  performance  standards and  speci-
 21       fications, and  systematic and economical  testing pro-.
 22       cedures to facilitate the comparison of recycled oil with
 23       new oil.
 25      SEC. 6.  (a)  This Act  shall in  no way preempt State,
 2^  regulation  of recycled  oil  or used  oil disposal  whenever

1   such regulation provides  for stricter control  of  recycled oil
2   or used oil thnn provided for by Federal law.
3        (b)  The States should encourage the use of recycled
4   oil in order to accomplish the purposes of this Act. In order
5   to qualify  for Federal grants under section  12  of  this Act,
6   States shall adopt lows, regulations, and administrative ma-
7   chincry which shall provide for, but not be limited to—
8            (1)  requiring that used oil collectors  obtain State
9        permits prior to engaging in used oil collecting activities.
10       Such  permits shall require  as a  minimum information
11       pertaining to methods for collecting, storing, transferring,
12       and disposing of used oil, as well a,s the identity of used
13       oil sources,  purchasers, transferees, and disposal sites;
14           (2)  requiring that  used  oil  rccyclers  obtain State
15       permits prior to engaging in recycling operations. Such
16       operating permits shall require as a minimum information
17       identifying—
18                (A )  the  sources and quantities of used oil to be
19           acquired for recycling;
20                (B)  the  recycling facility's  plant size and op-
21           crating capacity;
22                (0)  the specific  recycling  technologies to be
23           utilized;
24                (1))  the quantities and grades of  recycled oil to
-•*»           be produced; and

1               (E)  the  methods  of  disposing  of  the waste
2           byproducts;
3           (3)  when recycled  oil is  available at prices com-
4       petitive with new oil, using recycled oil for all automotive
")       and industrial  uses of the State government, and requir-
0'       ing all parties contracting with the State to use recycled
7       oil in the performance of  such contracts;
8           (4)  regulating the retail sales of automobile oil not
9       covered by  section 8 of this Act so as to encourage the
1U       recycling of used oil;
11        •   (5)  prohibiting the use of used oil as fuel oil or for
12      the oiling of State roads, unless such oil has been pro.c-
13      essed  to meet the  minimum  standards  for  such uses
14      established  by Federal and  State pollution control laws;
15           (6) educating the public  and private sectors of the
10'      State as to the merits of  recycled oil, and the need for its
17      use in order to reduce the  drain  on  the  nation's  oil re-
18      serves and minimize  the disposal of used oil in  ways
19      harmful to the environment.
20                      LABELING OF OIL
21       SEC.  7. (a)  All  recycled  oil  shall  bear on the front
22   panel of the container in which such oil is packaged for sale
23   the inscription "RECYCLED OIL" clearly and prominently
24   placed. All automotive  and  industrial oil, both.new and rc-

1   cycled, slwll War OH  the container in which such oil is sold
2   the inscription  "It is in the national interest to recycle this
3   product after use."
4       (b)  The Administrator of the Environmental Protection
5   Agency shall promulgate regulations requiring nil containers
G   of automotive and industrial oil, both new and recycled, to
7   bear labels relating to tho proper disposal of such oils after
8   use.
10      SEC. 8.  (a) Automotive  oil packaged for sale for self-
11  service or carry away by the consumer shall be sold in reseal-
12  able containers capable of holding used oil without spillage.
13       (b)  All persons making resealable container sales shall
14  collect a customer deposit of SO. 10  per resealable container
15  regardless of size. This deposit shall be refunded upon  return
16  of  the container, either containing used oil or empty.
17       (c)  All persons who sell automotive oils shall maintain
18  used oil collection facilities on (heir premises. Such  facilities
19  shall—
20            (1)  be of suflicient si/e and capacity to handle all
21       customer returns of used oil and used oil containers; and
22            (2)  be serviced  on a regular basis by used oil col-
23       lectors who dispose of such used oil in a manner not in
24       contravention  to this  Act.



2       SKC. 9.  (a)  It sliiill be unlawful for nriy person to enter

3   into any contract  or  agreement where the intent of such

4   contract or agreement is to discourage the recycling of used

0   oil.

6       (I))  Violations of subsection  (a)  are  subject to a fine

7   of 850,000 for each violation thereof, or imprisonment for

8   a term not to exceed one year,  or both.

 9                          RECORDS

10      SKC. 10. (n) Users of more than 100 gallons of industrial

11  oil per year shall maintain complete records of—

12           (1) the quantities and types of all oils  purchased

!•*      for industrial  use;

14           (2) the  quantities and types of  all industrial oils

15      consumed during use; and

16           (3) the  quantities and types of  all industrial oils

1?      disposed of after use—

1&               (A) by in-house recycling;

19               (B)  by delivery to  or pickup by used oil col-

2°           lectors or used oil recyclers; or

21               (C)  by any other method of disposal.

22       (b)  Used oil recyclers shall  maintain  complete records

23   of-

•^            (1)  the quantities  and  types of all used oil  ac-

25       quired;


1           (2) the quantities and types of all new oil acquired

2       for use in blending recycled oil;

3           (3)  the quantities,  types, and sources  of sale or

4       other  disposal of all recycled oil produced; and

5           (4) the quantities,  types, and  places of  disposal of

6       all waste byproduct generated in the recycling process.

?        (c) Used oil collectors  shall maintain complete records

8   of-
 9            (1)  the quantities  and types of used oil collected;

10      and

11           (2)  the quantities and types of used oil-^-

12               (A)  delivered to recyclers; and

13               (B)  otherwise disposed  (including the place

14          of disposal).

15       (d)   .Records required to be kept by this section or any

16  other provision  of this Act  shall be kept in accordance with

17  regulations promulgated  by the Secretary of the Treasury,

18  the Secretary of Commerce, and the Administrator of the Kn-

19  vironmental Protection Agency.

20                          w HI'OUTS

21      SKC. 11. The Administrator of the Environmental 1'ro-

 22  tcction Agency shall make  reports to Congress no later than

 23  March 31 of each year, such reports containing,  but not lim-

 24  iled to, the following information—


1           (1)  the amount of automotive and industrial oil sold
2      throughout the United States each year;
3           (2)  the amount of used oil recycled each year;
4           (:•{)  the significance of used oil as a  contributor to
>f>      water pollution and other environmental problems; and
G           (4)  the problems of the oil recycling industry (in-
7      eluding new technological requirements mid necessity for
8      tax incentives).
 9                   MANDATORY  LICENSING
10       SKC. 12. Whenever the Administrator of the  Environ-
11   mental Protection Agency determines—
^           (1) thut-
1:5               (A) in implementing the provisions of this Act,
14          a United States patent right not otherwise available
15          is necessary to enable any person to comply with
16          this Act; and
17              (B) there are no  reasonable alternative methods
18          to accomplish  this Act's purposes; and
I9           (2) that the inavailability of such patent  right may
20       result  in  a  substantial lessening of competition or fl.
21       tendency to create a monopoly in any line of the Nation's
22       commerce,  the Administrator,  through  the  Attorney
23       General, may so certify to a district court of the  United
24       States,  which may order the person owning  the patent
25       to license it on such reasonable terms as the court, after
26       hearing, may determine.

                                       Reproduced  from
                                       best available copy.
1                  1'KNAl/riRK  AND KNFOKCEMKNT

2       SKO. 1)J.  (a)  Violations of section 4 shall he punished

•'*   as  provided  for by the Internal Revenue Code of  1954  (MS

4   amended).  Violations of section 9  (Restrictive  Contracts

•r>   Prohibited)  shall he punished  as provided for in section 9.

('   Any person violating any provision of this Act which  docs

^   not provide for  specific penalties or  punishment thereunder

^   shall be subject to a civil fine not. to exceed $25,000 for  each

"*   violation, or ho guilty of a misdemeanor punishable  by six

•^  months in a Federal penitentiary for each violation, or both.

J1        (b) It  shall be the  duly of the  United Slates Allonicv
         \  f                   %•                              •

lwl  (leneral and his representatives, United  States attorneys, to

ll{  prosecute, violations of this Act: In (he event that the  Fed-

    eral (lovernment fails to fulfill its duty of enforcement under

    this Act, any citizen may bring an action in his or her name

 '  to enforce this Act without regard to any amount  of  alleged

 '  damnjres.

                  CKANTS  AND AI'I'l.'OI'IMATIONS

         SKC. 14.  (a)  There is herebv authorized to lie appro-

     j>riated  for the fiscal year ending  June  ol),  1974, and  for

     each succeeding fiscal  year.  -s25.OOO.OtlO for  grants  to  the

     Slates to assist them in fulfilling the purposes and provisions

     of  this Act. The  Adni'misiralor of the Knvironmenlal Pro-

     lection Agency shall make1 allotments  to tlie  Stales,  noi  to
 %) •*
     exceed  10 cents  per  capita  for  any  Slate  based  on  the



1  latest national  census, when he  has determined that they

2  arc  in compliance  \viih  this Act. The Administrator may

:?  prescribe regulations,  pursuant to this Act, governing the

4  expenditure of the allotments.

;>       (h)  There  is hereby  aulhorixed  to he  appropriated

(>  for  the  fiscal year ending  June 30, 1974,  and for each

 '  succeeding fiscal year through the fiscal year ending June 30,

8   1977, $10,000,000 for  the development of new processes

9  and technology to he  used in  the economical and ecological

10   recycling of used oil. The Administrator of the Environ-

    mental Protection Agency may make grants of this money,

1 *)
    pursuant to regulations and  requirements  he  shall  adopt.

1 'I
    to private parties, or use this money  within  the Environ-

11  mental  Protection Agency for the above  purpose?.

]f>       (c)  There is hereby authorized to  he  appropriated for

1C  the fiscal year ending June 30, 1974, and for each succeeding

17  fiscal year, through the fiscal year ending June 30, 1977,

18  $5,000,000 for  the  development of  standards  and  testing

1'J  methods to facilitate the comparison of recycled oil with new

20  oil. The Secretary of Commerce may make grants  of this

21  money, pursuant to regulations and  requirements he shall

'2'2  adopt, to private parties, or use this money within the De-

2'»  partmcnl of Commerce for the above purposes.

2t                       KKKKCTiVK DATE

-•"'       Sue. 1f>. Section J)  (llestriclive Contracts Prohibited)  of

-(i  this Ad isclTcclivc immediately  upon this Act becoming law.


Section 4 (Tax Provisions) of this Act becomes effective on the first day
of the calendar quarter following the day this Act becomes law.  All  other
provisions of this Act become effective ninety days after this Act becomes

              APPENDIX  C
                    79      Preceding page blank

American Petroleum Institute, Engine Service Classifications and Guide
  to Crankcase Oil Selection, API Publication #1509, Washington, D.C.,
  January 1971.

  This pamphlet discusses why the engine service classification was
  developed and the basis of the classification system.  API gives a
  definition for each classification category.

American Petroleum Institute, Farm Equipment Lubrication-Questions/
  Answers. API Publication #1507, Washington, D.C.

American Petroleum Institute, Final Report of the Task Force On Used
  Oil Disposal. API Publication No. 4036, Washington, D.C., May 1970.

  The Task Force  recommended that the burning of used auto lubricating
  oils, blended with residual fuel oil, be encouraged as an effective
  way to deal  with disposal problems.  It also recommended  1)  that ser-
  vice stations continue to contract with scavengers for waste oil
  pick-up  (or  that major suppliers attempt to enter annual contracts
  for regional pick-up),  2)  that contracts  between oil companies
  and service  stations  require non-polluting disposal, and  3)  that the
  API should provide information and support  for state legislation which
  assumes  safe, cheap,  non-polluting, and non-disruptive disposal.
  API's Task Force conducted a survey of service stations and examined
  five burning tests by major oil producers.  Although burner fouling
  occurred  in  the burning tests, API recommended that waste oil be
  burned  in a  25% blend.
 American  Petroleum Institute,  How to  Sell  Motor  Oil.  API  Publication
   #1508,  1972.

   Marketing and  salesmanship techniques  for  the  service station
   attendant are  described.
 American Petroleum Institute,  Know Your Motor Oil.  API  Publication #1507,
   April  1971.

   Engine demands and motor oil  characteristics are  simply discussed.
   Criteria for choosing oil and determing oil change frequency are given.
                                              Preceding page blank

 American  Petroleum  Institute, Lubricant Service  Designations for
   Automotive  Manual  Transmissions,  API Publication No.  1560, 1972.

   The API-GL  series Is  described  for different engine designs and
   operating conditions.

 American  Petroleum  Institute, Lubrication  of Earth Moving  and Other
   Heavy Duty  Equipment. API  Publication #1578, Washington, D. C.

 American  Petroleum  Institute, Manual on Disposal of  Refinery Wastes,
   First Edition,  Washington, D.C.,  1969.

   A loose-leaf binder contains  technical  alternatives  for  disposing
   of liquid wastes  from references.

 American  Petroleum Institute, The Migration of Petroleum Products in
,   Soil and Groundwater,  Principles and Countermeasures. Publication No. 4149,
   Washington, D.C., January 1973„

   The booklet describes fire hazards and  safety procedures; water
   contamination hazards; spill  control and recovery; detection and
   analysis techniques; biological degradations of petroleum;  and
   actual  incidents of oil migration.

 American  Petroleum  Institute, Motor Oil Guide. API Publication  #1551,

   The guide discusses the same  issues covered by Know  Your Motor  Oil
   but in  a more thorough, less  popularized way.   it  discusses engine
   lubricating functions of motor oil, engine design, the lubrication
   system, contamination, driving habits,  additives,  and oil classifi-
   cation  systems.

 American  Petroleum Institute,  Petroleum Facts &  Figures 1971, and 1972
   Annual  Statistical Review. Washington,  D.C

   Statistics  are reported for crude production,  refining,  transportation,
   marketing,  use, prices, and taxes.

American Petroleum Institute, Committee on Disposal  of Waste Products,
  Division of Marketing, Waste Oil Roundup...  No.  1  and Waste Oil  Roundup...
  No. 2. API Publication No. 1582, Washington, D.C., September 1972 and
  April 1973.

  These reports are an attempt by the  API  to provide a  clearinghouse
  for new developments and findings  on waste oil collection  and disposal.
  The first Roundup reports data  on  the magnitude  of the waste oil
  problem, disposal methods, collection, research  on technical solutions,
  and legislation.   The second Issue reports comments made on the  first
  issue, repeats much of its data, and adds new Information  on waste oil
  research.  The Roundups  announce that the API's Committee on  Disposal
  of Waste Products has a program to develop non-polluting disposal
  techniques for using waste oil  1n  refinery feedstocks or for blending
  with heavy heating oil.

American Petroleum Institute, Why Change Motor Oil and  When, API
  Publication No. 1576, 1972.

  This is a slide show and accompanying script which describe what
  happens when motor oil is not changed periodically.

American Society for Testing and Materials, ASTM Research Report D2;1002,
  Revised January 1971.

  The ASTM here establishes the test methods and performance characteristics
  for various grades of  lube oil, and also technically describes each
  of the grades.

Armour  Research Foundation, Separation  and Characterization of Add Sludge,
  Report No. ARF-3859-3, April 19,  1962.

  The report done  for  the  Association of  Petroleum  Re-Refiners concludes
  that  one half the  acid sludge from  re-refining operations  is organic,
  including equal  parts  of lube oil,  polymers, and  asphalt.  Solids
  are  largely  lead,  barium sulfates,  and  carbon.  A boiling  paraffin
  solvent  was  found  best for  extracting the oil and polymers.  The  report
  represents the third phase  of a three-phase  project  for APR.

Armour  Research  Foundation,  Study of  Re-Refining  Waste Disposal,  Report
  No.  ARF-3829-7,  May 19,       *^
   The  report  done  for  the  Association of  Petroleum  Re-Refiners  examines
   solvent  extraction processes  in  an effort  to avoid  the  acid sludge
   residue  resulting from re-refining techniques.  Phenol  was the most
   effective sludge extraction solvent found,  but  it did not extract all
   ash  components.  Some work on acid sludge  disposal  and  separation was
   also reported.


Armour Research Foundation, Study of Re-Refining Haste Disposal  Problem.
  Report No. ARF-3829-6, AprTTT, 1961."                      "

  This report presents a bibliography of material relevant to Armour's
  study of non-acid re-refining methods for the Association of Petroleum
Armour Research Foundation, Study of Re-Ref1n1ng Waste Disposal. by
  R. E. Putscher, Report No. ARF-3808-5, January 29, 1960.

  The study for the Petroleum Re-tef1ners Association examined ways of
  eliminating or minimizing the acid sludge disposal problems by non-
  acid methods of treatment.  Crankcase drainings from different parts of
  the country were found to be uniform 1n composition.  Evaluation of
  several chemical flocculents and solvent predpitants showed no obvious
  preferred choice.
Arthur D. Little, Study of Waste Oil Disposal Practices in Massachusetts,
  Report to the Commonwealth of Massachusetts, Division of Water
  Pollution Control, Report No. C-70698, Cambridge, Mass., January 1969.

  The study was commissioned to provide a basis for future waste oil
  program planning  in the state.  The scope  included:  annual quantities
  generated,  geographic distribution, types  of sources, amounts disposed
  of by  various methods, disposal practices  of collectors and reprocessors,
  cost of reprocessing to fuel, and long-term trends.  Among other findings,
  the study reported that 42% of automobile  waste oil becomes a probable
  pollutant (1% dumped in sewer, 18% fate unknown, and 23% dumped on
  ground) and 22% becomes a potential pollutant (11% road oil, 8% taken
  from state, and 2% farm use).  Some 37% appeared to be reclaimed as
  fuel oil, more as lube oil.

 Ash,  David, "Used Motor Oil-Any Good?", Argosy, Vol.364, No. 4, April  1967.

  The author  presents a well-argued and well-researched commentary on
  some of the major institutional  issues  surroundlsng recycling of waste
  oil.   He  notes the resistance of the major oil companies to re-refiners
  and speculates on economic motives that might Induce such  resistance.
  Examples  of major fleets  using re-refined  oil are  provided and the difficul
  ties  of oil disposal alternatives to  re-refining are described.  The
  author cites testimonials for recycled  oil by lube experts, briefly
  reports the technical  problems encountered in re-refining, and evaluates
  two major critiques of  recycled  oil.   He  rejects the allegation  that
  lube  oil  wears out  but  at least  partially accepts  the  idea that  the
  quality of  re-refined  service station waste oil  can  vary widely.
  He suggests the  buyer  look  for  the APR emblem  label.

Barclay and Company, Inc., Barclay Waste 011  Burner,  Product Bulletin,
  New York.

  The process described will Incinerate waste oil.
Bernard, Harold/'Embroiled in 01?, EPA, Agriculture and Marine Pollution
  Control Branch, Division of Applied Sciences and Technology, reprinted
  in the Proceedings of the Joint ERA-API Conference on Prevention and
  Control of Oil Spills. Washington, D.C.. June 15-17, 1971. pp. 91-96.

  This oft-quoted paper on waste oil disposal discusses the fate of
  used automotive crankcase oil and concludes that about 500 million
  gallons each year go into the environment.  Burning tests produce mixed
  results; although some tests showed 3 to 1 dilution with virgin fuel
  would be adequate, other tests showed burner clogging.  The vacuum
  distillation experience of NORCO  (g.v.) was presented.  The paper does
  not go into detail in any one area, but it raises many of the Important
  issues in waste oil disposal.
Bethea, S. R., et.al., A Modern Technique for Automotive Haste Oil Re-
  Refining - DistiTTation Plus HydrotreatiTig submitted for Publication
  in HPI.
 Bonnifay,  Pierre  and  Durtiau,  Robert, A New Process for Reclaiming Spent
   Lubricating  Oils,Institute Frangais du Petrole, New York, New York,
   September  1972,  also  published  as  Report No. F&L-72-51, National
   Petroleum  Re-Refiners Association, September 1972.

   A process  developed by  the French  Petroleum Institute 1s described
   for propane  clarification of spent lube oils prior to conventional
   acid/clay  treating.   The  IFP process lowers but does not eliminate
   the amounts  of  acid and clay needed, improves  oxldative stability of
   reclaimed  oil,  and  lowers ash content.  The authors claim that  product
   quality  is constant,  yields  are higher, and plant  investment is low.
   Technical  information given  is  inadequate for  experimental  replication
   of the IFP process.

 Booth, G.  T.,  The Oil Company's Partner  in  Proper  Service Station Waste 011
   Disposal - The  Collector  and Re-Refiner.  Paper #  F&L-72-46, National
   Petroleum Refiners  Association, Washington,  D.C.,  September 1972.

   Booth reports a study showing that manufacturers  of  second  and third
   grade lube oils sometimes abuse the  API/SAE  quality  rating  system.
   He also  reports a Bureau  of  Mines  plan to establish  regional waste oil
   collection centers  nationwide to provide  recycled oil  for federal

Bowen, D.H. Michael, "Waste Lube 011  Pose Disposal  Dilemma",  Environmental
  Science and Technology. Vol. 6, No. 1, p.  25, American Chemical  Society,
  Washington, D.C., January 1972.

  The article reviews much of the waste oil  research carried  on up to
  publication date.  It concludes that reprocessing may be the best
  answer but that the new technology required would add costs to an
  industry already under severe economic pressure.   API and A.D. Little
  waste oil disposal surveys (q.v.) are summarized.  Scavenger operations
  and obstacles to re-ref1n1ng are Indicated:  tax burdens, Increasing
  additives, and residual disposal.  The NORCO and IFP processes for re-
  refining are discussed and the API's recommendation to use  waste oil
  for fuel Is reviewed.
Bunker, John, "From Pollutant to Resource", Christian Science Monitor.
  July 25, 1973.

  Standard data on waste oil generation and on EPA research efforts is
  given.  Although a generally accurate overview, some assertions are
Burhenne, W.E. and Irwin, W.A., "A Model Waste 011 Disposal Program 1n
  The  Federal Republic of Germany," Ecology Law Quarterly. School of Law,
  University of California, Berkeley, California, Vol. 1, No. 3, Summer

  The  article is a detailed description of the 1968 Waste Oil Law 1n
  West Germany.  The law established a complicated, but nonetheless
  effective, bureaucratic and economic structure to regulate disposal
  of waste oil.  The government taxes all oil brought Into the country
  and  then uses these funds to support a subsidy Incentive system for
  proper disposal of waste oil.  A small payment 1s allowed for  Incinera-
  tion, a larger sum for use as fuel oil,  and an even larger sum for re-
   refining  to  lube oil.  The  authors  note some of  the law's  defects,  sug-
   gest improvements, compare  the  actions of  other  European countries, and
   comment on the dangers of arbitrary  disposal of  waste  oil  to  the environ-
 Bylinski,  Gene,  "Metallic  Menaces  1n  the  Environment,"  Fortune, January

   The dangers  of metals  as non-degradable pollutants  1s discussed.   Ex-
   pected federal  restrictions on metallic pollutants  can be  expected to
   hinder plans to dispose  of waste oil  by burning 1t  as fuel.

 Byrne, J., Presentation  of the API Committee on Disposal of  Waste^Products;
   National Petroleum Refiners Association 197Z Fuels  and Lubricants  Meeting,
   New York, New York, September 14, 1972.

"California Project Turning Sump to Soil,"  011  and Gas Journal.  58,
  September 11, 1972.

Christiansen, F.A., Clingan, W.W.,  Hartmann, L.M., Engines Like  Ash!ess
  Detergents, Society of Automotive Engineers,  June 1962.
Commander, J.C., Nonradioactive Waste Oil Disposal  Study, Idaho Nuclear
  Corporation, prepared for U.S.AEC, Idaho Operations Office, under
  contract No. AT(10-1)-1230, Idaho, February 1971.

  The report reviews applicable regulations and standards, estimates
  the volume and character of waste oil generated,  describes collection
  and storage techniques, and discusses disposal alternatives.  Cost
  trade-off studies and environmental Impact statements are included.
  The analysis concludes that commercial reclamation is economically
  unattractive due to disadvantageous tax and labeling laws and that
  waste oil should be used for surface treatment of unpaved roads.

Conner, Michael J.,  "Project of a Small New Jersey Company Could Cut
  Oil Pollution of U. S. Waters,"  Wall Street Journal, February 7, 1973,
  p. 10.

  EPA's research  at  the National Oil Recovery Corporation  (NORCO)  is
  discussed.  The article gives economics and production data on the firm
  and comments  on the decline of the re-refining industry.   It describes
  EPA's major financial support for NORCO, implies that the  results of
  the first  phase were not what was hoped for.  However, it  quotes rosy
  predictions of  future successes made  by both  the firm's  owners and by
  EPA officials.
 Cornell,  Howland,  Hayes  and  Merryfield,  Seattle  Area  Oil  Waste  Disposal
   Facility Study,  Seattle, Washington, August 1969.

 Crittenden, A.M.,  Re-Refining Lubricating Oils for Railroads, American
   Society of Lubricating Engineers 15th  Annual Meeting,  Cincinnati,  Ohio,
   April  1960.
 Cruikshank, Major Charles B.,  Oil  Re-Ref1ning--Its Importance to the USAF
   Economy,  Research paper submitted to the faculty of the Air Command
   and Staff School  of the Air University, Historical  Research Center,
 •  Maxwell AFB, Alabama, October 1949.
 "Current Developments", Environmental Reporter, Vol.2, Nos. 1, 40, 43,
   50, Bureau of National Affairs, May 1, 1971 - April 30, 1972.

   Miscellaneous Congressional and Administration actions on waste oil
   are reported.


Cutler, Edward Taylor, "Reusing Oil", Environment,  Vol.  14, No.  3, p.55,
  a letter to the editors, April 1972.

  The letter comments on the A.D. Little and API waste oil  reports (q.v.)
  and suggests that re-refining to lube oil  is too  difficult while
  blending for fuel oil is too polluting.  Instead  he argues for reprocessing
  used oil to fuel oil using a new method developed by the author's firm,
  Pilot Research and Development Corp., Merlon Station, Pennsylvania.

Delos, J.W., Techniques of Haste Oil Handling - Automotive Operations,
  24th ASLE Annual Meeting, Philadelphia, Pal, May 1969.

Del sky, Richard, "011 Pollution  In Sewers?" New York Post. December 26, 1970.

  Commissioner of Water Resources, Maurice Feldman, says gas stations
  probably will have to begin accounting for all their used oil.  The
  possibility of oil build-up and explosions in the sewers is reported.
  See also, "Gas Stations Found  Dumping Waste 011 in Sewer Systems,"
  loc. cit.
Dotson, D., etal.,Land Spreading; A Conserving and Non-Polluting Method
  of Disposing of Oil Wastes, August 1970.

Ebrey, 6.O., "Re-Refining of Used Mineral Oils by Treatment with Activated
  Clay and Heat," Lubrication Engineering. December 1950.

Environmental Law Institute, "The Legal Aspects to Incentive Approach
   to Pollution Control", EPA Contract No. 68-01-2203, Washington, D.C.,
  June 28, 1973.

  The contract provides $60,000, a part of which will be devoted to study
  of alternative federal policies on waste oil control.

Environmental Quality Systems,  Inc., Waste Oil Recovery Practices State
  of the  Art, (1972), prepared  for State  of Maryland, Maryland  Environmental
  Service and U.S.  Environmental Protection Agency, Washington,  D.C.,
  December 1972.

  This report completes the first objective described in the MES grant
 1 application to  EPA (q.v.).  Although there  are some errors,  1t is the
  best data  compilation on this Issue now available.  Its  chapters cover
  these  issues:   sources and amounts of waste oils  in Maryland,  national
  waste oil  projections, physical and chemical characteristics  of waste
  oils, present versus future oil characteristics,  properties  of recovered
  products,  trends  in oil use,  survey of  existing  laws and regulations,
  lube oil base stocks, physical and chemical processes  for re-refining
  waste oils, review of patent  literature, direct  and indirect waste  oil
  disposal techniques.  There  is a good technical  bibiography
  of the  report,  p. 169.

Esso Research and Engineering Company, POL Disposal  Techniques.  U.S.  A1r
  Force Contract No.  F29601-73-C-0047, Linden, New Jersey,  January 23,  1973.

  The contract is for $39,000 and calls for Esso to perform a paper
  study of alternative techniques that the Air Force might  use 1n disposing
  of waste petroleum, oils, and lubricants (POL's).

Esso Research and Engineering Company, Research on Oily Wastes,  by R.H.
  Salvesan ^t-iL., Government Research Laboratory, prepared under contract
  No. N00600-72-C-0761 for the U.S. Navy, Naval Supply Systems Command,
  R&D Branch, Final reports due June 25, 1973.

  Nine reports on major Navy Terminal complexes describe systems for
  collection and use of oily wastes as fuel.

Esso Research and Engineering Company, Waste Oil Reprocessing, by Gilford
  A. Chappell, Government Research Laboratory, Project 72-5, prepared for
  the Division of Water Pollution Control, Water Resources Commission,
  Commonwealth of Massachusetts, January 1973.

  Esso studied the technical problems of using waste oil as fuel oil
  for Massachusetts.  It performed combustion tests, precipitation tests,
  and distillation experiments.  The combustion trials showed severe fouling
  of the heat exchange tubes.  Sludge precipitation was less effective
  than distillation  in removing metals but offered fewer problems 1n
  residual disposal.

"Fact Book,"  National Petroleum News. Mid-May 1972, p. 136.

Farrington,  John  W.  and Quinn, James  G.,  "Petroleum Hydrocarbons and Fatty
  Acids  in Sewage Effluents,"  Woods  Hole  Oceanographic  Institution
  Contribution  No. 2812.

Fritsch, Albert  J.,  "Waste  Oil Disposal:  Time  for Change,"  Environmental
  Action, January 20, 1973,  p. 3-5.

  This article  presents fresh  information on  waste oil disposal  alternatives.
   It discusses  metallic contaminants  in  waste  oil, describes military
  attitudes  toward recycled oil,  and mentions  Sweden's  recycling program.
  A two-fold mechanism  is  suggested  to  resolve  waste oil problems:  1)  a means
  of collecting,  storing,  and  reprocessing waste  oil and 2)  incentives and
   regulations to deal with  individual  consumers.  A  federal  subsidy program
   is recommended.

GCA Corporation, A Study of the Economic,Technical,  and Environmental
  Factors Affecting Reuse of Waste Oil  as a Blended  Fuel  Oil, EPA Contract
  No. 68-01-1859, May 17, 1973.

  The contract specifies that GCA will  focus on use  of waste oil  as a
  fuel for power plants.

GCA Corporation, Study of Haste Automotive Lubricating Oil as an Auxiliary
  Fuel to Improve the Municipal Incineration Combustion Process, Environmental
  Protection Agency Contract No.68-01-6l86, EPA Contracts Management
  Division, Washington Contract Operations, April 19, 1972.

  The contract report concludes that the physical and chemical properties
  of automotive waste oil make it suitable as an auxiliary fuel in
  municipal incinerators.  It is found to reduce combustible air pollutants
  and excessive residues that result from  the  burning  of wet or  low heat
  value  refuse.

Gallapoulos, N. E., Projected Lubricant Requirements of  Engines Operating
  with Lead Free Gasoline. Society of Automotive Engineers,  June l§71.

"Gas  Stations  Found Dumping Waste Oil  in Sewer System",  New  York Times,
  December 26,  1970.

  EPA's  investigation Into waste oil dumping by service  stations is
  reported.  Neil  Fabricant,  assistant administrator for legal services,
   threatened  prosecution for  such  polluters.   See also Loetterle,  op. clt.

Gruse, W.A., Motor Oils, Performance and Evaluations.  Reinhold Publishing
  Company,  New  York, 1967.

Goetsch, H.C., Address  To:   The Association of Petroleum Re-Refiners,
   St.  Louis,  Missouri,  July  26, 1972.

   The Vanik  bill,  HR  15502 (q.v.),  is  the  occasion  for the APR meeting
   and the topic of this paper.  The author offers amendments to  strengthen
   the bill:   the labeling section should be replaced with a provision for
   a uniform classification section for lube oil  quality;   virgin
   oils should be taxed  and the funds used  to abate  oil pollution,  e.g.,
   by developing ways  to deal  with re-refininq wastes;  and the federal
   government should develop  understandable quality  specifications for
   lube oil  testing and  educate consumers on how to  buy oil.

 Hartung, H.  D., Economic Recovery of Waste Lubricating Oils, 30th
   International Water Conference of Engineers Society of Western
   Pennsylvania, Pittsburgh,  October 28-30, 1969.

"HECO Waste Oil  Burning Due for Pollution Ruling,"  Honolulu  Advertiser,
  December 17, 1972.

Harvey, James, "General Motors Recycles Over Million Gallons of Waste
  Industrial Oils", Congressional Record, June 7, 1972, E6030-E6031.

  Congressman Harvey of Michigan discusses the program of GM's Steering
  Gear Division to install a "closed loop" system for recycling more than
  one million gallons of industrial oils each year.

"Hawaii Utility Has Good Result Burning Waste Oil," Platt's Oil gram
  News Service, Vol. 50, No. 220, November 14, 1972.

"Hearing Scheduled on Waste Oil in Harbor,"  Argus-Citizen. Dorchester,
  Massachusetts, September 14, 1972.

Herschel, W.H., Anderson, A.H., "Reclamation of Used Petroleum Lubricating
  Oils," National Bureau of Standards Technological Papers, Vol. 17, No. 223,
  October 1922.

Humble Oil  Company,  "Lubetest  DG-2C", Product Bulletin.

"Is  Lube-Oil  Reclaiming Being  Abandoned  Because of  Economic Unfeas1b1l1ty?"
  Oil  and Gas Journal, December  13, 1971.

Jack,  R. W.,  "Laboratory  Engine  Specification Test  for Crankcase Oil -  I",
  Lubrication,  Vol.  55, No. 8, Texaco,  Inc., New York, New  York, 1969.

  The  background,  purpose,  and significance of most common  crankcase
  lubricant specification  engine tests  are  discussed,  and a brief
  description of  each test  procedure  is  provided.

Jackson,  Howard E., "Re-Refined  Oil for Private  Airplanes", Aero Magazine,
  Vol.  3,  No. 3,  May/June 1970.

  The  article claims that many private pilots, flying  school  operators, and
  mechanics prefer re-refined lube oil  because  it  gives longer engine  life
  at considerable savings.   The  evidence is personal  rather than survey
  data, and most  individuals  are not  adequately  identified.  The author
  argues  that the oil is  improved by  being  processed  three  times:   in  the
  original  refining, in  the engine, and by  the  re-refiner.   Weaker parts of
  the oil  are seen to be  destroyed leaving  lube  oil superior to that
  originally sold.   Favorable engine  tests  by Analysts, Inc.  (Oakland,
  California) are reported.   However, resistance to re-refined oil by
  major aviation  fuel dealers because of variability of re-refined feedstocks
   is also indicated.


Kalichevsky, V.A., Modern Methods of Refining Lubricating Oils,  Relnhold
  Publishing Company, Ifew York.  1938.

Levine, Alan, The Recycling of Waste 011, unpublished paper, Environmental
  Law Seminar, Georgetown University Law School, Mr.  Fabrikant,  December 21,

  The paper reviews the generation of waste oil, the decline of the re-
  refining industry, views of the API, and the Vanlk bill (q.v.)

Loetterle, Fred, "Use of Sewers for Oil Dumping Probed", New York Dally
  News, December 26, 1970.

  The start of a New York City EPA investigation of gas stations' use of
  sewers for waste oil  dumping Is reported.  The study was begun after
  the Metropolitan Waste 011 Dealers Association estimated that 20% of the
  city's service stations were Illegally dumping.  One year earlier,
  service stations had begun to pay for collection of waste oil they
  had previously been able to sell.  Increased use of additives was blamed
  for the switch.
"Low Cost System Readies Waste 011 for Boilers", Power, August 1972.

  The Carrier Corporation 1s using waste Industrial lube oil as fuel oil
  at its plant in Syracuse, New York.  Only settling to remove water 1s
  performed before bu riling.  Carrier then blends this oil with No. 5
  or No. 6 fuel oil 1n proportions up to 2535.
 Lowther,  H.V., Lube  Effects with Unleaded Gasolines. API Proceedings,
   May  12-14,  1971, San  Francisco, California.

   Removal  of  lead from  gasoline  causes  rusting of engine parts,  and in-
   creases varnish deposits.   Exhaust valve  recession frequently  occurs
   but  the effect on  oil oxidation  and thickening is ambiguous.
 "Lube Oil  Refining  Rebounds",  Chemical  Engineering,  September 9,  >968,
   pp.  54-56.

 Lubrizol  Corporation,  Fuel  and Lubricant Test Capabilities,  January 1972.

   This loose-leaf binder contains descriptions and uses of the various
   engine  tests used to evaluate lube oil.

Lubrizol  Corporation, Modern Automotive LubHcants-1972,  by  P. A. Asseff.

   This pamphlet gives a relatively non-technical  description of  types
   of vehicle lube oil and engine tests used to evaluate  lube oil.

 M/PF, Re-Refined Motor Oil - Market and Supply, M/PF Research Report No.
   713-485C, August 1971.

   This 15 page report for the Texas American Oil  Company identifies
   quantities and major suppliers 6f used oil in the Ft.  Worth-Houston
   Area and quantities and major purchaser of waste oil  1n the same area.
   It concludes that there is some opportunity for expansion of  sales with
   different labeling approaches, e.g., use of the term,  "recycled".

 Mallatt, R.C., Grutsch, J.F., Simons, H.F., "Incinerate Sludge  and
   Caustic", Hydrocarbon Processing, May 1970.

 Maryland Environmental Service, Oil Recovery Program, Application for
   Environmental Protection Agency Research, Development and Demonstration
   Grant, State of Maryland, December 7, 1971.

   MES received $140,000 to develop a comprehensive collection and treatment
   plan to  solve the  state's waste oil problems.  The grant proposal states
   four objectives:   1) a  state-of-the-art review of existing waste oil
   recovery technology,  2) a management program for waste oil collection
   and handling, 3) a financing plan, 4) preliminary engineering and
   preparation of plans  for a state-wide waste oil recovery system.  See
   also "Environmental Quality Systems, Inc.", op.cit.

 Massachusetts Hazardous Waste Board,  Hazardous Waste Regulations.
   Division of Water  Pollution Control, Boston, Mass., Publication  6672, August

   The regulations  permit  the Division to  control collection and disposal
   activities through licensing of waste collection  and  disposal firms.  The
   intent of the  licensing is to  promote reclaiming  of wastes insofar  as
   practical.  Where  this  is  not  possible,  incineration,  neutralization
   or other processes eliminating the  wastes from the environment  are
   preferred.  Where  such  alternate  disposal  is  not  available, selected
   sanitary landfill  sites are  being approved for sludge and solid wastes.
   Regulations promulgated under  G.L.  Chap.  21,  sees. 52, 57, and  58.

 McCrone  Associates,  Bibliographical  Study of Re-Refining Used  Lubricating
   Oil,  by  Richard  E. Putscher,  Project MA-1982,  Oct. 9, 1970.

   This  work for the Association  of Petroleum Re-Refiners updates  the
   technical non-acid waste oil  treatment  bibliography  prepared  by R.  E.
   Putscher for Armour  in April  1961.


McCrone Associates, Study of Problems of Refining Lubricating Oil  Drainings,
  Project MA-1982, May 11, 1971.

  This short study for the Association of Petroleum Re-Refiners was
  funded in an effort to find technical means of dealing with recycling
  problems caused by the growing variety of additives and additive products
  found in waste oil.   Two process problems were studied:  the thermal
  effects of pre-distilling the oil prior to sulfuric acid treatment,
  and the nature of the materials causing filter press plugging.  Half
  of the total research effort went into screening non-acid flocculents to
  precipitate these suspended materials in used oils.

McMahon, Thomas C., "Can the Waste Lube 011 Problem Be Solved?", Yankee
  Oilman, December 1972.

  The Director of the Massachusetts Division of Water Pollution Control
  summarized the status of the  Division's programs to abate waste lube
  oil problems.  The author notes  that re-refining firms operate under
  special burdens and that none now exist in New England.  The state's
  research programs on treatment technology (Esso Research and Engineering),
  biological degradation  (Tyco  Laboratories), and statewide waste oil
  generation  (A.D. Little) are  reported.  The author describes the state's
  new hazardous waste regulations  and the state's joint plans with EPA
  to locate a waste oil  collection facility at Braintree.

Millar,  F. W.,  "Under the  Hood,"   Chemistry, Vol. 44, No. 6, June  1971.

Modrock,  E.,  "Treated Fuel 011  Reduces Deposit Build Up," Maintenance
  Engineers,  1970.

National  Academy  of  Sciences  and National Academy  of  Engineering,  Water
  Quality Criteria 1972,  prepared  by  the Committee  on Water  Quality
  Criteria,  1973.

National  Academy  of  Sciences  and National Academy  of  Engineering,
  Research Needs  in  Water Quality  Criteria,  Report of the Committee  on
  Water Quality Criteria,  Environmental  Studies  Board,  1973.

National  Oil  Recovery Corporation, "Conversion of  Crankcase Waste Oil into
  Useful  Products,"   EPA WPCR Series  15080 DBO,  March 1971.

  This  EPA technical  publication issued  by the Office of Water Quality
  describes NORCO's  progress  in developing  and demonstrating a simplified
  technique for reprocessing  spent automobile crankcase oils.   The objective
  was to produce useful  non-lube petroleum products such as low sulfur
  fuel  oil  and diesel  fuels,  without producing residues which cause water
   pollution.   The product goals specified were substantially achieved but
   the disposal  of residual "bottoms" remained a  problem.  A $
   Federal grant financed the  research.


National Oil Recovery Corporation,  Recycling of Haste Oils  Into  Diesel  Fuels
  and Other Petroleum Products, Environmental  Protection  Agency  Contract  No.
  68-01-0177, EPA Contracts Management Division, RID Procurement Section  A,
  March 7, 1972.

  The $352,000 contract calls for further work by NORCO.   The objectives  are  to
  Improve the quality of fuel oil produced, solve the "bottoms"  residual  problem,
  determine the quality of products, and obtain more systems design and operating

National Petroleum Refiners Association, A New Process for Reclaiming Spent Lub-
  ricating Oils. Report No. F & L-72-51, September 197Z.

"Oil on Troubled Waters", Government Executive. February 1970, p. 24.

•  A standard account of the waste oil problem,  tax  discrimination, and  FTC
  labeling  laws is provided.

"Oil Purification! Filtration and Reclamation," Lubrication, Vol. 33, No. 1,
  January 1947, p. 1-12.

Olcott, William, "Motor Oil  Sales Flow from Stations to Mass Merchandisers,"
  National  Petroleum News, July  1971.

  This  article  is the  source of  the  frequently  cited figure that the service
  stations'share of the 600  million  gallon/year auto lube market has slipped
  from  70%  in 1961 to  about  45%  today.  Some 30% of new auto lube oil 1s now
  sold  through  mass marketers  such as discount  houses, and the percentage is
  expected  to rise to  40%  or more 1n  the  70's.  In addition,major suppliers
  who  have  traditionally shunned this market are increasingly selling directly
  to such distributors.  Various other changes  1n the auto lube oil market are
  discussed: do-it-yourself  oil  changes,  smaller cars, longer drain periods,
  increasing car numbers,  improving  oil quality, non-leaded gasoline, rise of
  multigrade oil, and  the  trend  to  racing oil.

Pollack,  Jack M.,  "Change  Your Oil,  Mister?",  True.  June 1952.

  This  is  an interesting expose  of  the  prejudiced economic  treatment accorded
  re-refined oil,  even this  long ago.  Although the  article  is  quite old,  issues
  described are the  same ones  being fought today  --  such as  quality consistency
  and  supposed  bias  on the part  of  major  oil  companies and  the  military.

Porcello,  Joseph  A.,  "Allied Used  Up Old  Auto Oil,"  Syracuse Herald American,
  January 1972.

 Recon, Inc., Study to Obtain and Develop  Information on  Waste Oil  Recycling,  EPA
  Contract 68-01-1870, Princeton,  New Jersey, March 1,  1973.

  The  contract  calls for Recon to  1) assess waste oil  disposal  techniques,  2)
  evaluate existing technology for waste  oil  processing, 3)  determine the en-
  vironmental  impacts of various processes, and 4)  perform a national  material
  balance on waste oil and recommend improvements.

 "Recycled Fuel," Quincy Patriot Ledger,  Quincy, Massachusetts, October 7,  1972.

 "Refining of Motor Oils," Lubrication. December 1946.

 Reitze., Arnold W. Jr., Environmental Law, Second Edition, "Lubricating 011," by
  Jeffrey E. Howard and Dennis P. Koehler, J.D.'s the National  Law Center,
  George Washington University, June 1972, p. 79.

;- This appendix to Chapter 2 provides a survey of waste lube oil disposal  Issues:
  air and water pollution, effect of retailing, and the recycling Industry and
  its problems.  Much of the Information has been used 1n statements drafted for
  Congressman Charles A. Vanlk (q.vj.

 Rek. L.,  Combustion of 01} or Gas  in Fluidlzed Beds,  Proceedings 2nd Internation-
  al Conference on Fluldlzed Bed Combustion, Publication #AP-109, EPA.

 Schilling,  A., Motor Oils and Engine Lubrication. 2nd Ed.t England, Scientific
  Publications Ltd., 1968.

 "The Schuylkill  011 Swamp: Ecology Gone Haywire," The Philadelphia Inquirer,
  Philadelphia, Pa., July 10, 1972.                "

 Seidl, H.C..  "Evaluation of Reclaimed Oil,"  History HQ OCAMA. Oklahoma City.
  Oklahoma. FY 1948. Historical Research Center, Maxwell AFB, Alabama, July -
  December  1948.

 Shell  Oil Company, Notes of Disposal of Refinery Wastes by Biological Action
   in Soil,  Deer Park, Texas.

 Shields,  Wilfred H.  Jr.. and Miles, Walter A.,  Used Oils - a Waste? or a Resource?,
   Solid  Waste Services, Maryland Department  of  National Resources, and Division
   of Solid  Waste Management, Maryland  Department of Mental Health and Hygiene,
   April  1971.

   This is a forthright  report  of the  authors'  personal  study of waste  oil disposal.
   It estimates  the amounts  and  sources  of waste oil  discarded,  describes the  kinds
   of changes that  result,  and  accuses  the Federal  government of bringing about
   the  decline in  recycling  through unfavorable  tax and  labeling decisions.   It
   strongly  criticizes  the API  for  underestimating  the oil  pollution problem.
   Finally,  the report  recommends that waste  auto oil  be recycled to lube oil, that
   waste  industrial oil  be  used  as  fuel,  and  that the state establish  a major  system
   for  recovery of waste oil.   This last  recommendation  led to  the current  MES re-
   search with Environmental  Quality Systems, Inc.  (q.v.)

Smalheer, C.V., and Smith, Kennedy,  Lubricant Additives, Lez1us-H1les Co.,
  Cleveland, Ohio, 1967.

  Lubrizol Corporation, a major additive manufacturer  distributes this technical
  work on the chemistry and application of additives and the testing and evalua-
  tions of lubricants.

Society of Automotive Engineers, Crankcase Oil  Viscosity Classification. J 300a
  April 1967,  editorial change, October 1972.

  The SAE specifies a recommended practice for  classifying lube oils according
  to viscosity: 5W, 10W, and so forth.

Society of Automotive Engineers, Engine Oil Performance and Engine  Service
  Classifications, J 183a, April T57T                     '.

  In this "Recommended  Practice" document the SAE updates  and  promulgates engine
  lube oil catagories,  SA through SE, and CA through CD.   It gives  API engine
  service descriptions, ASTM engine oil descriptions,  and  primary performance
  criteria for each catagory  (grade).

Society of Automotive Engineers, Engine Tests for Evaluating Engine Oils, J  304a,
  June 1971.

  In this "Information  Report", the SAE describes some of the more widely used
  engine  tests for evaluation of lubricants.

Society  of Automotive Engineers, Physical and Chemical Properties of Crankcase
  Oils,   J 357, August  1969, editorial change, June 1971.

  This SAE  "Information Report" discusses a number of the physical  and chemical
  properties  of new and used crankcase oils.  Standardized test methods are
  also listed.

 "Spectrum,"  Environment. January/February 1972,  p. 26.

  Summarizes  article  by Bowen,  Environmental Science  and  Technology (q.v.).

 "Squeezing  Pure Lube  from Waste Oils",  Chemical  Engineering, by B. Cross, June 11,
   1962,  pp.  126-128.     .	

  A process  flowsheet is provided for the operations  of Motor  Oils Refining  Co.,
  a re-refiner in Illinois.

Streets, R.E., a letter to Mr.  H.  Paul  Butz,  Chief  of  the  FTC's  Division of
  Trade Regulation Rules, File  959,  June 5,  1964.

  Streets, the Chief of the Army Material  Command's Power  Sources  Section,
  writes to support the FTC's proposed  Trade Regulation  Rule  (q.v.).  He
  states that the variability in the charge  stock makes  adequate process
  control in re-refining impossible  and that earlier engine tests  have  shown
  available re-refined oils to  be very  inferior.  Streets  also  indicates that
  control specifications proposed by the re-refiners would not  be  adequate to
  assure quality and that routine performance tests using  actual equipment are
  the only real guarantee of high quality.

Supta, N.P. and Gairola, V.K. "Use of Waste  Engine  011 as  Fuel,"
  Chemical Engineering World. Vol. 7, No. 6, June  1972.

Swain, J.W., Disposal of Spent Industrial Lubricants,  Paper  #FL-72-4T,  September
  1972, National Petroleum Refiners Association, Washington,  D.C.

  This seven page non-technical commentary briefly surveys disposal  alternatives
  for industrial lubricants.  The author concludes  that disposal can be Improved
  if the oil user reduces his usage and separates  types of waste oil during
  collection.  He recommends reprocessing for use  as lubricants, metal  working
  fluids, or fuel.

Swain, John W., Jr., Reclaiming, Re-Refining, and  Uses of Waste Oil. American
  Society of Lubrication Engineers, Annual Meeting, Chicago, Illinois,  April  29,

  The disposal alternatives  for waste industrial and crankcase oils is  discussed.
  Contaminants in both  types are enumerated.  The paper describes  provisions of
  several new Michigan  laws which require industries to report on  their waste
  generation, which  license  and control waste oil  scavengers, and  which permit
  citizen suits against polluters.  Purchase, collection, mixing,  reprocessing
  and product alternatives for used oils are reviewed.

 "Swarf  Crushing and  Oil  Reclamation Plant," Environmental Science and Technology,
  September  22, 1967,  p.  387.

Teknekron, Inc. "Technical and Economic Study of Waste 011  Recovery",
  EPA Contract No. 68-01-1806, Berkeley, California, March  26, 1973.

  This contract for $58,000 calls for Teknekron and Its subcontractor,
  The Institute of Public Administration, to Investigate the feasibility
  of closed-loop oil recycling systems, the economics of the re-refining
  industry, consumer waste oil disposal, and federal research efforts 1n
  waste auto lube oil disposal.

Thurmond, Strom, "The Need for Recycling of 011",  Congressional Record,
  January 16,  1973, p. S66.

  Remarks were made on the introduction of S 409, a bill to amend the excise
  tax code to  encourage reuse of waste oil.  Thurmond discusses the genera-
  tion of waste oil, its  environmental impact, and federal  obstacles to

Tyco Laboratories,  Biological Degradation of Haste 011 Sludge, contract
  report  for Massachusetts Water Resources Commission, 1971.

U.S. Congress, 93rd, 1st  Session, HR  5902:  National Oil Recycling Act, a
  Bill to  Provide  for the Recycling of Used Oil  and for Other Purposes,
  House Committee  on Ways and Means,  introducted March 20,  1973 by Charles
  P. Vanlk (D-Ohio).

  Identical  bill  to Vanik's  bill, HR  15502, Introduced June  14, 1972.

U.S. Congress, 93rd,  1st  Session, s 409,"A Bill  to Amend the Internal  Re-
  venue  Code of  1959 to  Encourage the Use of  Recycled  Oil",  Senate Finance
  Committee, introduced  January 16,  1973, by  Strom Thurmond (R-S.C.).

  This  bill  is identical  to  a  bill  introduced March 21,  1972 with remarks
  by Senator Thurmond  (q.v.).   It and a  bill  by Congressman Vigarito (q.v.)
  are  identical  to the  bill  Congressman  Vanik first introduced  in January
   1972.   All  these measures  would allow re-refiners to be  exempted from
   payment of excise taxes on virgin  oil  that  they  blend  with their re-refined

U.S. Congress, 92nd, 2nd Session,  HR 15502:  Natural 011  Recycling Act, a
  Bill to Provide for the Recycling of Used  011  and for  Other  Purposes,
  House Committee on Mays and Means, Introduced  June  14, 1972  by Charles A.
  Vanik (D-Oh1o).

  A major provision of the bill  would reform the excise  tax  treatment of
  lubricating oils by abolishing the current tax exemption enjoyed  by virgin
  lube oil that 1s not used 1n highway vehicles.  The bill would also change
  the labeling requirements for re-refined oil  imposed by the  Federal Trade
  Commission, prohibit oil companies from restricting their  service stations
  from selling recycled oil, encourage Federal  procurement of  recycled oil,
  and force all lube oil retailers to provide disposal facilities and to
  sell oil only in returnable containers.

U.S. Congress, 92nd, 2nd Session, House.  Ways and  Means  Committee,  Subcommittee
  on Natural  Resources,  March 20 and 21,  1972.

  A statement of Belton Williams, President  of the Association of  Petroleum
  Re-Refiners, asks for restitution of the6$/gallon  excise  tax on  virgin
  industrial oil.  He supports  S  409 by  Senator Thurmond.

U.S. Congress, 92nd, 1st Session, Joint Economics Subcommittee on  Fiscal
  Policy, The Economics of Recycling Haste Materials. Hearings, November 8 and
  9, 1971, esp. p. 179.

  Witnesses testified from the National Association of Secondary Materials
  (NASMI), the American Paper Institute, the National Commission on Materials
  Policy, New York EPA, Resources for the Future, and the U.S. EPA.  The
  Association of Petroleum Re-Refiners (APR) submitted a statement decrying  the
  pollution damage of waste  oil and  the pollution hazards of burning 1t.   The
  APR  further asked for statutory changes 1n the excise tax treatment of lubri-
  cants,  including a new  provision  allowing re-refiners to collect a refund  on
  virgin  oil  purchased  for blending.

U.S.  Congress, 90th, 1st  Session, Senate Public Works Subcommittee on Air and
  Water  Pollution, Water  Pollution  -  1967 (Part 1). Hearings on Si591 and S1604,
  June 7, 8,  and 9, 1967.

  Hearings chaired  by J. Caleb  Boggs  (R-Del.) examined  the automotive oil pollu-
  tion problems  arising from the  Excise  Tax Reduction Act of 1965.  Testifying
  were James  M.  Quigley,  Commissioner of the Federal  Water Pollution Control
  Administration;  Harold  L.  Jacobs, Vice Chairman, Delaware Water  and Air Resources
  Commission;  Alfred E.  Peloquin, Executive Secretary,  New England  Interstate Water
  Pollution  Control Commission; P.N.  Gammelgard,  Vice President, Conservation and
  Manufacturing, American Petroleum Institute;  and H.K.  Robertson,  President,
  Association of Petroleum Re-Refiners,  accompanied  by  V.I. Worthington, Executive
  Director.   The API  produced survey figures to show  that service  stations are
  adequately serviced  by waste  oil  collections.   The  APR showed increasing economic
  failures  among Its member  firms and argued that Federal tax  and  labeling require-
  ments  were to  blame.


U.S. Congress, 89th, 1st Session, Senate,  Excise  Tax  Reduction Act of 1965.
  Report No. 324, to accompy HR 8371, Committee on  Finance, June  14. 1965.

  The Senate disagreed with lube oil  excise tax reductions prepared both by
  President Johnson and the House on  the grounds  that the tax was needed to
  keep the re-refiners alive.  It also removed the  House provision that
  assigned lube oil taxes to the Highway Trust Fund.

U.S. Congress, 89th, 1st Session, House, Excise Tax Reduction Act of 1965,
  Report No. 433, to accompany HR 8371, Committee on Ways and Means, May 28,

  President Johnson's bill would have repealed all  excise taxes  on lube oils.
  The House agreed to drop the tax on off-highway uses (through  a refund pro-
  cedure) but kept the tax on highway oil  on the  grounds  that  1)  the Highway
  Trust Fund was in need of more revenue and 2)  that some tax advantage was
  needed to keep the re-refining industry alive.

U.S. Department of Commerce, Letter Circular LC-990, National  Bureau of  Stan-
  dards, August 1950.

  The three-page report  concludes that the quality of re-refined oil depends  on
  the quality of new oils  from which  it is obtained, the extent of deterioration,
  and the re-refining  process.   No performance test data is  given.

U.S. Department of  Commerce,  "Sales of Lubricating and Industrial Oils and
  Greases,  1969,"  Bureau of  the  Census, Current  Industrial  Reports.  Series MA-29C
   (69)-l, January  7,  1971, and MH-29C(71)-1, October 1972.

U.S. Department of Commerce,  "Sales of Lubricating and Industrial Oils and
   Greases,  1967,"  Bureau of  the  Census, Current  Industrial  Reports, November 21,

U.S. Department  of Commerce, "Sales  of  Lubricating and Industrial Oils and
   Greases,  1965,"  Bureau of  the  Census, Current  Industrial Reports, September 7,

 U.S.  Department  of Commerce, "Sales  of  Lubricating and Industrial Oils and
   Greases,  1965,"  Bureau of  the Census, Current  Industrial Reports, September 7,

 U.S.  Department  of Commerce, "Sales  of Lubricating  and  Industrial Oils and
   Greases,  1962,  Bureau of the Census,  Current Industrial Reports, October 14,

U.S. Department of the Interior,  Additives  in  Re-Refined Oilsby Atomic Ab-
  sorption, study conducted by the Bureau of Mines,  Bartlesville Energy
  Research Center, concerning metal  content of some  re-refined  oils,  February
  22, 1972.

U.S. Department of the Interior,  The Cost of Clean Mater and Its Economic  Impact.
  Vol. 1 of FWPCA Reports of 1968 and 1969.

U.S. Department of the Interior,  The Cost of Clean Mater.  Petroleum Refining.
  Vol. Ill, Industrial Waste Profile No. 5, FWPCA Publication No.  I.W.P.-5.

U.S. Department of the Interior,  An Issue Support Paper About....  Waste Oil
  Recycling, Bureau of Mines, April 1972.

  An extensive five year research effort to develop  and demonstrate methods  of
  waste oil re-refining is proposed.  The program is to use the technical
  facilities at the Bureau's Bartlesville Energy Research  Center in Oklahoma.

U.S. Department of the Interior, Petrochemical Plant Effluent Treatment
  Practices, FWPCA Report  12020, February 1970."

U.S. Department of the Interior, Water Quality Criteria. Report of the National
  Technical Advisory  Committee to the Secretary, FWPCA, 1968.

U.S.  Department of the Interior  and U.S. Department of Transportation, Oil
  Pollution. A Report to the  President,  February 1968.

  The  ocean pollution impact  of  oil spills and other hazardous substances is
  emphasized.  Waste  oils  from gasoline  service stations is mentioned as an
  important source for the first time.

U.S.  Department  of the Treasury, Section 4091  -  Imposition  of  Tax, Reserve
  Ruling  57-204,  p. 371.          	

  The Treasury ruled  that  the introduction  of used  oil into the process of
  refining virgin crude  oil  does not  thereby  make the  product  "a mere blend or
  mixture" of  mixable and  non-taxable oils  that  is  tax exempt  under  section
  314.40  (d)  (3)  of Regulations  44.

U.S. Department of the Treasury, Section 6424 - Lubricating 011  Not Used in
  Highway Motor Vehicles. Reserve Ruling 68-108, p.  561.

  The Treasury Department ruled on two issues.  It decided that re-refiners
  do not qualify as off-highway users and therefore are Ineligible for a tax
  refund on virgin oil purchased for blending.  It also decided that Industrial
  buyers of blended re-refined lube oil could not collect a refund either since
  the product purchased is nontaxable.

U.S. Environmental Protection Agency, The Impact of Q11.Y Materials on Activated
  Sludge System. Hydroscience, Inc., EPA Report No. 12050 DSH 03/71, 1971.

  The 110 page report studied the effect of a variety of compounds on small
  scale continuous activated sludge systems.  Batch studies to determine bio-
  degradability and the effect of   emulsification and temperature on the rate
  of biological reaction were also conducted.

U.S. Environmental Protection Agency, Ocean Disposal of Barge Delivered Liquid
  and Solid Waste  from U.S. Coastal Cities. EPA Publication No. SW-19c, 1971.

  This  119 page report by the Dillingham Corporation provides a baseline survey
  of ocean waste disposal.  Included  is a discussion of current marine disposal
  operations,  environmental effects of  barging wastes to  sea, monitoring of
  marine waste disposal  operations, and institutional factors and  recommendations.
  Some  passing references are made  to  the role of waste oil.

U.S. Environmental Protection Agency, Oily Waste Disposal by Soil Cultivation
  Process, Office  of  Research and Monitoring, EPA-R2-72-110, December 1972.

  The study in Deer Park, Texas, showed that  soil microorganisms can decompose
  oily  wastes  in landfills.  The rate of decomposition was about one half
  pound per cubic  foot of soil each month without fertilizers, double with

U.S. Environmental Protection Agency,  Run off of Oils from Rural Roads Treated
  to Suppress  Dust. EPA  Report  EPA-R2-72-054, October 1972.

  The study indicates that  some  seventy percent of  the oil  leaves  the roadway
  on dust  particles or  in water  runoff.  Most of the remaining  thirty percent
  volatilizes  and  is  biodeqraded.

U.S. Environmental Protection Agency,  Waste  Oil Study. Preliminary Report to
  Congress, April  1973.

  This  report  fulfills  the  6 month  report requirements of section  104(m)  of the
  Federal  Water Pollution Control Act Amendments of 1972.  It covers  quantities
  of waste oil separated, physical  and  chemical characteristics of waste  oils,
  present  methods  of  collection  and disposal, biological  effects  of waste oil,
  and economic and legal  aspects of waste oil policy.  The report includes  little

  information on long-term biological  effects,  economics  of reprocessing,
  disposition of home users, research  efforts by other federal  agencies, or
  institutional/policy factors.

U.S. Executive Office of the President, "Petroleum Refineries," The  Economic
  Impact of Pollution Control. Council on Environmental Quality, Department
  of Commerce, Environmental Protection Agency, March 1972, pp. 263-73.

U.S. Federal Trade Commission, In Re Double Eagle Refining Co.. 54 FTC 1035

  In its original early decisions, the FTC ruled that Double Eagle and other
  lube oil re-refiners must 1) not represent,  contrary to fact, that Its  lube
  oil is refined other than from previously used oil and  2) not advertise Its
  products without disclosing prior use of the oil to the purchaser, Including
  "a clear and conspicuous statement to that effect on the container."

U.S. Federal Trade Commission, In Re Double Eagle Lubricants. 66 FTC 1039 (1964).

  In its later decisions on labeling of re-refined lube oil, the FTC argued  that
  disclosure of prior use had to be on the "front panel or front panels of the
  container."  The decision imposed no new restrictions on the use of the word,
  "re-refined".  The FTC claimed that its decisions were made without regard to
  the quality of the respondents' lube oil product.

U.S. Federal Trade Commission, a letter of Congressman Charles A. Vanik regarding
  waste  oil, by Miles W. K1rkpatr1ck, Chairman, August 19, 1971.

  Chairman  Kirkpatrick explains that  the FTC's Trade Regulation Rule on re-refined
  lube oil  (q.v.) is not premised on  the quality  of such oil,  but on the public's
  preference for virgin oil.  However, he proceeds to acknowledge that, based on
  many submissions,  the FTC believes  re-refined oil to be of inferior quality and
  that the  labeling  rule would be reconsidered  1f valid evidence showed that it
  could  compete  in quality  with virgin oil.

U.S. Federal Trade Commission, Trade  Regulation  Rule  Relating  Deceptive Advertising
  and Labeling  of Previously  Used Lubricating Oil,  effective September 1, 1965.

  The FTC  labeling rule repeated  the  regulation  announced  in In^Re  Double Eagle
  Lubricants  (q.v.)  but also  required clear disclosure of  "Previous Use" and
  restricted  the use of the word  "re-refined".   The Trade  Regulation  Rule can be
  found  at  16 CFR 406.

U.S. Statutes, 89th, 1st Session,  Excise  Tax  Reduction Act of 1965. Vol. 79,
  Public Law 89-44, June 21, 1965, p.  I3b tK

  Title II, Manufacturers Excise Tax,  Imposes  a  s1x-cent-a-gallon tax on lube
  oils  (sec. 4091 of the Internal Revenue Code  of 1954)  and then sets up a
  tax refund procedure for lube oil  used  for  off-highway  purposes (sec. 6424).
  The law's provisions and associated  Treasury regulations can  be found at 26
  CFR 48.4091 and 26 CFR 48.4218.

"Used Lube Oil... oh just throw it away," U.S. 011 Week.  January 1971, p. 3.

  Some new information is added to a review of points made in Bernard
  and the API Final Report (q.v.).  A New York City survey of service station
  waste oil disposal is discussed.  The Wisconsin Petroleum Association reports
  that waste oils foul sewage treatment plants.   The Nebraska Petroleum Market-
  ers Association reports that a survey of state jobbers  shows  collection costs
  up to 10$ a gallon and one third the jobbers supplying  fanners who use waste
  oil for dust control, hog oiling, tank heaters, and weed control.

"Used Lube Oil Present a Slippery Problem," Rodale's Environmental  Action
  Bulletin. Vol.  9, No. 6, April  17, 1971.

  Points made in  "Used Lube Oil", U.S. Oil Week,  (q.v.) are  repeated.   In  addition,
  the article suggests that readers patronize only service stations with  adequate
  waste oil collection and  that they write to the API, the APR, and the  FTC about
  the need for better ways  to dispose of waste oil.

Vanlk,  Charles A.,  "Natural Oil Recycling Act," Congressional  Record, June 14,
  1972, E6208-E6210.

  Vanik comments  on his  bill,  HR  15502,  introduced the same day.  He discusses
  waste oil  generation,  water  pollution,  air  pollution, mass marketing of auto
  lube  oil,  and  impediments to economic  recycling operations.   Finally, he
  describes  the  provisions  of  his bill.

 Vanlk,  Charles A., "011  Recycling," Congressional Record. December 2, 1971,
  E 12927-E12929.

   Vanik makes points repeated  in  later  Congressional  Record remarks.  He proposes
   to allow re-refiners  to label their product "recycled  oil" and introduces a
   bill, HR 12015, which would  make re-refiners  eligible  for the off-highway six-
  cents-a-gallon tax refund.

Vanik, Charles A.  "Oil  Recycling Act  of  1973".  Congressional Record. March 14,
  1973, E 1543-E 1545.

  Vanik comments upon his bill, HR 5902, introduced March 20,  1973.  He repeats
  many of the points he made upon the introduction of an identical bill 1n 1972,
  but drops the description of the bill's provisions  and adds  some data on waste
  oil generation and on fuel oil shortages.
Villanova University, Final  Progress Report on Water Pollution  Control  Demonstra-
  tion Project Grant No. WPD-17'
  Control Administration, 1968.
tion Project Grant No.  WPD-174-01-67,  submitted  to  Federal Water Pollution
  A re-refining process using dehydration and caustic treating is  described.
  The process uses less acid than traditional methods and reduces  acid sludge
  disposal problems.  There is, however, some question about the economic feasi-
  bility of the process.

Wadt, W.F.,  The Outlook for Lubricating 011s,  Enjay Chemical Co., March 1971.

Walter C. McCrone Associates, Inc. Pounds of Combustion Products Per 10,000
  Gallons of Draining^, Chicago, 111., July 15, 1970.•

  A chart frequently circulated by the Association of Petroleum Re-Refiners shows
  that 1,000 pounds of metal oxide wastes are released when 10,000 gallons of
  waste motor oils are burned.  Fourteen different metals were found in the resi-
  due, a  large portion of which would normally occur as air pollution.

 "What Price Lube-Oil Reclaiming?"  Oil and Gas Journal. April 26, 1954.

 "What to  Do with  Drained Oil," National Petroleum News, November 1970, p. 6.

  API's  Final  Report of the Task Force on Used Oil Disposal  (q.v.) is summarized.

 Wiley, Morris  A. ."Environmental Aspects of the Oil Spill  Problem" Paper  No. 1661,
  Environmental  Protection  Department, Texaco, Inc.,  June 1972.
 Wisconsin Department of Natural  Resources,  Drain  Oil  Disposal  in Wisconsin.
   Technical  Bulletin No. 63, Madison, Wisconsin,  1973.

   A survey of service station drain oil  disposal  was  carried  out by petroleum
   inspectors of the Department of Resources in 1971.   The results  indicate that
   service stations handle from 55 to 65  percent of the oil  drained from cnankcases


  in Wisconsin.   Of this,  97.6  percent  is reused, and 2.4 percent wasted.

Worthington,  VernonT.,  Despite Talk of Recycling.  Government Still Discriminates
  Against Recycling of Lubricating Oil...,  Association of Petroleum Re-Refiners,

  The memorandum emphatically proclaims the APR's  complaints  to  the President,
  Congress, FTC, and pollution control  agencies.   It cites  figures and statements
  on environmental damage, economic obstacles,  and the pollution dangers of burning.
  An adequate profit margin is requested but no particular  program of changes is
  advocated.  Quoted in toto in U.S. Congress,  Economics of Recycling Waste Materi-
  .flli, (q.v.).

Zeldin, Marvin,  "Audubon Black Paper #1 - Oil Pollution," Audubon Magazine, May