SEP

2 8

1

BEFORE THE

ILLINOIS POLLUTION CONTROL BOARD

STATE OIILLj~sj~~~

POllL~tIoflControl Board

IN THE MATTER OF:

)

)

R99-18

AMENDMENTS TO PERMITTING

)

(Rulemaking-Land)

FOR USED OIL MANAGEMENT AND)

USED OIL TRANSPORT

)

)

NOTICE OF FILING

TO:

Joel

J.

Sternstein, Esquire

Hearing Officer

Illinois Pollution Control Board

100 West Randolph Street

Suite 11-500

Chicago, Illinois 60601

(VIA U.S.

Mail)

PERSONS ON ATTACHED SERVICE LIST

(Via U.S.

Mail)

PLEASE TAKE NOTICE that I have today filed with theOffice of the Clerk of the

Pollution Control Board the Comments of the National Oil Recyclers Association Before

the Illinois Pollution Control Board Concerning Used Oil Regulations Docket R98-29;

Docket R99-18, a copy of which is herewith served upon you.

/~

Christopher Harris

General Counsel

National Oil Recyclers Association

DATE:

September 24, 1999

National Oil Recyclers Association

1439 West Babcock

Bozeman, Montana 59715

---

PROOF OF SERVICE

I, the undersigned, certify that I have served the attached the Comments

of the

National

Oil Recyclers Association Before the Illinois Pollution Control Board

Concerning Used Oil Regulations Docket R98-29; Docket R99-18,

upon:

Joel

J.

Sternstein, Esquire

Hearing Officer

Illinois Pollution Control Board

100 West Randolph Street

Suite 11-500

Chicago, Illinois 60601

by sending said documents Via U.S. Mail in Bozeman, Montana on

or before 5:00 p.m.

on September 24, 1999, and upon:

Mr. Matthew

J.

Dunn, Chief

Environmental

Bureau

Office of the Attorney General

100 West Randolph St., 12th Floor

Chicago, Illinois

60601

Ms. Dorothy M. Gunn, Clerk

IL Pollution Control Board

100 West Randolph Street

Suite 11-500

Chicago, IL

60601

Ms. Cynthia Hilton, Executive Director

Association of Waste Hazardous

Materials Transporters

2200 Mill Road

Alexandria, VA 22314

Mr. Jeffrey Jeep

EMCO Chemical Distributors,

Inc.

2100 Commonwealth Avenue

North Chicago, IL 60064

Ms. Jennifer Marsh

Chemical Industry Council of Illinois

---

920 South Spring

Springfield, IL 62704

Sanjay

K. Sofat

Illinois Environmental Regulatory Group

215 East Adams Street

Springfield, IL

62701

Ms. Vicki Thomas

JCAR Wm. G. Stratton Bldg., Room 700

Springfield, Illinois 62706

Ms. Kimberly A. Geving, Assistant Counsel

Illinois EPA

Division of Legal Counsel

1021 North Grand Avenue East

Springfield,

IL 62704-9276

Ms. Katherine D. Hodge

Hodge & Dwyer

808 South Second Street

Springfield, IL 62704

Mr. Robert Lawley, Chief Legal Counsel

Department of Natural Resources

524 South Second Street

Springfield, IL 62701-1787

Mr. Paul Pike

(MC-602)

Ameren Services

P.O. Box 66149

St. Louis, MO 63166

by depositing said documents in the U.S.

Mail in Bozeman, Montana on or before 5:00

p.m. on September 24, 1999.

Christopher Harris

---

SERVICE LIST (R99-018)

Mr. Matthew

J.

Dunn, Chief

Environmental Bureau

Office of the Attorney General

100 West Randolph St., 12thFloor

Chicago, Illinois

60601

Ms. Dorothy M. Gunn, Clerk

IL Pollution Control Board

100 West Randolph Street

Suite 11-500

Chicago, IL

60601

Ms. Cynthia Hilton, Executive Director

Association of Waste Hazardous

Materials Transporters

2200 Mill Road

Alexandria, VA 22314

Mr. Jeffrey Jeep

EMCO Chemical Distributors,

Inc.

2100 Commonwealth Avenue

North Chicago, IL 60064

Ms. Jennifer Marsh

Chemical Industry Council of Illinois

920 South Spring

Springfield,

IL 62704

Sanjay

K. Sofat

Illinois Environmental Regulatory Group

215 East Adams Street

Springfield,

IL 62701

Ms. Vicki Thomas

JCAR Wm. G. Stratton Bldg., Room 700

Springfield, Illinois 62706

---

Ms. Kimberly A. Geving, Assistant Counsel

Illinois EPA

Division of Legal Counsel

1021 North Grand Avenue East

Springfield,

IL 62704-9276

Ms. Katherine D. Hodge

Hodge & Dwyer

808 South Second Street

Springfield, IL 62704

Mr. Robert Lawley, Chief Legal Counsel

Department of Natural Resources

524 South Second Street

Springfield, IL 62701-1787

Mr. Paul Pike

(MC-602)

Ameren Services

P.O. Box 66149

St. Louis,

MO 63166

Mr. Joel Sternstien, Hearing Officer

Illinois Pollution Control Board

100 West Randolph Street

Suite 11-500

Chicago, IL 60601

Christopher Harris

National Oil Recylcers Association

1439 West Babcock

Bozeman, Montana 59715

---

~,0IL~

—

~

~

National

Oil

Recyclers

Association

Christopher Harris

General Counsel

‘~

.~•

1439 West Babcock

.

Bozeman, Montana

59715

(406)

586-9714

•

FAX

(406) 586-9720

~OóIA~°

Comments of the

National Oil

Recyclers

Association

RECEIVED

Before the

CLERr’S

()PPI(’F

Illinois Pollution Control Board

SEP

2

8

1999

Concerning Used Oil Regulations

STATE OF ILUNUIS

Pollution

Control Board

September 24, 1999

These comments

supplement the testimony provided

by the National

Oil

Recyclers Association (“NORA”) on August

23, 1999 before the Illinois

Pollution

Control Board.

As the Board

is

aware, the

National

Oil

Recyclers Association

considers

the proposal

by

the

Illinois

Environmental

Protection

Agency

to be

premature.

This is because the Agency has failed

to

articulate the need for permit authority

over

used

oil

processing

and

storage

facilities.

Currently,

such

facilities

are

regulated

by

Part

739

(IEPA’s

regulations

which

mirror

the

federal

used

oil

management

standards

found

at

40

CFR Part

279).

NORA

contends

that

the

current used oil management standards, promulgated by the U.S. Environmental

Protection

Agency

in

1985 and

1992,

constitute appropriate

regulatory controls.

Virtually every other state has adopted these standards with few, if any, changes.

No

other

state which

has adopted

40

CFR Part

279

has

found

it

necessary

to

create

a

new

set

of

controls

in

the

form

of

permit

authority

over

used

oil

processing and/or

storage facilities.

When entities are subject to an existing regulatory regime,

it is fair to ask

an agency asking for additional authority, “What are the problems that

exist that

your existing

authority

cannot address?”

When IEPA

officials were asked

that

question at the August

23, 1999 hearing, there was no clear response, except that

(1)

permitfed

facilities

are

inspected

more

frequently

than

non-permitted

facilities; and

(2) the old used oil recycling operations had a lot of problems.

Neither

answer

is

persuasive.

First,

IEPA,

as it admitted,

does not need

permit

authority

to conduct inspections.

If signifiEant environmental

problems

were

believed to exist

at used

oil

processing and/or

storage facilities

in recent

years,

IEPA

had

a

duty

to

conduct

inspections.

Had

such

inspections

been

---

Comments of the national Oil Recyclers Association

Illinois Pollution Control Board

September 24, 1999

Page

2

conducted

and

had such inspections revealed environmental problems, the Board

would have a record upon which to evaluate a case for permit authority.

Even if

such a

record

had

been placed

before

the

Board

(which

it

wasn’t)

it

is

worth

asking why permit authority,

as opposed to enforcement of existing

regulations,

is required.. In any

event, IEPA has not responded

to this most basic question.

(Significantly,

in

Illinois

inspections

of

non-permitted

facilities

are

often

triggered

by

complaints

or

other

information

received

by

the

agency.

Apparently,

the

absence

of

an

inspection

record

is

because

few,

if

any,

complaints concerning oil processing facilities have been registered with IEPA.)

JEPA did

cite

several used oil related environmental problems

that have

occurred

over

a

12 year

period.

Many

of

these

problems

were

found at re-

refining facilities that were closed or abandoned more than ten years ago.

NORA

does not dispute or minimize the fact that sites with abandoned tanks and drums

have

resulted

in

serious

contamination

problems.

The

point

is

that

these

facilities

never

operated

under

the

used

oil

management

standards

and

consequently

do

not

provide

support

for

any

assertion

that

the

used

oil

management standards

are inadequate as a set of regulatory controls.

Other examples

of problems cited by

IEPA relate to used oil generators.

It

is not immediately

clear why generator-caused problems, such as used oil spills,

would

provide

a

reason

to

require

processors

to

obtain

permits.

The

few

compliance issues attributed to currently operational processors do not appear to

be

outside the

scope

of the used

oil management

standards.

Moreover,

IEPA

does not base its case on this small set of compliance issues.

It should

also be

emphasized that

used oil processing

operations

are not

exclusively regulated, by

the Part

739

used oil

management

standards.

On the

contrary, several other laws govern various aspects of used oil management.

To

provide

a few examples:

oil processors must possess

and comply

with

a

valid

Spill Prevention Control and Countermeasure Plan (“SPCC Plan”) as required by

the

federal

Clean Water

Act.

Transportation

of used

oil

is

controlled

by

the

Hazardous

Materials Transportation

Act.

Used oil containing PCBs

is governed

by

the

Toxic

Substances

Control

Act.

Each

of the

requirements

under

these

statutes is enforceable.

In combination with the used oil management standards,

these requirements form a comprehensive

blanket of regulations

covering every

aspect of a used oil processor’s operations.

It

is

significant that IEPA

has not conducted

any study

of the

economic

effects of its proposal

to impose permit

requirements.

As explained during

the

---

Comments of the national Oil Recyclers Association

Illinois Pollution Control Board

September 24, 1999

Page 3

hearing before the Board

on August 23, 1999,

costs imposed by regulation

on an

oil

processor

—

but not on

its

competitor, the seller

of virgin fuel

oil

—

causes

competitive

burdens to

be

placed

on

the sale

of used

oil fuel.

Some

of those

burdens

can

be

absorbed

by

the

used

oil

processor

-

but

at

some

point

such

regulations

begin

to undermine

the

oil recycler’s

capacity to

compete.

This

is

particularly ‘true

if the regulatory

burdens

adversely affect

the ability of the

oil

processor

to

seller

to

burners.

See

attached

description

of used

oil

markets.

NORA

also

-

contends

that

the

Illinois

Legislature,

in

adopting

section

9

of the

Illinois

Waste

Oil

Recycling

Act,

intended

to

prevent

the

adoption

of

any

regulatory

requirement

that

discourages

legitimate

methods

of

used

oil

recycling.

One

of

the

Legislature’s

principal

concerns

was

the

problem

of

widespread

illegal dumping of used oil, particularly

by

Do

It Yourself

(“DIY”)

Oil Changers.’

NORA believes that improper disposal can be minimized through

education and the availability

of convenient DIY used oil tanks

-

provided there

is

a market for used oil fuel.

However, if there is little or no demand for used oil

fuel, and’consequently no one is processing the used oil for sale, the problem will

be

how

to

handle

massive

quantities

of unwanted

used

oil.

In

other

words,

undermining the

market for used

oil fuel

—

even

if that

result

is

caused

by

the

best

of

environmental

intentions

—

can

create

the

unintended

effect

of

widespread improper disposal.

Requiring

permits

for

commercial

storage

of

used

oil

fuel

is

a

good

example

of the

kind

of burden

on

competition

that

the

Legislature

sought

to

avoid.

As explained at the hearing, commercial petroleum storage tanks facilities

will ~

undertake

any effort to become permitted used oil storage facilities.

The

threat of regulatory entanglement

is simply not worth the compensation received

in rent.

Yet, in periods

of high volume

sales of used oil fuel, such as the winter

months,

oil

processors

need

the

additional

storage

capacity

provided

by

commercial tank storage facilities.

Without such storage capacity, oil processors

are forced to rely on their own storage capacity which is invariably insufficient to

meet the demand of the winter

season.

Sellers

of virgin

oil, who are not subject

to

any

such

permit

requirements,

would

gain

an

important

and

permanent

competitive advantage as a result of this permit requirement.

Another

issue

directly

related to

the question of the

economic impact of

IEPA’s

proposal

is the

definition of special waste.

-IEPA

at the

August

23,

1999

hearing suggested that

the

definition could be flexible

such that if

a quantity

of

high bottom

sediment

and water

(“BS&W”) content

of used oil fuel was under

---

Comments of the national Oil Recyclers Association

Illinois Pollution Control

Board

September 24, 1999

Page 4

contract to

be sold

as

fuel,

it

would

not

be

classified

as

a

special

waste

—

but

would

be

so

classified

in

the

absence

of such

contracts.

NORA

appreciates

IEPA’s

willingness

to

be

flexible

but

foresees

a

host

of

regulatory

problems

attending this

concept.,

For

example, consider

the situation

where

a processor

has a quantity of high

BS&W fuel that is under

contract to be sold to a steel mill

but the contract

is

cancelled and

there is

a

48 hour period before

the processor

finds another buyer.

If this fuel is considered a special waste during this 48-hour

period, what regulations or permit conditions

are imposed during this time?

To

avoid

the unpredictable

consequences

of a flexible

definition,

NORA

proposes that used oil fuel containing

a BS&W content

of 10

percent or more be

classified as a “special waste.”

This classification would be applicable regardless

of whether such fuel

met

the criteria of

“specification used

oil

fuel.”

Although

used oil

containing

10 percent

BS&W can

be used a

fuel

or

can

be

blended

to

produce

a fuel and therefore

has value

as a product,

NORA

appreciates

IEPA’s

concern that

such material would

not be handled

as carefully

as

other used oil

fuel products.

Consequently,

designating such material as a “special waste” will

address the Agency’s stated need to have permit authority

over used oil that

is

less likely to be carefully managed.

At the same time,

a clear bright line

will be

created between used oil

meeting the criteria for

“special waste”

and used oil

that

competes

with

virgin

petroleum

products.

NORA’s

proposed

regulatory

language is as follows:

Part 808

Special waste Classification

Subpart

A: General Provisions

Section

808.124

Special

Waste Used

Oil.

Used

oil that

has

been

generated

by

a

commercial

source

is

classified

as

a nonhazardous

special

waste

if

it

has

not

been

certified

as

meeting

U.S.

Environmental Protection Agency criteria for

specification used oil

fuel

under

40

CFR

279.11

or

contains,

by

volume,

10

percent

or

more

of bottom

sediment

and/or

water.

Special

waste

used

oil

shall

not

be

stored,

transported,

treated,

or

otherwise

managed

except as allowed by a permit under 35 Ill. Admin. Code. 809.201

Finally, NORA also regards the entire permitting process, particularly

the

engineering studies

and

the

permit

negotiations

with

IEPA,

to be

a

costly and

time-consuming

exercise.

NORA

members

anticipate

that

for

any

given

---

Comments

of the national Oil Recyclers Association

Illinois Pollution Control Board

September

24, 1999

Pages

processor

or

storage

facility

permit

conditions

would

be

imposed

on

a

wide

variety

of

“site

specific”

circumstances

and

that

expensive

“design

criteria”

would

be

substituted

for

the

performance

requirements

set

forth

in Part

739.

Moreover,

any

appeal

of a

facility’s

permit

conditions

to the

Illinois

Pollution

Control

Board

can

result

in

a

significant

expenditure

of

professional

time

(engineers and attorneys) on behalf of the used oil processor.

Conclusion-

-

IEPA’s proposal to

obtain

permit

autliority

over

used oil processing

and

storage facilities has not been justified.

The existing regulatory controls have not

been shown

to be

inadequate in any way.

Nor has IEPA

demonstrated that

its

proposal

would

not

have significant

adverse impacts

on used oil processors in

Illinois

or

the

used

oil

fuel market.

Compliance with

section

9

of the

Illinois

Waste Oil

Recycling

Act

requires

government

agencies to

avoid

such

adverse

impacts.

To facilitate a workable

compromise solution,

NORA proposes that used

oil

containing

10

percent

or

more of BS&tW be regulated

as a “special waste”

—

thereby creating a clear, bright line between valuable feedstock and fuel products

and materials which are less valuable and could be managed with less care.

---

National

Oil

Recyclers

Association

Christopher Harris,

General Counsel

1439 West Babcock

•

Bozeman, Montana

59715

(406)

586-9714

•

FAX

(406) 586-9720

Perspectives on Used Oil Markets in the United States

,/7~~

f/•~.~

\~2

~“-“

i_i

U

Introduction

August 1999

Whether

used

oil is

a waste

or

a

commodity

was

a

crucial

question

in

Washington, D.C.

during

the mid-1980s.

By

1999,

this question

has

long since

been

decisively

answered.

Used

oil

is

a

commodity

-.

actually

a

variety

of

petroleum products that are traded in numerous recognized markets.

The essential fact about used oil is that having served its initial function as

a lubricant,

it has

the

opportunity

to

serve subsequent

functions.

Through re-

refining

it

can

once

again

become

a

lubricant

—

or

through

processing

it can

become

a fuel.

Since there are no subsidies

for used oil recycling, whether used

oil

serves

a

subsequent

function

is

entirely

a

question

of

whether

there

is

demand for

it.

As discussed

below, the

history, strength

and

variety

of well

established markets for products

made from used oil demonstrates the existence

of this demand.

Background

Although oil recycling in the United States can be traced to the early part

of this century, Congressional interest in used oil is

relatively recent.

Nearly two

decades ago Congress enacted the Used Oil Recycling Act of 1980. Pub.

L. 96-463,

Oct. 15,

1980, 94 Stat. 2055.

The legislative history of this statute makes clear that

Congress believed that the “recycling of used oil will result in the conservation of

a valuable energy resources

as well as diminish the likelihood of posing a threat

to

public

health and

the environment if disposed~.ofimproperly.”

H.R. Rep. No

1415,

96th Cong., 2d

Sess.,

10

(1980).

According to the Senate Environment

and

Public Works Committee,

“the purpose

of

the

legislation

is

to encourage

safe

reuse

of used

oil

in the

United States

and

to discourage

improper burning

or

~so~p~’o~

Christopher Harris

National Oil Recyclers Association

---

Perspectives on Used Oil Markets in the United States

Page 2

disposal of used oil.”

S. Rep. No.

879,

96th Cong., 2d

Sess.

1

(1980).

The statute

itself, declares that

“used

oil

is

a valuable

source

of increasingly

scarce energy

and materials”

and

that

“technology

exists to re-refine,

reprocess,

reclaim

and

otherwise

recycle used oil.”

42

U.S.C.

6901a.

Some states have

enacted similar

legislation

designed

to

encourage

proper

recycling.

For example,

the

Illinois

Waste Oil Recovery Act declares that used oil “is a valuable natural resource, the

conservation

of which

can

benefit the

people of

Illinois.”

815

ILCS

440/3(b).

Further,

the

Illinois

statute

establishes

the

policy

of

“promoting

the

use

of

recycled

oil

and

reducing

consumption

of new

oil

by

promoting

increasing

utilization of recycled oil.” 815

ILCS 440/4(a),(c).

-

Other

provisions

of the federal statute

directed EPA to

provide

technical

and

financial

assistance

to

states

to

address

“the

economic

and

institutional

impediments

to the recycling of used

oil.”

EPA was also required to conduct a

comprehensive

study

-

which

it never completed

-

concerning the economics of

the

used

oil

industry

and

the

energy

savings

attributable

to

recycling.

See

sections 5, 6, and

9

of the Used Oil Recycling Act of 1980, Pub.

L.

96-463, section

2, Oct.

15, 1980, 94 Stat. 2055.

Frustrated

by

EPA’s

failure to take

any

regulatory

action pursuant

to the

Used Oil Recycling Act, Congress passed sections

241. and 242

of the Hazardous

and Solid Waste Amendments

of 1984

(“HSWA”). 42 U.S.C.

6935.

The purpose

of these provisions was to prompt EPA to develop regulatory controls governing

used oil recycling.

However,

Congress was mindful of the economic forces that

form the foundation for a successful recycling system.

W

here protection

of human

health

and

the environment

can be

assured,... the EPA

Administrator should make every effort not to

discourage recycling of used oil.

For

example,

if there are several

alternative controls that

would be environmentally acceptable, the

Agency

should

allow

those

which

would

be

least

likely

to

discourage used oil recycling.

H.R. Rep. 1133, 98th Cong., 2d Sess.

114 (1984)

See also

H.R.

Rep. 198

(Part 1) 98th Cong.,

1st Sess., 64 (1983).

On

November

19,

1986,

after

originally

proposing

to

list

used

oil

as

a

hazardous

waste,

EPA

reversed

course

and

decided

not

to~

The

Agency’s

decision

was

based

on

the

realization

that

listing_would

discourage

recycling

activities

which,

in

turn,

“could

cause

an increased

quantity

of

used

oil

to be

disposed

of in uncontrolled ways, causing

harm, to

the environment.”

51

Fed.

Reg-.

41901

(November

19,

1986).

A

November

1986

report,

cited

by

EPA,

---

Perspectives on Used Oil Markets in the United States

Page

3

estimated

that

listing

recycled

used

oil

as

a

hazardous

waste

could

cause

an

additional

61 to 128 million gallons of used oil to be disposed of improperly.

See

Temple, Barker

& Sloane, Inc.,

Analysis

of

Possible

Market Impacts

Resulting

From

Stigmatizing Effect of Listing Recycled Oil

(Nov. 1986).

In

1992

EPA

promulgated

the

long-awaited

used

oil

management

standards.

These standards, codified at 40 CFR Part 279, combine the regulations

governing

burning

of

used

oil

fuel

that

were

issued

in

1985

with

the

requirements

for

managing

used

oil

by

transporters,

recyclers

and

transfer

facilities.

Most

states have

adopted the

Part

279

regulations

with

few,

if

any,

substantive

changes.

In

general,

the

Part

279

management

standards

form

a

regulatory framework that provides necessary tracking and operational controls

without undermining the market for recycled oil products.

The

1985

regulations

addressing

used

oil fuel created

two

categories

of

used

oil

fuel:

specification

and

off-specification.

40

C.F.R.

279.11.

Once

specification fuel meets all of EPA’s limits on arsenic, lead, cadmium, chromium,

flash point and

total ‘halogens

it is

no

longer subject to

any

regulatory

control

pursuant. to

RCRA.

According to

EPA,

“specification

used

oil fuel

poses

no

greater

risk than virgin fuel

oil

and

once it enters

the

commercial fuel market

should

not

be

regulated

differently

than

virgin fuel

oil.”

50

Fed.

Reg.

49189.

Meeting the specification criteria has been significantly easier in the 1990s than in

the ‘1980s

because

the

phase-out

of

lead

in

gasoline

resulted

in

a

dramatic

reduction of lead found in used oil.

Because used

oil

fuel

that

the processor

certifies meets

the

specification

criteria is not subject to Part

279

regulations,

the demand

for specification used

oil

fuel

greatly

exceeds

the

demand

for

“off-spec”, fuel.

Today,

virtually

all

processors

only

produce

specification

used

oil

fuel which

is

sold

to

industrial

burners such

as asphalt

(“hot mix”)

plants, steel

mills,

smelters,

electric

power

utilities

as well as

cement, lime and phosphate

kilns.

The demand for used

oil

fuel

is

also

generated

by

greenhouses,

foundries,

sand drying

ovens

and

ships.

In

1988,

a

Temple,

Barker

&

Sloane

study

indicated

that

approximately

80

percent

of the oil entering

the used oil management system was burned

as fuel.

Generation and Flow of Used Oil in

the

United

States in

2988.

(Nov. 1988) at 8,

n.

2.

Today,

as

a

result

of

increased

regulation,

more

efficient

collection

and

marketing

efforts

by

processors

and

less

demand for

re-refined lubricants,

that

percentage

is

likely to substantially

higher.

Moreover,

as

a result of efforts by

states and municipalities

to encourage recycling of~!’JJo

It Yourself” (“DIY”) used

oil, more

oil is

entering

the used oil

management

system rather

than

is

being

discarded.

---

Perspectives on Used Oil Markets in

the

United States

Page 4

ASTM Standards

To achieve greater recognition

of the important role of used oil fuel in the

industrial

fuel

market,,

the

National

Oil

Recyclers

Association

(“NORA”)

proposed that the American Society for’Testing and Materials

(“ASTM”) adopt a

new specification that addresses certain criteria that are not encompassed by the

Part 279 fuel standards.

The ASTM standard,, adopted in final form by

ASTM in

June 1999,

covers

four

grades

of fuel

oil made

in whole

or

in part

from

used

lubricating or hydraulic

oils.

With

the

exception

of flash point, the parameters

for

each

grade

encompass

properties

that

are

of

interest

to

the

buyers

(the

burners) rather than any governmental authority.

The eight parameters are:

(1)

viscosity;

(2)

flash point;.

(3)

water and sediment;

(4)

pour point;

(5)

density;

(5)

ash;

(6)

sulfur;

(7)

extracted pH; and

(8)

BTUs (heating value)

The detailed requirements are set forth in Attachment A.

The four grades of reprocessed fuel oil (“RFO”) are intended for use in oil

burning industrial equipment

—

not residential heaters, small

commercial boilers,

or combustion

engines.

The

ASTM description

of the four

grades

is

set

forth

below:

Grade

RFO4

Primarily

a

blend

of

used

lubrication

oils

and

distillate or a reprocessed distillate product derived from used oil.

It is intended for use in pressure atomizing industrial burners with

no

pre-heating.

This

grade

of

recycled

fuel

is

used

in

many

medium

capacity

industrial

burners

where

ease

of

handling

justifies the higher cost of the lighter used oil fuels.

Grade

RFO5L

A

straight

(100)

used lubricating oil blend or

a

used

lubricating

oil

and

distillate

blend

fuel

of

intermediate

viscosity,

heavier

than

RFO4.

It

is

intended

for

use

both

in

pressure-atomizing

industrial

burners

not

requiring

higher

cost

distillates

and

in

burners

equipped

to

atomize

oils

of

higher

viscosity

with

or without

pre-heating.

Its

permissible

viscosity

---

Perspectives on Used Oil Markets in the United States

Page

5

range

allows

it

to

be

pumped

and

atomized

at

relatively

low

storage temperatures.

Grade RFO5H

A straight

(100)

used lubricating blend or a used

‘lubricating oil and residual blend fuel, heavier than Grade RFO5L.

It is intended for use in industrial burners equipped with

devices

at

atomize

oil

of

higher

viscosity

than

domestic

burners

can

handle.

Preheating may be necessary in some types of equipment

for burning and in colder climates for handling.

Grade

RFO6

A

high

viscosity

used lubricating

oil

and

residual

blend

fuel, heavier

than Grade

RFO5H.

It

is intended

for use

in

large industrial heaters and may require preheating in the storage

tank

to

permit

pumping.

Additional

pre-heating at

the

burner

may

be

necessary

to

permit

satisfactory

atomization.

The

extra

equipment

and

maintenance

required

to

handle

this

fuel

may

preclude its use in small installations.

The

ASTM

standards

for reprocessed

fuels,

in combination

with

a

1996

study. conducted

by

Entropy,

Inc.,

provide

greater

confidence

to

industrial

burners that

used oil fuel not

only can achieve

stringent quality

standards

but

will also address concerns about

air emissions.

A key component

of the Entropy

Study involved emissions tests at two asphalt plants that evaluated the potential

for

release

of

heavy

metals

from

virgin

petroleum

fuel

and

used

oil

fuel.

According

to

the

author

of

the

study,

“tlhe

information

from

the

study

demonstrated

that the

combustion

of used oil in asphalt plants equipped

with

baghouses

in

good

working

condition

resulted

in

emission

of

lead

below

detection

limits.

In

fact,

the

emissions

of

lead

and

other

metals

from

the

combustion

of used oil at both test facilities did not

differ significantly from the

emissions associated

with the

combustion of number

2 virgin fuel at one

of the

test facilities.” Entropy, Inc.,

Quantification of Metals Emissions

From Burning

Used

Oil Fuel,

July 1996, p. iv.

See

Attachment B.

Used Oil Markets in the United States

According to estimates

by EPA,

in 1960 there were more than

150

active

re-refiners operating in the United States.

These companies produced more than

300 million gallons of re-refined

oil each year.

52

Fed.

Reg.

38840

(Oct.

19, 1987).

At

that

time

there was

a market

for

re-refined

lub~icants. With

the advent of

increasingly

sophisticated

additive

packages,

re-refining

became

significantly

more expensive and

less able to compete with

virgin lubricants.

Unfortunately,

despite

a

substantial

effort by

the federal

government

to

promote

government

---

Perspectives on Used Oil Markets in the United States

Page 6

procurement of re-refined lubricants, the re-refining industry in the United States

has

all but

collapsed.

By

the late

1990s used oil

recycling means

burning

for

energy recovery.

The

markets

for

used

oil

fuel

(also

known

as

reprocessed

fuel

oil

or

“RFO”)

exist because

used

oil

fuel is

less

expensive

than

virgin

oil

fuel

even

though the

BTU content is comparable.

It is worth noting that

while virgin fuel

oil and recycled fuel oil are direct competitors, oil fuel also competes with (and is

a

good

substitute

for)

other

forms

of

energy

such

as

coal

and

natural

gas.

Consequently, the

availability

and demand for coal and natural ga~has

a direct

impact

on

overall

energy

prices

that,

in

turn,

eventually

affects

used

oil

fuel

prices.

‘.

Because used oil fuel and virgin products are direct competitors,

prices for

RFO are usually determined

by reference

to

the posted price

for the virgin fuel

oil product for the nearest city where

petroleum products

are

sold at wholesale

prices.

For

example,

in

August

1997,

the

posted

price

for virgin

distillate

in

Chicago was

$55.13 per barrel.

A nearby used oil processor set a price of $.36

a

gallon

for

its

competing

RFO

product.

Price

data

for

this

used

oil

processor

during the period from May 1991 to May 1999 shows that the RFO prices tracked

virgin distillate prices and ranged from a high of $.42 a gallon

in October 1992 to

a low of $.30 a gallon in May 1999.

A review by NORA of confidential price data

from oil processors from all

regions of the United States during the 1990s reveals

remarkable similarity in their basic strategy for setting prices: use of the relevant

posted price for the virgin oil product, discounts based on water and ash content,

additional

discounts

based

on

high

volume

purchase

orders

or contracts,

and

upward

adjustments for meeting other specifications

requirements

and charges

for transportation.

As

a

general

matter,

the

principal

differences

between

any

category

of

virgin

oil fuel for industrial

burners and its

RFO counterpart

are water content

and

ash.

The higher

the

water

and/or

ash content

of a

used

oil product,

the

lower the price. For burners whose boilers or furnaces can tolerate higher water

and/or

ash content,

such

as blast

furnaces

at steel mills,

there is

a

substantial

price

advantage

over

virgin

petroleum

products.

In

September

1994,

for

example, one used oil processor in the mid-west (whose business in the recycled

oil

business

dates

from

the

early

1930s)

established

a

base

price

of

$.322

per

gallon

for

two

products:

Blast

Furnace

Oil

and

Boiler

Fuel’ and

a

discount

formula based

on

the moisture

(water) content

of-the fuel.

The base price was

pegged to the posted price for No. 6 virgin oil.

A discount of $.11 was provided

for fuel with less than

1 percent moisture content; a $.16

discount was provided

---

Perspectives on Used Oil Markets in the United States

Page 7

for

fuel

with

less

than

3

percent

moisture

content

and

a

$.21

discount

was

provided for fuel with a moisture

content of less than 5 percent.

While

blast furnaces

are

more

“tolerant”

of water and

ash content,

the

production process

may be

less

tolerant of ‘certain other chemical

and

physical

properties.

For

example,

the

operators

of

a

blast

furnace ,for

specialty

steel

products set certain restrictions on

trace elements such as a maximum of 50 ‘parts

per million (“ppm”) of cobalt, molybdenum, nickel, tin and vanadium.

Although

the economics

of the market

dictate substantial

price discounts

for RFO, the used oil processor must,

nonetheless, pay for all transportation and

operating expenses incurred in producing the fuel and delivering it to the buyer

and still attempt to make a profit.

Obviously, for oil recyclers making

a profit in

an

era

of high

energy

prices

is

a

much

easier

task

than

during

a

period

of

depressed prices.

Two key factors are at work in the ability of the oil recycler to

make a profit

during

periods

of low

energy prices:

operating

costs and

supply.

The

principal

variable

in

operating

costs

are

those

imposed

by

regulatory

requirements;

most

‘other

components

of

operating

costs,

such

as

labor

and

electricity, are relatively stable.

The costs

of regulatory compliance relate to many of the federal and state

environmental

laws,

principally

the

Resource

Conservation

and

Recovery

Act

(“RCRA”),

42

U.S.

6901,

et

seq.

These costs

include

testing

of used

oil

at

the

points

of collection from generators, receipt at the facility and prior to shipment

as a

RFO.

Numerous regulatory

compliance

costs relate to the

operation of the

facility.

These include: stormwater runoff compliance, air monitoring, secondary

containment,

shipment

tracking

and

other recordkeeping,

maintenance

of spill

prevention

plans,

security

systems,

compliance

with

wastewater

discharge

requirements, etc.

At present, compliance costs

constitute a major portion of the

cost of

operations

but,

are

not

an

overwhelming

expenditure.

However,

any

significant increase in regulatory

burdens, whether imposed directly or recyclers

or on their customers, will dramatically decrease the capacity for

oil processors

to be profitable.

The

second

factor

is

the

economics

of

supply.

A

processor

does

not

normally

have

one

or

two

suppliers

of used

oil.

Rather,

the

processor

has

developed

a

collection

system

involving

hundreds,

if

not

thousands,

of

generators

of used oil.

Most

of these customers

generate automotive

used

oil

because

they are

in the business

of servicing cars..a~ndtrucks.

Others generate

industrial

oil

as

a

result

of

machinery

that

requires

continuous

lubrication.

Regardless

of

the

source

of

the

oil,

the

economic

relationship

between

the

customer and the collector is the same.

When energy prices are high, used oil is

---

Perspectiveson Used Oil Markets in the United States

Page 8

more valuable

and

the generator

can command

a substantial

price.

During the

1980s an east coast collector and

oil ‘processor developed

a pricing formula that

pegged

the’ price paid

to the

generator

to

the

price

of

virgin

fuel

oil,

thereby

creating

certainty

in

the

pricing

structure.

See

Attachment

C.

When energy

prices are

significantly

lower,

collectors may be forced

to charge generators ‘for

oil collection services.

The Impact

of Regulation

and

Pricing on

Collection of Do It Yourself Generated

Used Oil

DIY

generated

used

oil

is

generally

the

regarded

as

the

“unwanted

orphan”

of the

oil recycling industry

-

prin~arilybecause it is not a

dependable

source of supply

for the used oil collector, ei~therin terms of quantity

or quality.

The

DIY used oil is generated not by

a regular business customer of the used

oil

collector but

by

anonymous

motorists

who

changes

his

own

oil

to

avoid

the

expense of a commercial oil change.

There is

no

assurance that the material left

by

the

DIY

oil

changer

is

pure

used

oil.

Although

the

reported

number

of

incidents

of DIY used

oil

that

has been contaminated

with hazardous

waste

is

surprisingly

small,

the

general

aversion

to

this

type

of

used

oil

remains

significant.

Yet because DIY used oil is the principal source of used oil pollution,

most state

governments

—

and thousands of local governments

-

have made this

their

top

priority

in

the

used

oil

arena.

(A

1991

estimate

by

Clayton

Environmental

Consultants,

an

EPA

contractor,

indicated

that

185

million

gallons of used oil is

illegally dumped each year.

Most of this illegal

disposal

is

attributable

to

DIY

oil

changers.)

State

and

local

governments’

principal

approach

in

encouraging

proper

recycling

of

DIY

used

oil

is

to

provide

numerous and convenient disposal tanks where

the DIY oil changer can drop off

the oil free of charge.

While used oil collectors are often paid by the government

to

pick up

the used oil, many

others

perform

this service, without

charge, as a

civic responsibility.

For businesses that

generate used oil (such as quick lubes and automobile

dealers),

a

provision

enacted

by

Congress

in

1986

provides

specific

encouragement

for

the

collection

of

DIY

used

oil.

Section

114(c)

of

the

Comprehensive

Environmental

Response

Compensation

and

Liability

Act

(“CERCLA”

or

“Superfund”)

provides

an

exemption for

all

off-site

Superfund

liability

involving

used

oil

provided

certain

conditions

are

met.

42

U.S.C.

9614(c).

To

be eligible

for this exemption, the used

oil

generator

must

(1)

be a

“service station

dealer”

i.e.

a business

that sells, services or repairs automobiles

or

light

duty

trucks

(See

42

U.S.C.

9601(37)(A));

(2)

comply

with

applicable

management

standards under RCRA for used oil generators;

(3) not mix used oil

---

Perspectives on Used Oil Markets in the United States

Page9

with hazardous waste; and

(4) provide

a collection tank for DIY-generated used

oil.

In

discussing

section

114(c),

the

Conference

Committee

offered

these

observations on the used oil ‘recycling system:

While

the

pressures

to recycle

waste

oil

for

energy conservation

have eased recently, the pressures to safely manage such used oil

and

to

prevent

environmental

pollution

are

ever

growing.

America’s

used

oil

recycling

system

handles

approximately

57

percent

of the more than one billion gallons of used oil generated

each year.

The balance of the used o~l

is

disposed of improperly

-

into

sewers, backyards,

or

into the

ti~ash

which

eventually winds

up

in municipal landfills.

The current used

oil recycling system

in this country

depends,

in

large

measure,

on

volunteers.

These

include

small

business

owners, such as service station dealers, who perform a community

service by collecting used

oil from do-it-yourself oil changers and

delivering

such

used

oil

to

recyclers.

The

volume

of

waste

involved

and

the

connection

with

the

problem

of

properly

managing

household

hazardous

waste

are just

two

examples

of

the factors that make the subjectof this amendment unique.

Used

oil,

when

properly

recycled

and

managed,

is

a

valuable

resource.

However, a number of factors, such as lower prices for

virgin oil and fear of liability under Superfund or the Solid Waste

Disposal

Act,

have

recently

resulted

in

a

reduced

demand

by

commercial users of recycled

oil.

To the extent such a reduction in

demand disrupts

the entire chain of commerce

in recycled oil and

leaves numerous

households

with

no

safe outlet for the

oil

do-it-

yourself automobile oil changers, the Federal government can and

should, as a consumer, help rectify the problem

H.R. Rep.

962,

99th Cong., 2d

Sess.,

227-28 (1986).

Accordingly, the Conference

Committee recommended that the EPA Administrator use the purchasing power

of the federal government, pursuant to section 6002(c)(2) of RCRA, to expand the

demand for used oil fuel products.

Id.

at 228.

With

EPA’s

promulgation

of

the

used

oil

management

standards

in

September

1992,

the

so-called

“service

station,

dealer’s

exemption”

became

operational.

Encouraged

by

their

trade associations, hundreds

of thousands

of

---

“C

Perspectives on Used

Oil

Markets in the UnitedStates

Page 10

quick

lubes,

truck and

automobile

dealers, garages,

and service

station

dealers

are

now

providing

used

oil

collection

tanks

(usually

250,

500

or

1000

gallon

tanks) that are set aside for public use.

The public

is admonished not to mix used

oil with

any contaminants

such as paints,

inks,

gasoline, kerosene, solvents,

or

‘other ‘hazardous

wastes.

As

long

as

the

DIY’ used

oil

is

relatively

free

of

contamination

and

there

remains

a

demand

for

used

oil

fuel,

the

system

for

collecting

DIY used oil is

expected

to expand and

strengthen.’

However, if the

demand

for used oil fuel declines,

DIY used

oil

is

the

category

of used oil that

collectors are least likely to collect.

Conclusions

Used

oil

when

processed

into

fuel

competes

with

virgin

petroleum

products and other

forms of energy such as coal.

Used oil is

less expensive than

virgin petroleum products even though its heating value is virtually identical.

In

fact, the only reason

there is

a used

oil fuel market is that used oil competes on

the basis

of comparable quality at a lower price.

The used oil market can be undermined whenever (1) regulatory

controls

are imposed on used oil (and not on virgin products)

to such an extentthat

the

costs

of processing

used

oil

significantly

narrow

the

price

difference

between

used oil fuel and virgin fuel products; (2) regulatory controls are imposed on the

burners of used oil fuel; or

(3)

regulatory

controls

--

or the threat

of liability

--

convinces burners that

the price advantage of used oil fuel is not worth the risk

of regulatory

or

legal problems.

When burners

decide

against using

used

oil

fuel, the market

shrinks.

The gradual destruction

of the used oil market

in the

United States should be

a serious concern to

policy-makers because the absence

of

appropriate

recycling

opportunities,

such

as

burning

for

energy

recovery,

means that the used oil will ultimately be disposed of improperly.

---

Standard

Specification

for

Industrial

Burner

Fuels

From

Used

Lubricating

Oils1

1.

Scope

1.1

This

specification

covers

four

grades

of

fuel

oil made

in

whole

or in part with

hydrocarbon-based

used

or

reprocessed

lubricating

oil

or

functional

fluids,

such

as

preservative

and

hydraulic

fluids.

The four grades of fuel are irnended for use in various

types

of

fuel-oil-burning

industrial

equipment

under

various

climatic

and

operating

conditions.

These

fuels

are

not

intended

for use in residential heaters, small

commercial

boilers, or combustion engines.

1.1.1

Grades RFO4. RFO5L, RFO5H and

RFO6 are used lubricating oil blends, with

or without

distillate

andior residual fuel oil, of increasing

viscosity and

are intended

for

use in

industrial burners

equipped to handle these types ofrecycled fuels.

Note

1

—

For information

on the

significance of the

terminology

and test methods

used

in

this spcciflcation, see Appendix Xl.

1.2

This

specification is

for use in contracts

for the purchase of fuel oils derived from

used lubricating oil

and for the

guidance of consumers

of such

fuels.

This specification

does not address the frequency

with

which any particular test

must be run.

1.3

Nothing

in

this

specification

shall

preclude

observance

of

nationalThr

local

regulations

which

can

be more restrictive.

In some jurisdictions,

used oil

is

considered a

hazardous

waste and

fuels from used oil

are required to meet certain criteria before use as

a fuel.

Note

2

—

For

U.S. federal

requirements

imposed on

uscd oil

generators, transporters

and

transfer

facilities, reprocessors,

marketers and burners, see

40 CFR 2798.

Note

3

—

Thc

generation

and

dissipation

of

static

elecuicity

can

create

problems

in

the

handling of

distillate burner fuel oils. For

more information on

the subject, see Guide D 4865.

1

ATTACBMENT

A

---

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1.4

The values stated in

SI units

are to

be

regarded

as standard;

non-SI

units, when

given, are for information

only.

2.

Referenced Documents

ASTM Standards

D 56

Test Method for Flash Point by Tag Closed Tester2

D 93

Test Methods for Flash Point by

Pensky-Martens Closed Cup Tester2’

D 95

Test Method for Water in Petroleum Products and Bituminous Materials by

Distillation2

D 96

Water & Sediment in Crude Oil

by Centrifuge Method (Field Procedure)2

D

97

Test Method

for Pour Point ofPetroleum Products2

D

129

Test Method for Sulfur in Petroleum

Products (General Bomb Method)2

D 240

Test Method for Heat ofCombustion of Liquid Hydrocarbon Fuels by Bomb

Calorimeter2

D 396

Standard Specification for Fuel Oils2

D

445

Test Method for

Kinematic Viscosity of Transparent arid Opaque Liquids (and

the

Calculation ofDynamic Viscosity)2

D 473

Test Method

for Sediment in Crude Oils and Fuel Oils

by the Extraction Method2

D 482

Test Method for

Ash from Petroleum Products2

D

1266

Test Method for

Sulfur

in Petroleum Products (Lamp Method)2

D

1298

Practice for Density, Relative Density (Specific Gravity), or API Gravity of Crude

Petroleum and Liquid Petroleum Products by Hydrometer Method2

D 1552

Test Method for Sulfur in Petroleum Products (High-Temperature Method)2

D1796

TestMethod for Determination of Water & Sediment in Fuel Oils

by the Centrifuge

Method (Laboratory Procedure)2

D 2622

TestMethod for Sulfur in Petroleum Products by X-Ray Spectrometry3

D 2709

TestMethod for Water and

Sediment in Distillate Fuels by

Centrifuge3

D 3245

TestMethod for Pumpability of Industrial Fuel

~

D 3828

Test Methods for Flash Point by Small Scale Closed Tester3

D 4052

Test Method for Density and Relative Density of Uquids by Digital Density Meter3

D 4057

Practice for Manual Sampling of Petroleum and Petroleum Products3

D 4175

Terminology Relating to Petroleum, Petroleum

Products, and Lubricants3

D

4177

Method for Automatic Sampling of Petroleum

and Petroleum Products3

D 4294

Test Method for Sulfur in Petroleum Products by Energy-Dispersive X-Ray

Fluorescence

Spectrometry3

D 4377

Test Method for ~Vaterin Crude Oils (Karl Fisher) Titration3

D 4865

Guide for the Generation

and

Dissipation of Static Electricity in Petroleum Fuel

Systems4

D 4868

TestMethod

for Estimation of Net and Gross Heatof Combustion of

Burner

and

Diesel Fuels4

D 4980

TestMethod

for Screening of pl-l

in Waste5

2

---

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P.85/14

D

5185

Test Method forDetermination of Additive Elements, WearMetals and Contaminants

mUsed Lubricating Oils and Determination

of

Selected Elements in Base

Oils

by Inductively

Coupled Plasma Atomic Emission Spectrometry (TCP-AES)4

U.S.

EPA Methods:

300.0

Determination of Inorganic Anions by Ion Chromatography6

9000

Determination of Water in Waste Materials by Karl fisher Titration7

9001

Determination of Water in Waste Lubricants by

Quantitative Calcium Hydride

Reaction7

9056

Determination of Inorganic Anions by Ion Chromatography7

Gor’ernment Standards

Referenced.

40CFR279

Standards forthe Management of Used Oil8

3.

Terminology

3.1

Definitions:

3.1.1

burner

fuel oil,

n

—

any petroleum liquid suitable for the generation of heat by

combustion in a furnace or firebox as a vapour or a spray, or a combination of both.

DiscussioN

—

Different grades are characterized primarily by viscosity ranges.

3.1.2

reclaiming,

n

—

the

use

of

cleaning

methods

during

recycling

primarily

to

remove insoluble contaminants, thus

making

the oil

suitable for further

use. The methods

may include settling, heating. dehydration, filtration

and centrifuging.

3.1 .3

recycling,

n

—

in petroleum

technology,

the

acquisition of oil that has become

unsuitable

for its intended use, and processing

it in order to regain useful materials.

3.) .4

re-refining

n

—

the

use of refining processes

during recycling

to produce

high

quality

base

stocks

for lubricants or

other petroleum

products.

Re-refining

may include

distillation,

hydrotreating,

andlor treatments employing acid,

caustic,

solvent, clay

andlor

other

chemicals.

3.1.5

used

oil,

n

—

in

petroleum product recycling,

oil

whose

characteristics

have

changed since being originally manufactured, and which is suitable

for recycling.

3.1.6

waste

oil,

n

—

in petroleum

technology,

oil

having

characteristics

making

it

unsuitable either for further use or for economic recycling

3.2

For definitions of other terms used in this specification, refer to Terminology

D41

75.

3.3

Definition of Terms

~pecific

to

this Standard:

3.3.1

reprocessing,

n

—

in petroleum product recycling,

the preparation of used oil to

be suitable as a fuel.

DiscussioN

—

Reprocessing

includes

procedures

such

as

settling,

filtration,

blending,

distillation, or chemical

treatment.

3

---

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P.06/14

3.3.2

industriaL burner,

n

—

a device

which produces heat for industrial use

through

the combustion of liquid hydrocarbon fuels.

DISCUSSION

—

Industrial burners are typically designed for one oftwo applications:

industrial

furnaces

—

integral

components

of manufacturing

processes

that

provide

direct

heating,

for

example

in

aggregate,

cement,

lime

or

phosphate

kilns;

coke ovens;

or

blast,

smelting, melting, refining, or drying ovens.

industrial boilers

large indirect heating units which

trarnsfer thermal energy to water or other

fluids or gases for use in

heating

in industrial settings and

in manufacturing processes

4.

Classification

There are four grades of industrial

burner

~ueIcontaining recycled

lubricating oils covered

by

this

standard.

These

grades

may or may

not

correlate directly with

similar

grades

in

other ASTM standards.

The RFO designation

identifies them as ~eprocessed Euel Qils. The

usage descriptions

of each

grade

may not describe

all

the uses,

but

are included as

general

information.

The four grades are described as follows:

4.1

Grade

RFO4

Primarily

a

blend

of used

lubricating

oils

and

distillate

or

a

reprocessed

distillate

product derived

from

used

oil.

It is

intended

for use

in pressure

atomizing industrial

burners with no pre-heating.

This grade of recycled oil fuel

is used in

many

medium

capacity industrial burners where

ease of handling justifies the higher cost

over the heavier used oil fuels,

4.2

Grade RFQ5L

—

A straight (100)

used lubricating oil blend or a used lubricating

oil and

distillate

blend fuel

of intermediate viscosity heavier

than RPO4.

It

is

intended

for use both

in

pressure-atomizing industrial

burners not requiring

higher cost

distillates

and

in

burners equipped to

atomize oils ofhigher viscosity

with

or without pre-heating.

Its

permissible

viscosity

range

allows

it

to

be

pumped and

atomized at

relatively

low-

storage temperatures.

4.3

Grade

RFO5H

—

A

straight

(100)

used

lubricating

oil

blend

or

a

used

lubricating oil and

residual

blend

fuel,

heavier than Grade

RFO5L.

It

is intended

for use

in

industrial

burners

equipped

with

devices

that

atomize

oil

of

higher

viscosity

than

domestic

burners can handle.

Preheating may

be

necessary in some

types of eq~ipment

for burning and in colder climates for handling.

4.4

Grade

R.F06

—

A

high-viscosity

used

lubricating

oil

and

residual

blend

fuel

heavier

than

Grade

RFO5H.

It

is

intended

for use

in

large

industrial

heaters

and

may

require preheating

in

the

storage

tzin1~~

to

permit

pumping.

Additional

preheating

at the

burncr

may

be

necessary

to

permit

satisfactory

atomization.

The

extra equipment

and

maintenance required to

handle this fuel

usually preclude its use in small

installations.

4

---

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5.

General Requirements

5.1 The fuel oils specified herein shall contain a minimum of

25

(vol.) of used

lubricating oil-derived products, the balance being

a Specification D396 fuel

oil or

suitable refinery stocks.

5.2

The fuel oils shall be homogeneous fluids consisting primarily of

hydrocarbons.

Fuel oils containing residual components shall remain

uniform

in storage

and

shall not

separate by gtavity or aging into layers in normal operating conditions.

Note

4

—

Prolonged storage or equipment

down

time may necessitate circulation of the

fuel

oil in-tank to prevent such separation.

5.3

The fuel oil shall not contain

excessive amounts oforganic andlor

inorganic

acids

and

shall be

free of

solid or fibrous matter

that could cause system handling

or

maintenance problems. The buyer and seller should agree on

any

requirements for particle size.

Note

5

—

The fuels defined by this

standard

are appropriate only

for burners

capable of

handling and combusting..fuels with potentially higher metals and ash content.

6.

Detailed Requirements

6.1

Grade

RFO4.

The requirements for this type of fuel

are

presented in

Table

I

and

include

fuels in

the viscosity range below

5

mm2 /sec (cSt)

at 100°Caccording to ASTM

D445.

6.2 Grade RFO5L. The requirements for this

type offuel.

are presented in Table

1

and

include fuels in the viscosity range 5.0

to

8.9 mm2 fsec (cSt) at 100°Caccording to

ASTM

D445.

6.3 Grade RFOSH.

The requirements for this

type of

fuel are

presented in Table

I

and

include

fuels

in

the

viscosity

range

9.0

to

14.9mm2

fsec

(cSt)

at

100°C according

to

ASTMD44S.

6.4

Grade RFO6.

The requirements for this

type of fuel are presented in

Table

1

and

include

fuels

in

the

viscosity

range

15.0

to

50.0mm2

/sec

(cSt)

at

100CC

according

to

ASTM D44S.

iVote

6

—

In

the

U.S.,

fuel

must

also

meet

USEPA

on-specification

parameters

for

recycled

used oil fuels as defined

under 4OCFR Part

279.11.

6.5

The

properties

listed

in

this

specification

are

those

of

greatest

significance

in

obtaining

acceptable performance

of’ the burner.

Only

referee test methods are shown

in

Table

1.

(See

Section

7

for alternate test methods and

Appendix Xl.

for significance of

test requirements).

5

---

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P.88/14

6.6

A representative sample shall be

obtained

for testing:

Practices D4057, D41 77, or

other

comparable

sampling

standards

should

be

followed.

In case

of dIspute,

D

4057

shall be

the

referee, practice.

A minimum

sample

size

of about

1

litre

(1

US

qt)

is

recommended.

6.7

Testing frequency

and

any modifications oflimiting

requirements to meet special

operating conditions shall

be agreed upon by

both the buyer and the seller.

iVote

7—

rt

is possible that

one or more ofthe parameters

listed in Table

I

may

be used

as an indicator ofwhen more extensive testing is

required.

6

---

Table

I

—

Detailed

Requirements

for

Industrial

Fuels

From

Lubricating

Oils

PROPERTIES

lYlethodE

LThUTSG

—

RFO4

RFO5L

RFO5H

RFO6

PHYSICAL:

Viscosity

~

100

°C

min2/sec

A

0445

minimum

---

---

5.0

9.0

15.0

maximum

---

5.0

8.9

‘

14.9

50.0

Flash

Point,

GC

(°F),

mm.

D93

38

(lOG)

-

55(130)

60(140)

Waler

&

Sediment’3,

vol.

max.

D95

&

D473

2.0

3.0

3.0

3.0

Pour

Point,

°C

(°F),

max.

D97

-6

(21)

NA

NA

NA

Density,

Kg/rn3

@

15°C

C

D1298

Report

NA

NA

NA

Cii

EMJ

CAL:

Ash,

mass,

max.

D482

0.7

0.8

0.8

Report

Sulphur,

mass!

0129

Report

Report

Report

Report

Extracted

p1-I,

thin.

.

04980

4.0

,

4.0

4.0

4.0

PERFORMANCE:

Gross

Heating

Value,

Mj/kg

(DTU/US

gal’3),

nm

D240

40.0

(130,000)

41.5

V35,O09~J

41.5

(135,000)

43.0

(140,000)

JD

0

L~JCo

w

()1

r~,)

vi

-Il

Ui

-D

0

Co

Cm

r

0

-U

Coz

H

-‘3

Cd

COI’)

vi

-‘3riD

(‘U

A

H

0

w

A Co

‘31

viCO

01Ui-‘3r\JCo

Co Ui

A

A

~

cSt

‘=

I

min2/sec

n

Solids

conCent

should

not

exceed

1.0

for

RFO4

&

5;

2.0

for

RFO

6;

Filtration

may

be

rcquircd

to

obtain

appropriate

particle

size

for

use

~

Density

in

kg/L

at

15°C

multiplied

by

1000

=

Kgfm3

‘3

Assumes

7.5

lb/VS

gal

~

Sec

Section

7

for

details

and

additional

methods

Local

jurisdictions

may

limit

the

sulphur

content

in

burner

(liels

G

thiiLs

givell

tn

parenthesis

are

for

informational

purposes

only

.7

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.7.

Test Methods

7.1

The

requirements

enumerated

in

this

specification

shall

be

determined

in

accordance with

the following ASTM

methods

except as noted:

7.1.1

~j~çp.s,iw

—

Test Method

1)

445.

For

quality

control,

a

Brookfield

rotary

viscometer (D2983)

may be used.

In

case of dispute, D445

shall be

used

as

the referee

method.

7.1 .2

Flash ~pj~t

—

Test Method D 93,

except where other methods are

prescribed by

law.

For

all

grades, Test Method D

3828

may be used as an alternative method

with the

same limits.

For RFO4

fuel

oils,

Test

Method

D

56

may be

used as an alternate

with the

same

limits, provided the

flash point is below 93°C

and

the viscosity

is

below

5.5

rnm~/s

at 40°C.This test method will

give slightly

lower values.

In case of dispute, Test Method

D 93

shall be used as the referee method.

7.1.3

Water

and Sediment

—

Test Method ID 95 for water

arid

Test Method

ID

473

for

sediment.

A

density

of 1.0

kg/L shall

be

used for Test Method D 95. Test Methods

D 96

for water

and

sediment,

D

1796

for water

and sediment.

D

4377 for water, EPA SW-846

Method

9000

for

water,

and

EPA

SW-846

Method

9001

for

water

may

be

used

as

alternate

test

methods

with

the

same

limits.

For

RFO4

fuel

oils, Test Method

D

2709

may he used as an alternate with the same limits, provided

the

viscosity

is

in

the range of

1.0

to

4.1

mm2/sec

(1.0 to

4.1

cSt)

at 40°Cand

the density

is in the

range

of 0.870

to

0.900 kg/L at 15°C.In case of dispute, Test Methods D95

and D

473

shall be the referee

methods.

7.1.4

Pour Point

—

Test Method D

97.

7.1.5

Density

—

Practice

D

1298.

Test

Method

D 4052

may

be used as an

alternate

with

the same limits. In case ofdispute. PracticeD 1298 shall

be the referee method.

7.1.6

Ash—TestMethodD 482.

7.1.7

Sulfur

—

Test Method

D

129.

Test Methods D

1266, D

1552,

D

2622,

ID 4294,

D5185,

EPA 300.0,

and

SW-846

Method

9056

may also

be

used for all

grades

with the

same

limits.

For Grade

RFO4

fuels

having

a

sulphur

content

below

0.4

(mass),

Test

Method

ID

1266 may be used as an

alternate with the

same limits. In case of dispute, Test

Method D

129 shall be

the referee

method.

7.1.8

Extracted pH

—

Test Method D 4980.

B

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7.1.9

Heating Value (Heat of Combustion)

—

Test Method D 240.

Method D 4868,

a

calculation method, may be used as

an

alternate,

with the same limits, where precise heat

determinations

are not critical.

In

case of dispute,

Method

D

240

shall

be

the

referee

method.

.

S

8.

Keywords

8.1

burr~er fuels;

fuel

oils;

furnace

oils;

petroleum

and

petroleum

products;

specifications, used oils.

APPENDIX

(Nonmandatory Information)

Xl.

SIGNTFICANCE

OF

ASTM

SPECIFICATiON

FOR

INDUSTRIAL BURNER

FUELS

FROM USED

LUBRICATING OILS

Xl.1

SCOPE

Xl.1.l

This

specification

divides

fuel

oils

into

grades

based

upon

kinematic

viscosity.

It places limiting values on

the properties of the oils in each

grade

believed to be

of the greatest significance

in detcrmining

the performance characteristics of the fuel oils in

the types of burners in which they are

most commonly used.

The

type ofburner for which

a

fuel oil is suitable depends largely on the fuel’s viscosity.

Xl.2

SIGNIFICANCE

OF TEST METHODS

X1.2.l

Physical Properties

X1.2.1.1

Viscosity

—The measure of a

fluid’s resistance to

flow. In

fuel

oil it

is

highly

significant;

it indicates

both

the relative ease

with which the oil will

flow or

can

be pumped,

and

the case of

atomization.

Viscosity

is

particularly

important

for the

heavier grades which may require appropriate preheating facilities to permit

the

product

to be pumped

to the burner and

forgood atomiz~tion.

XL2.1.2

Flash Point—The

flash point of a fuel oil is an indication ofthe maximum

temperature

at

which

it

cart

be

stored

and

handled

without

serious

.

fire hazard. The

minimum

permissible

flash point is

usually regulated

by national or local laws

and

is based

on

accepted practice in handling and

use.

X1,2.1.3

Water

and

Sediment

—

Appreciable amounts of water

and

sediment in a

fuel

oil

tend

to

cause

fou1in~

of

fuel-handling

facilities

and

to

give

trouble

in

burner

mechanisms.

Sediment

may

accumulate

in

storage

tanks

and

on

filter

screens

or

burner

---

AUG 30 ‘9~15:26 FR BK PROD DELJELOPMENT

773 825 7854 TO 914065869720

p.12/14

parts, resulting

in obstruction

to

flow

of oil from the tank

to

the

burner.

Water in

distillate

fuel

can cause

corrosion

of tanks

and equipment,

and

water

in

residual

fuel

may

cause

emulsions. The presence of water

in

a burner

fuel

can

also

cause “spattering” in

a burner

flame,

and

lead

to

damage of

burner

nozzles (erosion or “explosive”

damage)

due

to

the

rapid expansion ofwater in water vapour at a hot nozzle tip.

Excessive water in burner fuel

could lead to “flame out” or extinguishing the flame.

Xl.2.l.4

Pour Point

—

An

indication of the lowest

temperature

at which

a fuel oil

can

be

stored

and

still

be

capable

of flowing

under

very

row

forces.

The

pour

point

is

prescribed in~

accordance with the conditions ofstorage and use. Higher pour point fuels

are

permissible where heated storage

and

adequate piping facilities are

provided.

A.n increase

in

pour point

can

occur when residual fuel oils

are

subjected to cyclic temperature variations

that can occur in

the course of storage or when the fuel is preheated

and

returned to

storage

tanks. To predict these properties, Test Method D

3245

may be required.

Xl.2.l.5

Density

—

Density

alone

is

of little

significance as

an

indication of the

burning characteristics

of fuel oil. However, when used in conjunction with

other properties,

it is of value in mass-volume

relationships

and

in

calculating the

specific

energy

(heating

value per

unit

mass)

of an oil.

Higher density burner fuels

may indicate higher aromatics

content, which may

result

in

more

soot

or

carbonaceous

deposits

if

combustion

temperatures

are

not hotenough forcomplete combustion.

Xl.2.2

Chemical

Properties

Xl .2.2.1

Ash

The

amount

of noncombustible

material

in

an

oil.

Ash-forming

materials may be present in fuel oil in two forms, solid particles and

for oil- or water-soluble

metallic

compounds.

The solid particles are,

for the

most part, the same material

that

is

designated

as sediment

in

the water

and sediment

test.

Depending

upon

their size,

these

particles can con~-ibuteto wear

of burner pumps

and

valves,

and

decrease fuel efficiency.

The soluble metallic compounds

have little

or no effect

on wear

or plugging, but they can

contain elements that produce corrosion

and

deposits on boiler heating

surfaces.

Excessive

amounts of

ash

also may cause violation ofnational or local air emission regulations.

Xl .2.2.2

Sulfur

—

A knowledge of the sulfur content of fuel oil can be

useful for

special applications

in

connection with heat treatment, nonferrous metal,

glass,

arid”~eramic

furnaces or to meet

national or local legislation

or regulations.

XI.2.2.3

pH

—

An

indication

of

potentially

hazardous

levels

of

acidity

or

alkalinity.

Xl.2.3

Performance

Properties

X1.2.3.l

Heat of Combustion

-

A knowledge

of

the

heat of combu.stion is useful in

determining the thermal efficiency of equipment for producing either power or heat.

This

in

rum

may determine

the

economic value ofthe fuel.

10

---

AUG 30

‘99 15:27 FR SK PROD DELJELOPMEN4T

773 825 7854 TO 914065869720

P.13/14

X1.3

ViscosiTY

CONVERSIONS

X1.3.l

This

standard specifies limiting values of kinematic viscosity at

100°Cfor

the

fuel

oil categories

contained

in

Table

1.

In some

cases

kinematic

viscosity

may

be

measured

or

quoted

at

other

temperatures

or

in

other

units,

and

Table

A. I,

below,

gives

approximate relationships.

The data

shouid be used

with

caution, firstly since the precision

of measurements

at temperatures other

than

100°Cmay differ,

and

secondly

because

the

variability

of composition

of

these

fuels

may

cause

variations

in

viscosity-temperature

relationships~

Table A.1

—

~

estimated from those measured

at 100°C

Estimated Viscosity at Temperature:

Kinematic Viscosity,

mm?/sec

Kinematic Viscosity,

mrn2/sec

Saybolt Universal

Seconds

Saybolt Furol

Seconds

IOOC

40°C

50°C

100°F

1

122°F

.5.0

24

58

170

1350

17

40

tOO

640

125

290

900

7400

21

48

300

9.0

15.0

50.0

FOOTNOTES

Footnote

1

This speciflcation

is

under the jurisdiction of ASTM Committee

D-2

on

Petroleum

Products and Lubricants and

is

the

direct

responsibility

of Subcommittee

D02.P

on

Recycled

Petroleum Products.

Current edition approved XXXX.

Footnote 2

Annual

Book ofASTM Standards, Vol.

05.01.

Footnote

3

Annual

Book ofASTM

Standards,

Vol.

05.02.

Footnote ~

Annual Book ofASTM Standards, Vol. 05.03.

Fo~mote

S

Annual

Book of A.STM

Standards,

Vol.

11

.04.

Footnote 6

U.

S.

EPA

—

600/4-79-020,“Methods for

Chemical Analysis of Water

and

Wastes”

Footnote

7

U.

S.

EPA

—

SW-846,

“Test

Methods

for

Evaluating

Solid

Waste,

Physical/Chemical Methods”

11

---

AUG 30 ~99 15:27 FR SK PROD DEL)ELOPMENT

773 825 7854 TO 914065869720

P.14/14

Footnote ~

National

Archives

and

Records

Administration,

Code

of

FederaJ

Regulations,

Volume 40.

12

---

ENTROPY

INC.

SpéciaUsts

in

Air

Emissions Technology

P.O. Box

1229

I

•

Research Triangle

Park,

Non’h

Carolina

27709-2291

(919)787-3550

•

(800)486-3550

•

Fax (919)

787-8442

STATIONARY SOURCE

SAMPLING

REFERENCE NO.

VOLUME

Particulate

Arsenic

Barium

Cadmium

Hexavalent Chromium

Lead

JULY 1995

ATTACHMENT

B

---

EXECUTIVE SUMMARY

The

Used

Oil

Recycling

Coalition

(UORC)

contracted

with

Entropy,

Inc.

to

evaluate

metals

emissions from used

oil

combustion.

The primary objective of the study was to

compile

accurate

data on

emissions

of

lead

for

combustion

sources

utilizing

used

oil

as

a

fuel.

The

secondary

objective was

to

compile

accurate

emissions

data

for

other metals

including

barium,cadmium,

chromium, arsenic, and zinc.

The

project was divided

into two

phases.

In

Phase

I,

Entropy,

Inc.

conducted

a

comprehensive

literature

search

to determine

if there were

significant

gaps

in

the available

technical

information

regarding the

emissions

of

metals

from the

combustion

of used

oil.

In

addition,

an

emissions

inventory for used

oil

combustion

sources was

compiled

to

evaluate the

emission

quantities

of

each source

category.

Portions of the

conclusions and

recommendations for Entrop~sPhase

I

report (dated April

27,

1994)

are excerpted below.

In

Phase

II

of the

project,

Entropy,

Inc.

conducted emissions

test

programs at

two asphalt

plants

that

combust

used

oil.

Testing

at

one

of the

plants

also

involved

the

combustion

of

virgin

oil.

Asphalt plants were

chosen for

emissions testing because they

are the

single

largest category

of

sources

that

burn

used

oil,

and

they

consume

approximately

43

percent

of

the

total

used

oil

collected and used as fuel

in the United States.

The

information

from

the

study demonstrates

that

the

combustion

of

used

oil

in

asphalt

plants

equipped

with baghouses in

good

working condition resulted

in emissions of lead

below detection

limits.

In fact,

the emissions

of lead

and other metals from the combustion of used

oil at both test

facilities did

not

differ significantly from the emissions associated with the combustion of number 2

virgin

oil at one of the test facilities.

Phase

I

Conclusions:

1.

Due to significant

reductions in the concentrations of some

of the

metals in used

oils,

most of

the metals emission test data obtained

prior to

1985

is

not representative of present-day emissions.

2.

Due to the lead-in-gasoline

phase-down

requirements, lead levels in automotive used

oil after

processing

have decreased

substantially.

Average levels are

now

in

the

range

of

40

ppm,

well

below the pre-1985

levels

of

200 to 1000 ppm.

3.

Barium

levels in

used

oil

have decreased

substantially due to

changes

in the

composition of

additive packages used for lubricating oils.

Average levels in

automotive used

oils are now in

the

range of

10

ppm.

4.

A large

fraction of the metals contained in used

oil fuel stays

within

the combustion

chamber

and

is

not

emitted

into

the

effluent

stream.

The

metals

are trapped as

deposits

on

combustion

chamber

walls

and

heat

exchange

surfaces.

For

industrial

boilers,

commercial

boilers,

space

heaters,

and

other small

combustion

sources, the

quantitie.s

retained

as permanent

deposits

are

probably

50 percent pf

the total quantity of metals entering with the

fuel.

iv

---

5.

A significant fraction

of

tlw metals. contained

in used

oil fuel for industrial furnaces

is captured

by the

product streams proce~~b~d

in the

furnaces.

These metals are trapped as permanent solid

deposits

in

the

surfaces

of th~product

materials

and

are

not

emitted

to

the atmosphere.

For

cement

kilns and

asphalt plai~lrotary dryers,

metal

capture

by-product materials can

çange from

20

percent to

90 percent.

6.

Metal-containing

particles

formed

due

to

vaporization

in

the

combustion

chamber

and

nucleation

during gas

strean~(.ooling

are

primarily

in

the

submicron

size

range.

Multicyclone

collectors are ineffective for

thI1~

particle size range. The

collection efficiencies

forthe types

of wet

scrubbers,

electrostatic

precii~~lU1t0rs

and fabric filters employed

on

used

oil

combustion

sources

range from approximately

50 1~t~~ent

to greaterthan 99 percent.

7.

Asphalt

plants

are

the

Ij~rgest single

category

of

sources

burning

used

oil.

They

consume approximately

43

~cent

of the total

used

oil

collected

and

Used as fuel

in

the

United

States,

and

there are

indicatk~’5

that

the

consumption

rates

are

increasing.

Metals removal

in

baghouse-controlled

plants is

y~iryhigh. There

is considerable uncertainty regarding the capability

of wet scrubber controlled ~

to collect metals-containing

particles efficiently.

8.

Utility

boilers are

an

imp~~1lnnt

consumer of

used

oil.

More data

are

needed

regarding

the

types

of boilers

that burn

used

oil, the types

of fuels

co-fired with used oil,

the types

of air pollution

control

systems

on

these

1~l(~rs,

and

the

used

oil

firing

practices.

There

are

no

previously

conducted

air

emissions

sWdies

on

utility

boilers

regarding

the

potential

metals

emissions

attributableto the burning

of ui~d

oil.

9.

Industrial

boilers

used f~

~rJaceheating and

steam generation are important because of the

quantities of used oil

consurn~’d

and

the limited

air

pollution control system capability.

Emissions

data

are

needed

to

evaluate

Uio

metals

retention

as deposits in the

boilers and

to

evaluate the

fractions removed as

part

of ~)ltom

ash or flyash streams.

There are no

relevant, up-to-date data

concerning metals emissions tuim industrial boilers.

10.

Space heaters

are an

important

category due to the quantities

of used

oil

burned and the

lack

of air pollution control system~.There is very little relevant, up-to-date emissions

data.

However,

a

study being coordinated by

tk~

f3tate

of Vermont is

likely to

provide valuable data.

(See Volume

1,

Appendix

A of this report).

11.

The NORA survey

data indicates that

small

commercial

boilers,

apartment house

boilers,

and school boilers (collectiwlY termed “residential/commercial” boilers) receive a relatively small

fraction

of the overall used o~

U(~nerated

in the United

States.

12.

Cement kilns and other ~

of industrial processes do not

appear

to be significant sources of

metals emissions due to

high particulate collection efficiencies and to metal capture

in the product

streams.

V

---

Phase

I

Recommendations:

1.

An emission test program should

be conducted to characterize

emissions from three

types of

used

oil combustion

sources:

(1)

asphalt

plants,

(2)

utility

boilers, and

(3)

industrial

boilers.

The

tests should include

analyses of the used

oil fuel and the accumulation of

metals

on

heat exchange

surfaces

and

refractory within

the

boilers.

The

scope

of the

tests

should

include

lead,

barium,

cadmium, chromium, arsenic, and zinc.

2.

Air

pollution

emission

data obtained as

part

of the

State

of Vermont

study

of space

heaters

should be requested as soon as

it

is available to further evaluate the environmental aspects

of

used

oil combustion

in space heaters. (See Volume

1, Appendix A of this report).

Phase

II:

Pursuant

to

the

Phase

I

recommendations,

extensive

efforts

were

made

to

locate

suitable

combustion sources

from

all

three recommended

categories,

but

no

suitable

utility

or

industrial

boilers

were: identified

as

test

subjects.

No

utility

boilers were

identified that

co-burned

used

oil

with

virgin

oil.

Aithough

many

utility

boilers

co-bum

used

oil

with

coal,

these

burners were

determined

not to

be appropriate test subjects

because the used

oil generally constitutes a small

constituent

of the

fuel

load

and because of the difficulties

inherent

in differentiating the very slight

impact of

metals associated

with

the combustion of used

oil from the metals associated

with the

combustion

of coal.

A

small number of

potential

industrial

boiler

candidates were

identified

and

contacted.

Ultimately,

however,

none would

allow the

testing

to

be

performed.

Thus,

Phase

II

testing was limited to two asphalt plants.

Stack testing was conducted at

two

asphalt pants, designated

as

Facility A and

B throughout this

report,

to

determine the

emissions

of

lead,

barium,

cadmium,

chromium

(hexavalent

and

total),

arsenic, and zinc.

At

Facility A,

tests were conducted

during the

combustion

of

virgin

number

2

fuel

oil

(designated as Condition

I)

as

well as used oil,

which is referred.to

by the asphalt

plants as

number 4 recycled

oil

(designated

as

Condition

II).

At

Facility

B, tests were conducted during the

combustion of number

4 recycled

oil.

Comparison

of the

emissions

from

the

different

fuels

fully

supports

the

contention

that

metals

removal

in baghouse-controlled

plants

is very

high.

At

Facility

A,

lead

content of

the recycled

oil

was

50 times

higher than that

of the virgin

oil,

yet

emissions

remained at or

below the

detection

limit

with

corresponding

removal

efficiencies

greater than

99.98

percent.

A

comparison

of

the

average percent removal efficiencies

for each metal under each of the test cortditions

is

presented

in the following table.

vi

---

Metals

Removal Efficiency

-

Average ofThree Test Runs

ArSenic

Barium

CadmIum

Chromium

Lead

Z3r~c

Facility A Virgin

Number 2

Fuel Ofi

98.63

92.06

97.55

96.07

95.33

70.49

Facility A Recycled

Number

4 Fuel OIl

~

98.70

98.72

99.42

99.05

99.98

99.97

Facility

B

Recycled Number

4

Fuel

Oil

98.03

96.59

98.56

98.74

99.95

99.96

At

Facility

B,

lead

content

in

the

recycled

oil

was

slightly

lower

than that

in the

recycled

oil

at

Facility

A, and

removal

efficiencies

remained

high

-

greater than

99.95

percent.

At

both

facilities,

—

removal

efficiencies of the other metals tested were

similarly high.

The informationfrom the study indicates that the combustion

of used

oil in asphalt plants equipped

with

baghouses

in good

working

condition

resulted

in

low levels

of

emissions

of lead

and

other

metals

at or

below detection

limits.

In

fact,

the

emissions

of

lead

and

other

metals

from

the

—

combustion of used

oil at these facilities

did

not

differ significantly

from the

emissions associated

with

the

combustion

of

number

2

virgin

fuel

oil

at

Facility

A.

The

mass

balance

calculations

indicate

overall

removal

efficiencies

of 96.05 percent to 99.98 percent of the metals tested.

Thus,

—

the study demonstrates

that the combustion

of used

oil

in these types of asphalt

plants

is a

good

option for resource recovery.

I-

vii