The EPA stated in its 1974 Report to Congress that all airborn lead "...contributes to excessive lead exposure in... adults and children... [and] that it would be prudent to reduce preventable lead exposure." I would ask you to reflect on the presentation before this workshop just a year ago by officials from the Aberdeen Proving Grounds. This was the basis for a directive to military and government facilities to burn used oil. The first oil tested was reported to contain jet fuel and was mixed with No. 2 fuel oil at a 1-percent level. It was found to burn without undue stack emissions. A more typical waste oil containing crankcase drainings was collected from the base, mixed at 50-percent levels with a No. 2 fuel, and was found to fail stack emission tests. now for the conclusion. It is all right to burn at blend ratios up to 5 percent in No. 2 fuel! Who takes the responsibility for this? And At the risk of exaggerating the point, I would inform you that there is a panic among the people of northwest Washington; that is the affluent section of this community where many congressmen and government officials live. It has been found that children have dangerously high blood lead levels in this area and the cause is uncertain. Women are going from door to door in the Cleveland Park section in a campaign to have children's blood tested. We have no evidence that the burning of used oil has contributed to this, but we have no evidence that it has not. An attempt in this area to determine where used oil is being burned is not productive because the collectors are not saying who is doing the burning. We are certain that most of the collected used oil in this area is burned and that it is burned untreated. The typical scavenger needs only a rental truck and he is in business, and it is difficult for the re-refiner, with his investment in plant and equipment, to compete for these feedstocks. There are those who say let economics determine whether used oil is burned or re-refined. This is fine, but let the economics include the costs of pollution and the costs of a lost resource. The APR opposes burning on conservation grounds. It believes that accountability for disposal will be nonexistent without government regulation and therefore supports the programs of the EPA and the Federal Trade Commission toward this end. In those cases where it is not practical to re-refine, burning may be conducted only after the used oil is processed to remove the contaminants and its equivalency to fuel demonstrated. What about the claim that the re-refiners are too small to handle a surge of used oils diverted to this higher order? It is expected that regulations would have an implementation period to allow the industry to position itself to handle increased volumes. There is ample evidence that the industry is capable of this growth. Unused capacity would enable an immediate increase in volume to an estimated 150 million gallons a year. In recent years, corporations with larger capital resources have entered the field, including Esmark, Anchor Hocking, and most recently Phillips Petroleum Company. There is great interest in the future of re-refining. There can be no doubt that, given sufficient economic incentives, the re-refining industry will provide the capacity to handle the volumes of oil generated. Two As to the technical problems that exist within the industry, we are very optimistic in this area also. A veteran re-refiner said to me just last week he has seen more process development and innovation in the past 2 years than in the entire 25-year history of our Association. Can we solve the acid/sludge problem? The answer is yes. Two new processes in pilot-plant stage, the Bartlesville Energy Research Center and Phillips processes claim to have solved the sludge problem. re-refiners, using the acid-clay process, report to me that they have process developments which have solved their sludge disposal problems. It is important that small members of the industry be allowed time to make adjustments so that they can expand in volume and still be capable of disposing of by-product materials. Process developments will have to be made available to these companies in an equitable way that will enable them to survive. The EPA must recognize the need for a growing rerefining industry and make allowances for interim sludge disposal at the local level. oil. oils. Finally, I would like to comment on the question of the quality of re-refined In the past year, two tests of considerable significance were run on re-refined One was the City of San Diego fleet test. The city had used re-refined oil for 3 years in its vehicles. In all, 1,500 vehicles used 120,000 gallons of rerefined oil in the period. After 100,000 miles of service, typical engines were torn down and compared to another city whose vehicles used virgin oils. The report from an independent laboratory, conducted under the auspices of the EPA, concluded that the engines run on re-refined oil were "...as good as if not better than those using virgin oils." In addition, Department of Defense/EPA-sponsored engine sequence tests were conducted on six samples of re-refined oil selected to be broadly representative of oils produced. Preliminary results of these tests are that four of the six passed all the tests for SE qualification and that overall pass/fail ratio for a one-time test was remarkable, comparing favorably to the best of the virgin oils. I I The engine sequence test has been a problem for re-refiners. With costs up to $40,000 per oil, it is understandable that we cannot afford to conduct the tests. recognize that for many of you the engine sequence tests are the product of many years development and that they have served you well. But there are things about this test that are worrisome besides its cost. First is the reproducibility of the test. understand that there is a high fail rate of all oils, even the best that are subjected to the tests, and that it is the practice to run the test repeatedly until a pass is achieved and then to report only passes. I also understand that it is the practice to start with a low additive level and gradually increase the level until a pass is achieved. Is this a quality test for a base oil or for the additive package, or is it a test to show the minimum additive blend needed for those few companies who can afford repeated tests? Is it possible that any base oil with sufficient additive will pass an engine sequence test? When all is said and done, what does the SE label mean? The purpose of any label is simply to inform the consumer. Not many consumers have any idea what the label on their motor oil means. Try your local service attendant and see how much he knows about the American Petroleum Institute (API) classification system. Add to this the fact that marketers of oils are apparently misrepresenting the SE label. This was shown in a recent survey by an automotive company showing that a low percentage of the oils sampled which were labeled SE actually met those quality levels. These tests have been developed by a small number of large companies, and only a small number of large companies can afford to participate in the system. The problem is that the system, by excluding the re-refiner, has posed a barrier to recycling and the conservation of a valuable resource. Now that the quality of re-refined oils is being demonstrated, the obstacle to broader acceptance seems to be questions as to consistency of re-refiner feedstock. Re-refiners have claimed that through proper segregation of incoming stocks they do have a consistent feed source. The Bartlesville Laboratory of the Department of Energy, in Part V of its Waste Lubricating Oil Research series entitled "A Comprehensive Characterization of Five Typical Re-refinery Feedstocks," reported that after careful analysis of samples of waste oil collected from 20 States to give geographic and seasonal variations, "The data show the various samples to be extremely similar, implying that an acceptable reclamation procedure should produce consistent re-refinery product with minimal effects from feedstock variations." Is it possible that the re-refiners' feedstock would compare favorably with variations in crudes? There are changes in crude makeup when the field begins to run out. How easy is it to control the consistency of foreign crudes which make up more and more of domestic production? I am told this is very difficult and that foreign crudes are identified by their port of origin and these crudes can be a blend of oils from as many as three different fields. Most domestic plants are using a combination of domestic and foreign crudes. One plant I talked to has used 25 different foreign crudes in the past 5-year period. Half of the products on the Defense Department's qualified list are imported crudes. At a time of national emergency, lube producers will probably have to take crude from wherever they can get it. What happens to the elaborate military specification qualification system then? It fails when it is needed most. Is it possible that the most consistent products at that time would be re-refined oils, the very products excluded by the current military specifications? If consistency of feedstocks is indeed the major problem that the engine manufacturers and additive people have as to determining the consistent quality of re-refined oils, by all means let us now work together to develop the test methods that will enable us to satisfy you as to our feedstocks and then to show the equivalency of re-refined oils with the original materials. A re-refiner capable of producing a quality product should have the opportunity to qualify his product and then provide the ongoing assurances of quality based on the tests that will enable him to show that equivalency. In conclusion, to preserve this valuable finite resource and abate pollution of our environment, the first step, in our view, is to manage and control the disposal of used oil. We ask your support for the need to demand accountability for the disposition of used oil and to stop the uncontrolled burning. We share the same goal in seeking an orderly development of the re-refining industry that will not be disruptive of fair procedures for establishing the quality of all such products. The re-refiners ask for the opportunity to compete by the same rules that apply to all and for the opportunity to demonstrate the equivalency of their products to the original for its intended use. And that is why we so heartily support the fine work at the National Bureau of Standards. National Bureau of Standards Special Publication 556. Proceedings of a Workshop on Measurements and Standards for Recycled Oil - II held at NBS, Gaithersburg, Maryland, November 29 and 30, 1977. (Issued September 1979) A LIMITED INTEGRATED ASSESSMENT OF THE WASTE OIL RE-REFINING INDUSTRY 1 Stuart D. Liroff Resource Management Division Teknekron, Inc. 2118 Milvia Street Berkeley, California 94704 In the United States, the Resource Conservation and Recovery Act of 1976 (RCRA, Public Law 94-580) will have profound impacts on the waste oil re-refining industry. The two broad goals of the RCRA are: ⚫ to conserve natural resources both directly and through the • to assure that all solid and hazardous wastes are managed in a Few would argue with the individual merits of these goals. Unfortunately, there exist circumstances where the pursuit of one may jeopardize the other. Where national objectives work at cross purposes, administrative and regulatory agencies find themselves in the unenviable position of having to choose between the lesser of two evils. The waste oil re-refining industry's future may be determined, in part, by the relative priorities given these goals by Federal and State environmental agencies. Given the present technological profile of the re-refining industry, the re-refining of waste oil to promote the reuse of an exhaustible resource generates toxic by-products which present an environmental hazard. Strict regulation to prohibit the latter may result in diminishing the former. In seeking to achieve resource conservation while assuring environmental protection, or at least to achieve one without undermining the other, the Environmental Protection Agency (EPA), in promulgating regulations under the RCRA, must be aware of the secondary impacts and tradeoffs involved. In the case of waste oil re-refining, environmental regulation should bear in mind not only the reduction in solid waste, but also the secondary impact such a reduction might have on the cost of re-refining; the profitability of the industry; and, ultimately, the volume of waste oil re-refined. This requires an assessment of the industry and its likely response to different assumptions about future environmental regulations, the re-refined oil market, and the technologies available to re-refiners. Supported by a grant from the National Science Foundation (Grant No. AEN-7517302), Teknekron's Resource Management Division conducted a Limited Integrated Assessment of the Waste Oil Re-refining Industry. Answers to the following questions comprise, in part, this analysis and permit such an assessment. Are there process technologies for re-refining currently available, What is the nature of the industry's present hazardous waste dis- • Can the present hazardous by-products be safely disposed of, either • Can economically justified investments be made to retrofit existing 1This paper was not able to be presented at the Conference. |