In the Resource Conservation and Recovery Act, the stated purposes are essentially the same as for the first act. Section 6002 of this act will require government agencies to purchase recycled oils in preference to virgin oils, and to even possibly pay a higher price for it. This becomes effective on October 22, 1978, less than 11

months from now.

In addition, the review of government specifications for petroleum products must take place by April 22, 1978, approximately 5 months from now, and all exclusionary clauses must be revised to allow the use of recycled oils. For example, there is a clause in the present Federal procurement specification for burner fuel oil (VV-F-815C) which excludes fuel oil containing waste crankcase oil, even if it is processed to meet all other requirements. Also, military specifications for engine oils contain clauses excluding all lubricating oils made from recycled or previously used oils. These military specifications are used for essentially all Federal procurement of engine oils, and they often form the basis for procurement by industry and State and local governments.

The third area of legislation of interest is the Model (States) Used Oil Recycling Act. This model act was written by Mr. William Irwin (one of our speakers) for the Federal Energy Administration (now the Department of Energy), and was designed to assist individual States in establishing control over used oil disposal. It clearly encourages used oil recycling as a superior method of disposal. This model act makes use of the Energy Policy and Conservation Act-mandated NBS test procedures for establishing appropriate quality criteria for recycled oil products. A number of States have introduced such legislation, based almost word-for-word on the model act. California has just recently become the first State to pass such a law and put it into effect (California Senate Bill No. 68, signed September 1977).

The legislation just discussed will have four basic consequences in the real
These are:

world.

1. The FTC must change their labeling requirements for all recycled oils which are found to be "substantially equivalent" to virgin oils, using the NBS test procedures.

2. Federal agencies must review and revise specifications for petroleum products where necessary.

3. Federal agencies must purchase the highest percentage of recycled materials practicable.

4. Finally, in light of the above, it is a reasonable conclusion that the collection and recycling of used oil will be substantially increased.

In 1975 the Environmental Protection Agency estimated the amounts of recoverable used oil potentially available for recycling to total approximately 1.2 billion gallons, or over 28 million barrels. Of this amount, almost 55 percent was generated from automotive or vehicular uses. The fate of used oils in 1975 included approximately 47 percent burned as fuel--often without suitable emission controls--and apparently less than 10 percent was re-refined for reuse as lubricants. The fate of 35 percent of this used oil was stated to be unknown, and much of this is assumed to be disposed of by ecologically harmful methods such as dumping into ditches, landfills, and storm sewers by do-it-yourself mechanics.

In order for the NBS program to systematically consider the primary end uses of recycled oils, we have divided the work into four phases based on these end-use categories: Phase I--Recycled Oils Used as Fuel, Phase II-- Recycled Oil Used as Engine Oils, Phase III--Recycled Oil Used as Industrial Oils, and Phase IV--Recycled Oil Used as Hydraulic Oils. Each type of oil has different specifications and performance requirements, based on a variety of test procedures. We recognize that many test procedures currently exist for virgin petroleum oils. However, we also know that at least some of these tests either are not valid with recycled oils, or that insufficient data exist to determine whether they are valid. Laboratory evaluation of these tests is required; and, in some cases, development of new or modified test procedures is necessary before a complete set of tests can be transmitted to the FTC.

We can briefly summarize our program plan as follows. For each end-use category

we will

review existing (virgin oil) test procedures;

evaluate these tests for applicability and validity for recycled oil

develop new or revised test procedures when required;

transmit the set of approved test procedures to the FTC; and

5. provide technical support to the FTC as required.

The problems we have found with existing virgin oil tests and our technical efforts to date will be discussed in detail by Dr. J. J. Come ford later on this morning, so I will not go into them here.

2. holding the first NBS workshop in November 1976 (proceedings published as NBS Special Publication 488);

integrating cooperative interactions with the many committees and organizations interested in oil recycling; and

3.

4. obtaining an Industrial Research Associate agreement with the Association of Petroleum Re-refiners (ARP). The Research Associate with the NBS Recycled Oil Program is Mr. Robert F. Pedall, Chief Chemist of the Motor Oils Refining Company in McCook, Illinois. The APR, in their October meeting, voted to continue their support of the Research Associate Program through the motor oils phase.

Finally, let me take several minutes to describe our priorities in the technical work in which the NBS is currently involved. As I mentioned earlier in my talk, we have initiated our program by considering the end use of burning used oil as fuel for energy recovery (Phase I). For this category, some examples of characteristics we are addressing for substantial equivalency are heat content (Btu); effects on the environment and health; burner erosion; tank, pipe, and burner corrosion (including effects on refractory materials ); deposit formation; and so on. We expect to complete the technical portion of Phase I, Test Procedures for Recycled Oil Used as Fuel, early in 1978.

Once the fuel category is completed, the second end-use category to be addressed by the NBS program is engine oils (Phase II). As I am sure you realize, this second category contains the most difficult technical questions and problems of all the end Some of these questions include the following:

uses.

1. For the straight mineral lubrication oil (API SA classification), which at the present has no performance tests or requirements--to what should recycled oils be equivalent?

2. How can the problem of obsolete engine sequence tests be resolved (API classifications SB, SC, SD, CA, CB, and CC)?

3. What is the variability, if any, of re-refined lube oil base stocks on a batch-to-batch basis, or as a function of time? What tests are capable of detecting that variability if it does occur?

What is the variability of petroleum oil products in the marketplace, both virgin and recycled?

Do recycled oils require additional or revised specifications compared to virgin oils?

5.

As I stated before, we realize that there are some difficult technical problems which lie ahead of this NBS program. However, all of the information we have obtained, and that includes some of what you will be hearing this afternoon, indicates the following.

1.

The basic hydrocarbon structure of petroleum lubricating oil is not significantly changed during use;

2. An adequately re-refined oil can be as good as a high-quality virgin lubricating oil; and finally

3. I think there is no question that oil recycling is here to stay.

I am looking forward to the papers to be presented here in the next 2 days, and

I hope that the discussions and comments on the various topics will be both numerous and constructive. I also invite your comments and cooperation with the NBS program and with our efforts to help resolve these technical questions and problems.

It is a pleasure for me to speak to you this morning on behalf of the Association of Petroleum Re-refiners (APR), an organization which represents the re-refiners in the United States and Canada. The APR is privileged to place a research associate, Mr. Robert F. Pedall, at the Bureau of Standards, and this is an indication of our full support of the important effort being carried out at the Bureau on recycled oils.

In my remarks this morning I would like to take a brief look at the re-refining industry, and then share with you our views with respect to the key issues which surround the work being undertaken here at the National Bureau of Standards (NBS). I am sure most of the attendees at this session are aware of the decline of the rerefining industry. In 1965, there were an estimated 160 companies reported to be re-refiners, and today the number is about 25. From a high in the early 1960's of 300 million gallons of oil re-refined, the figure has dipped below 100 million gallons and continues at these low levels although we estimate production increased a bit in the past year.

It is hard to understand why this decline could occur at a time in our history when there has been a lube oil shortage due to an oil embargo and the word "recycle" has become a buzz word in our society. It happened, as I believe you know, through a combination of circumstances. Government action took its toll. Changes in tax policy hurt the re-refiners. Incredibly, the re-refiners pay a tax that producers of virgin oils do not pay. Labels are required to carry the onerous clause, "made from previously used oils." Market barriers were erected, particularly in the military. And, indeed, among the factors was also the performance of the industry-the fact that anyone could call himself a re-refiner and sell a product of any quality that he determined would fit his customers' needs.

I would like to state to the auto manufacturers here today, to the additive manufacturers, and to potential users of re-refined oil that we in the Association of Petroleum Re-refiners share with you a need to establish procedures to assure the quality of re-refined oils. We do not want a return to the pre-1965 days. We are calling for a system that will enable us to demonstrate the quality of re-refined oil and its equivalency with the original product. And we are asking also for the opportunity to compete equally with the producers of the original material.

Does it not make much more sense to recycle and use the product over and over again than to burn it and use it once?

It is a problem for the re-refiners that by far the largest disposal of used oil is burning. We estimate that three-fourths of all used oil is burned; that is about 10 times the amount re-refined. This compares to West Germany, where over half of all used oil is re-refined.

It

The lube fraction is the high-quality portion of the crude oil stream. makes up roughly 2 percent of the crude barrel. From United States fields, it now averages 1.7 percent as the richer Pennsylvania and mid-continent fields play themselves out. Every authority I have talked to confirms that crude from the newer sources -- that is the Alaskan North Slope and the North Sea and Mid-East crudes-are substantially lower in the lube fraction. A spokesman from a major lube producer told me, "There is considerable effort being devoted to the development of new technology in order to produce quality lube from lesser-quality crudes."

It is possible, of course, to manufacture lubes from the lower-quality portions of the crude stream, but it is more difficult and more costly, and also consumes more process energy.

One does not conserve energy by burning used oil. The process energy needed to refine virgin lube is double the process energy used, to re-refine. Taking into account all the energy factors in burning versus re-refining, there is a net savings of 23,590 Btu's for every gallon of oil re-refined.

At the workshop held last year, I took some notes on statements from the following company representatives:

Chrysler:

Alcoa:

Ford:

"One rule we have is don't burn-- then it's gone. We can
make something of it."

"We burn our oil only as a last resort. There are better
uses."

"We have a corporate mandate. We don't burn."

It was not too many years ago that there was a lube shortage. Lube oils were on allocation due to the import embargo. Have we forgotten this? With the political instability in the Middle East, we could awaken any morning and find that there is a war among those countries or that other political events have cut off our source of imported oil. Why does it not make sense to lessen our dependence on foreign sources of this very valuable fraction of the crude stream? And yet there are those who would say burn it--burn it and we will supply you with new.

In addition to the need to conserve a valuable resource, there are serious environmental considerations which favor re-refining over burning or dumping.

It

Used oil improperly disposed of is a considerable hazard to our environment. contains high levels of contaminants, including the spent additive package; heavy metals such as lead, barium, zinc, and magnesium; and various complex organic compounds. Crankcase drainings contain an average of 0.8 percent weight lead; that is about 1,000 pounds of lead in every 1,000 gallons of drainings. Although the lead level in gasoline is declining, we do not find a comparable decrease in the lead in used oil. Lead will probably always be a significant part of the used oil contaminant. and, indeed, lead substitutes, the MMT's, are under investigation as potential carcinogens.

But let us look at lead. Lead buildup in the human body is cumulative, and it attacks the central nervous system, causing serious illness. Children are most affected, as they appear less able to pass the lead through their systems.

Used oil is burned as a fuel substitute primarily in populated areas where it is collected. Comparing this to auto emissions as a source of lead, there is particular concern for a source which is stationary, with stack emissions creating a steady fallour over the surrounding populace as compared to a moving source causing air movement close to the ground.

To date there has been a limited amount of testing of ambient lead levels surrounding the facilities burning used oil. It is good that the Environmental Protection Agency (EPA) is stepping up its activity in this area. One example is the Fairfax County school system in Virginia, which undertook to determine in 1974 the feasibility of burning used oil as a fuel supplement in the school system. Tests were conducted in conformance with the EPA specifications, and the findings were that, "...continual burning of waste oil in schools would expose students to unacceptable levels of contamination." This was in spite of the fact that the used oils in the test contained an unusually low amount of lead, only 0.2 percent, and the tests were run with as little as 25 percent used oil blend. The study further concluded that, "...it would be expected that the fallout of the contaminants would be in a concentrated area close to the building and hence would be expected to settle in the playground area and would be ingested into the school ventilating and fresh air system." Testing actual stack emissions, the schools concluded that, "...lead content would cause the level to increase as high as 6 to 8 micrograms per cubic meter, significantly higher than threshold levels quoted by EPA."

A recent Canadian study showed that atmospheric lead concentrations of less than 2 micrograms per cubic meter caused lead concentrations in the blood of exposed children higher than those of the average urban child. Blood levels exceed the amount considered hazardous. The American Petroleum Institute - conducted Hawaiian Electric tests showed atmospheric lead levels during blowout in excess of 2 micrograms per cubic meter.