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NORA: And the NORA 2010 Keynote Speaker is...

Scott Parker — Fri, 03 Sep 2010 22:27:31 GMT

Hello [firstname],

Patrick J. Buchanan, 2010 NORA Keynote Speaker

Three-Time Presidential Candidate and Political Commentator

Pat Buchanan will present "A Conservative View from Washington" at the 2010 NORA Conference in Scottsdale, Arizona (November 10-13, 2010). Pat's Keynote will be on the morning of November 11th.

Click here to register.

Pat will be addressing NORA just a week after the 2010 Mid-Term Elections where most experts are expecting a major political shift in Congress. Pat will provide his opinion on what this means for the country and what it will mean for the members of NORA.

Pat will dissect what’s going on in the Obama Administration and on Capitol Hill, sharing with audiences what today’s news means for tomorrow’s political outcomes. Pat will analyze the day’s top political and cultural headlines, examining current policies under discussion and how they could change the country’s future. With incisive analysis and articulate opinions, Pat discusses the battle over national sovereignty, the global economy, American foreign policy and the future of the traditional values coalition.

Biography

Patrick Buchanan has been a senior advisor to three Presidents, a two-time candidate for the Republican presidential nomination and was the presidential nominee of the Reform Party in 2000.

From 1966 through 1974, Buchanan was an assistant to Richard Nixon, and from 1985 to 1987, White House Director of Communications for Ronald Reagan. In 1992, Buchanan challenged George Bush for the Republican nomination and almost upset the President in the New Hampshire primary. In 1996, he won the New Hampshire primary and finished second to Senator Dole with three million Republican votes.

Born in Washington, D.C., educated at Catholic and Jesuit schools, Buchanan received his master’s degree in journalism from Columbia in 1962. At 23, he became the youngest editorial writer on a major newspaper in America, the St. Louis Globe-Democrat.

In 1966, Buchanan became the first full-time staffer to Richard Nixon in his legendary comeback. He traveled with the future President in the campaigns of 1966 and 1968, and served as special assistant through the final days of Watergate.

On leaving the Ford White House in 1974, Buchanan became a syndicated columnist and founding member of three of the most enduring—if not endearing—talk shows in television history: NBC’s The McLaughlin Group, and CNN’s Capital Gang and Crossfire.

In his White House years, Buchanan wrote foreign policy speeches and attended four summits, including Mr. Nixon’s historic opening to China in 1972 and Ronald Reagan’s Reykjavik summit in 1986 with Mikhail Gorbachev.

Buchanan has written ten books, including six straight New York Times best-sellers, A Republic, Not an Empire, The Death of the West, Where the Right Went Wrong, State of Emergency, Day of Reckoning and Churchill, Hitler and The Unnecessary War.

Buchanan is currently a columnist, political analyst for MSNBC, chairman of The American Cause foundation and an editor of The American Conservative. He is married to the former Shelley Ann Scarney, who was a member of the White House Staff from 1969 to 1975.

Don't miss this great presentation.

If you have not already done so, register today to save: click here.

The 2010 NORA Annual Recycling Conference & Trade Show will be held November 10-13, 2010.

The event will be held at the Fairmont Scottsdale in Scottsdale, Arizona.T o register, click here.

Our room block at the Fairmont Scottsdale is 35% sold out. Call 800-344-4758 to reserve your room today (make sure you ask about the hotel's cancellation policy).

This an AAA 5-Diamond Resort and our basic room rate is just $179/night.

Regarding travel, plan on arriving to Arizona by mid-day on Wednesday, November 10th as the conference will kick off at 4:15 pm that day. Plan on departing on November 13th so you can attend the closing party on Friday evening, November 12th. It will conclude at 10 pm on the 12th.

The NORA conference attracts over 300 leaders from the industry related to the recycling of used oil and related materials. In addition to invaluable networking and education sessions, the conference will feature a trade show that will likely have over 30 exhibitors.

More info to follow shortly.

3-Sep-10 6:27 PM

NORA: Keynote Speaker Update

Scott Parker — Thu, 02 Sep 2010 17:59:17 GMT

Hello [firstname],

NORA will be announcing the 2010 NORA Conference Keynote Speaker on Friday afternoon.

Here is a clue: The NORA Keynote Speaker was a candidate for President three times.

Don't miss this great presentation. The Early Bird Rate for the 2010 NORA Conference expires on Friday, September 3rd. If you have not already done so, register today to save: click here.

The 2010 NORA Annual Recycling Conference & Trade Show will be held November 10-13, 2010. The event will be held at the Fairmont Scottsdale in Scottsdale, Arizona.

To register, click here. The Early Bird rates are good through September 3rd.

Additional details about the Conference will be released over the next two weeks.

Our room block at the Fairmont Scottsdale is 35% sold out. Call 800-344-4758 to reserve your room today (make sure you ask about the hotel's cancellation policy). This an AAA 5-Diamond Resort and our basic room rate is just $179/night.

More info to follow shortly.

2-Sep-10 1:59 PM

NORA: Brett Morton, 1958 - 2010

Scott Parker — Fri, 20 Aug 2010 13:22:05 GMT

Brett Morton, 1958 – 2010

Shell Lubricants
NORA Board Member

It is with great sadness that we inform you of the passing of Brett Morton of Shell Lubricants, on August 11, 2010 in Houston, Texas.

Brett was an active member of NORA since 2004 and had been serving as a member of the Board of Directors for the last year. In addition, Brett was an active participant on the American Petroleum Institute’s Used Oil Task Force and was a valuable liaison to that group for NORA.

Brett will be missed by his colleagues in the used oil industry.

20-Aug-10 9:22 AM

NORA: SPCC Deadline Being Extended Beyond November 2010

Scott Parker — Wed, 11 Aug 2010 10:45:19 GMT

Hello [firstname],

EPA is planning on extending the compliance date for facilities to comply with the amendments to the Spill Prevention Control and Countermeasure rule (SPCC). The extension will change the compliance date from November 10, 2010 to November 10, 2011.

NORA's Jack Waggener is reporting from DC that the extension has passed through the Office of Management and Budget and it should be published in the Federal Register soon.

For additional information, visit http://www.epa.gov/emergencies/content/spcc/compliance_dates.htm

NORA will be addressing this issue further at the 2010 NORA Conference in Arizona (November 10-13).

Thank you for being a member of NORA. We will let members know of any updates to this issue.

Scott D. Parker, NORA

sparker@noranews.org

703-753-4277

11-Aug-10 6:45 AM

NORA: Member announces Largest Re-Refining Plant in South America

Scott Parker — Mon, 12 Jul 2010 19:06:30 GMT

Hello [firstname],

NORA Member CEP announced today that it has inked a contract to build the largest re-refinery in South America. LWART Group (also a NORA Member), headquartered in Brazil, has contracted with CEP for the design of the plant.

The press release from CEP follows. If you would like more information, contact Mark Williams, CEP, 949-757-7555 or email mark.williams@ceptechnology.com.

Thank you.

Scott D. Parker, NORA

sparker@noranews.org

703-753-4277

Press Release from CEP

Chemical Engineering Partners (CEP) announced today the signing of a contract to build the largest re-refinery in South America. This facility will be the first of its kind in South America; it will produce API Group II base oil. “We are very excited to bring the CEP Process to South America” said George Lamont, President of CEP. The plant will be located in Brazil. The facility will be state of the art and the largest facility designed by CEP. Brazil is a leader in environmental initiatives. It is the only country where used oil must be re-refined by law. “We have received many inquiries from South America and we think there are some excellent opportunities in this region” said Mark Williams, Business Development Manager for CEP. “There are no Group II base oil plants in South America, neither crude refinery nor re-refinery so all Group II base oil is imported”. CEP has started the Technology Design phase of the project. The LWART Group, headquartered in Lençóis Paulista, Brazil, has contracted CEP to design the plant. LWART is regarded as the largest company in South America in the field of collecting and re-refining of used oil.

CEP is one of the leading technology design and process technology firms in the re-refining industry. CEP is an affiliate of Evergreen Oil Inc. (EOI) who has successfully operated its state of the art facility for used oil re-refinery in Newark, California since 1986. CEP is responsible for licensing the re-refining technology developed at the EOI facility to third parties. Over the years, CEP has worked closely with EOI to develop and improve the re-refining process now called the CEP Process. The CEP Process produces API Group II base oils. These base oils have been tested and certified by API. CEP has designed re-refineries around the world that use the CEP Process. In 2009, CEP commissioned three plants in the USA and Europe, collectively. For more information about CEP, visit our website at www.ceptechnology.com.

12-Jul-10 3:06 PM

NORA Member NexLube to Construct Re-Refining Plant in Tampa, FL

Scott Parker — Wed, 16 Jun 2010 12:00:00 GMT

NORA member NexLube Tampa, LLC has announced they will be constructing a 24 million gallon oil re-refining plant in Tampa, Florida. Two related news stories are provided below.

A representative for NexLube will be at the 2010 NORA Mid-Year Meeting.

Thank you for being a member of NORA.

Scott D. Parker, NORA

sparker@noranews.org

703-753-4277

Tampa Port signs lease for $75 million recycling project

The Tampa Port Authority approved a lease option agreement with NextLube Tampa LLC, which plans to build a $75 million recycling facility at the Port of Tampa.

The facility will be on 12 acres at Pendola Point, a release said.

Up to 24 million gallons of used oil per year will be processed at the facility, which would be the first of its kind in Florida.

The project is expected to create jobs during its two-year construction phase and provide 100 direct and indirect jobs during the 20-year agreement, the release said.

When fully operational, the facility will provide $10 million in revenue to the Port of Tampa.

Recycled oil from the facility will be used to produce lubricants, diesel and asphalt and reprocessed into motor oil.

Port of Tampa signs lease for oil recycling facility

Board commissioners at the Tampa Port Authority have this week approved a lease option agreement with NexLube Tampa, LLC to construct a recycling facility capable of processing up to 24 million gallons of used oil per year at the port.

Tampa port is the "shipping gateway" for about 40% of all the petroleum-related products that serve the fuel needs of most of west central Florida.

The facility will be located on 12 acres at Pendola Point and will be the first of its kind in Florida. The recycled oil at the facility will be used to produce lubricants, diesel and asphalt.

"Green industries are increasingly being developed at ports across the United States, and fit in well at the Port of Tampa," said Richard Wainio, port director and chief executive.

"We are happy to welcome NexLube Tampa, LLC to the Port of Tampa and are eager to see their business succeed. As a major petroleum port, Tampa is a logical center for significant oil recycling," Wainio added.

The project is estimated to cost $75 million and is expected to begin operations in 2012.

16-Jun-10 8:00 AM

NORA Provides Testimony to EPA on Proposed Solid Waste Rule

Scott Parker — Tue, 15 Jun 2010 23:35:08 GMT

Hello [firstname],

On June 15, 2010, NORA's Executive Director Scott D. Parker provided testimony on behalf of the liquid recycling industry to the US EPA regarding the Proposed Rule Concerning Burning Non-Hazardous Secondary Materials. A copy of NORA's testimony may be found at the bottom of this email.

The proposed rule was issued in the Federal Register on June 4, 2010. It has wide ranging implications for all aspects of the used oil recycling industry.

To download a copy of the rule, click here. There are two approaches that are being offered related to used oil. The proposed approach for used oil can be found on pages 22 and 23. The alternative approach for used oil can be found on pages 43 and 44.

NORA has created a working group that is gathering input from all members as the association is working on developing a policy position on the issue. NORA will have comments prepared before the EPA comment deadline on August 3.

The deadline for EPA to complete this rule is December 16, 2010. It is expected that the final rule will be implemented over a three year period. This will be a major topic of discussion at the 2010 NORA Mid-Year Meeting.

Statement of NORA, An Association of Responsible Recyclers

Concerning EPA’s Proposed Rule

Concerning Burning Non-Hazardous Secondary Materials

Good morning. My name is Scott Parker. I am the Executive Director of NORA, An Association of Responsible Recyclers (formerly the National Oil Recyclers Association). Today NORA offers a general statement concerning the rule recently proposed by the U.S. Environmental Protection Agency (“EPA”) to promulgate regulations governing solid waste-derived fuels. NORA will submit much more detailed comments on or before the August 3, 2010 deadline. To provide you with some background on the oil recycling industry, NORA’s more than 240 members provide collection and recycling services in each of the 50 states and the District of Columbia. Our members collect and recycle used oil, antifreeze, waste water, oil filters and absorbents, and parts cleaning chemicals and comply with stringent regulatory safeguards for used oil recycling pursuant to 40 CFR Part 279 and many other sets of environmental regulations, including the Clean Air Act. The basic components of Part 279 were adopted by EPA in 1985 and strengthened in 1992 -- pursuant to a clear Congressional mandate to encourage legitimate methods of used oil recycling.

The legislative history of used oil regulation should not be ignored in the present rule-making effort. In 1980, 1984 and 1986 Congress directed EPA to develop regulations that protect human health and the environment while encouraging legitimate used oil recycling. In other words, Congress recognized that if over-regulation kills a recycling market, the adverse environmental consequences may be severe.

A set of balanced regulatory controls emerged that, for all practical purposes, accomplished Congress’ goals. NORA members collect and manage vast quantities of used oil as a valuable product – in compliance with EPA’s regulations. If, instead of a balanced regulatory approach, used oil had been declared a hazardous waste, as had been seriously considered, far less used oil would be recycled and the system for handling used oil would be extremely expensive – without any environmental protection benefits. The history of used oil regulation in the United States provides a valuable lesson and blueprint for policy makers who genuinely care about environmental protection.

NORA’s basic perspective on the proposed rule is very straightforward. NORA agrees with EPA’s conclusion that on-specification used oil fuel does not constitute a solid waste because it is not abandoned or otherwise discarded. It constitutes a legitimate and traditional fuel. NORA contends that -- for precisely the same reasons -- off-specification used oil fuel does not constitute a solid waste. The facts demonstrate that off-spec used oil is a legitimate and traditional fuel. It should be emphasized that the distinction between on-spec and off-spec used oil fuel has nothing to do with its heating quality. Both categories of used oil fuel will generally have the same Btu content (approximately 140,000 British Thermal Units per gallon) -- the equivalent of virgin petroleum oil if the water content is the same.

The distinction between the two categories of used oil fuel is a somewhat arbitrary one, created by EPA in 1985. If any parameter of four metals exceeds a specified concentration, the used oil is classified as off-specification. If total halogens are greater than 4000 parts per million, the used oil is off-specification. Also, if the flashpoint of the used oil is lower than 100 degrees F., the used oil is classified as off-specification. NORA’s collective experience in the nearly 25 years since this rule was adopted by EPA is that the metals rarely exceed the specified concentrations.[1] Rather, used oil fuel is off-spec because of total halogens or flashpoint. However, neither of these factors adversely affects the quality of this type of used oil as a fuel. The market for off-spec used oil – under the current regulations – is strong and reliable.

There are, according to EPA’s Materials Characterization Paper on used oil for this rule-making, approximately 750 industrial furnaces and boilers that burn off-spec used oil fuel. These are primarily cement kilns, boilers for utilities, furnaces at steel mills and other major industrial burners. All of these burners are stringently regulated by the Clean Air Act and each utilizes and maintains expensive pollution control equipment. There is absolutely nothing in the preamble to any of the proposed rules that suggests that when burning used oil fuel these industrial furnaces and boilers emits halogens in quantities greater than would be the case if the off-spec used oil fuel were burned in facilities with Section 129 permits. This point needs to be carefully considered by EPA because there would be no justification of this proposed rule (as it would apply to off-specification used oil fuel) if no environmental benefits are to be achieved.

It is also worth pointing out that Exhibit 6 of the Material Characterization Paper shows that “the principal benefits of combustion of used oil are associated with upstream production offsets and include substantial reductions of NOx, CO, and CO2 emissions. In terms of combustion-specific emissions, use of used oil results in notably lower NOx emissions, in particular when compared to residual fuel oil.” (see page 9). The term “upstream production offsets” is a shorthand way of recognizing some of the benefits of used oil recycling. It means that when a quantity of fuel is produced from used oil that is collected and recycled, the adverse environmental impacts that would have beeen created by producing the same quantity of virgin fuel have been eliminated. Unfortunately, these benefits are threatened by the proposed rule that, perhaps unintentionally, could effectively destroy the market for off-spec used oil fuel.

Currently, there is a steady and reliable market for off-spec used oil fuel. Off-spec used oil is collected and marketed in much the same way as on-spec used oil. The difference is in the number of end users (approximately 750 industrial furnaces and boilers) versus a more limited number of section 129 solid waste incinerators. Fewer outlets will result in dramatically increased transportation costs from the geographically diverse generator locations to these limited facilities.

What are the consequences of severely diminishing the market for off-spec used oil fuel? There could be several including the potential mismanagement of this product due to the increased management costs. NORA strongly recommends that when EPA evaluates the effect of the proposed rule, it should consider the real-world impact of the rule on the environment. NORA contends that there are numerous environmental benefits to the existing used oil recycling market which includes the recycling of off spec used oil. Consequently, we need to very carefully identify the outlets and impact on the management of off-spec used oil before we eliminate existing management programs – programs that currently collect and recycle used oil very effectively.

Finally, I would like to address an issue relating to the “Alternative Approach.” On page 31885 in Section VII.E, which is titled "Alternative Approach," EPA states:

"Under this alternative (referring to the alternative proposal), traditional fuels that we have identified earlier, which includes clean biomass, and that have been burned historically as fuels and managed as valuable products (as discussed in section VII.C.5.) would not be solid wastes."

The traditional fuels definition for the "alternative approach" is apparently changed from the "traditional fuels we have identified earlier" to specifically exclude on-spec used oil, and this change should have been addressed in the above statement. On-spec used oil has been identified multiple times as a traditional fuel in the proposed rule, one that fully qualified under Section VII.C.5.

Likewise, in the FAQ sheet put out by EPA (specifically, the last question that discusses the alternative approach) is also misleading, because it too identifies "traditional fuels" as not being solid wastes under the Alternative Approach -- without discussing the exclusion of on-spec used oil from the "traditional fuels" that was previously discussed in the rule. EPA needs to specifically address this contradiction and formally explain its position. This clarification needs to be provided in the near future so that commenters can comprehend EPA’s intent and reasoning.

Thank you. NORA appreciates the opportunity to present this statement.

[1] NORA strongly disagrees with certain “findings” in the 2003 study referenced in the Material Characterization Paper on Used Oil. Specifically, the study by Dominguez-Rosado and Pichtel indicates that lead is found in used oil at 110 parts per million and cadmium at 9.4 parts per million. On a nearly daily basis NORA members test used oil generated from hundreds of thousands of generator customers and have been doing so for 25 years. Based on our test data, the results in the 2003 for these metals are far too high. We will provide EPA with our data in our formal comments.

15-Jun-10 7:35 PM

NORA BREAKING NEW: EPA Proposed Solid Waste Rule in Today's Federal Register

Scott Parker — Fri, 04 Jun 2010 15:30:43 GMT

All NORA members should attend the 2010 NORA Mid-Year Meeting to learn more about this important issue and help develop NORA's strategy to address it. Register now for the: NORA 2010 Mid-Year Meeting, June 20-22, Washington, DC - click here for agenda, hotel info and registration form

EPA's Proposed Solid Waste Rule In Today's Federal Register - Input from all members requested

NORA has confirmed that the proposed rule for the "Identification of Non-Hazardous Materials That Are Solid Waste" was published in today's Federal Register.

NORA is requesting that all members review the document carefully and provide their initial comments to NORA by June 11th by emailing sparker@noranews.org

To view a copy, click here: http://edocket.access.gpo.gov/2010/pdf/2010-10837.pdf

NORA members should read the entire document. The "Proposed Approach" related to used oil starts on page 31864. The "Alternative Approach" related to used oil starts on page 31885.

The deadline for comments is listed as July 19th. However, NORA has learned that EPA will likely extend the comment period on this proposed rulemaking from 45 to 60 days. That means that NORA will have until August 3rd to develop a position and file comments.

Also, EPA is planning a public hearing in DC on June 21st regarding the proposed rules.

At this point, NORA requests that members read this document carefully and provide initial comments to us by Friday, June 11th. Thank you. Your input is important.

Make sure you attend the 2010 NORA Mid-Year Meeting. Click here for details. Over 100 industry leaders will be in attendance discussing this issue and many others.

4-Jun-10 11:30 AM

NORA News Alert: EPA Proposed Solid Waste Rule to be in Federal Register on Friday June 4th

Scott Parker — Thu, 03 Jun 2010 15:20:24 GMT

EPA's Proposed Solid Waste Rule Will Be Published in the Federal Register on June 4th - Comment Period Extended

NORA has learned that the proposed rule for the "Identification of Non-Hazardous Materials That Are Solid Waste" is scheduled to be published in the Federal Register on Friday, June 4th.

NORA has also learned that EPA plans to extend the comment period on this proposed rulemaking from 45 to 60 days. That means that NORA will have until August 3rd to develop a position and file comments.

Once the official version has been published, NORA will provide the appropriate links to members. NORA will seek comments from members on this important issue to the used oil industry. A committee has been formed by NORA to review comments from members and provide strategy options to the Board of Directors.

George Faison from EPA will be at the NORA Mid-Year Meeting on June 21st to discuss this issue and answer questions from members. NORA will use the meeting to further understand the proposed rule and develop the industry's position.

Make sure you attend the 2010 NORA Mid-Year Meeting. Click here for details. Over 100 industry leaders will be in attendance discussing this issue and many others.

3-Jun-10 11:20 AM

NORA: PCB issue added to Mid-Year Meeting Program - Register today

Scott Parker — Tue, 25 May 2010 12:48:22 GMT

(NOTE: The deadline for hotel reservations is this Friday. The hotel is 70% sold out. Click here for details and call 800-546-7866 to make your reservation.)

New Issue for NORA Event: PCBs - The Return of a Toxic Threat?

Although the production of PCBs were banned by federal law (TSCA) more than 40 years ago, they keep coming back. Odorless, colorless and hard to detect, PCBs have shown up with inexplicable frequency in recent years. NORA has learned about numerous PCB incidents in which the collector/recycler has had his trucks, equipment and/or tanks contaminated by PCBs from generators whose used oil contained high quantities of PCBs.

At NORA's Conference in Washington, D.C. we will examine this major problem. Among the questions presented:

Are there any reliable assurances that generators can provide regarding the absence of PCBs in used oil?
Does the collector/recycler have to test for PCBs before the load of used oil is collected?
What is EPA doing, if anything, about finding the source of PCBs?
Is EPA prosecuting used oil collectors and recyclers and ignoring the generators of PCBs?
Which generators are most likely to be the source of PCBs?
What are the best procedures for avoiding widespread PCB contamination of a processor's trucks and facilities?
What are the required procedures under EPA's TSCA regulations for decontamination of trucks, equipment and tanks?

Although there is no "magic bullet" solution to the PCB problem, NORA will present a comprehensive examination of this issue along with the best advice currently available.

A list of pre-registered attendees will be sent later this week.

Click here to register, a timeline and hotel information. NOTE: The hotel is now 70% sold out. Register today.

25-May-10 8:48 AM

NORA Participates in US SBA Meeting Addressing Proposed EPA Rule

Scott Parker — Mon, 24 May 2010 12:02:51 GMT

NORA Participates in U.S. Small Business Administration Meeting Addressing Proposed EPA Rule

On May19th, NORA participated in a roundtable meeting of the US Small Business Administration Office of Advocacy regarding EPA's proposed rule on the Definition of Solid Wastes Burned in Incinerators.

Approximately 25 trade association participated including NORA, National Asphalt Pavers Association, National Automotive Dealers Association, Portland Cement Association, American Forest & Paper Association, and many more.

NORA shared with the group its positions on the the proposed rule. Here is some of the new information that came out of the meeting:

The proposed rule was expected to be published in the Federal Register last week (NORA has not confirmed that it has been published yet). Once it is published, NORA and its members will have 45 days to comment.
According to the presenter, some of the criteria in the Solid Waste rule are more stringent than HazWaste rules.
The group as a whole thought that the likelihood of the alternative approach (where virtually all on-spec used oil is a solid waste) was less likely, but that a solid effort needs to be put forth to defeat it.

The NORA Executive Committee is establishing a committee to review comments from members and to help develop potential policy choices for the Board of Directors to consider.

The comment period deadline on this rule will be several weeks after the NORA Mid-Year Meeting. Make sure you make plans to attend 2010 NORA Mid-Year Meeting.

A list of pre-registered attendees will be sent later this week.

Click here to register, a timeline and hotel information. NOTE: The hotel is 60% sold out. Register today.

24-May-10 8:02 AM

NORA: EPA Official to address Proposed Rule at Mid-Year Meeting - participate in Q & A

Scott Parker — Fri, 07 May 2010 12:07:32 GMT

EPA Official will address Proposed Solid Waste Rule at the 2010 NORA Mid-Year Meeting

NORA has arranged for EPA Official George Faison to attend the 2010 NORA Mid-Year Meeting. He will provide the lunch presentation (on June 21) regarding EPA's Proposed Rule titled "Identification of Non-Hazardous Secondary Materials that are Solid Waste." Faison will also answer questions of attendees.

The 2010 NORA Mid-Year Meeting will be held June 20-22, 2010. To register for this event, click here. To reserve your room within the NORA block (just $179/night), call the Hotel Monaco Alexandria at 800-546-7866. Attendees should plan on arriving on the afternoon of June 20 and departing late on the afternoon of June 22.

Here is what we know now:

EPA has provided a "Federal Register Notice - Pre-Publication" version of their "Identification of Non-Hazardous Materials That Are Solid Waste". To open this document, click here.
It is important to note that this has not appeared in the Federal Register yet, so this copy is "unofficial".
Once it appears in the Federal Register, NORA and its members will have 45 days to comment. This comment deadline will likely be AFTER the NORA Mid-Year meeting. Attendees at the Mid-Year meeting will assist in finalizing NORA's comments.
In the proposed rule, EPA has two primary sections related to Used Oil - A "Proposed Approach" and an "Alternative Approach".
Starting on page 77, you can read about EPA's "Proposed Approach" which states that:

On-spec used oil will not be classified as a solid waste and will continue to be regulated by Part 279 and will continue to be allowed to be combusted in facilities that meet Section 112 of the Clean Air Act, such as asphalt plants;
Off-spec used oil will be classified as a solid waste and will now need to meet Section 129 of the Clean Air Act or be blended to meet on-spec rules.
The space heater exemption will be eliminated if the space heater burns off-spec used oil.

Starting on page 154, you can read about EPA's "Alternative Approach" which would declare virtually all used oil to be a solid waste. It could be combusted in facilities that meet Section 129 of the Clean Air Act.

What is NORA doing now:

Researching all angles on this issue and providing regular communications to members.
Securing an EPA speaker on the topic for the Mid-Year Meeting.
Coordinating with related associations that may be affected by this proposed rule. Currently, NORA is reaching out to the National Asphalt Pavers Association, the American Petroleum Institute, the Portland Cement Association and many others.
Once the proposed rule is published in the Federal Register, we will officially begin to request input from all members. NORA will develop comments for the EPA that the association will submit. In addition, NORA will develop a template for members to use to assist in preparing their own comments.

What should YOU be doing now:

Read the appropriate sections of the Proposed Rule.
Provide your views on the issue to NORA.
Attend the NORA Mid-Year Meeting to learn about this issue and help NORA finalize the association position.

Thank you for being a member of NORA. We will continue to keep you updated. Let me know if you have any questions.

Scott D. Parker, NORA

sparker@noranews.org

703-753-4277

7-May-10 8:07 AM

NORA News Alert: EPA "Alternative Approach" Would Classify Virtually All Used Oil as a Solid Waste

Scott Parker — Wed, 05 May 2010 20:10:54 GMT

EPA "Alternative Approach" in Proposed Solid Waste Rule Would Classify Virtually All Used Oil as a Solid Waste

In addition to its formal proposal, EPA has put forward an “alternative approach” which, if adopted, would cause major changes in the way used oil is managed in the United States. Simply stated, the “alternative approach” would classify virtually all used oil as a solid waste and require burners of used oil fuel to meet stringent section 129 standards. Currently, most used oil fuel burners, such as hot mix asphalt plants, comply with section 112 standards. To read the alternative approach, visit http://www.epa.gov/wastes/nonhaz/pdfs/pre-pub-rule.pdf and go to page 154.

Please note that this rule has still not been published in the Federal Register. NORA will alert you when it is published. After it is published, NORA and its members will have 45 days to comment on it. By Court Order, this rule needs to be finalized by December 16, 2010.

If it is published after Friday, the comment period will fall right after the NORA Mid-Year Meeting in DC. Please click here now to register for the NORA Mid-Year Meeting and book your hotel room.

The “alternative approach” raises numerous questions such as:

Would burners that currently purchase used oil fuel be willing to incur the major expenses involved in converting to section 129 standards in order to be able to burn used oil fuel in the future?
Would burners that currently purchase used oil fuel find it more convenient and less costly to purchase virgin fuels such as natural gas or virgin petroleum fuels?
If most used oil burners were unable or unwilling to convert to section 129 standards, what changes would occur in the present system of collecting used oil from generators?
If most used oil burners were unable or unwilling to convert to section 129 standards, would there be sufficient demand from re-refiners to maintain the current used oil collection system?
If the use of used oil fuel were to be significantly curtailed, would the demand for used oil by re-refiners and the remaining burners of used oil fuel be sufficient to maintain the prices paid to generators? Alternatively, would generators be compelled to pay for the collection of their used oil?
If generators had to pay for used oil collection services, would there be a significant drop in the amount of used oil collected?
If generators had to pay for used oil collection services, would there be a significant decline in DIY collection projects and services?
If the current used oil collection system is significantly diminished, how will used oil be managed and disposed of?
What realistic scenarios exist for the proper collection and management of used oil if the “alternative approach” is adopted?
How much used oil would be properly collected and managed under such scenarios?

Although the “alternative approach,” is not the option being proposed by EPA, it has considerable support among “environmental justice” advocates. It also has sufficient credibility with Agency officials for it to be put forward as a serious regulatory option. Accordingly, it would be helpful to NORA as we prepare our comments to EPA for NORA members to consider the questions set forth above and provide your thoughts on the likely answers to these questions.

If you have questions, let me know. We will continue to keep you updated on this important issue.

Scott D. Parker, NORA

sparker@noranews.org

703-753-4277

5-May-10 4:10 PM

NORA: Save the Date - NORA Conference Dates and Location Announced

Scott Parker — Mon, 03 May 2010 15:42:26 GMT

Register now for the: NORA 2010 Mid-Year Meeting, June 20-22, Washington, DC - click here for agenda, hotel info and registration form (NORA Room block at hotel is 23% sold - act now!)

Hello [firstname],

Save the Date: NORA Announces 2010 Conference Dates and Location

The 2010 NORA Annual Recycling Conference & Trade Show will be held November 10-13, 2010. The event will be held at the Fairmont Scottsdale in Scottsdale, Arizona.

The NORA Conference attracts 300 - 400 liquid recycling leaders from around the US and the world. Attendees will explore the most important issues facing the industry. In addition, the trade show is expected to have up to 40 exhibitors displaying the best products and services available for your business.

NORA will release registration, hotel and exhibiting information in the next few weeks. Make sure to clear your calendar to attend this incredible event.

The NORA Annual Recycling Conference and Trade Show is the liquid recycling industry's premier networking and education event.

3-May-10 11:42 AM

NORA News Alert: EPA Releases Proposed Rules Affecting Used Oil Industry

Scott Parker — Fri, 30 Apr 2010 15:22:35 GMT

EPA Releases Proposed Rules Affecting Used Oil Recycling Industry: Quick analysis

Today, EPA released proposed rules regarding Emissions Standards for Boilers and Process Heaters and Commercial / Industrial Solid Waste Incinerators. Details can be found at http://www.epa.gov/airquality/combustion/

It will be published in the Federal Register within the next few weeks. Once it is published, NORA will have 45 days to develop its strategy and issue comments. IT IS EXTREMELY IMPORTANT THAT YOU ATTEND THE NORA MID-YEAR MEETING to help your industry respond appropriately to this issue: Register now!

Here is NORA's quick assessment:

1. On-spec used oil will not be classified as a solid waste and will continue to be regulated by Part 279.

2. Off-spec used oil will be classified as a solid waste and will have to meet stringent standards of Section 129 of the Clean Air Act.

3. The space heater exemption will be eliminated if the space heater burns off-spec used oil.

Here is relevant information from EPA (Federal Register - unofficial pre-publication version):

d. Used Oil. As indicated in the ANPRM, we consider off-specification (or “off-spec”) used oil that is collected from repair shops to have been discarded. Used oil that meets the on- specification (or “on-spec”) levels and properties of 40 CFR 279.11 is considered be a legitimate non-waste fuel product. We requested comment on whether off-spec used oil managed pursuant to the 40 CFR part 279 used oil management standards and which is burned for energy recovery in certain types of combustion devices should be considered a legitimate non-waste fuel.

Comments:

Most commenters believe that off-spec (and on-spec) used oil should not be classified as a solid waste. Various reasons were provided in support. Specifically, one commenter reasoned that off-spec used oil should not be treated as a solid waste if it has been delivered to a legitimate recycler for processing. Designation as a solid waste would lead to costly burning in hazardous waste incinerators, burning in uncontrolled space heaters, and more undesirable disposal methods. Many commenters also referred to Congress’ intent to manage used oil differently and EPA’s regulatory structure for the management of used oil as evidence that used oil should not be classified as a solid waste. They added that used oil is typically neither disposed of, thrown away, nor abandoned, but is collected and contained. Used oil is a valuable product that is subject to EPA’s recycling presumption. Btu content is not necessarily lower than on-spec used oil or virgin fuel, and contaminants, such as water, flashpoint, and metals can be effectively addressed. In a similar, but slightly different view, a number of commenters argued that on-spec and off-spec used oil should be included in the list of traditional fuels. Since neither is discarded, the presumption is that it is recycled. Only one commenter thought that off-spec used oil should continue to be considered a solid waste within the RCRA framework.

EPA’s Response:

We agree with the commenters who said that on-spec used oil should not be classified as a solid waste. Based upon how we define traditional fuels (i.e. fuels that have been historically managed as valuable fuel products rather than being managed as waste materials), we believe that on-spec used oil should be considered a traditional fuel. In accordance with 40 CFR part 279, once used oil is determined to be on-spec, it is no longer regulated under the used oil management standards. Used oil that has been determined to be on-spec has verified that it contains contaminants at levels below the maximum concentration limits established in the standards, such that the emissions resulting from the burning of on-spec used oil will not pose an increased threat to human health or the environment than the emissions resulting from the burning of virgin oil or diesel. This is because the contaminants of concern (i.e., those for which maximum concentration levels have been set) present in on-spec used oil are either at the same concentration or a lower concentration than virgin refined fuel oil.

This approach is supported by Safe Food and Fertilizer v. EPA, 350 F.3d 1263 (D.C. Cir. 2003). The decision upheld an EPA rule that excluded from the definition of solid waste certain recycled materials used to make zinc fertilizers (and the fertilizers themselves) as long as they were not speculatively accumulated, met certain handling, storage and reporting conditions, and were “identical” to fertilizers made from raw materials, i.e., they had concentration levels for certain chemicals that fall below specified thresholds. 350 F.3d at 1265. We believe on-spec used oil satisfies these criteria.

In regard to off-spec used oil, we disagree that it should not be classified as a solid waste. The used oil regulations are structured such that off-spec used oil is managed within the constraints of the used oil management standards until it is processed into on-spec used oil or it is properly disposed of. It may only be burned in specific types of combustion devices.36 Although off-spec used oil may be managed within the control of the generator, it contains contaminants at levels that are not comparable to traditional fuels, and thus would not be considered a legitimate non-waste fuel per the legitimacy criteria. Therefore, today’s proposed rule considers off-spec used oil as a solid waste subject to the CAA section 129 requirements, as wells as state, and local requirements, unless it is processed to meet the on-spec used oil limits specified in 40 CFR 279.11.

It also should be noted that off-spec used oil may be burned in used oil-fired space heaters pursuant to 40 CFR part 279, provided: 1) the heater burns only used oil that the owner or operator generates or used oil received from household do-it-yourself used oil generators; 2) the heater is designed to have a maximum capacity of not more than 0.5 million Btu per hour; and 3) the combustion gases from the heater are vented to the ambient air. The RCRA used oil regulations base this provision on a finding that uncontrolled emissions from these sources do not pose a significant threat to human health and the environment. However, consistent with our determination that off-spec used oil be considered a solid waste when burned as a fuel, we believe that off-spec used oil managed within the control of the generator would not qualify for the generator controlled exclusion when burned in a used oil fired-space heater, since contaminant levels are not comparable to traditional fuels. Therefore, we are proposing that off- spec used oil combusted at a unit that is within the control of the generator would be solid waste. We request comment on this approach, as well as any supporting information.

30-Apr-10 11:22 AM

NORA: Top Attractions (most FREE) for Mid-Year meeting attendees in DC

Scott Parker — Fri, 23 Apr 2010 11:17:57 GMT

Hello [firstname],

The 2010 NORA Mid-Year Meeting will be held June 20-22 in Washington, DC.

NORA has negotiated an amazing room rate of just $179/night at the Hotel Monaco in Old Town Alexandria. The hotel offers free shuttle service to the King Street Metro which can easily (and inexpensively) get you all over DC.

The NORA room rate may be available 3 days before/after the event. Call 800-546-7866 to reserve your room before they sell out. If you are NOT extending your stay, plan on arriving by Sunday evening (for the always popular XL Insurance Opening Reception, 6pm - 8pm) and departing Tuesday afternoon. Click here for a registration form and a tentative timeline.

Washington, DC is a very popular destination at this time of year. DC is packed with history and tradition. Many of the unique opportunities to explore DC are free. Here are few examples:

Washington DC Top Attractions for Visitors

U.S. Capitol – NORA staff can assist you in setting up a visit to your Congressman’s office. Please contact sparker@noranews.org to arrange a visit with your Congressional office. Please include your home and office zip codes so that we may assist in arranging the meeting. If you would like to visit with your Congressional office in DC, make sure you schedule your departure for late afternoon on Wednesday, June 23^rd.
The White House – Free public tours offered through Congressional offices.
http://www.whitehouse.gov/about/tours-and-events
The Supreme Court – Learn about the most significant judicial decisions in our nation’s history and listen to live oral arguments when Court is in session.
http://www.supremecourt.gov/visiting/visiting.aspx
Washington Nationals baseball – Walk less than 5 minutes from the Hotel Monaco to a water taxi which will take you directly to Nationals’ Park, home to Washington Nationals baseball. The Nats have home games on Sunday, June 20 v. Chicago White Sox; Monday, June 21, Tuesday June 22 and Wednesday June 23 v. Kansas City Royals.
http://washington.nationals.mlb.com/index.jsp?c_id=was
http://www.potomacriverboatco.com/baseball-boat.php
Washington Monument – Shaped like an Egyptian obelisk and standing 555 feet tall, this is one of the oldest attractions in Washington D.C. and is dedicated to America’s first President. Free tickets are available.
http://www.nps.gov/wamo/index.htm
Jefferson Memorial – A tribute to the primary author of the Declaration of Independence and the country’s third President.
http://www.nps.gov/thje/
Lincoln Memorial – A tribute to our country’s 16th President, who led during the Civil War. His second Inaugural Address and his Gettysburg Address are engraved on the walls. The memorial is featured on the back of a penny.
http://www.nps.gov/linc/index.htm
Vietnam Veterans Memorial – A tribute to all the lives lost in this war; the names of American soldiers who died in Vietnam are engraved on this memorial.
http://www.nps.gov/vive/index.htm
The Pentagon – Free walking tours feature the work of the Department of Defense, military history and information about all branches of service.
http://pentagon.afis.osd.mil/tours.html
Smithsonian Air and Space Museum – Home to the largest collection of air and space artifacts including the Wright Brothers’ first airplane and the space suit that Neil Armstrong wore during the historic walk on the moon. Admission is free.
http://www.nasm.si.edu/
Smithsonian American History Museum - Recently reopened after a two-year project to revitalize the museum. Exhibits range from national treasures in American history such as the flag to which Francis Scott Key wrote “The Star Spangled Banner” to Dorothy’s ruby slippers and Indiana Jones’ whip. Admission is free.
http://americanhistory.si.edu/
Smithsonian Natural History Museum – Featured in “Night at the Museum: Battle of the Smithsonian”. Exhibits include dinosaur fossils, gems including the Hope Diamond and an insect zoo. Admission is free.
http://www.mnh.si.edu/
National Gallery of Art – An impressive collection featuring western painting, sculpture and art dating from the Middle Ages to the present day. Admission is free.
http://www.nga.gov/
Arlington National Cemetery – A final resting place for American soldiers. The Tomb of the Unknown Soldiers as well as President John F. Kennedy’s grave are located here.
http://www.arlingtoncemetery.org/
The National Archives - The Rotunda of the National Archives Building in downtown Washington, DC, displays the Constitution, the Bill of Rights, and the Declaration of Independence. As seen in the movie “National Treasure”. Admission is free.
http://www.archives.gov/dc-metro/washington/
The National Zoo - A 163-acre zoological park set in the heart of Washington, D.C., home to 2,000 individual animals of nearly 400 different species. Some of its best known residents include giant pandas Tian Tian and Mei Xiang. Admission is free.
http://nationalzoo.si.edu/
The Kennedy Center for the Performing Arts – The nation’s busiest performing arts center, also a living memorial to President John F. Kennedy. Free tours are offered as well as free nightly performances on the Millennium Stage.
http://www.kennedy-center.org/
Holocaust Museum – Museum created as a living memorial to the Holocaust through hundreds of photographs, diaries, survivor testimonials and videos. Admission is free.
http://www.ushmm.org/

23-Apr-10 7:17 AM

NORA News Alert: Judge Extends EPA Deadline for Proposed Rule that may affect members

Scott Parker — Wed, 21 Apr 2010 16:29:25 GMT

To learn more about this important issue, register now for the: NORA 2010 Mid-Year Meeting, June 20-22, Washington, DC - click here for agenda, hotel info and registration form

Deadline for EPA Proposed Rule Extended to April 29th: May Affect NORA Members

NORA has just learned that US District Court Judge Paul Friedman has extended the deadline until April 29, 2010 for EPA to issue a proposed rule for emission standards for non-hazardous waste fuel.

The details from this proposed rule are not known at this time. Industry experts have predicted that this proposed rule may have a drastic impact on the off-spec used oil market, and possibly the on-spec used oil market. Even if the rule only addresses off-spec used oil, it may indirectly impact NORA members who market on-spec used oil because of changes to permitting requirements.

The deadline is court mandated from the case Sierra Club v. US EPA. The proposed rule is regarding standards for Industrial, Commercial and Institutional Boilers located at area and major sources of hazardous air pollutants under Section 112 and Commercial and Industrial Solid Waste Incinerators (CISWI) under Section 129 of the Clean Air Act.

According to reports, EPA plans to issue a definition of non-hazardous waste under the Resource Conservation and Recovery Act (RCRA), which will have an impact on the boiler and CISWI rules. While there is no court-mandated schedule for the RCRA definition, the agency plans to issue that proposal along with the boiler and CISWI proposals. The deadline for the final rules has not been extended and remains December 16, 2010.

Once the proposed rule is released, NORA will distribute it to all members and will provide an analysis of the rule by NORA's experts.

To learn more about this important issue, register now for the: NORA 2010 Mid-Year Meeting, June 20-22, Washington, DC -click here for agenda, hotel info and registration form

21-Apr-10 12:29 PM