From: 	<Luben.Lyn@epamail.epa.gov>

To:	"Jason Price" <jprice@indecon.com>

CC:	"Mark Ewen" <MEwen@indecon.com>

Date: 	10/21/2008 1:45 PM

Subject: 	Re: Fw: Question on Used Oil Comments

I think this document discuses the 1997 API report.

http://fossil.energy.gov/epact/used_oil_report.pdf.

Mr. Lyn D Luben

703-308-0508 (phone)

703-308-0511 (FAX)

luben.lyn@epa.gov

EPA Mail Code - 5307P

                                                                        

             "Jason Price"                                              

             <jprice@indecon.                                           

             com>                                                    To 

                                      Lyn Luben/DC/USEPA/US@EPA         

             10/21/2008 01:23                                        cc 

             PM                       "Mark Ewen" <MEwen@indecon.com>   

                                                                Subject 

                                      Re: Fw: Question on Used Oil      

                                      Comments                          

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

Hi Lyn,

Thanks for sending this along.  Sorry to make this complicated, but I

have a few follow-up questions/comments:

1.  Does Mike have a full reference for the 1997 API study that he can

provide?

2.   As Mike pointed out in a previous email, the 90 percent estimate

from the API study differs from our estimate by more than 30 percentage

points.  Rather than presenting just one value though, it may be

worthwhile to present a range of values based on the API study and the

more recent data that serve as the basis of our estimate.  This approach

would acknowledge the uncertainty inherent in the energy recovery rate,

and both ends of the estimated range would show that the majority of

used oil is burned for energy recovery.

3.  Related to (2), I wonder if our estimate and the API value differ

because they're looking at different universes of used oil.  Mike's

language states that 90 percent of COLLECTED oil is burned for energy

recovery.  If collected oil as estimated by API does not include used

oil that is improperly disposed, this would suggest that less than 90

percent of all used oil is managed through energy recovery.

Jason

>>> <Luben.Lyn@epamail.epa.gov> 10/21/2008 10:13 AM >>>

Please see attached.

Mr. Lyn D Luben

703-308-0508 (phone)

703-308-0511 (FAX)

luben.lyn@epa.gov

EPA Mail Code - 5307P

----- Forwarded by Lyn Luben/DC/USEPA/US on 10/21/2008 10:14 AM -----

             Michael

             Svizzero/DC/USEP

             A/US                                                    To

                                      Lyn Luben/DC/USEPA/US@EPA

             10/21/2008 07:31                                        cc

             AM

                                                                Subject

                                      Re: Question on Used Oil Comments

                                      (Document link: Lyn Luben)

The estimate came from a 1997 API report.  Unfortunately, I don't have a

copy of it anymore.  Of the used oil collected approximately 90% of it

is burned for energy recovery.

             Lyn

             Luben/DC/USEPA/U

             S                                                       To

                                      Michael Svizzero/DC/USEPA/US@EPA

             10/20/2008 09:57                                        cc

             AM

                                                                Subject

                                      Question on Used Oil Comments

Mike:

In regard to your comment on the used oil section of the ANPRM, what is

the source for the 90% energy recovery estimate?   Also, could you

please clarify what the 90% value is referring to, does it mean that 90%

of used oil is burned for energy recovery or that 90% of the used oil

that is beneficially used in some way is used as a fuel (rather than

being re-refined).

Thanks.

(See attached file: ANPRM FAR_used oil sections_mps edits.doc)

Mr. Lyn D Luben

703-308-0508 (phone)

703-308-0511 (FAX)

luben.lyn@epa.gov

EPA Mail Code - 5307P

