It is with great sadness that Enfinite informs you that Roger Wilson passed away on November 24, 2025. 

Roger was a long-serving Board Member and served as the 18th President of the association in 2010. His easygoing nature and kind heart will be missed by all who knew him. Roger is survived by his wife of 31 years, Dana.

A visitation to celebrate Roger’s life was held on Tuesday, December 2, 2025 at Brainerd Presbyterian Church, 1624 Jenkins Rd, Chattanooga, TN 37421, at 11:00 a.m. followed by a memorial service at 12:30 p.m. More details about the service may be found here.

Enfinite was present to offer condolences on behalf of members. 

If you would like to share your thoughts with the Wilson Family, simply email Scott D. Parker at sparker@enfinite.org and ENFINITE will make sure the message is relayed to the family. 

In the episode, host Sean Grady welcomed Parker to discuss Enfinite’s transition from its former identity as NORA and the association’s mission to connect, educate, and protect the industrial liquid recycling industry. Parker outlined the organization’s history, its regulatory advocacy efforts, and key challenges facing the sector—including PFAS management and ongoing driver shortages. He also highlights how Enfinite members are adopting new technologies and strengthening their sustainability strategies to meet evolving industry demands.

“Opportunities like this podcast help amplify Enfinite’s mission and bring greater visibility to the work our members do every day,” Parker said.

The Environmental Transformation Podcast is available on all major streaming platforms and features interviews with experts across environmental management, remediation, technology, and compliance.

Listen to the episode on YouTube: https://www.youtube.com/watch?app=desktop&v=u9IIPADGrE4

About ENFINITE: The Industrial Liquid Recyclers Association:

ENFINITE: The Industrial Liquid Recyclers Association connects, educates and protects the industrial liquid recycling industry, and adjacent services. 

ENFINITE members do seemingly impossible work. We take the industrial liquid waste that burdens partner companies and transform it into usable products. Through innovative purification processes we recycle, reuse and dispose of these fluids—creating a circular economy that’s environmentally friendly. 

Born out of necessity, we responded to the EPA initial misclassification of oil as hazardous waste in 1984. And we’ve aided in the development of their used oil management standards ever since. For 40 years, we’ve refined our inventive process for sustainability that respects our planet and industry. 

Gainesville, VA (November 19, 2025)— ENFINITE: The Industrial Liquid Recyclers Association installed its new leadership during the 2026 ENFINITE Conference & Trade Show in Aventura, Florida, naming Jeff Baxter of World Oil Corp. as the 27^th president. Craig Patrick of Buck’s Oil was also appointed as Enfinite’s new vice president.

“It is an honor to serve as Enfinite’s 27th President,” Baxter said. “My focus is simple—continue developing the association and supporting its growth. More specifically, we will develop a new website that will connect members, attract new prospects, and increase event attendance; we will continue to expand membership across haz waste, field services and other industrial sectors; and we will promote the brand and culture nationally.”

Baxter takes the gavel from Carrie Reese of Reworld, who led Enfinite through its rebrand and oversaw record membership growth of more than 100 new member companies.

Baxter oversees refining, recycling, terminal, and environmental service operations for World Oil Corp., the largest recycler of used oil, waste antifreeze, and oily water in California and the Western United States. He previously held leadership roles at Vertex Energy and Safety-Kleen and has been active in ENFINITE for over 10 years, chairing the Used Oil Committee, Conference Committee and serving on the Board of Directors. He holds engineering degrees from the University of Michigan, an MBA from the University of Chicago Booth School of Business and is a licensed Professional Engineer.

Enfinite also welcomed Jorge Gonzalez of GFL Environmental Inc. and Ken Hines of Valicor to its Board of Directors. Departing board members Ken Bentfeld of Valicor and Steve Lewis of BlueTide were recognized for their service.

To learn more about Enfinite or to become a member, visit www.Enfinite.org.

Contact:

Scott D. Parker

Executive Director

ENFINITE: The Industrial Liquid Recyclers Association

sparker@enfinite.org

About ENFINITE: The Industrial Liquid Recyclers Association:

ENFINITE: The Industrial Liquid Recyclers Association connects, educates and protects the industrial liquid recycling industry, and adjacent services. 

ENFINITE members do seemingly impossible work. We take the industrial liquid waste that burdens partner companies and transform it into usable products. Through innovative purification processes we recycle, reuse and dispose of these fluids—creating a circular economy that’s environmentally friendly. 

Born out of necessity, we responded to the EPA initial misclassification of oil as hazardous waste in 1984. And we’ve aided in the development of their used oil management standards ever since. For 40 years, we’ve refined our inventive process for sustainability that respects our planet and industry. 

Gainesville, VA — November 6, 2025 — WasteLinq is now offering an exclusive discount to members of ENFINITE: The Industrial Liquid Recyclers Association that increases the overall value of membership.

The WasteLinq New Customer – Enfinite Member 10% Discount is available to new customers who sign up after November 1, 2025. The discount applies to base-level subscriptions only; additional modules and services are not included.

WasteLinq leverages AI enabled software to transform how generators, service providers, and TSDs manage waste by simplifying workflows, improving compliance, and building a more sustainable future.

“The Enfinite Affinity Program provides members with meaningful, cost-saving opportunities that strengthen their operations,” said Scott D. Parker, Executive Director of Enfinite. “Offers like the one from WasteLinq add value to being a member of Enfinite.”

“At WasteLinq, we’re helping customers every day simplify waste management processes, improve compliance, and achieve sustainability goals,” said Sean Easton, Co-Founder of WasteLinq. “We’re pleased to make this offer available to Enfinite members and support their continued success.”

This offer is part of the Enfinite Affinity Program, which connects members with exclusive savings and solutions that support business growth across the industrial liquid recycling industry. Other members that offer exclusive savings and solutions through the Enfinite Affinity Program include Dexsil, EHS Momentum, Best Working Wipes and AXA XL.
Enfinite Partnerships are collaborative connections, not endorsements, of any specific product, service or company. 

How to Redeem:
Contact WasteLinq directly and mention your Enfinite membership when creating a new account. The discount will be applied during onboarding.
• Website: www.wastelinq.com 
• Email: info@wastelinq.com

About Enfinite:
ENFINITE: The Industrial Liquid Recyclers Association connects, educates and protects the industrial liquid recycling industry, and adjacent services. 

Enfinite members do seemingly impossible work. We take the industrial liquid waste that burdens partner companies and transform it into usable products. Through innovative purification processes we recycle, reuse and dispose of these fluids—creating a circular economy that’s environmentally friendly. 

Born out of necessity, we responded to the EPA initial misclassification of oil as hazardous waste in 1984. And we’ve aided in the development of their used oil management standards ever since. For 40 years, we’ve refined our inventive process for sustainability that respects our planet and industry. 

About Wastelinq:
At WasteLinq, we don’t just build software, we live and breathe the waste industry. With years of hands-on experience managing successful service providers, transporters, and disposal facilities, we understand the challenges our customers face. That’s why we’ve created technology solutions that make waste management simple, connected, and transparent.

Gainesville, Virginia – August 18, 2025 – ENFINITE is proud to announce that Johnny “Joey” Jones, Staff Sergeant (Ret.), will deliver the keynote address at the 2025 ENFINITE Conference & Trade Show, taking place November 12–15, 2025, at the JW Marriott Miami Turnberry Resort & Spa in Aventura, Florida. Jones will speak during the conference’s general session, sharing his inspiring story of resilience, service, and leadership.

A Marine Corps veteran and former Explosive Ordnance Disposal (EOD) Technician, Jones served in both Iraq and Afghanistan before sustaining life-changing injuries in 2010, resulting in the loss of both legs above the knee. Since then, he has become a nationally recognized motivational speaker and FOX News Media contributor, inspiring audiences across the country with his message of perseverance and purpose.

“ENFINITE is thrilled to have Joey Jones kick off our annual conference and trade show,” stated Scott D. Parker, ENFINITE Executive Director. “His incredible story of overcoming adversity will provide the perfect message for the 300 industrial liquid recycling leaders in attendance who face their own challenges in collecting and recycling billions of gallons each year."

Conference registration is now open. Industry professionals are encouraged to secure their spot for this premier networking and educational event by visiting www.noranews.org/2025ConfInfo. For more information, please reach out to Scott D. Parker at sparker@enfinite.org, or call the ENFINITE headquarters at 703-753-4277. 

About ENFINITE

ENFINITE: The Industrial Liquid Recyclers Association connects, educates and protects the industrial liquid recycling industry, and adjacent services. 

ENFINITE members do seemingly impossible work. We take the industrial liquid waste that burdens partner companies and transform it into usable products. Through innovative purification processes we recycle, reuse and dispose of these fluids—creating a circular economy that’s environmentally friendly. 

Born out of necessity, we responded to the EPA initial misclassification of oil as hazardous waste in 1984. And we’ve aided in the development of their used oil management standards ever since. For 40 years, we’ve refined our inventive process for sustainability that respects our planet and industry. 

GAINESVILLE, VIRGINIA, July 18, 2025 – Used oil industry leaders from around the world will
gather on Wednesday, November 12, 2025 for International Day at the ENFINITE 2025 Conference
in Aventura, Florida, United States. The event will feature an impressive lineup of speakers and
representatives from various international organizations and companies dedicated to advancing
used oil management globally.

This is the second year in a row that ENFINITE has hosted the event. In 2024, 60 attendees
participated representing 13 number of countries.

Attendees will experience a day of insightful discussions and networking opportunities while sharing
best practices among nations. The global conversation will drive innovation and sustainability related
to used oil management.

"ENFINITE currently represents dozens of international members from six continents,” stated Scott
D. Parker, Executive Director of ENFINITE. “This event will prove to be a significant initiative in our
association’s mission to collect and responsibly recycle every drop of used oil no matter where it is
generated. ENFINITE is honored to host International Day again and I believe this will lead to
greater collaboration in the future among these global used oil leaders.”

International Day at ENFINITE 2025 is hosted by ENFINITE: The Industrial Liquid Recyclers
Association, in collaboration with Interchange Recycling (Canada), ALUPAN (Panama), and
APEL/RECOIL (Ecuador). The event will be held immediately preceding the ENFINITE Annual
Conference & Trade Show that will feature over 300 attendees and over 50 exhibitors.
Registration is now open starting as low as $150. Sponsorships to support this event are now
available.

For registration and sponsorship information, visit www.noranews.org/page/2025InternationalDay

Scott D. Parker, Executive Director
ENFINITE: The Industrial Liquid Recyclers Association
sparker@enfinite.org
www.enfinite.org
703-753-4277

GAINESVILLE, VIRGINIA, April 23, 2025 – ENFINITE: The Industrial Liquid Recyclers Association announces that Brian Recatto, President and CEO of ENFINITE member Crystal Clean, will deliver the CEO Perspective presentation at the upcoming Mid-Year Meeting, taking place June 18–20, 2025, in Chicago, Illinois.

Recatto’s presentation, titled “Looking Ahead: Forecasting the Industry’s Future,” will address the challenges and opportunities facing the industrial liquid recycling industry over the next five years.

“The top leaders in the industrial liquid recycling industry will be gathering in Chicago during the Mid-Year Meeting for networking, industry education and business development,” stated ENFINITE Executive Director Scott D. Parker. “Brian will provide valuable insight for members in the environmental and industrial services sector as they plan and prepare to succeed in the future.”

Crystal Clean operates a national network of over 120 facilities. Like many ENFINITE members, the company began with parts cleaning and used oil collection services and has since expanded to provide a broad range of environmental and industrial services. As a leader in the industry, Crystal Clean offers a valuable perspective that reflects the evolving scope of ENFINITE’s membership.

To learn more about the Mid-Year Meeting or to register, visit the ENFINITE website here.

Contact: 
Scott Parker, Executive Director
ENFINITE: The Industrial Liquid Recyclers Association
sparker@enfinite.org
703-753-4277

About ENFINITE
ENFINITE: The Industrial Liquid Recyclers Association connects, educates and protects the industrial liquid recycling industry, and adjacent services. 

ENFINITE members do seemingly impossible work. We take the industrial liquid waste that burdens partner companies and transform it into usable products. Through innovative purification processes we recycle, reuse and dispose of these fluids—creating a circular economy that’s environmentally friendly. 

Born out of necessity, we responded to the EPA initial misclassification of oil as hazardous waste in 1984. And we’ve aided in the development of their used oil management standards ever since. For 40 years, we’ve refined our inventive process for sustainability that respects our planet and industry. 

Contact Info: 
Scott D. Parker
Executive Director
sparker@enfinite.org


About ENFINITE:
ENFINITE: The Industrial Liquid Recyclers Association connects, educates and protects the industrial liquid recycling industry, and adjacent services. 

ENFINITE members do seemingly impossible work. We take the industrial liquid waste that burdens partner companies and transform it into usable products. Through innovative purification processes we recycle, reuse and dispose of these fluids—creating a circular economy that’s environmentally friendly. 

Born out of necessity, we responded to the EPA initial misclassification of oil as hazardous waste in 1984. And we’ve aided in the development of their used oil management standards ever since. For 40 years, we’ve refined our inventive process for sustainability that respects our planet and industry. 

NORA Rebrands as

ENFINITE: The Industrial Liquid Recyclers Association

GAINESVILLE, VIRGINIA, November 13, 2024 - NORA, An Association of Responsible Recyclers announces it is rebranding as ENFINITE: The Industrial Liquid Recyclers Association. The announcement is being made on November 13, 2024 during the opening of it annual conference and trade show in Coronado, California.

Forty years ago, NORA was founded by four companies as the National Oil Recyclers Association. Following several mergers and member diversification into wastewater, antifreeze, filters, solvents and more, the association was renamed NORA, An Association of Responsible Recyclers in 2001.

Over the last 23 years, the 300 members of the association have continued to diversify into collecting and recycling a wide variety of industrial liquids as well as a providing a wide array of industrial and environmental services.

More details about ENFINITE, including the release of a new rebrand video can be viewed here. 

“From the oil in your engine to the metalworking fluids for manufacturing and everything in between, industrial liquids across industries get the job done,” stated ENFINITE Executive Director Scott D. Parker. “But what happens to those to the billions of gallons of industrial liquids that no longer serve their purpose? That’s where our members come in to recycle and reuse industrial liquid waste. When left untreated, liquids can seep into the ground wreaking havoc on our planet and wasting valuable products.”

Each year ENFINITE members, collect and recycle billions of gallons of industrial liquids such as oil, fuels, wastewater, glycol, solvents and so much more that no longer serve their purpose. Members transform those products into usable products giving them new life and creating a circular economy.

“As our industry continues to evolve, it is important that the association evolves as well so that it reflects the important work our members provide to protect the environment,” stated Parker. “We are excited to share our new brand with members and industry as we prepare to serve members for the next 40 years no matter what the future holds.”

In keeping with its legacy, ENFINITE will continue to connect, educate and protect the industrial liquid recycling industry, and adjacent services.

ENFINITE will be launching a new website soon.

For more information:

Scott D. Parker, Executive Director

ENFINITE: The Industrial Liquid Recyclers Association

sparker@enfinite.org

703-753-4277

International Day at NORA 2024 will feature speakers and representatives of companies from the United States, Canada, Ecuador, Panama, Spain, Portugal, Costa Rica, Mexico and more.

Registration is now open. Sponsorships to support this event are now available.
For registration and sponsorship information, visit www.noranews.org/InternationalDay24

Insight from the organizers:
"NORA currently represents dozens of international members from six continents. This event will prove to be a significant initiative in our association’s mission to collect and responsibly recycle every drop of used oil no matter where it is generated. NORA is honored to host International Day and I believe this will lead to greater collaboration in the future among these global used oil leaders.”
- Scott D. Parker, Executive Director, NORA

"Interchange Recycling is excited to support International Day at NORA 2024. We look forward to sharing best practices and learning from other organizations from around the globe to better understand the global business perspectives within the used oil recycling industry."
- David Lawes, CEO, Interchange Recycling (Canada)

"ALUPAN Panama is a non-profit association dedicated to collecting and properly disposing of Used Lubricating Oil (ULO). International Day at NORA 2024 is particularly important for ALUPAN as a new organization in ULO management, providing valuable insights, resources, and support to navigate growth and success challenges based on the experiences of established organizations and companies."
- Simon Suarez, ALUPAN (Panama)

Scott D. Parker, Executive Director
NORA, An Association of Responsible Recyclers
sparker@noranews.org
www.noranews.org
703-753-4277

NORA’s 2022-2023 President Ken Bentfeld of Valicor Environmental Services handed the gavel to newly appointed President Carrie Reese of Circon, a Covanta Company. Ken served as President during a time when strength of leadership was tested for all trade associations during COVID. Ken remarked on Carrie's ability to lead and guide the association to further growth, and wished her well on the next two years of her tenure.

“It is an honor to serve as NORA’s 26 th President,” stated Carrie Reese. “NORA will be celebrating its 40th  anniversary in 2024. I look forward to building off the success of the past presidents and working with the Board of Directors to build a stronger and bigger association.”

Also elected was Jeff Baxter of World Oil to the Executive Vice President position. Jeff has been a member of the Board of Directors for 3 years and will serve another two in the Vice President seat. Four other seats on the Board were elected as well:

• Mitch Jefcoat, Heritage - Crystal Clean LLC
• Eric Spencer, EcoLube Recovery LLC
• John Wasilchuk, Gallagher
• Jesse Watson, Innovative Resource Management

In addition, two existing members of the Board were re-elected:

• Mills Heard, CRH Americas Materials
• Steve Lewis, Blue Tide Environmental

“The value of being a member of NORA continues to grow because of the oversight and direction of our Board of Directors,” stated Scott D. Parker, NORA Executive Director. “The past and current leadership have ensured that the association is well positioned to help protect and grow the industry.”

The newly elected board will have its first official meeting at the 2024 NORA Winter Meeting and EH&S Forum in March.

NORA also recognized the efforts of the members who were leaving the Board after years of service. They include:

• Ellie Bruce, Heritage - Crystal Clean, LLC
• Jeff Biamonte, ExxonMobil Fuels and Lubricants
• Mark Giaquinto, Noble Oil Services Inc.
• Gary Risse, Trihydro Corporation

About NORA

NORA, An Association of Responsible Recyclers represents 300 leading companies involved in responsibly recycling used oil and related materials that would otherwise negatively impact the environment. NORA members work every day to ensure that more than a billion gallons per year of used oil and related materials are collected, recycled and given another useful life. NORA has been defending and promoting the industry since 1985. For more information on NORA, visit www.noranews.org.

EPA Drops Plan to Seek Comment on Changing Part 279

Action preserves existing regulatory framework that ensures responsible recycling of billions of gallons of used oil and oily wastewater every year.

Gainesville, Virginia (November 28, 2023) – NORA was recently informed by the US Environmental Protection Agency (EPA) that they are dropping their plan to “request comment on adding language to Part 279 to address used oil and wastewater mixtures” as part of their upcoming Resource Conservation Recovery Act (RCRA) “Permitting Updates Proposed Rulemaking” project.

EPA has not added language to Part 279 (outside of corrections) in over three decades. The first portion of the Standards for the Management of Used Oil was published on November 29, 1985 and the second portion was published on September 10, 1992.

With the assistance of the US Small Business Administration Office of Advocacy, representatives from NORA met with representatives from EPA in Washington, DC on September 13th to discuss potential changes to Part 279. NORA representatives included Scott D. Parker, NORA Executive Director, Ken Bentfeld, Valicor Senior Vice President and Jack Waggener, NORA Senior Consultant. 

On November 27th, an EPA representative communicated to Parker, “We appreciated meeting with you, Jack and Ken back in September. We value the input you provided regarding used oil/wastewater management practices and potential impacts to those practices from changes to the used oil regulations, and have considered your input in relation to other information we have gathered about used oil and wastewaters. We wanted to loop back with you to let you know that, at this point, we no longer plan to discuss used oil in the upcoming Permitting Updates Proposed Rulemaking.”

“Part 279 is the regulatory foundation for used oil recyclers and oily wastewater processors. It has effectively established the framework that members have utilized for decades,” stated Parker. “We appreciate EPA thoughtfully considering the information provided by NORA in coming to this decision. NORA remains committed to defending the rights of members to responsibly collect and recycle billions of gallons of used oil, oily wastewater and related materials each year.”

At the direction of the NORA Board of Directors, NORA earlier this year formed the Part 279 Coalition since it would be critical for EPA to hear from all potentially impacted industry sectors by changing Part 279. They represent original producers of lubricants, generators of used oil and wastewater mixtures, end users of used oil derived products and other related groups. NORA thanks the following Coalition members for their assistance:

• Automotive Oil Change Association
  
• American Petroleum Institute
  
• Energy Marketers of America
  
• Independent Lubricant Manufacturers Association
  
• National Association of Manufacturers
  
• National Automobile Dealers Association
  
• Service Station Dealers of America
  
• Tire Industry Association

NORA also thanks its members for their attention and participation in this project. In particular, NORA is appreciative of its members who donated to the NORA Defense Fund to financially support this effort. Those members include:

• Chemline Products Co
  
• Clean Burn LLC
  
• Clean Water of New York, Inc.
  
• CRH Americas Materials
  
• Illinois Recovery Group, Inc.
  
• Lone Wolf Petroleum Co
  
• Noble Oil Services Inc.
  
• Thomas Oil Company
  
• Turn-Key Environmental
  
• Valley Environmental Services LLC
  
• Vertex Energy Inc
  
• Vesco Oil Corporation

About NORA

NORA, An Association of Responsible Recyclers represents nearly 300 leading companies involved in responsibly recycling used oil, oily wastewater and related materials that would otherwise negatively impact the environment. In addition, NORA members provide a wide variety of industrial and environmental services. NORA members work every day to ensure that more than a billion gallons per year of used oil and related materials are collected, recycled and given another useful life. NORA has been defending and promoting the industry since 1984.

Contact Information:

Scott D. Parker, Executive Director
NORA, An Association of Responsible Recyclers
sparker@noranews.org
www.noranews.org
703-753-4277

Gainesville, Virginia (July 26, 2023) – Dr. Elliot Eisenberg will be a speaker for the 2023 NORA Annual Conference and Trade Show, to be held November 8-11, 2023 at the JW Marriott San Antonio Hill Country Resort & Spa in San Antonio, Texas.

“NORA is thrilled to have Elliot back at this year’s convention,” stated NORA Executive Director Scott D. Parker. “His sessions are always highly rated by members and his insight is extremely useful in budgeting and planning.”

As you begin to prepare your 2024 budgets and business strategies, this session will provide you with customized economic forecast for the rest of 2023 and beyond. This session will address the overall economy, how GDP will perform, how oil prices will behave, labor market conditions, inflation, how much higher rates will get, and much more of interest to NORA members.  

Elliot is an internationally acclaimed economist and public speaker specializing in making the arcana and minutia of economics fun, relevant and educational. Oil prices. Government spending and the deficit. Supply chain conditions. Peak oil. Recession timing. The last nine months have been like nothing we have ever seen. Register now to see Elliot speak in November.
 
The 2023 NORA Annual Conference and Trade Show will attract over 250 industry leaders, over 40 exhibitors and eight industry education sessions.

Click here for information about the 2023 NORA Annual Conference.

About NORA

NORA, An Association of Responsible Recyclers represents 300 leading companies involved in responsibly recycling used oil and related materials that would otherwise negatively impact the environment. NORA members work every day to ensure that more than a billion gallons per year of used oil and related materials are collected, recycled and given another useful life. NORA has been defending and promoting the industry since 1985. For more information on NORA, visit www.noranews.org.

Gainesville, VA - NORA, An Association of Responsible Recyclers (NORA) recently joined the PFAS Regulatory Coalition (Coalition). The Coalition’s members are a broad collection of potentially affected and interested parties engaged in and/or affected by PFAS-related developments. The members include trade associations, companies, and municipal entities and representatives. 

Each year, NORA members responsibly manage well over a billion gallons of wastewater. NORA members collect wastewater and operate Centralized Waste Treatment (CWT) facilities that play a vital role in ensuring water stays clean and safe. 

Per- and poly-fluorinated alkyl substances (PFAS) were invented in the 1930s. Since the 1950s, many products commonly used by consumers and industry have been manufactured with or from PFAS. Today, more than 9,000 PFAS have been identified according to the National Institutes of Health. Since PFAS are “forever chemicals” and do not break down under typical environmental conditions, they will likely be impacting wastewater streams NORA members manage indefinitely.

The US Environmental Protection Agency (EPA) has recently noted that a few PFAS – two in particular that were phased out by 2015 (PFOS and PFOA) –  “are likely to cause cancer (i.e., liver and kidney), and that there is no dose below which either chemical is considered safe.” EPA has recently proposed a drinking water standard for PFOS and PFOA with limits of 4 parts per trillion, respectively.
The proposed drinking water standards will continue to put pressure on Publicly Owned Treatment Works (POTW) to look upstream at CWTs to limit PFAS entering POTWs and subsequently any drinking water resources (e.g., lakes and rivers) to which the POTWs discharge.

“Since NORA members collect and manage wastewater streams that likely contain various sources of PFAS, it is critical that NORA’s voice is represented while federal and state regulations are being developed,” stated NORA Executive Director Scott D. Parker. “NORA members play a critical role in treating polluted wastewater and therefore keeping our drinking water resources clean and safe. Joining the PFAS Regulatory Coalition is the perfect platform to ensure NORA’s unique role in managing PFAS materials is heard.

"The PFAS Regulatory Coalition’s focus is to ensure that PFAS are regulated based on sound science and that groups like NORA, which neither manufacture PFAS nor control the addition of PFAS into the wastewater that they treat, are recognized and understood for the environmental benefits that they provide,” according to Jeff Longsworth of Earth & Water Law and Co-Coordinator of the Coalition.  “NORA’s participation in the Coalition will help to amplify the message that NORA members provide critical wastewater treatment services to our society and they should not be punished by overly-stringent and unnecessarily-costly regulatory mandates for providing those services,” Longsworth continued.

The Coalition is focused on two priority sets of activities: (1) information-sharing related to national and precedent-setting state/local PFAS-related developments of interest to the regulated community; and (2) developing and implementing advocacy positions on PFAS-related regulatory activities at the Federal and State levels.

NORA will keep its members current on PFAS updates from the Coalition and will seek member input related to comments on proposed PFAS regulations.

PFAS REGULATORY COALITION MEMBERS
1. Airports Council International – North America 
2. American Coke and Coal Chemicals Institute 
3. American Forest & Paper Association 
4. American Fuel & Petrochemical Manufacturers 
5. American Iron and Steel Institute 
6. American Petroleum Institute 
7. Barr Engineering 
8. Brown and Caldwell 
9. Burns & McDonnell 
10. City of Lowell (MA) 
11. City of Pueblo (CO) 
12. City of Tempe (AZ) 
13. Coalition of Recyclers of Residual Organics by Practitioners of Sustainability 
14. Dane County (WI) Airport 
15. Freeport-McMoRan Inc. 
16. Gary Sanitary District (IN) 
17. GEI 
18. HDR 
19. Illinois Association of Wastewater Agencies 
20. National Oilseed Processors Association 
21. National Stone, Sand and Gravel Association 
22. NORA, An Associaiton of Responsible Recyclers
23. Toyota 
24. Trihydro 
25. Utility Solid Waste Activities Group 
26. Yucaipa Valley Water District (CA) 

by Scott D. Parker, NORA Executive Director

2023 is shaping up to be extremely active for NORA Government Affairs issues at the state level. This article documents some of the more prominent state issues that could impact NORA members.

These and other issues will be addressed in detail at the NORA Winter Meeting in New Orleans, February 22-24, 2023.

Even if a NORA member does not operate in these states, it is important to understand and address these issues directly. Based on past experience, certain state regulations can act as precedent for other states to implement. Or, it may be even be considered by the Federal government, as is occurring with the Vermont oily wastewater issue.

NORA stands ready to actively defend the rights of its members to responsibly recycle used oil and related materials.

Maine Updating Waste Oil Management Rules

The Maine Department of Environmental Protection (MDEP) adopted Chapter 860 Waste Oil Management Rules in 1985. An upcoming rulemaking will be the first major update since that time and it will impact generator, collection site, burner, marketer, transporter and facility (processor) standards. It was expected that the Rule Revision Adoption will occur in the first half of 2023. However, NORA has recently learned that MDEP is currently working on an entirely different rulemaking that will delay Waste Oil rule updates.

NORA participated in a webinar in October of 2022 that provided insight to the proposed changes. Several of the changes may be of concern to NORA Members, including:

1. Waste Oil Identification: Maine proposes for waste oil to not be identified as waste oil with “contaminants in excess of quantities normally found in waste oil”.  The state has stated that the contaminant quantities would be dependent of on-spec and off-spec for burning and if it was being refined (not burned) by the hazardous waste thresholds in Part 261.20. It is unclear if Maine has evaluated how much waste oil currently classified as used oil would now have to be managed as hazardous waste since many used oil streams may have both heavy metal and organic chemical contamination from normal use and without being mixed with a hazardous waste.
2. Waste Oil Exclusions: Maine propose that materials with no visible signs of free flowing oil be excluded from the waste oil program. Maine has not defined free flowing oil, for example sheen, 1%, etc. NORA has questions on how this will impact wastewater treatment facilities once they have recovered the oil and are meeting their own permit treatment and discharge requirements of the water.
3. Hazardous Waste Manifest & Generator EPA ID: Maine is proposing that all waste oil shipments be on a hazardous waste manifest or Maine specific Bill of Lading. Also, Maine is proposing to require all generators to register with the MDEP and obtain and EPA ID number.  Both requirements may disincentivize small generators from properly managing their material and will likely result in less used oil being properly transported and managed. 
4. Immediately Report Spills: For generators and burners, Maine would now require immediate reporting of spills of waste oil. However, there is not minimum volume or criteria for impacts to the environment.  This would be more stringent than hazardous waste spill requirements.  
5. Waste Oil Management Facility Standards: The proposal contains very aggressive closure and post closure requirements that are similar to hazardous waste facilities.

Michigan Banning On-specification Used Oil Fuel

In March 2021, an asphalt company was going through the permit process to build a plant in Michigan. During the initial permit application process, the asphalt company worked with the Michigan Department of Environment, Great Lakes and Energy (EGLE) to develop the language for the proposed permit. In it, the fuel that the permittee could burn included natural gas, propane, recycled used oil (RUO) and fuel oil #1-6.

On July 1, 2021, the proposed permit was opened to public comment. In addition, the permit was further evaluated using the US EPA’s Environmental Justice Screen. The comment period closed on September 22, 2021.

EPA’s comments to EGLE included this language regarding RUO:

“We recommend that the permittee consider not using RUO as a fuel for the proposed source. Although EGLE has established requirements that apply when combusting RUO, eliminating the use of RUO as a fuel could reduce air toxics and sulfur impacts on the local community. Should the permittee choose to combust RUO as part of this process, we recommend that the permittee or EGLE analyze the additional impact combusting RUO could have on the local community over the impact of using other fuels such as natural gas.”

On November 15, 2021, a permit was issued with 13 changes from the original based on the comments from interested parties. The first of those changes was: “The ability to burn recycled oil has been eliminated.” All other fuel sources in the proposed permit were kept.

After a phone call from NORA to EGLE and review of EGLE’s response to the comments, NORA believes that EGLE provided a misguided basis for banning RUO. Here are the relevant response to comments:

1.     RUO Not Fundamental to the Process: EGLE stated that it was keeping the natural gas, propane, and fuel oil #1-6 alternatives but was eliminating RUO because is “not fundamental to the process and operation of the facilities” and to be compliant with Rule 224 (use of best available technology). First, the rationale of banning RUO because it is “not fundamental to the process and operation of the facilities” but keeping the other alternative fuels is flawed logic. RUO, and the other alternative materials, are not fundamental to ANY asphalt plant. Second, EGLE states that eliminating RUO demonstrates compliance with Rule 224 which relates to using Best Available Control Technology for Toxics to maximize the degree of emission reduction. EGLE states that eliminating RUO reduces “potential emissions” and, as stated on a call, only related to natural gas – not the other alternative fuels. EGLE allowed the use of #6 oil with a sulfur limit at 1% (twice the limit of the other fuels) but would not allow RUO.

2.     RUO and Lead Based Paint: Responding to a comment that a higher portion of homes with lead-based paint are in the area, EGLE noted that the burning of RUO was the main source of predicted lead at the facility. It is not clear how EGLE modeled the lead emissions related to RUO. Although Part 279 allows 100 PPM of lead, it is NORA’s understanding that RFO generally has 5 – 7 PPM of lead. In addition, it is not clear if the model incorporated a bag house.

3.     RUO & PCBs: A commenter shared concerns about how Polychlorinated Biphenyls (PCBs) from the air emissions would impact a stream on the property. EGLE responded the PCBs emissions from the facility is from the burning of RUO and the use of recycled asphalt pavement (RAP). NORA has contacted EGLE to let them know there are rules on the books that already prevent PCBs from being in RUO burned at asphalt plants. EGLE responded that they have data that suggest otherwise. An EGLE representative stated that, “in the past asphalt plants blended used oil with PCBs in conjunction with hazardous waste.”

The NORA Board approved hiring attorney Chris Harris to work with Executive Director Scott D. Parker to draft a forceful Amicus Brief to the court to help correct the record. NORA is specifically replying to the misguided response to comments by EGLE related to RUO. NORA’s Amicus Brief will be filed in early 2023.

Michigan’s response to comments appear to be using On-specification Used Oil Fuel as the boogeyman and solving all sorts of issues by banning it. NORA knows that On-specification Used Oil Fuel can be used safely and we will put a tremendous effort to correct the record.

California e-Manifest Issue

In late 2022, NORA became aware of an issue that would impact twenty-three NORA member companies that provide used oil collection services in the state of California. California is requesting consolidated manifests be reported through the Federal E-manifest system. Representatives for the Federal E-manifest system have stated that their system does not apply to consolidated manifests. 

Obviously this creates a conflict. In addition, the fees for the industry to use the Federal E-manifest system for consolidated manifests are estimated to be $1.3 million/year.

The California Department of Toxic Substances Control (DTSC) recently began requesting Treatment, Storage and Disposal Facilities (TSDFs) to upload consolidated manifests to the e-Manifest system maintained by the U.S. Environmental Protection Agency (EPA). Consolidated manifests are typically used for shipments of used oil and antifreeze that are destined for recycling; these so-called “milk runs” allow for the efficient collection and tracking of these ubiquitous wastes without the administrative burdens associated with manifesting individual waste pick-ups.

However, EPA expressly states that consolidated manifests are not required to be submitted through the e-Manifest system. In its Frequently Asked Questions About e-Manifests webpage, EPA states: “Are “milk-run” or “consolidated waste” manifests subject to e-Manifest's submission and fee requirements? No. Receiving facilities need only submit manifests that apply to waste shipments for which the RCRA manifest is required under either federal or state law. “Milk run” or “consolidated waste” manifests are separate tracking documents required by states for certain state-only regulated wastes.”

NORA hosted meetings for members impacted by this. They agreed that NORA should comment on this.

On December 15, 2022, a letter from NORA was sent to DTSC that describes the issue and the concerns of NORA members. The director DTSC stated in January that her staff is reviewing our letter and will respond on her behalf.

Alaska Air Rules May Impact Burners

In January of 2023, a United States District Court Judge granted a motion for the state of Alaska to intervene in the federal Environmental Protection Agency’s (EPA) regulation of air quality in and around Fairbanks, Alaska. According to the Alaska Department of Environmental Conservation (ADEC) the nonattainment area around Fairbanks has been under a Fine Particulate State Implementation Plan, which the EPA failed to approve or disapprove by the stated deadline of June 15 of 2022.

According to the ADEC, this issue has been caused by EPA’s failure to oversee and certify wood stoves that contribute nearly 90% of the health-threatening pollution in the area.

While this issue appears targeted to wood stoves, it may impact companies that utilize used oil space heaters and possibly other burners of On-specification Used Oil Fuel.

A public comment period on proposed EPA regulations is open until March 13. NORA is reviewing the issue to determine the threat to NORA members and if comments will be submitted.

Illinois Applying Rule to the Wrong Acronym?

On January 1, 2017, the Illinois Pollution Control Board (IPCB) new emission standards and limitations for stationary source, including asphalt plants, went into effect. One part of the limitation stated that “the sulfur content of all Residual Fuel Oil used by [a] process emission source must not exceed 1,000-ppm.”

Per Illinois administrative code, Residual Fuel Oil is defined as “fuel oils of grade No. 4, 5 and 6 as specified in detailed requirements for fuel oils ASTM D-396-69 (1971).” Additionally, the US Energy Information Agency defines Residual Fuel Oil as “a general classification for the heavier oils, known as No. 5 and No. 6 fuel oils, that remain after the distillate fuel oils and lighter hydrocarbons are distilled away in refinery operations." 

While Residual Fuel Oil and Recycled Fuel Oil share the same acronym, they are different products entirely. In fact, Recycled Fuel Oil is a marketing term that is not defined in regulations. The US EPA Part 279 term for what is generally considered Recycled Fuel Oil is properly defined as “On-specification Used Oil Fuel.”

In late 2022, a member of the Illinois Asphalt Pavement Association was notified that Recycled Fuel Oil is considered Residual Fuel Oil and therefore the sulfur limit of 1000 ppm applies. NORA members have stated that On-specification Used Oil Fuel generally exceeds 1000 ppm for sulfur. NORA understands there about 20 asphalt plants using On-specification Used Oil Fuel primarily because they do not have access to natural gas.

It appears that this may be as simple as applying a regulation to the wrong RFO acronym.

NORA is working with the Illinois Asphalt Pavement Association in drafting communication to the Illinois Environmental Protection Agency to clarify that their Residual Fuel Oil sulfur limits do not apply to On-specification Used Oil Fuel based on their regulations. 

Part 279 Under the Microscope

Future Part 279 Policy Decisions & Rule Makings: EPA RCRA Office Seeks Comments

by Scott D. Parker, NORA Executive Director

On October 13, 2022, the United States Environmental Protection Agency (EPA) presented information on their Resource Conservation Recovery Act (RCRA) “Permitting Updates Proposed Rulemaking” project that will begin in 2023. As part of that proposal, EPA indicated they intend to “request comment on adding language to Part 279 to address used oil and wastewater mixtures.”

EPA has not added language to Part 279 (outside of corrections) in over three decades. The first portion of the Standards for the Management of Used Oil was published on November 29, 1985 and the second portion was published on September 10, 1992.

Part 279 is the regulatory foundation for used oil recyclers and oily wastewater processors. It has effectively established the framework that has allowed this industry to responsibly collect and recycle billions of gallons of used oil and related materials.

Potential changes to Part 279 rightfully should cause concern for NORA members. This article will explore how we got to where we are today, what is driving this new EPA action and what the potential threats are.

This issue will be discussed further at the NORA Winter Meeting in New Orleans, February 22-24, 2023.

A Brief History

After passing both Chambers of Congress, the Used Oil Recycling Act of 1980 was signed by the President of the United States on October 15, 1980.

That act stated that it was in the “national interest to recycle used oil in a manner that does not constitute a threat to public health and the environment and which conserves energy and materials”. Additionally, the act required the EPA Administrator to promulgate regulations for the oil recycling industry and that the Administrator “shall ensure that such regulations do not discourage the recovery or recycling of used oil.”

Despite this Congressional support for recycling, it was not clear what EPA would decide when it promulgated the used oil regulations. Recognizing there was a powerful effort to persuade EPA to classify used oil as a hazardous waste, a handful of companies formed the National Oil Recyclers Association (now known as NORA, An Association of Recyclers) in December of 1984 to oppose that effort.

In 1985, NORA drafted legislation at the request of Congressman Ike Skelton of Missouri. This bill was co-sponsored by 131 other members of Congress. The widespread support for Congressman Skelton’s bill influenced EPA to adopt management standards for handling used oil without being designated as a hazardous waste.

NORA’s first victory on EPA rulemaking remains its most important. Now codified at 40 CFR Part 279, the used oil management standards were delivered in two parts. The first part was promulgated on November 29, 1985 and focused on burning for energy recovery and also included the presumption that used oil was destined for recycling. The second component of the used oil management standards, promulgated on September 10, 1992, established the regulatory requirements for each of the entities in the used oil recycling system: generators, transporters, marketers, processors and burners.

In the late 1990s, NORA worked on behalf of its wastewater treatment members to persuade EPA to develop sensible treatment standards for Centralized Waste Treatment facilities (“CWTs”) that manage oily wastewater. The realistic effluent limitations advocated by NORA were incorporated into the Clean Water Act regulations, now codified at 40 CFR Part 437.

For over 30 years, the language in Part 279 and the CWT regulations have created a regulatory structure that has effectively protected the environment. One very important feature of Part 279 is that oily wastewater, generated by numerous different industries, is defined, classified and managed as used oil under Part 279 and EPA guidance documents.

EPA has consistently stated that “... wastewater that contains used oil meets the §279.1 definition of used oil and is subject to regulation under the used oil management standards.”

Oily wastewater is currently properly managed in compliance with the Used Oil Management Standards, CWTs’ stringent permits, 40 CFR Part 437 and other applicable provisions of the Clean Water Act.

Prelude: Vermont 2021

In late July 2021, NORA became aware that the Vermont Department of Environmental Conservation (VDEC) was proposing language related to used oil through their hazardous waste program reauthorization with the EPA.

VDEC proposed adding a section which would only allow oily wastewater to be managed as used oil if it has greater than 50% used oil. If the used oil was less than 50% and has any hazardous characteristics, it would be managed as hazardous waste.

If approved, Vermont would have been the only state that would implement this Draconian requirement that automatically transforms oily wastewater into hazardous waste.

NORA members took a careful look at this proposal and concluded that it was a regulation in search of a problem. On August 20, 2021, NORA submitted lengthy comments on Vermont’s proposal. NORA explained in excruciating detail why the proposal would be unworkable, extremely expensive and counterproductive.

RCRA is a “cradle to grave” hazardous waste management system and the “grave” is proper disposal. But how do you properly dispose of tremendous quantities of oily (suddenly hazardous) wastewater? NORA’s comments pointed out that:

There are few options for disposing of wastewater as a hazardous waste. In the absence of a RCRA treatment permit and compliance with applicable Clean Air Act regulations, it would be illegal to evaporate the water. Wastewater cannot easily be disposed of in a landfill. The cost of attempting to solidify the water would be prohibitively expensive and consume immense quantities of landfill space. Also, if the landfill eventually fails and becomes a Superfund site, the wastewater generators would become liable for remediating the site.

The only other almost feasible option is incineration. However, there are only a handful of commercially available hazardous waste incinerators in the United States. Even if incinerator capacity was available, transportation costs would be overwhelming.

NORA’s comments recommended that VDEC carefully evaluate incineration capacity and availability as well as the costs of incineration, storage and transportation that would have been imposed on Vermont’s oily wastewater generators.

On October 15, 2021, NORA was informed that Vermont had “pulled the used oil changes out of the proposed rules and proceeding with the rulemaking without this change at this time.”

Despite NORA’s successful effort in removing the used oil section, some of the interactions with the Vermont regulators caused a new concern. Some of the regulators, who have been trained to enforce RCRA’s hazardous waste rules, made clear that they consider Part 279 to be a “loophole”. NORA was informed by a VDEC representative that they believed the US EPA was looking into this and was considering taking action within the next two years (2022-2023). At the time, NORA was unable to verify that.

EPA May Consider Future Part 279 Policy Decisions/Rulemakings

RCRA gives EPA the authority to control hazardous waste from the "cradle-to-grave" which is overseen by the EPA Office of Resource Conservation and Recovery (ORCR).

The EPA ORCR hosted a webinar on October 13, 2022 titled “National RCRA Permitting Priorities”. The webinar focused on a variety proposed RCRA permit changes. EPA ORCR stated they are planning to also use the proposed rulemaking to discuss broader policy areas. Items under consideration in this category include those that may be discussed for the purpose of soliciting information through public comment but will not be included as proposed changes. Public comment received on those items may inform future policy decisions and/or rulemakings.

According to EPA, used oil fell in that second group. This is the language EPA included about used oil during the webinar:

“Used Oil - Request comment on adding language to part 279 to address used oil and wastewater mixtures, especially for situations when used oil is only a minute fraction; how to manage wastewater after separation; how emulsions are managed, how phase-separable mixtures are managed.”

NORA contacted EPA to understand why they were including used oil in a RCRA permitting change project. Our point of contact noted that some states had issued a concern that Part 279 was being used as a loophole for oily wastewater. While not specifically noted, it is reasonable to assume that the concerns from Vermont are driving the EPA action.

It is NORA’s understanding that EPA ORCR will be publishing their request for comments regarding Part 279 in the Federal Register in the July/August timeframe. EPA may put a prepublication version of the notice on their website before it appears in the Federal Register.

Potential Threat to NORA Members

While the specific language of what EPA will have in their request for comment is not known yet, NORA can make reasonable expectations based on Vermont’s initial language and EPA’s language from their webinar.

Our industry has defined and managed used oil and oily wastewater in a consistent and responsible manner for decades based on Part 279 and the CWT regulations.

EPA appears to be placing the regulations under a microscope and raising questions about what is and is not “used oil” from a regulatory perspective.

Similar to the Vermont initiative, EPA potentially considering future Part 279 policy decisions and rule makings seems to be a solution in search of a problem.

While some have described Part 279 to be a “loophole” that should be fixed, that does not reflect reality. Part 279 and the CWT regulations work in tandem and create a highly efficient system that responsibly recycles billions and billions of gallons of used oil and oily wastewater.

What Should NORA Members Do

First, every NORA member that recycles used oil or processes oily wastewater should have representation at the upcoming NORA Winter Meeting in New Orleans, February 22-24. Input from members in necessary for NORA to represent the interest of members before the EPA.

Second, every NORA member should be prepared to offer comments once the EPA request is finalized. NORA will provide resources to assist you in your response.

NORA will be actively monitoring and informing members about this important topic. NORA stands ready to actively defend the rights of its members to responsibly recycle used oil and related materials.

On July 1, 2022, Colorado will be the first state to enact a law that requires contractors to submit environmental impact data for asphalt mixes, cement and concrete mixes and steel. To comply, contractors will be required to have an “environmental product declaration” or EPD.

If you are like me, I had to ask what is an EPD?

EPD is an independently verified document, defined by the International Organization for Standardization (ISO) 14025 as a declaration that "quantifies environmental information on the lifecycle of a product to enable comparisons between products fulfilling the same function." 

Joseph Shacat, the National Asphalt Pavement Association (NAPA) Director of Sustainable Pavements, likened the EPD to the nutritional labels found on food products. “Instead of counting calories, you’re counting things like how much energy is involved with producing this product,” stated Shacat.

Market Driver for RFO & VTAE

The Buy Clean Colorado Act is likely the beginning of agencies at the federal, state, and local level using EPDs to identify low carbon pavement materials in the procurement and project delivery process.

The article, located here, details the asphalt industry’s effort in developing a tool for their members to generate site specific EPDs. Increasingly, agencies at the federal, state, and local level are using EPDs to identify low carbon pavement materials in the procurement and project delivery process.

Members of NORA provide the asphalt industry Recycled Fuel Oil (RFO) and Vacuum Tower Asphalt Extender (VTAE).

Since RFO and VTAE are products derived from recycled materials, they are burden free (from a Life Cycle Analysis perspective) from the upstream environmental impacts associated with the original product (drilling, extraction, refining, transportation, etc).

In conversations with Shacat, NAPA is in need to accurate data sets to properly compute their EPDs. Otherwise, they use a ‘proxy’ material. Until recently, NAPA did not have a dataset for RFO so they were using diesel as a proxy. 

NORA is reviewing the possibility of generating Environmental Product Declarations for RFO and VTAE. Because they are ‘burden free’ from upstream environmental impacts, they may have a competitive advantage over competitive products. NORA will continue to work to defend and develop markets for products derived from used oil and related materials.  

Adding Up Your Impact

How and Why to Quantify GHG Emissions Related to Asphalt Mixture Production

By Joseph Shacat, NAPA

© 2021 National Asphalt Pavement Association. Reprinted with permission.

Editor’s Notes: This article was originally published by the National Asphalt Pavement Association (NAPA). NAPA has developed a tool for their members to generate site specific Environmental Product Declarations (EPD) which independently verify and document transparent and comparable information about the life-cycle environmental impact (including carbon) of products. Increasingly, agencies at the federal, state, and local level are using EPDs to identify low carbon pavement materials in the procurement and project delivery process.
Members of NORA provide the asphalt industry Recycled Fuel Oil (RFO) and Vacuum Tower Asphalt Extender (VTAE). Since RFO and VTAE are products derived from recycled materials, they are burden free (from a Life Cycle Analysis perspective) from the upstream environmental impacts associated with the original product (drilling, extraction, refining, transportation, etc). NORA is reviewing the possibility of generating Environmental Product Declarations for RFO and VTAE so the NAPA model will have access to an accurate data set.

As the pressure to publicly disclose greenhouse gas (GHG) emissions grows, asphalt companies can get ahead by benchmarking and tracking their emissions. Calculating GHG emissions across a company’s entire operations can be a daunting task, but several tools and resources, including some designed specifically for the asphalt mix production industry, are available to help companies as they begin this journey.

Why Do Companies Calculate GHG Emissions?

In recent years, publicly traded companies have seen growing pressure from investors and other stakeholders to disclose GHG emissions. Meanwhile, the Securities and Exchange Commission is developing regulations that are expected to require climate-related disclosures, including GHG emissions. For privately held companies, which represent the majority of companies in the asphalt paving industry, pressure may come from customers rather than investors. One example of customer pressure is California Senate Bill 260, which is set to be reconsidered in 2022 and would require companies that do business in the state and have more than $1 billion in gross revenues to report GHG emissions to the California Air Resources Board.

Even if a company isn’t planning to disclose GHG emissions, there are a number of reasons to quantify and track emissions for internal purposes. Many companies use GHG emissions as a key performance indicator to track the environmental impacts of  operations; some use an internal cost of carbon to incentivize process improvements and capital expenditures that reduce GHG emissions. Quantifying GHG emissions can also help to understand the potential financial impact of carbon pricing regulations. While carbon pricing mechanisms may seem far-fetched, even the American Petroleum Institute has endorsed carbon pricing as a climate change mitigation measure, giving credence to a future in which each ton of GHG emissions has a financial cost.

The demand for corporate disclosure of GHG emissions will continue to grow as pressure ratchets up from investors, customers, government agencies, and other stakeholders. For example, Granite Construction conducted a formal sustainability materiality assessment in 2019 and identified GHG emissions as materially significant to company operations. Raven Adams, Granite’s sustainability lead, explained that developing a GHG emissions inventory helped the company prioritize emission reduction projects as part of its effort to reduce GHG emissions by 25% by 2030. "Most direct emissions come from our equipment fleet, so we will focus on reducing this by using alternative fuels and electrifying our fleet," Adams said. "Our next largest source of emissions is asphalt production, where the biggest reduction opportunities involve innovating to reduce fuel used for drying aggregate."

How to Calculate GHG Emissions

Once you’ve made the business case for quantifying GHG emissions, the next step is to select an appropriate tool or methodology. Adding to available resources from government agencies and nonprofit organizations, NAPA developed two tools specifically for asphalt mix producers to help measure and reduce GHG emissions. Each tool has its own purpose, scope, system boundaries, upstream datasets, and other considerations, so it’s important to understand the assumptions and limitations of each tool. Avoid direct comparison of the outputs from different tools without careful consideration of each tool’s inherent assumptions.

NAPA GHG Calculator

NAPA’s GHG Calculator is a free, web-based tool that provides a gate-to-gate analysis of the GHG emissions associated with asphalt mix production. The gate-to-gate scope means that it quantifies emissions directly associated with asphalt plant operations. This includes on-site fuel consumption for burners and equipment, as well as upstream emissions from the generation of purchased electricity. The upstream electricity emissions are regionalized based on the plant location to reflect the local mix of power generation that feeds the grid.

Beyond quantifying GHG emissions, features include the ability to estimate potential emission reductions from the use of warm-mix asphalt (WMA) technologies and the allowance of credits for upstream GHG emission reductions associated with the use of reclaimed asphalt pavement (RAP) and recycled asphalt shingles (RAS). More information is available in the User Guide.

Emerald Eco-Label EPD Tool

Emerald Eco-Label is NAPA’s web-based tool for developing verified plant- and product-specific cradle-to-gate Environmental Product Declarations (EPDs). The tool meets the requirements of the Product Category Rules (PCR) for Asphalt Mixtures. The cradle-to-gate scope includes upstream emissions associated with extracting and processing raw materials and transporting raw materials to the asphalt plant, as well as plant operations. EPDs provide much more information than GHG emissions, including environmental impacts such as smog forming potential, acid rain potential, ozone layer depletion, and resource use indicators.

One of the biggest benefits of the Emerald Eco-Label tool is the new Optimizer function, which helps companies understand how they can reduce the environmental impacts reported in an EPD. With the Optimizer, users can develop scenarios that evaluate the benefits of operational improvements such as energy efficiency projects. It also provides more granular data at the unit process level, which can help users identify and prioritize process improvements. The Optimizer allows users to evaluate the economic impacts of  changing fuels and reducing aggregate moisture content, providing an economic lens to assess the sustainability of process improvements.

GHG Protocol

The GHG Protocol (ghgprotocol.org) is a standardized framework and set of emission factors used for corporate GHG emissions reporting. Where NAPA’s GHG Calculator and Emerald Eco-Label tool focus exclusively on asphalt mix production, the GHG Protocol can be used by any enterprise to calculate its GHG emissions. It categorizes GHG emissions into three scopes.

U.S. EPA Center for Corporate Climate Leadership

Under this umbrella, the Environmental Protection Agency offers technical tools, guidance documents, educational materials, and resources to help companies quantify, track, and reduce GHG emissions. It covers everything from developing a GHG management program to supply chain engagement. Learn more at  epa.gov/ClimateLeadership.

NORA’s Successful in Defending 279 in New England and Beyond

NORA and its members successfully tackled a significant threat to 40 CFR Part 279 (Standards for the Management of Used Oil) that emerged late last year.

During their hazardous waste program reauthorization in 2021, the Vermont Department of Environmental Conservation (VDEC) added a section (§ 7-805(g)) which would only allow oily wastewater to be managed as used oil if it has greater than 50% used oil. If the used oil was less than 50% and has any hazardous characteristics, it would be managed as hazardous waste.

The Threat to 279

In Vermont, the proposal would have undermined the entire existing used oil regulatory frame work. If approved, Vermont would be the only state that would implement this Draconian requirement that automatically transforms oily wastewater into hazardous waste.

For NORA members in all other states, this also created a real threat for two reasons:
• Vermont could have become a precedent for other states to implement
• NORA was informed by a VDEC representative they believe the US EPA is looking into this and considering taking action within the next two years. (NORA has not yet independently confirmed this).

NORA’s Action

The Vermont proposal was a real and direct threat to NORA’s mission and its members. After consulting with NORA members for their input, NORA delivered oral comments in Vermont on August 10, 2021. On August 20, 2021,  NORA submitted formal written comments to Vermont.

NORA’s Victory

After reviewing NORA’s comments and those of members and industry partners, a representative from Vermont in October 2021 stated, “We pulled the used oil changes out of the proposed rules and proceeding with rulemaking without this change at this time.”

In December 2021, Vermont issued their “Response to Comments Hazardous Waste Regulations”. In those responses, VDEC “received comments from 14 interested parties. Most of those comments opposed the addition of proposed § 7-805(g) requiring that hazardous waste determinations be made on the aqueous component of used oil/water mixtures under certain circumstances.”

The following interested parties provided comments:

• NORA, an Association of Responsible Recyclers
• Associated General Contractors of Vermont
• Associated Industries of Vermont
• Automotive Oil Change Association
• Casella Waste Systems, Inc.
• Safety-Kleen Systems, Inc.
• Specialized Environmental Services, L.P.
• Sustainable and Renewable Products, LLC
• TAS Environmental Services, L.P.
• Vermont Fuel Dealers Association
• Vermont Vehicle & Automotive Distributors Association

Since VDEC removed the proposed § 7-805(g)) from the final proposed rule and due to the extensive nature of the comments received on that proposed regulation, the Agency decided to not provide responses to the comments of NORA or the other interested parties.

Interestingly though, VDEC “believes that subchapter 8 of the VHWMR must eventually address this matter (since it is not currently addressed under the federal Resource Conservation and Recovery Act (RCRA) 40 CFR part 279 regulations), it agrees that more extensive outreach to, and collaboration with, all interested parties is necessary to properly convey they Agency’s concerns with the current used oil regulatory framework, as well as the concerns identified by interested parties during the public comment period.”

“Members of the association came together as they always do to challenge misguided threats to 279 such as Vermont’s proposal,” stated NORA Executive Director Scott D. Parker. “NORA will continue to defend the rights of members to responsibly recycle used oil and related materials in a forceful and effective way.”

Since Vermont incorrectly believes Part 279 and the Centralized Water Treatment system does not address the “Agency’s concerns with the current used oil regulatory framework,” this incredible victory is not the end, but the beginning of a sustained effort to promote responsible recycling.

Scott D. Parker, Executive Director
NORA, An Association of Responsible Recyclers
sparker@noranews.org
703-753-4277

Thank you for the opportunity to comment on the Environmental Protection Agency’s (EPA) Interim Guidance on the Destruction and Disposal of Perfluoroalkyl and Polyfluoroalkyl (PFAS) Substances and Materials Containing Perfluoroalkyl and Polyfluoroalkyl Substances.

NORA, An Association of Responsible Recyclers is a non-profit trade organization that was founded in 1984. Each year, NORA members responsibly collect and process billions of gallons of various liquids, including used oil, wastewater, antifreeze and more. NORA represents over 300 companies in this sector.

NORA recognizes the importance of EPA’s efforts related to PFAS. The EPA interim guidance identifies needed and ongoing research and development activities related to destruction and disposal technologies, which may inform future guidance. 
NORA members have reviewed the interim guidance and have prepared the following comments. It contains principles NORA believes should be considered regarding ongoing research and potential future guidance.

Speed
While NORA understands that solid scientific research and data collection takes time, the association and its members would like to highlight the importance of the need for speed in developing future guidance. The primary reason is the importance of having the appropriate information for all stakeholders to responsibly manage PFAS and materials containing PFAS.

In addition, the longer it takes for further guidance to come from EPA, the more likely additional States will issue their own independent PFAS rules. Already, multiple states have or are moving to issue their own PFAS regulatory language – often independent of each other and with limited scientific information. This patchwork approach is challenging for many in the regulated community. Many NORA members have facilities in multiple states and accept waste streams that may come from different states.

Timely further guidance from EPA will help create a consistent manner in responsibly managing PFAS and materials containing PFAS.

Testing
NORA understands challenges in testing for PFAS and is encouraged that EPA is testing and developing PFAS testing methods for wastewater.
An EPA approved PFAS test method that is affordable and efficient is a critical first step for industry to responsibly manage PFAS and materials containing PFAS. Once an EPA approved PFAS test method is approved, industry will have the tool needed to characterize sources, evaluate the fate and transport of PFAS and monitor the destruction and disposal approaches used to manage PFAS.

Until a PFAS test method is approved by EPA, NORA encourages the EPA to keep all reasonable treatment options available for managing PFAS and materials containing PFAS.

Treatment
In the interim guidance, EPA makes clear that the identified technologies in the report have significant uncertainties related to their potential for PFAS migration to the environment. 

To the extent existing and emerging technologies are environmentally responsible, NORA encourages EPA to take an “all of the above” approach to approving treatment technologies.
One reason for this approach is that PFAS and materials containing PFAS are generated all over the country. If there are a limited number of approved treatment technologies that may not be geographically diverse, there would be significant obstacles in getting the material to the most appropriate treatment location.

Another reason for an “all of the above approach” is that there will be, in the short and long term, new treatment technologies for PFAS and materials containing PFAS. American industrial ingenuity has for centuries risen to serious challenges. NORA is confident that will be the case for PFAS. NORA members report they are already working on research and development projects in this area and many of their suppliers have been demonstrating their efforts as well. Many of these technologies will be based or have to be adjusted on further EPA guidance.

NORA members would like further EPA guidance to be ‘future-proof’ by using an approach that anticipates these emerging technologies.

Conclusion
Again, NORA appreciates the opportunity to comment on this important issue. NORA members will be part of the solution in responsibly managing PFAS and materials containing PFAS. The association is optimistic that EPA, NORA and other stakeholders will work together to develop a practical approach to this important issue.

NORA and its members look forward to working with the EPA on this initiative.

If you have any questions, please let me know.

Scott D. Parker, Executive Director 
NORA
sparker@noranews.org 
703-753-4277

NORA and its members have a tradition of being ‘responsible’. In fact, it is part of our legal name: “NORA, An Association of Responsible Recyclers”.

Prior to COVID-19, NORA members made health, safety and environmental considerations a top priority in their planning for all existing and new facilities, processes, products and services. Once COVID-19 hit, NORA members developed and implemented new best practices based on federal and local guidance to minimize the risks to their customers and employees. This ensured the essential role of collecting and recycling over a billion gallons of used oil and related materials each year continued uninterrupted.

As we continue to learn and understand about the virus, it is becoming clearer that a binary choice of a fully open or fully closed economy is not plausible. Using the appropriate risk mitigation strategies, it is possible for all of us to take the appropriate action to find a ‘new normal’.

Just as your companies forged a path for you to safely provide service to your customers and operate your facilities, NORA has been working to do the same for the upcoming Conference & Trade Show in Tucson, Arizona in November.

Under the leadership of Conference Chairman Ken Bentfeld, we have been studying the Center for Disease Control’s “Considerations for Events and Gatherings” as well as state and local rules. We have developed a series of NORA Safety Protocols, some of which are outlined on page 20 of NORA’s Liquid Recycling Magazine. The Westin La Paloma Safety Protocols are also available for review. We have other procedures that will be in place onsite that will be in full compliance with the CDC guiding principles.

If there were any year where members would benefit by gathering to network about the best path forward, interacting with leading vendors, learning from top presenters and hearing motivational messages, 2020 is that year.

Or, perhaps you are like some of our members who are feeling a sense of extreme cabin fever and are looking for a safe escape. Our event in Tucson offers that to you.

Regardless of the reason on why you are attending, we look forward to welcoming you safely and responsibly to Tucson. If you have questions about our safety protocols, please contact me directly.

June 27, 1975 – September 23, 2020

It is with great sadness that NORA reports the passing of Wayman Andrew “Andy” Pritchard, of Enterprise Oil on Wednesday, September 23, 2020. 

Andy was the CEO of Enterprise Oil, a long-time member of NORA. Because of his involvement and dedication to the industry, he was elected in 2017 by the members to serve on the Board of Directors of the association. He was re-elected to that leadership role in 2019.

He was a member of Grace Baptist Church, a devoted husband and father, and a fun-loving friend to many. Andy loved spending time with his family on their farm, watching his daughter compete in horse shows and his sons participate in sports. He was always sharing his love of life with others, including volunteering with the Mission of Hope. He loved his work family at Enterprise Waste Oil in Knoxville and the many he encountered while traveling for work. 

He recently helped get supplies donated by Grace Baptist Church members to Louisiana after the recent hurricane. Preceded in death by his mother, Margaret Dunaway Pritchard. Andy leaves behind his wife, Ginger; daughter, Tristan; sons, Ty and Evan; father, Wayman; brother, Adam; sister-in-law, Sandra; nieces, Maddie and Elizabeth; aunt Sissy Shirer. Andy brought many laughs to his friends, especially special friends Jason and Tracy Grooms. 

Andy will be missed. He was humble, joyful and always willing to help. The prayers of the entire NORA community go out to the Pritchard Family and the Enterprise Oil team.

In lieu of flowers, donations may be made to Mission of Hope, P.O. Box 51824, Knoxville, 37950 (www.missionofhope.org). Weaver Funeral Home - 5815 Western Ave. Knoxville, TN 379

The phrase “hindsight is 20/20” describes the fact that it is easy for one to be knowledgeable about an event after it has happened. Ironically, that perfectly describes the year 2020.

As business people, NORA members do not have the luxury to wait until 2020 is done to begin future planning.

Budgeting & Planning for 2021
Over the next two months, many NORA members will be developing their budgets and business plans for 2021.

Under normal circumstances, the underlying data for these projects would come from the company’s 'crystal ball' - prior year business analytics, year-over-year sales, volume analysis and future market conditions.

For most, their ‘crystal ball’ has serious cracks this year. A chaotic 2020 rocked by COVID-19 shut downs have rendered prior year data less meaningful. In addition, 2021 brings substantial uncertainty. The Presidential candidates have drastically different economic policies, regulatory plans and environmental objectives.

Industry Guidance at NORA Conference
Working with NORA’s Executive Committee and Past Presidents, we are in the process of finalizing the sessions and speakers for the 2020 NORA Conference & Trade Show that will be held November 11-14 in Tucson, Arizona. 

NORA, now more than ever, is developing content to help members plan to succeed in 2021. The event will take place less than a week after the election. Attendees to the conference will hear a variety sessions about economic and regulatory anticipation as well as an outlook for the markets for used oil and related products next year.

The list of attendees is growing every day demonstrating the value of networking with peers. The upcoming issue of NORA's Liquid Recycling magazine features an article documenting the testimonials of several members on the value they receive simply by attending NORA events. 

As we welcome you to this year’s NORA Conference, we are committed to providing members with a safe environment. Safety protocols are being developed with the latest guidance to minimize risk for NORA members. Click here for an overview of the on-site safety protocols.

I look forward to seeing you in Tucson in November.

Scott D. Parker, Executive Director
NORA, An Association of Responsible Recyclers
sparker@noranews.org
703-753-4277