Heed these tips to simultaneously befriend your budget and the environment.
By Ken Bannister, MEch Eng (UK), CMRP, MLE, Contributing Editor
There was a time when the terms “used oil“ and “waste oil” meant the same thing and could be used interchangeably. Not anymore. Federal, state, and local environmental regulations have effectively redefined both terms as distinct oil states that must be dealt with in very different ways. Because legislation differs among authorities and jurisdictions, it’s the responsibility of plant owners/operators to contact appropriate authorities for clarification on regulations under local law regarding the definition, management, and disposal of the used and waste oils at their sites.
Identifying ‘used’ oil
Used oil is generally defined as a product refined from crude oil or any synthetic oil that has been used and, as a result of such use, is contaminated and unsuitable for its original purpose due to the presence of impurities (water or dirt) or the loss of original properties (through loss of additives).
Like virgin stock oils, used oil should be thought of as a resource that can be reprocessed in situ with an industrial filter cart to clean and polish the oil while it’s in the machine reservoir. Or, it can be shipped to an oil recycler where it will be treated using settling, dehydration, filtration, coagulation, and centrifugation to remove contaminants and, if needed, refortified with its required additive package and placed back into service—all at a fraction of the cost of new oil, with no disposal management and associated fees.
Alternatively, used oil can be re-refined into lubricant or fuel oil products that can legally be sold as new oil. Re-refined products must be processed to meet the same stringent requirements and standards set for their virgin-oil counterparts. Once the re-refining is completed, the products are considered brand new oils.
Less expensive to manufacture and purchase, re-refined products conserve virgin-oil stocks—10 barrels of crude are conserved for every barrel of re-refined new oil made from used oil—and minimize the negative environmental impact of oil disposal.
Typical used-oil candidates for re-refining include:
• compressor oil
• electrical insulating oil (except that likely to contain PCBs)
• crankcase (engine) oil
• gear oil
• hydraulic oil (non-synthetic)
• industrial process oil
• neat (undiluted) metalworking fluids and oils
• refrigeration oil
• transfer oil
• transformer oil
• transmission oil
• turbine oil.
In some jurisdictions, used oil is allowed as a fuel oil and can be burned for heat.
Although used oil is generally considered a commodity, in a handful of states it is viewed as a hazardous material and, as such, must be treated as hazardous waste when stored for disposal. Plants must check with their local authorities in this regard.
Identifying ‘waste oil’
Waste oil differs from used oil in that it reflects new oil that has become contaminated and, consequently, is deemed no longer useful for service. In the view of many jurisdictions, such oil is a hazardous waste. Used oil, cross-contaminated with chlorinated products or other chemical products, must be treated as a hazardous liquid and disposed of accordingly. Once again, it’s imperative for facility personnel to check with their local authorities to understand the legislative definitions and requirements.
Collecting used and waste oil on site is a natural occurrence in any industrial plant and allowable in all jurisdictions. There are, however, regulations regarding its labelling, storage, spillage, and disposal.
The photo above reflects a typical outdoor storage area for the collection of used and waste oils in a plant. Although it shows a designated area, it exposes a very poor—and expensive—oil-management approach that contravenes most of today’s regulations in the following ways:
Used- or waste-oil tanks must be clearly labelled and accessible.
The tanks in the photo are grated pits that would be classified as confined spaces and not allowed in many jurisdictions. Only one of these two restricted-access pit tanks is labelled as “Waste Oil,” a fact that’s partially obscured by the barrels.
Given the proximity of the two pits to each other, poor access to the rear one, and their uncontrolled exposure to outside elements, most regulatory agencies would probably classify oil pumped from both of those tanks as hazardous waste, requiring costly disposal procedures.
• Decommission the pits.
• Install two above-ground steel tanks in accordance with regulations, designating each separately for used oil and waste oil. For correct tank sizing, work with your oil-disposal company to ascertain its minimum and maximum haulage capability.
• Clearly label each tank in accordance with local regulations.
• Move tanks into a controlled indoor space or cover the area to protect from outside elements.
• All tanks are to be bunded (placing the tank inside a leak proof bermed concrete, asphalt, or steel/plastic catch-basin control area. The bund must equal or exceed the volume of the largest tank in that bunded area.
• Padlock tanks shut when not in use.
Dedicated oil-transfer containers must be used to control cross-contamination.
In the photo example the company has a variety of different-sized open pails containing non-descript oils and what appears to be a white chemical product. Once again, all of those fluids are exposed to the elements and to each another. That automatically makes all of them hazardous waste. The only way to be sure used oil does not become contaminated with hazardous waste is to never mix it with anything else and store used oil separately from all solvents, chemicals, and other incompatible products.
• List all oil and non-oil products used in the plant and work with your oil-disposal partner to decide which products are to be treated as recyclable used oil, waste oil, and hazardous materials (chemicals and non-oils).
• Use closed, dedicated containers for used oil, waste oils, and other products stored in the same area.
• Log any bulk transfer of oils into the tanks.
• Record all products being held in the area on a manifest and log their release to the disposal company.
• Retain all records in a accordance with the company’s record-retention schedule.
Spill controls are mandatory.
Although the photo above also shows evidence of a contained spill around the oil pallet, the contaminated spill material hasn’t been removed and is itself an uncontained, contaminated oil product.
In accordance with most safety legislation, every oil-storage facility will generally be required to have and keep the following information and equipment up to date:
• spill contingency plan and procedures
• spill-control equipment
• fire plan
• emergency-evacuation plan.
If a site’s oil-storage building is indoors or in a closed area, it will require ventilation as regulated by local building codes.
The cost of doing business
Disposing of hazardous waste can be time-consuming and costly. Research local oil recyclers and hazardous-waste haulage companies to determine what they charge for their services. Some will handle both oil reclamation and disposal of hazardous waste. Such organization should be able to work with your site to set up a value-based program that adheres to all local regulations. MT
Editor’s Note: Recycling and disposing of old oil is closely associated with lubrication-consolidation efforts in a plant. This feature addresses that topic with insight from Des-Case.
Contributing editor Ken Bannister is co-author, with Heinz Bloch, of the book Practical Lubrication for Industrial Facilities, 3rd Edition (The Fairmont Press, Lilburn, GA). As managing partner and principal consultant for Engtech Industries Inc. (Innerkip, Ontario), Bannister specializes in the implementation of lubrication-effectiveness reviews to ISO 55001 standards, asset-management systems, and development of training programs. Contact him at firstname.lastname@example.org or telephone 519-469-9173.