Machinery Lubrication magazine published by Noria Corporation
Issue link: http://www.e-digitaleditions.com/i/520842
56 | May- June 2015 | www.machinerylubrication.com ML (OSHA), U.S. Department of Transporta- tion (USDOT), etc. Going back to the oil drum example, imagine if the seal on that drum had held and no water was allowed to enter. The lubricant was then put into service, and the seals leaked on the pump in which the lubri- cant was placed. Due to the leaking seals, water was allowed to enter the lubricant sump and mix with the oil. Once this mixture was drained and placed into a container, it would be classifi ed as "used oil." While the end result of both of these processes was a mixture of oil and water, there is a signifi - cant difference in the requirements for each. Several plants have "used oil" being stored in drums, tanks and totes marked as "waste oil." In addition to the EPA's used oil manage- ment standards, your business may be required to comply with federal and state hazardous waste regulations if your used oil becomes contaminated by mixing it with hazardous waste or waste oil. Hazardous waste disposal is a lengthy, costly and strict regulatory process. The only way to be sure your used oil does not become contami- nated with hazardous waste is to store it separately from all solvents and chemicals and not to mix it with anything. State and local regulations are often even more stringent than the EPA guide- lines. For this reason, it is important to be familiar with your local laws and regula- tions regarding waste and used oil. There have been occurrences in which an inspector walked through a plant and assessed severe penalties and fi nes due to the mislabeling of used oil containers. The easiest way to ensure that you are in compliance and can avoid these fees and headaches is to label containers correctly. Unless it is truly waste oil, it should be labeled as "used oil." Also, be sure to keep proper records. The EPA uses 12-digit identifi cation (ID) numbers to track used oil. Transporters hauling used oil must have a valid EPA ID number, and generators, collection centers and aggregation points must use trans- porters with EPA ID numbers for shipping used oil offsite. Used oil transporters, processors, marketers and burners are required to keep records of each used oil shipment accepted for transport. These records for shipment must include: • the name and address of the generator, transporter or processor/re-refi ner that provided the used oil for transport; • the EPA identifi cation number (if appli- cable) of the generator, transporter or processor/re-refi ner who provided the used oil for transport; • the quantity of used oil accepted; and • the date of acceptance. These records are required to be kept for at least three years. It is recommended that you maintain these same records for the same period. As the ISO 55001 certifi cation becomes more prevalent, this record- keeping will be a positive step toward certifi cation. It should be noted that any used oil shipments less than 55 gallons do not need an EPA tracking number. However, special permitting may be required by state and local governments. While re-refi ners, processors, transfer facilities and burners must have secondary containment systems (e.g., oil-impervious dikes, berms, retaining walls, etc.) to miti- gate oil escaping into the environment in the event of a leak or spill, the EPA encour- ages generators to use a secondary containment system to prevent used oil from contaminating the environment. Used Oil and Filters During a root cause analysis/failure investigation, a post-mortem oil sample can contain a vast amount of information that can be very helpful in establishing the cause of failure. Simply pouring the used oil into a container is essentially just throwing away this potentially useful information. The same is true of the fi lter and the oil it contains. The fi lter has been called the "hard drive" of the lubricant system, storing all the information about the system's contamination. Frequently, once the fi lter is changed, it is placed on top of a drum to drain the oil and then thrown into a waste container. A better way is to use a fi lter cutter. Take some of the fi lter media, rinse it with kero- sene or a very light clean oil and conduct a patch test. You likely will be shocked and amazed at what you see. Based on the particles you fi nd, you can determine if wear is occurring, what specifi c part of the equipment is wearing, and the type of wear that is taking place. You can use the same approach for the oil contained in the fi lter. Both of these are excellent sources of information that are often just thrown away. Collecting data from these sources will help round out your oil analysis program. In conclusion, it is critical that used and waste oil be identifi ed and handled correctly. This can help to avoid signifi cant costs and fi nes. In most cases, the "waste oil" in a plant is in fact used oil and is not subject to the special handling that is required of true waste oil, which is consid- ered to be a hazardous material. About the Author Loren Green is a technical consultant with Noria Corporation, focusing on machinery lubrication and maintenance in support of Noria's Lubrication Program Development (LPD). He is a mechanical engineer who holds a Machine Lubrication Technician (MLT) Level I certifi cation and a Machine Lubricant Analyst (MLA) Level III certifi cation through the International Council for Machinery Lubrication (ICML). Contact Loren at lgreen@noria.com. Facts About Used Oil • The used oil from one oil change can contaminate 1 million gallons of fresh water. • It only takes one cup of used motor oil to put an oil sheen on a 1-acre pond. • The United States produces 1.3 billion gallons of waste oil each year, of which 800 million gallons are recycled. (Almost 40 percent is not being recycled). • If all the waste oil in the United States was recycled in a single year, it would save half the output of the Alaskan pipeline for the same period. • Recycled used motor oil can be re-refi ned into new oil, processed into fuel oils and used as raw materials for the petroleum industry. • One gallon of used motor oil provides the same 2.5 quarts of lubricating oil as 42 gallons of crude oil. • If all the oil from American do-it-yourself oil changers was recycled, it would be enough motor oil for more than 50 million cars a year.