The EPA Didn't Have to Look Long to Write This Fine

In addition to not having a written SPCC Plan, this service center had oil and antifreeze spills throughout their location. This picture doesn't show the open floor drain on the other side of the un-dyked bulk tank. A floor drain, by the way, that did not have an oil/water separator and went directly into the main sewer line.

Botton-line: the EPA made a surprise visit and found many reasons to make it a long visit writing up this owner/generator/location.

Gear Oil Looked Like Mud with Chunks of Junk

One of our industrial customers ran his business on some vintage presses. So vintage they looked, sounded and felt like they were on their last legs with servo valves and motors failing.

The first thing we did was take an oil sample from all of his presses, analalyzed them and because the reports from the labs are written in "Greek", interpreted them in plain English for the plant reliability manager.

Normally, we'd be foucsed on microscopic particle counts (which were off the charts and found significant wear metals). In this case the paticles floating around in his resevoirs were big enough to be seen by the naked eye. So big, they were actually chunks of junk. The manager saw what had been the mystery as to why he was consistently losing $25k gear pumps. Poor contamination control practices and no regular oil analysis left him blind as to what was going on inside his machines. A widow-maker just waiting to happen.

Long story short: the oil was so old, so dirty because he didn't have filters or other contamination control measures in place over the years, that we had to recommend the dump-n-fill strategy. With the new oil however, he has new filters and plans to do in-line filtration to recycle his oil and with a disciplined oil analysis program, keep tabs on the life blood of his machines, the gear oil, to adopt a "conditioned-based", not time-based. approach to keeping his oil healthy.

TELM (Total Environmental and Lubrication Management)

Total Environmental and Lubrication Management (TELM). Based on things we heard in the field from our customers and clients, Rice has bundled a single-source environmental and lubrication products and services program. Its a complete, total program that manages the environmental and lubrication needs of fleets, commercial and industrial companies as well as car dealers, quicklube operators and automotive service facilities.

Oh yeah, MyGeneration. Now I remember why we didn't put it out to bid

Can I dump oil dri and other oil absorbents in my dumpster?

Good question. We don't know. The written EPA regs are very unclear on oil absorbents. We do know that if the waste absorbed is hazardous, you can not. As far as non-hazardous used oil, grease, used antifreeze, ideally the EPA would want you to take a representative sample, perform a TCLP test on it and if the analysis proves its non-hazardous, the EPA suggests in principle it can be landfilled. As the environmental movement picks up steam and more innovation develops around reduce, reuse, recycle and rethink, invariably some smart boy or girl will figure out a way to recycle or up-cycle spent oil absorbents and keep them out of the landfills.

Fired Employee Calls EPA. MyGeneration is Ready

Universal Antifreeze: Yellow Brick Road?

Yellow antifreeze is a "universal top-off". What does this mean? If you top-off with yellow antifreeze it doesn't change the color (green, organge, red, blue, purple) of the existing antifreeze. Other benefits? You can reduce the rainbow of antifreeze colors and your inventory on hand.

MyGeneration as Fire Insurance for Superfund

Hot oil, hotter machine, unscheduled downtime on the way

A plastic injection blow mold customer had a machine going into alarm and shutting down. He couldn't make his widgets and didn't know why all the alarms were going off. We took a oil sample, had it analyzed, interpreted the results (he thought the oil analysis was "Greek") and suggested he recycle his hydraulic oil through in-line filtration, swap out his filters and the problem went away. No more alarms and a lot more widgets. Based on this experience, he started an in-line filtration program on all his other plastic injection blow mold machions. He saw his plant and equipment reliability go up, his alarms go silent and his unscheduled downtime and forced outgaes decrease. In the past would have simply dumped the oil, had it hauled offsite and purchased more oil. By recycling, he eliminated all of this. He has become another believer that "it pays to reduce, reuse, recycle and rethink."

Dump-n-Fill Strategy

Can you extend drain intervals without practicing oil analysis?

It's a roll of the dice. You can, but its risky. As the old Fram filter commercial cautioned: "You can pay me now or you can pay me later" when unscheduled downtime arrives.

Extending drain intervals without practicing a disciplined oil analysis program is potentially hazardous to your equipments health and your reliability goals. The savings on oil can vanish in an instant if you're not monitoring the condition of your oil in your asset as you try to stretch the time between scheduled oil changes..

Latest round of lubricant price increases

The barrel price of crude and additives and increasing enegry costs continue to rise at the oil companies and base stock suppliers. Like gas at the pump, chemical products, food products, lubricant increases are in the same boat.

Fleets: Reducing emissions, fuel and oil consumption

Semi-synthetics and synthetics can help your efforts to reduce emissions and fuel and oil consumption. They are engineered (i.e., cost more) from the base stocks up to additive packages to provide benefits conventional/mineral-based oils cannot. The extra money saves money in the long run with reduced emissions and lower fuel and oil consumption to meet increasingly strict compliance mandates by the EPA. Trends toward bio-fuels and other forms of alternative energy as well as manufactuers' engine specs to work with these new fuel trends will fuel the adoption of fleets transitioning from conventional oils to semi- and full-synthetic greases, gear lubes and oils.

Best: Synthetics ($$$)
Better: Semi-synthetics/syn-blends ($$)
Good: Conventional/mineral-based oils ($)

DNA as a vigorous metaphor for MyGenerations certificates of analysis

When I described our MyGeneration service to someone outside our industry she said, "That sounds just like the benefits of DNA." Not being the sharpest knife in the drawer I asked her to explain.

"Its simple. It's just like some unlucky guy in the wrong place at the wrong time getting charged with rape or some other violent crime. With DNA evidence left at the scene of the crime, if he's innocent, all he needs to do is provide his DNA and without a match, he gets a get-out-of-jail free card, an apology from the DA and he's free to go.

"If one of your customers get pulled into a Super Fund claim by the EPA, your manifest and more importalty like the DNA, your certificates of analysis, prove that his used was not hazardous, it was on-spec, non-hazardous used oil. He or she gets a get-out-of-jail free card, an apology from the EPA and they are free to go."

Not bad for someone who doesn't know anything about the EPA's RCRA "generator responsibility" and "rebuttable presumption" clauses.

Recycling your oil vs. Dump-n-Fill Strategy

Recycling pays; or in this case, saves.

There are not a few companies that see themselves saving on the cost of a disciplined oil analysis program only to have all those savings washed away when they figure their oil is bad, dump it, have it hauled away and buy new product and fill their equipment. With oil analysis, many customers and clients discover that the oil is only "dirty" from use and can be recycled, or "up-cycled", with filtration and avoid the cost of new oil and the expsense and/or exposure of having the otherwise "good" oil hauled offsite.

50/50, Pre-Mixed Antifreeze

Recycled, or "up-cycled", 50/50 antifreeze renews a renewable resource with a cost savings over the "virgin" stuff. And with the 50/50, pre-mix, its ready-to-use. Rice's also has manufacturers approval and is being sold in over 50 quicklubes currently bulking the 50/50 antifreeze product. Their customers dig the environmental bennies and feel confident with the manufacturer's approval. Our customer loves the increased margin dollars.

Outside: Cold Days & Cold Nights. Inside: Free Heat

What the heck is up with red and green and blue and purple antifreeze?

Its a nightmare. Its confusing. Its frustrating. Just a guess, but it probably started as a recurring revenue strategy by the OEM's to make sure you don't buy any other antifreeze other than theirs. Then again, they may tell you with a straight face that their engines required a custom blend and thats why they made theirs.

The EPA is coming and I need my records from 2 years ago

Last week a customer called and said the EPA was coming in to audit his records the next morning and he needed all his records going back 18 months (why only 18 months I still don't know). I reminded him that all of his records and chain of custody documentation where all online in his secure MyGeneration portal site. I helped him logon and he said he felt much better once he saw what he hadn't had to deal with for a very long time: managing all the paperwork associated with his waste streams that are hauled offsite.

He called the next day and said the EPA was very impressed with his record-keeping and didn't stay long.

A lubricant storage & handling best practice

Most of us for years have used old washer fluid bottles, dirty, oily funnels and even watering cans to handle and pour oils and lubricants into our engines and equipment.

A better idea, a cleaner idea and a lubricant storage & handling best practice is the iCan.

A disgruntled employee called the EPA

Yesterday I got a call from a customer of ours saying the EPA was coming in the next morning and wanted to see and audit all of their records for wastes hauled offsite. I reminded him that all of his records we online on his secure MyGeneration portal site and helped him logon.

He shared that a recently terminated employee had called the EPA and said his former company was "dumping oil in a field behind the plant".

When the EPA arrived the Plant Reliabiolity Engineer was able to show her all the records and chain of custody and certificates of analysis for all waste streams that were collected and transported offsite for recycling and/or energy recovery.

He shared that the EPA didn't stay very long after he saw his MyGeneration site and all the detailed records.

The EPA is coming first thing tomorrow morning and wants to see all my records

I got a call today from a very frantic, nervous and worried Plant Manager because he had just found out the EPA was coming in at 8:am the next day. The EPA inspector wanted to see all his records and chains of custody for any and all waste streams he had hauled offsite.

Prior to calling me, he had just gotten off the phone with one of his collectors and they were vague and cagey about who was responsibile for what (generator vs. collector) and wasn't sure he could find this particular customers records on such short notice. Then he called Rice.

I reminded him that all of his records were online at his secure MyGeneration portal site and gave him his logon credentials. The next day he called and said the EPA audit went very smoothly (no fines) because he showed the inspector his MyGeneration site. The EPA agent didn't stay long (a good thing). He then asked us to manage all his non-hazardous waste streams with MyGeneration.

Can I pour my spent antifreeze in my used oil tank?

No. Here's a link from the EPA. See Page 2, "used oil does not include . . ."

http://www.epa.state.oh.us/dhwm/pdf/Used_Oil_Generators_Guidance.pdf

"I hate the EPA. I don't give a rats ass about SPCC"

This was shared at an oil changers convention the other week by an owner of a multi-location quicklube. Unfortunately for this entrepreneur, all his locations have above ground bulk oil and used oil storage tanks in excess of 1320 gallons. This capacity thrusts him kicking and screaming into the category of businesses the EPA requires to have an SPCC Plan written and in place for each location as well as monthly inspections performed.

Can I throw my hot-drained used oil filters in the trash?

In Michigan you can not. In Ohio you can. Until it becomes "illegal" in Ohio there are those generators of used oil filters that will say "I'm going to keep on throwing them into a landfill." Others, more enlightened about sustainability, will not.

Beyond the scrap metal that can be recycled and/or used as a "sweetener" to dilute the residual content of the lower quality scrap at a steel mill, the used oil still trapped in the filter even after a hot drain can be recycled, rerefined and/or used for energy recovery in a furnace. Either way, from just one month from one used oil filter recycling center, that's 60,000+ gallons of used oil that doesn't get dumped onto the ground in a landfill. Looked at another way, that would be like dumping 1090, 55 gallon drums of oil in your own back yard.

Can I throw "green-tipped" flourescent bulbs in the trash?

At a recent environmental seminar an attendee asked this question. Another attendee said "Yes" because he heard that GE (a maker of "green-tipped" flourescent light bulbs) said it was "OK" to throw their green-tips in the dumpster. At that point, the EPA representative from the Twinsburg, Ohio office said, with not a hint of flexibility, as far as she and the EPA was concerned, "don't. If you do, I, or one of my fellow EPA representatives, will write you up." Beyond the recycling opportunities and benefits, there are still small traces of Mercury that would end up in the ground of a landfill. See "dumb and dumber"

Can I throw my flourescent light bulbs in the trash?

The EPA says "No". They can be recycled. More importantly, however, they contain Mercury which is a very bad actor for humans and the soil and water tables in a landfill.

Flourescent Bulbs as Light Sabres

Remember the movie "Clerks" where they are playing with 4 and 8 foot flourescent light bulbs and smashing them in a mock sword fight? Funny but dumb. Those white light sabres contain Mercury. May the force be with you if you cross swords with flourescent lightbulbs; it makes the dumb, dumber (even small doses of Mercury over time leads to neurotoxicity i.e. loss of memory and IQ).

What's an SPCC Plan?

SPCC stands for Spill Prevention Countermeasure and Control Plan. It doesn't apply to everyone, however; just those that have above ground storage that totals more than 1320 gallons or anyone bulk tank that is equal to or greater than 650 gallons.