Oily Water Treatment & Chain of Liability

Oily Water Treatment & Chain of Liability

Many machining fluids are an emulsion – mix of water and oil. When these fluids have reached the end of their service life they must be disposed of. To do so, the emulsion must be broken. Once the emulsion is broken the oil can be recycled. However, the water that is left over must have metals such as zinc, copper and lead must be removed to acceptable levels before it can be discharged. Lube-Tech has developed a unique proprietary process to remove metals from oily water, making the water safe to discharge into the sewer. At Lube-Tech, the industrial oil or oily water is processed in four steps:  (1) Oil removal; (2) Metals removal; (3) Oil recovery; and (4) Water discharge. 

Why Recycle?

In 1992 the EPA classified used oil as a regulated waste and issued rules regarding its proper handling. The EPA requires used oil to be “recycled” and specifically prohibits any other type of disposal. Today, a billion gallons of waste oil is collected every year and 4-Million of that is collected by Lube-Tech.

Types of Waste

The first step in waste management is profiling or classifying the waste. In general, there are three types of waste, and those wastes are further broken down by either definition or characteristic:

Non-Regulated waste – Typically no special handling or disposal requirements apply to this type of waste.  Non-regulated waste is basically anything that can be put in a trash dumpster or recycling bin – paper, office waste, break room waste, general production area trash, etc.

Regulated Waste – Specific handling requirements apply.  Regulated waste includes used oil, oily water, coolant, antifreeze, absorbent pads, floor dry, and used filters. Given record keeping practices apply; it is important to verify you are in compliance.

Hazardous Waste – When dealing with hazardous waste, exact labeling, storage, testing, manifest, permit and record keeping requirements apply, and verifying you are in compliance is a must. Formal self-audits should be performed.  any material that leaves a shop that is not specifically exempted as a regulated waste must be evaluated against six hazardous waste characteristics and be compared against the lists of chemical types and processes.  Four are of primary concern to metal working operations:

  • Ignitable – flashpoint of less than 140F;
  • Corrosive – pH of less or equal to 2.0 or greater than or equal to 12.5;
  • Toxic – Any one of 40 specific chemical types at specific level with 8 metal of particular concern
  • F-Listed Wastes– Any one of 34 specific solvent types or mixtures used in degreasing and parts cleaning.

Liability Concerns For Machine Shops

Machine shops can run into trouble when it comes to disposing of regulated waste. Regulated waste carries “cradle to grave” liability and machine shops should verify all parties that touch any waste after it leaves their site. Unfortunately, this verification can be difficult when working through brokers and out of state disposal companies.

Additionally, following a few simple rules can also save shops from headaches when it comes to waste disposal:

  • Never mix fluids unless you have been explicitly told you can
  • Place materials into dedicated container and label using standard names
  • Keep drain pans separate
  • Always be conscious of what fluids are in close proximity to each other

As a solutions-driven company, Lube-Tech partners with its clients to supply fluids, analyze fluids and dispose of them properly when they reach the end of their service life, taking liability worries away from the shop owner.