ILMA Compoundings - May 2020 - 27

to improve the environment, and the bonus is we can make
money standing on our own two feet without relying on
government subsidies."
THE COLLECTION QUESTION
When an auto manufacturer needs steel, it's made in a few
places and arrives by railcar. When an oil re-refiner needs
feedstock, trucks hit the road by the thousands. They circulate to oil-change shops, industrial plants and disposal sites.
"Every day, our members are going out and reaching all the
generators of used oil across the nation, and they are picking up
that billion gallons one quick lube at a time, one service station,
one factory at a time," said Parker. "The biggest environmental
damage that can be done is not to collect it in the first place."
From its headquarters in Richardson, Texas, re-refiner
Safety-Kleen operates its own collections, gathering more
than 250 million gallons of used oil for its six re-refineries
in the U.S. and Canada. From that feedstock, the company
produces about 180 million gallons of base oil in three grades,
including the predominant RHT120 midgrade viscosity.
We're very proud of the Group II+ products that we
produce and the volume of the products we produce," said
Steve Lewis, Safety-Kleen senior vice president of commodity and re-refinery sales. "The best way to do that is to
control your collections and also the quality controls within
the refining network, as well as the procedures and quality
control on your collection sites."
Data on used motor oil that escapes the recycling loop
is scarce, agree industry insiders. But by the estimate of
the U.S. Environmental Protection Agency (EPA), about
200 million gallons of North America's used motor oil are
improperly disposed of every year.
Those uncollected gallons, added to the captured quantities,
became a factor in Gen III's commitment to investors that its new
plant would have steady access to used motor oil as feedstock.
"We didn't look only in our backyard but went all the way
to the Gulf Coast, Minnesota, Europe," said Redcliffe. "We
found that we could do it. We signed letters of intent, and
we've nailed down our feedstock."
BAD ENVIRONMENTAL ACTORS
Re-refiners can remove most contaminants from used oil, but
there are, in the words of Colin Colvin, vice president, quality
and technical services at Safety-Kleen, "bad environmental
actors that need to be closely monitored." The primary culprit
is polychlorinated biphenyls (PCBs), banned in the U.S. since
1979 for their adverse health effects. The long-lived chemicals
may still lurk in many items, including oil used in motors and
hydraulic systems, according to the EPA.
Safety-Kleen operates within the "vast network" of its
parent company, environmental services provider Clean
Harbors, to manage any hazardous waste, said Lewis.

"In the used oil world, just because
the asphalt plants weren't purchasing our oil at the same level doesn't
mean that we as a nation were
going to stop producing used oil."
Scott D. Parker, executive director, NORA
"If it falls out of certain properties deemed not characteristic for refining, we have different operations to properly
manage it and see to its proper disposal," Lewis said.
Every refinery has a fully stocked environmental and
finished-product testing lab, and "100% of any vessel that
arrives goes through all the testing prior to offloading,"
added Colvin. "If we find it's off spec, we have the ability to
reject it on the trailer."
Many collectors struggle with PCBs coming from
do-it-yourself drop-off sites. NORA is renewing its federal
strategy to seek regulatory relief from the EPA, but in the
meantime, "There is no field test kit," said Parker. "Our
members send out thousands of trucks, and there's no way
to test on-site for PCBs." Collectors cited for introducing
PCBs into commerce suffer the consequences, and any
municipalities billed for the costs of remediation might be
inclined to exit the drop-off site business.
"We as an industry are doing a service by bringing this
used oil back for recycling," said Parker. "If there are fewer
drop-offs, it's more difficult to recycle oil. It doesn't mean
that less oil is generated. It means there's less oil collected.
And what happens with it? It ends up in the waterways and
who knows where."
CHANGING MARKETS
Re-refiners strive for continuous innovation and the agility
to address the varied and niche needs of customers, whether
they demand performance or sustainability. Safety-Kleen's

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ILMA Compoundings - May 2020

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