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Overview: | In general, drum washers/recyclers wash contaminated drums inside an enclosed chamber. Drums can range in size from 5-gallon pails to 55- or 90-gallon drums. There are numerous suppliers of this type of equipment and multiple options, which can be specified for unique site needs. Units have both interior and exterior washing capability. Some units use heated water and detergent dispensing systems and a rinse cycle. The wastewater should be tested for hazardous contaminants. Other units offer an option for solvent washing. Some options include stainless steel construction, recirculating rinse tanks, live steam capability, explosion proofing, automatic cycle timers, and remotely located controls which can be operated from non-hazardous areas.
Navy personnel collect hazardous waste from on-base generators using 55-gallon drums. After pumping out the waste, the drums are disposed as hazardous waste. Empty drums that formerly contained hazardous materials or wastes and are in good condition can be re-used as collection containers for hazardous wastes, in lieu of purchasing new drums. Various hazardous materials and other chemicals used by the Navy are delivered in large metal drums. According to the U.S. EPA, empty drums that contained hazardous materials are exempt from hazardous waste regulation in 40 CFR Section 261.7. For hazardous wastes that are not "acute" as listed in 40 CFR 261.31, 261.32, or 261.33, "empty" is defined as containing less than three percent of the original contents (by weight) or less than one inch of residue on the bottom. Drums that contained acute hazardous waste are empty after they have been triple rinsed with a solvent (which may be water) capable of removing the product. Rinse water is the only waste stream from this process and it should be tested for hazardous substances to determine the method of treatment required. Damaged or excess metal drums can be conditioned or washed and recycled as ferrous scrap metal For additional information, see the Reuse and Recycling of Metal and Plastic Drums datasheet.
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Compliance Benefit: | A drum washer will allow the reuse of hazardous waste drums and therefore, will help facilities meet the requirements under Executive Order 13101 requiring executive agencies (e.g., DOD) to incorporate waste prevention and recycling in their daily operations. In addition, since the drum is no longer hazardous the facility decreases its hazardous waste which helps facilities meet the requirements of waste reduction under RCRA, 40 CFR 262, Appendix, and may also help facilities reduce their regulatory burden (i.e., recordkeeping, reporting, inspections, transportation, accumulation time, emergency prevention and preparedness, emergency response) under RCRA, 40 CFR 262.
The wastewater may be a new waste stream and may need to be disposed as a hazardous waste or require special treatment. In addition, the washer may increase water and electricity consumption. Under EO 12902, federal facilities are required to reduce energy consumption and implement water conservation projects. The compliance benefits listed here are only meant to be used as a general guideline and are not meant to be strictly interpreted. Actual compliance benefits will vary depending on the factors involved, e.g. the amount of workload involved.
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Materials Compatibility: | Empty drums should be stored and handled as if the drums were still full (i.e., store incompatibles separately), until properly washed. Rinse waters will contain the residues from the drums; therefore, segregation of incompatibles and proper treatment of rinse water is essential.
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Safety and Health: | Because the systems are enclosed, exposure to chemicals being removed from the drums is minimized. Automatic shut-down occurs when unsafe conditions (overheating and electrical shorting) are detected by the electronic controller. Consult your local industrial health specialist, the base safety office, and the appropriate MSDS prior to implementation.
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Benefits: |
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Disadvantages: |
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Economic Analysis: | The cost elements of washing drums are compared to the disposal of drums as a hazardous waste and the purchase of new drums. According to the Pollution Prevention Equipment Program, a drum conditioner costs approximately $35,000. Typically these units cost about $23,000, with an additional $5,000 to $10,000 for installation.
Assumptions:
Annual Operating Cost Comparison for Diversion and Disposal of Drums
Economic Analysis Summary
Capital Cost for Diversion Equipment/Process: $30,000 Payback Period for Investment in Equipment/Process: < 2.5 years Click Here to view an Active Spreadsheet for this Economic Analysis and Enter Your Own Values.
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Approving Authority: | Approval is controlled locally and should be implemented only after engineering approval has been granted. Major claimant approval is not required.
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NSN/MSDS:
Product
NSN
Unit Size
Cost
MSDS*
None Identified
$
*There are multiple MSDSs for most NSNs.
The MSDS (if shown above) is only meant to serve as an example.
Points of Contact:
Navy:
Mr. Michael Viggiano
Naval Facilities Engineering Service Center
1100 23rd Avenue
Code 423
Port Hueneme, CA 93043-4370
Phone: (805) 982-4895
DSN: 551-4895
Email: viggianoml@nfesc.navy.mil
Vendors:
Enviro-Techniques Products Incorporated
120 Thadeus Street
South Portland, ME 04106
Phone: (207) 767-5510
SRS Industrial Engineering, Inc.
550 Industrial Way, Unit C
Fallbrook, CA 92208
Phone: (760) 728-1790
FAX: (760) 728-3151
URL: http://www.srsindustrial.com
Contact: Mr. Arthur Legros
Americlean
11 East Ferguson
Wood River, IL 62095
Phone: (618) 254-2400
FAX: (618) 254-2101
URL: http://www.americlean-inc.com
Sources:
Mr. Michael Viggiano, Naval Facilities Engineering Service Center, May 1999.
Code of Federal Regulation, Title 40, Part 261, Section 261.7 - Residues of hazardous waste in empty containers.
Code of Federal Regulation, Title 49, Part 173.28, Reuse, reconditioning, and re-manufacture of packaging (D) Reconditioning of non-bulk packaging, reconditioning of metal drums.
Mr. Arthur Legros, STS Industrial Engineering, May 1996.
Mr. George Adams, Americlean, May 1996.
Ms. Julie Derscher, Public Works Center, San Diego, May 1996.
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