Legally empty drums are exempt from hazardous waste regulation in 40 CFR Section 261.7 and can be recycled. 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 a one inch residue on the bottom. Drums can be made empty by pumping out the residue or washing the drum. 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.

Drums which contain a residue such that the drum does not meet the legal definition of empty can still be re-used as collection and storage drums for hazardous wastes which are compatible with the residue in the drum. If the drum is used for any material different from the residue in the drum then a chemical safety reference needs to be checked to ensure that the residue and the new material will not react in any way. Incompatible materials may react to form heat, toxic gases, violent reactions, explosions, etc.. The list of incompatible material combinations is too long to include in this data sheet. Incompatible combinations include combinations such as acids and bases, oxidizing agents and reducing agents, inorganic sulfides and acids, etc.

Drum reconditioning, regulated by 49 CFR 173.28(c), is the process of stripping a metal drum down to the bare metal, removing all contents, paint, corrosion, and labels. The drum is then restored to its original shape and inspected for pitting, reduction in material thickness, metal fatigue, damaged threads or closures, or other significant defects. Drums that pass inspection can be painted and marked according to 49 CFR 178. Plastic drums are reconditioned by repair or replacement of non-integral packaging components to a condition such that they conform in all respects with the prescribed requirements of 49 CFR 178. Companies are available to recondition drums.

The re-use and recycling of drums can potentially remove 100% of drums from landfilling. Some drums have liners of LDPE #4 plastic which can be removed and recycled.

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.

• Re-using drums saves the cost of purchasing new drums.
• Recycling of drums prevents drums from becoming hazardous waste.
• Drum reuse and recycling reduces hazardous waste transportation and disposal costs.
• Recycling drums generates income.

• Wastewater from drum rinsing may require special treatment depending on test results of the rinse water.

Assumptions:

• 1,000 metal drums per year.
• Weight per empty drum: 10 lbs.
• 10% of drums (100 drums) held acutely hazardous wastes and require disposal as hazardous waste instead of as solid waste.
• Drums rinsed at 5 drums per hour.
• Same amount of labor expended to collect drums for washing or disposing.
• Estimated labor rate (for rinsing): $50/hr.
• Waste water treatment per drum: 5 gallons
• Waste water treatment cost: $0.25/drum
• Wash solution requirements: 55 gallons to wash approximately 200 drums
• Cost of wash solution: $800/55 gallon drum
• According to the Naval Station San Diego, landfill costs are not paid due to a lease the station has with the city. However, typical landfill costs for the San Diego area are estimated at $41/ton.
• Hazardous waste disposal costs: $2/lb.
• Utilities to operate: $125/yr to heat water and $75/yr to operate washer.
• Unit cost: $23,000
• Installation cost: $7,000
• Recycling profit: $20/ton
• Cost of new drums: $30 each

Economic Analysis Summary

Annual Savings for Re-use/Recycling: $17,735
Capital Cost for Diversion Equipment/Process: $30,000
Payback Period for Investment in Equipment/Process: < 2 years

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