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 Reuse and Recycling of Metal and Plastic Drums datasheet.

The wastewater may be a new waste stream and may need to be disposed of as a hazardous waste or require special treatment. In addition, the washer may increase water and electricity consumption. Under EO 13123, 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 general guidelines 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.

• Eliminates disposal of drums as hazardous waste, thereby reducing hazardous waste quantities.
• Avoids hazardous waste transportation and disposal costs.
• Washing and re-using drums saves the cost of purchasing new drums.
• Recycling damaged drums generates income.
• More effective than triple rinsing and less labor intensive.
• Decreases worker exposure to chemicals being removed as compared to manual triple-rinsing.
• Some drum washers are compatible with solvent solutions.

• Wastewater from drum washing may require special treatment depending on the test results of the rinse water.
• Drum washing using this type of self-contained equipment DOES NOT qualify a drum as a DOT reconditioned metal drum as defined in 49 CFA 173.28(c).

Assumptions:

• 500 metal drums per year.
• Weight per empty drum: 10 lbs.
• Drums previously containing hazardous wastes are disposed of as a hazardous waste.
• Same amount of labor expended to collect drums for washing or disposing.
• Drums washed at 5 drums per hour.
• Labor rate: $30/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
• Disposal cost for hazardous waste: $0.60/lb
• Utilities to operate: $125/yr. to heat water and $75/yr. to operate washer
• Recycling profit: $20/ton
• Unit cost: $23,000
• Installation cost: $7,000

Economic Analysis Summary:

• Annual Savings for Re-use/Recycling: $12,675
  
• Capital Cost for Diversion Equipment/Process: $30,000
  
• Payback Period for Investment in Equipment/Process: < 2.5 years

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