Putting the 'Green' in Used Material Disposal

By G. C. Skipper, Contributing Editor | September 28, 2010
Handling Hazmat

Not surprisingly, the disposal and storage of hazardous waste material require more stringent controls, documentation and training than those for other used products. Regardless of where hazmat originates – construction sites, quarries, plants, or private or public fleets – handling it incorrectly can have adverse affects on human health or the environment.

A number of different classifications exist for hazardous materials.

“Some have to do with toxicity, some are based on flammability, and some are specialized, such as radioactive material,” says Stephen D. Waggoner, quality management systems manager at D-A Lubricant Co.

As a marketer and manufacturer of heavy-duty lubricants in the United States and Canada, D-A Lubricant deals primarily with two types of hazmat: toxicity and flammability.

“Material that is classified as flammable has a flash point below 100 degrees F,” says Waggoner.

Hazmat waste is accumulated in drums, but unlike non-hazardous products, the material cannot be stored more than 90 days. If a facility generates less than 100 kilograms of hazardous waste in any single month, the company is considered a small quantity generator.

“If you generate more than 100 kilograms of hazardous waste in a month,” says Waggoner, “you are considered a large generator and the reporting procedure is different.”

Hazmat storage containers must have a sticker that provides a date when the first material was placed in the container and a sticker with the date when the last material was placed inside.

“We accumulate flammable material in drums,” says Waggoner, “and the first time we pour it into the drum, we have to put a sticker on with the date.”

A manifest must also be filled out, usually by the transporter.

“They come out for a pickup with the manifest already prepared,” he says. “What's not filled in is the quantity. We tell them how many drums or how many pounds, depending on the material, that we have and they fill in the quantity. This is a state-regulated document, and each state has its own document.”

Some of the hazardous material generated at D-A Lubricant comes from oil analysis samples and the testing of transmission fluids, hydraulic fluids and gear oils.

Hazardous material disposal has to be documented in more detail that other types of material.

”It depends on what it is,” says Levi Dungan, president of Dungan and Co. “The material has to be labeled clearly on the container. People that transport it must be trained to handle it. You also have to document the training.”

Hazmat disposal training covers such topics as identifying the materials, how to handle each type and recordkeeping requirements.

Jim Noble, president of Noble Oil Services, which handles a small amount of hazardous waste, says several things make hazmat different from other used materials when it comes to disposal: “There are limits on how long you can keep it. And there are very strict requirements on what types of containers you can use and where they are placed. Sometimes containers have to be kept in a dedicated area that is secured.”

Tips on Selecting a Transporter

Once a private or public fleet stores used or waste material in an environmentally effective way – keeping it covered and out of the rain, preventing contaminants from getting into it and using a secondary containment to protect against over-flow or spill – equipment managers must usually select a transporter to haul the waste away.

To choose a transporter, Jim Noble, president, Noble Oil Services, recommends you:

  • Make sure the company has adequate insurance
  • Make sure the company has a good compliance record
  • Check the company out through the Better Business Bureau or Dunn & Bradstreet to make sure they have a good reputation
  • Ask for references and call them to find out if the transporter's service is reliable and there are no past problems
  • Look at the paper work the transporter leaves behind. This is very important if a state auditor or some other official comes in and wants to see documentation that the material was properly disposed of. Make sure there are numbered manifests and a record of collection.

Hazmat Classifications

AEMP has identified the following waste characteristics that may impact health and the environment:

  • Ignitable waste – Material that can be easily lit or if when ignited, burns so vigorously that it creates a hazard; liquids with a flash point of less than 140 degrees F; and non-liquids capable under normal conditions (temperature and pressure) of causing a fire by means of friction, absorption of moisture or spontaneous chemical change.
  • Flammable compressed gases.
  • Oxidizers.
  • Corrosive waste – Aqueous waste with a pH less than 2 or greater than 12.5 (includes automotive batteries and battery acid, as well as certain rechargeable or alkaline batteries.) and wastes that corrode steel at a certain rate using a standard test method.
  • Reactive waste – Wastes that are unstable under "normal" conditions. They can cause explosions, toxic fumes, gases, or vapors when heated, compressed, or mixed with water (includes lithium-sulfur batteries and explosives).
  • Toxic wastes – Wastes that are harmful or fatal when ingested or absorbed (e.g., containing mercury, lead, etc.). To determine if a waste exhibits the toxicity characteristic, you must analyze it using EPA's Toxicity Characteristic Leaching Procedure. (Examples of toxic waste include batteries, paint wastes, Chromium, and fuel residues containing benzene.)

Although there are similarities, each type of material differs in disposal procedures and storage. In addition, fleet managers must follow federal, state and local environmental regulations to the letter and document how the disposal was done.

Or as Richard Puckett, president of Ohio-based Glockner Oil puts it, “We keep all the manifest records and hold them in storage forever. There is no sunset.”

According to Puckett, a large part of his customer base is made up of trucking companies, manufacturing plants, car dealerships and construction fleets. As a transporter, his job is to make sure whatever he picks up is disposed of in an environmentally effective way.

“That totally takes the worry off the fleet manager's mind,” says Puckett.

But all transporters are not created equal.

“I've heard horror stories about small, unqualified transporters that did not dispose of the material as it should be done,” says Puckett. “Two years later the fleet is contacted by the EPA and told it has a problem.”

One fleet operation that uses Glockner as a transporter is Plum Run Stone, a southern Ohio company that is part of Hanson Aggregates. Superintendent Terry Louderback says in years past, the company would store used oil during the summer months and burn it in furnaces to heat the shop during winter.

“Oil filters were turned on end in a stand and drained,” says Louderback. “The filters then went into the dumpster. But as regulatory standards tightened, it became obvious real quick that drying oil filters was not going to meet the standards.”

That's when the decision was made to bring a transporter in.

“Finding a company that was willing to have its employees trained and be licensed to handle this kind of stuff was really a big help,” he says.

At Plum Run, used oil is stored in 5,000-gallon tanks.

“With material such as used oil, there is always the question of what to do with that extra five gallons,” says Louderback. “If you don't do something quick, it will become contaminated and you can't use it. That's why we use bulk tanks.

Oil filters are stored in 55-gallon drums provided by Glockner.

“There are six drums on the floor at all times,” says Louderback. “As we fill them, Glockner picks them up.”

Used anti-freeze is usually stored in 55-gallon drums that are picked up regularly.

Batteries and Tires

In addition to used oil, anti-freeze and oil filters, Plum Run has to dispose of used batteries and tires.

“We store used batteries up off the ground and place them in a contained area with another container around them,” says Louderback. “You have to label everything, and after we accumulate so many batteries, we call Caterpillar to pick them up.”

As for tires, those that can't be repaired are piled up until the tire supplier picks them up.

“Our tire supplier disposes of the tires and does all the paper work to show where the tires go after they are picked up,” says Louderback. “Everything that's disposed of has to be handled with the thought that it's your responsibility from cradle to grave – batteries, light bulbs, floor dry or anything that has the potential to create a hazard in a landfill.”

Many states charge a tire disposal fee.

“Most of the time, a tire dealer will handle the disposal for you,” says Levi Dungan, CEM, president of Dungan and Co. “Local or state governments may set escalating fees depending on the size of the tire. Many of the recycled tires wind up in rubberized asphalt.”

Professional Help

Louderback recommends that equipment managers who want to set up an environmentally effective disposal program use one of the consulting firms that specialize in developing those plans. He uses an engineering consulting service based in Lexington, Ky.

“The consultants look at your operation and what your needs are, and basically create a booklet for you to follow step by step, so you are always in compliance,” he says.

Louderback says there is no limit to how far an equipment professional should go to set up an environmentally effective program.

“When you're comfortable with what you're doing, you better have current information on changing regulations and that's where environmental handling professionals become a necessity,” he says.


Jim Noble, president of Noble Oil Services, a North Carolina recycling company, says, “We tell fleets that some of the practices they did years ago, such as using oil as a dust suppressant, are no longer allowed. The days when you could put used oil on roads and in the corridors of sand pits to keep the dust down are gone.”

Noble never refers to waste oil or waste anti-freeze, because almost all the material he picks up is recycled. For example, after used oil is delivered to a recycling facility, it goes through three filtration steps to remove dirt and sediment. That oil is then resold as a base oil product that can be burned for heating purposes or blended with light oils, such as kerosene or diesel, for customers who want oil that will combust or atomize at ambient temperatures.

“To burn used oil, it has to be pre-heated,” says Noble. “Some customers can't, or don't want to, pre-heat the oil, so we make a light blend that doesn't have to be pre-heated.”

While the majority of recycled oil in the United States is used in asphalt plants, some is used in industrial applications, such as heating paper mills.

How It's Done

Most used oil is collected in single- or double-axle trucks that hold between 2,700 and 4,500 gallons. Typically, the trucks run regular routes and the drivers sample the oil before it's picked up to make sure there isn't anything in it, such as halogen. According to Noble, the presence of halogen indicates someone may have put solvents or other material in the used oil that the drivers can't pick up.

If the sample passes the field test, the oil is pumped into the truck and hauled to the recycling facility. When it gets to the plant, the oil is tested again to make sure no foreign material was picked up along the way.

“About 99 percent of the material we receive is suitable for recycling,” says Noble.

Any impurities, such as gasoline or water, are drained out and the oil goes through three filtration steps to remove dirt and sediment to produce the base product. The product is then ready to be resold.

Used oil filters go to a sorting table and then onto a conveyor belt. As they move down the belt, a plant worker picks out any debris that isn't suitable for cubing. The filters are then compressed into high-density blocks (approximately 1 foot x 1 foot) weighing about 65 pounds and sent to a steel smelter.

“During this process, a significant amount of oil is recovered and that oil is also recycled,” says Noble. “For every 55-gallon drum of oil filters we collect, we recover five to 12 gallons of oil.”

According to Dungan, regulations for disposing of oil filters may vary by state or locality.

“Some states allow crushed filters to be taken to landfills,” he says. “But other places require qualified companies to pick them up and incinerate them so they won't wind up in landfills.”

Used anti-freeze can be recycled two ways: micro filtration or two-stage distillation. With micro filtration, the used anti-freeze goes into a tank for chemical flocculation that forces any remaining oil in the anti-freeze to the top. After the small oil droplets are removed, the anti-freeze goes through three filtering steps. This produces a concentrated “water white” product. Appropriate additives are put in, and it's sold as a 50-50 concentrate.

In two-stage distillation, the first step takes out all the water and the second step distills the ethylene glycol to produce a clean base product. Additives are put in and it's sold as a concentrate.

Many fleets store used anti-freeze in plastic drums, preferably drums that are white or transparent, so the fleet manager can tell when it's nearly full. Large fleets that generate huge quantities of anti-freeze use plastic totes that hold between 250 and 300 gallons.

In areas where anti-freeze recycling services are not available, the fleet manager may be charged to haul the anti-freeze away.

“We pick it up free if customers use our recycling services,” says Noble.

Stephen D. Waggoner, quality management systems technical manager for D-A Lubricant Co. in Indianapolis says used lubricants, such as engine oil, can be accumulated in any size container.

“Used lubricants are not considered hazardous material, so there aren't as many regulations to adhere to,” he says. “When you're ready, you call a transporter who comes out, takes it to a facility where a high percentage is re-blended, mostly into heavy fuel, for burners, kilns and aggregate plants, such as asphalt plants.”

Used anti-freeze is a different animal.

”Most used anti-freeze contains ethylene glycol, and must be captured and stored in a separate tank for disposal,” says Dungan. “Some companies recycle used antifreeze but most fleet managers just want to dispose of it. Ethylene glycol is poisonous, and has to be stored, labeled and handled separately. Storage tanks are generally provided by the transporter who picks up the material.”

Kitty Litter

Puckett says there's another type of used product that requires careful handling.

“We call it kitty litter,” he says, “and it refers to any spill control product, such as pads or rags. We furnish the proper container and labels for that, as well. We pick them up and sell them to recyclers who drain off any excess through a squeezing process. The end product is ground up and used for boiler fuel.”