MANAGING GASOLINE DISPENSER FUEL FILTERS AND WASTES ASSOCIATED WITH THE OPERATION OF FUEL DISPENSING SYSTEMS

Hazardous Waste Program fact sheet
04/2014
Division of Environmental Quality Director: Leanne Tippett Mosby
PUB2364

Used gasoline dispenser fuel filters and other fuel dispensing system wastes, such as absorbent materials, water and debris can be toxic, ignitable and hazardous to people, property and the environment. Sometimes these wastes are illegally thrown into dumpsters or stored in ways that can lead to fires and explosions. The following guidance provides options for safely and legally managing used gasoline dispenser fuel filters and other media impacted by gasoline spills. This guidance does not pertain to the management of petroleum debris and media that is subject to 40 CFR part 280 subparts E and F.

Common Problem
The Missouri Department of Agriculture’s most issued violation is gasoline dispenser fuel filters or other waste stored in the sump containment beneath the dispenser. During an inspection, the violation typically cited in the Missouri Secretary of States Code of State Regulations as 2 CSR 90-30:

“Water or product shall not be allowed to accumulate within any secondary containment facility, this includes dikes and remote impoundments. Accumulated water and/or product within a secondary containment facility shall be removed and disposed of in a manner that is in compliance with applicable rules of the Department of Natural Resources.”

Gasoline dispenser fuel filters, absorbents or any other materials, including gasoline waste, may not be stored or dried in the sump containment. The sump containment is designed to hold gasoline product in the event of a release, any material stored in the sump containment reduces its capacity. The sump containment is intended only for abnormal operating conditions or emergency use. Storing gasoline dispenser fuel filters in the sump containment is also a fire hazard. Equipment in the dispenser can spark; igniting gasoline vapors and can cause a fire or explosion.

Proper management of used gasoline dispenser fuel filters

Scrap Metal Option
Metal gasoline dispenser fuel filters can be managed as scrap metal if the filters are drained of all liquids and sent for legitimate metal recycling.

Once drained and dried, metal gasoline tank dispenser filters should be stored in a closed container. The container should be labeled “scrap metal - gasoline dispenser fuel filters” and be sent to a scrap metal recycler with whom you have a written agreement and has the equipment to manage this type of metal and material. The Department of Natural Resources recommends you regularly contact your recycler to evaluate if scrap metal is being properly managed.

Hazardous Waste Option
Gasoline dispenser fuel filters and other related materials not destined for recycling should be considered hazardous waste since they are likely to contain enough benzene to be a toxic hazardous waste and they meet no other exemption. Gasoline dispenser fuel filters may only be considered an exempt scrap metal when drained and sent to a legitimate metal recycler.

Gasoline dispenser fuel filters intended for disposal must be managed as a hazardous waste, unless representative sampling demonstrates the wastes are not hazardous. If they contain free liquid, gasoline dispenser fuel filters are typically hazardous waste due to ignitability. If they are dry, but stored under high-heat conditions, they may spontaneously combust.

If you choose to characterize the gasoline dispenser fuel filters to determine if the waste is hazardous, the filters should be sampled for ignitability, also known as the flashpoint test, and benzene using the Toxicity Characteristic Leaching Procedure, or TCLP. If TCLP results show the wastes are at or above 0.5 mg/l (milligrams per liter) for benzene, if the filters fail the flashpoint test or if they are not tested, the gasoline dispenser fuel filters must be managed as hazardous waste. For more information about managing hazardous waste, see the fact sheet “Does Your Business Generate Hazardous Waste?” available on the department’s Web site at http://dnr.mo.gov/pubs/pub117.pdf.

Permitted Sanitary Landfill Option
If the results of representative samples show the gasoline dispenser fuel filters are below .5 mg/l for benzene and they do not fail the flashpoint test, they are not hazardous and may be sent to a permitted sanitary landfill. Testing results must be retained for a period of three years.

Safe Gasoline Dispenser Fuel Filter Draining Practices
If managing on-site for recycling, metal gasoline tank dispenser filters must be drained and dried over a suitable container such as elevated in a closed drum or closed bucket so there is no release of liquid gasoline product or gasoline vapor to the environment. Dry filters must then be placed in a closed container prior to being sent to a legitimate metal recycler. Absorbent materials such as pads, socks or booms used to absorb gasoline spills may be dried over an open container similar to the method used to drain and dry gasoline tank filters.

Other important draining practices are:

Managing captured gasoline - Residual gasoline product must be managed according to guidance explained in the fact sheet Management of Petroleum Storage Tank Wastes available online at http://dnr.mo.gov/pubs/pub2040.pdf or by contacting the Hazardous Waste Program at 573-751-3176. Captured gasoline product may also be sold if it meets Missouri Department of Agriculture fuel specifications.

What contractors should know
Contractors may transport drained metal filters to a legitimate metal recycler. Additionally, contractors may store and accumulate the drained metal filters at their facility as long the contractor can document that the filters will be recycled as scrap metal.

Contractors performing general maintenance on dispensers may transport gasoline dispenser fuel filters destined for recycling, in a closed container, directly back to their facility if they have a contractual agreement to conduct recycling activities.  Fuel filters may not be stored in or on a vehicle overnight and must be placed in the closed draining drum or bucket upon arriving at the contractor’s facility.  Contractors performing general maintenance on dispensers may also transport used absorbents, rags, paper towels generated in the course of performing their duties back to the contractor’s facility.  Absorbents, rags, paper towels must receive a hazardous waste determination upon arriving at the contractor’s facility and be appropriately stored.  These activities must be documented to ensure legitimate recycling/disposal activities.

However, contractors may not transport, store or accumulate hazardous gasoline dispenser fuel filters, used absorbents contaminated with gasoline or petroleum contaminated water destined for disposal that they did not generate while performing general maintenance on dispensers under a contractual agreement, unless the contractor’s site has a license, permit or certification from the state to transport or accept hazardous waste.

Ultimately, the burden rests on the generator to make a hazardous determination on filters, absorbents and petroleum contaminated water and to ensure their wastes are managed appropriately.

For more information

Missouri Department of Natural Resources
Hazardous Waste Program
P.O. Box 176
Jefferson City, MO 65102-0176
800-361-4827 or 573-751-3176
Fax 573-526-5268
http://dnr.mo.gov/env/hwp/index.html

Missouri Department of Natural Resources
Hazardous Waste Program
Tanks Compliance and Enforcement Unit
P.O. Box 176
Jefferson City, MO 65102-0176
575-522-5665
tanks-compliance@dnr.mo.gov

Missouri Department of Natural Resources
Solid Waste Management Program
P.O. Box 176
Jefferson City, MO 65109-0176
800-361-4827 or 573-751-5401
Fax 573-526-3902
http://dnr.mo.gov/env/swmp/index.html

Missouri Department of Agriculture
Petroleum/Propane/Anhydrous Ammonia Program
P.O. Box 630
Jefferson City, MO 65101-0630
573-751-5636
http://mda.mo.gov/weights/petroleum/