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.
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.
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 U.S. Environmental Protection Agency's webpage Typical Wastes Generated by Industry Sectors.
Permitted Sanitary Landfill Option
If the results of representative samples show the gasoline dispenser fuel filters are below .5 mg/l for benzen 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:
- Never place or drain gasoline dispenser fuel filters in a containment sump. This violates Department of Agriculture and Department of Natural Resources regulations.
- Do not throw gasoline dispenser fuel filters or absorbents in the trash. Wastes containing gasoline can cause fires or explosions or may be hazardous waste.
- Do not dry gasoline dispenser fuel filters outdoors. Precipitation can cause the container to overflow and release gasoline waste to the environment and volatilization of gasoline can result in an explosive atmosphere.
- Do not drain gasoline dispenser fuel filters or absorbents to the sewer. Wastes containing gasoline can cause fires or explosions in the sewer and conventional wastewater treatment plants and septic systems are not designed to handle these wastes. Storm sewers often drain to streams and lakes, and wastes containing gasoline can cause harm to fish and other aquatic organisms
- Do not pour gasoline on the ground. Waste gasoline from the drying of gasoline dispenser fuel filters or absorbents can contaminate the land, water and drinking water wells.
Managing captured gasoline - Residual gasoline product must be managed according to guidance explained in the fact sheet Management of Petroleum Storage Tank Wastes or by contacting the Environmental Remediation 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.