Compliance & Consequence
Acetylene Cylinder Disposal
Cylinders eventually reach the end of their useful life. The end is signaled when they fail either a periodic hydrostatic test or - in the case of acetylene cylinders-their requalification tests. Distributors must chose a method of disposal.
The buck never stops
The line of legal responsibility is clearly drawn.
"Distributors are responsible for either direct disposal of unused cylinders, or proper disposal by another party," said National Welding Supply Association Safety Consultant Mike Lopez.
Greg Shakley, manager at Worthington Cylinders' Citronelle, Ala. facility, agreed. "It is important for distributors to understand the U.S. Department Of Transportation vigorously enforces the guidelines," Shakley said.
Acetylene cylinder disposal
Some older acetylene cylinders contain asbestos. Distributors must familiarize themselves with local laws regarding asbestos disposal since regulations vary across the country.
Today, a silica lime slurry is put into cylinders during the manufacturing process. The slurry is hardened and baked. Acetylene is dissolved into the liquid acetone in acetylene cylinders.
When it comes time to dispose of acetylene cylinders, the acetone must be handled appropriately.
"Acetone is considered a hazardous waste by the Federal govemment," Lopez said.
"A new Model 420 acetylene cylinder contains almost eight gallons of liquid acetone. If not removed and recycled it has the potential to leach into the groundwater and pose the risk of an EPA fine," Shakley said.
"Distributors can use a designated hazardous waste landfill to dispose of cylinders with the acetone in it. However, more typically, acetone is baked out of the old cylinder and reclaimed," Lopez said.
Unto the tenth generation
If a distributor's old cylinder's are placed in a landfill that becomes a Superfund cleanup site the distributor can be held liable for the entire cost the remediation if other parties can't be found. Time does not mitigate the responsibility.
"In fact, they can come after the grandchildren who have inherited the business," Lopez said.
Because of the liability, a distributor needs to know who is disposing of its cylinders, how their operation works, and where they are taking them.
Using a disposal company
One means of disposing of acetylene cylinders is to contact a disposal company like Worthington Cylinders, headquartered in Columbus, Ohio.
Worthington's disposal services include removing and recycling the acetone, de-valving, and damaging the valve's inlet threads.
"We contain the asbestos in a non-friable form and remove and recycle the acetone. The cylinder is rendered unserviceable and transported to a Subtitle D landfill," he said.
A Subtitle D landfill is a disposal facility designated to accept municipal solid waste, construction waste, as well as various types of industrial wastes.
Three qualifying questions
A distributor should develop a standard set of questions for perspective disposal companies.
"First, ask to see the EPA ID number for transporting and disposing of hazardous waste. Second, find out where the cylinder is going - and if that disposal site has an EPA number. Third, ask if the cylinder markings will be removed," said Lopez.
Distributors should understand the entire process.
"Several companies can be involved in disposal activities. Some will broker out transportation or acetone removal. Some do everything.
"The bottom line is that a distributor needs adequate assurances," Lopez said.
That might even extend to indemnifying the distributor.
"Some companies will provide a legal contract that effectively transfers liability to the waste disposal company," Lopez said.
Elephant graveyards
According to Lopez, a major problem facing the industry are locations where cylinders have accumulated over a long period of time.
"These 'bone-yards' present multiple problems," he said. "The ownership of the cylinders may be questionable, the contents may be unknown, and the cylinders may have deteriorated to a point where they are unsafe to transport.
"Cylinders can be so corroded that they cannot be moved or they will release their contents either through the valve or the cylinder itself. The severity of the hazard depends on where the cylinders are stored and their contents: it may be flammable, toxic, or both. Even inert gases pose a pressure hazard if they burst."
"It has to be treated on-site before it is safe to transport as scrap steel or loaded into a special container and taken to a treatment facility," Lopez said. "Either way is expensive. It means a distributor must pay a specialty company to visit the site, test the cylinder, and deal with its contents."
Disposal of a single cylinder could run several thousand dollars.
The legacy
Distributors can inherit bone-yards, acquire them through acquisitions, and a few even allow cylinders to pile up themselves - out of sight, out of mind. One source is often overlooked.
"Drivers and salesmen will offer to take unidentified cylinders from potential customersm to get the business," Lopez said.
"Distributors should tell their sales staff not to accept cylinders that do not clearly belong to them."
Gases & Welding Distributor July/August 1998 Volume 42 Number 4