This program is an analysis of the machine coolant and sludge.  For most shops this is the only regulated waste they generate.  Ordinary office and business waste is generally not regulated.  Industrial waste including paints, cleaners and processing wastes are generally regulated.   Refer to the Machine Coolant Disposal for more information. 

Material:  Used machine coolant

Overall:  Very clean machine coolant – should easily qualify as recyclable material for low cost disposal – Hazardous waste reporting should not be necessary.  

Hazardous waste designation:  - Not required if recycling is done.  We do not believe that this material has to be treated as hazardous waste if it is properly recycled.  Per  40 CFR Section 261.2 (e) (1)  Materials are not solid wastes when they can be shown to be recycled. 

Contaminants: 

Metals:  Some metals are present, but it does not appear the levels are high enough to cause problems or require classification.  

Chrome: The chrome tested out to be entirely trivalent chrome within legal limits of federally required testing.  There was no hexavalent chrome detected (legally less than 0.01 mg/L). 

Oils and greases:  Good - There are oils and greases present so this material cannot usually be disposed of in a sewer or septic tank in any circumstances.  However, the oils and greases are recoverable and recyclable. 

Recommended classification:  Material held for recycling 

Recommended disposal:  Recycling through a reputable recycler such as Safety-Kleen @ (800) 323-5040  or VWR (Van Waters & Rogers)  @ (800) 909-4897.   It is extremely important that you select a recycler that is legal and trustworthy.  If you have the material hauled away and it is not handled properly you will still be liable for any damage done. 

Estimated cost of disposal:  One time fee to the disposal company of approximately $300 for testing.  Then $75 to $90 per barrel.  (Hazardous waste is usually $300 to $400 per barrel)  Additional testing may not be necessary with this report.  It will depend on the waste hauler.  

Other steps to consider:

1.  Filter the machine coolant regularly to extend machine coolant life. 

2.  This used machine coolant is approximately 90% water.  Evaporating the water may make economic sense.

Need for further testing:  None - Unless the materials used in this process change the tests done here should serve to establish this as a standard or typical batch.  No further testing should be needed unless the process is changed.  

Laboratory Analysis

This is how your waste tests legally.  Show this to the recycler and to the government if they ask.  This test should serve as "a standard batch" test.  Unless you change your process no further tests should be necessary. 

Oil and Grease testing performed by EPA Method 413.2 (Partition Infrared)

Total Petroleum Hydrocarbon testing performed by EPA Method 418.1

Hexavalent Chromium testing performed by Standard Method  307-B

TCLP by EPA Method 1311

Metals performed by EPA Method 6010

* Cadmium detection limit raised due to matrix effects

** Mercury analysis by EPA Method 7470 

Disposal

The TCLP is a test of whether it is safe to dispose of metal containing compounds in a landfill.  It is based on how much of each metal is likely to leach out and contaminate the surrounding area. 

It may not make sense, but it is the federal standard arrived at by science and politics.  It does give a standard to measure against.  

This machine coolant exceeds the TCLP limits for disposal in a landfill.  However, there are several methods to legally dispose of this machine coolant and the sludge it contains.