PROPANE TANK

PRODUCT STEWARDSHIP PROJECT

Analysis and Actions for

Minimizing 20-Pound Propane Tanks in the Waste Stream

Prepared for SEMASS Partnership by

Product Stewardship Institute

July 14, 2003

ACKNOWLEDGEMENTS

This guide was prepared under the direction of Scott Cassel, Director of the Product Stewardship Institute. Principal authors are Susan Loucks and Scott Cassel, with additional assistance from Alan Phipps. The Project Manager for SEMASS was Derek Grasso.

We would like to thank all those interviewed for contributing both their time and insight.

TABLE OF CONTENTS

Page

Acknowledgementsi

Introduction1

Identifying the Project Area3

ISSUES AND POTENTIAL SOLUTIONS6

SECTION I: Education6

Problems6

Potential actions for SEMASS6

Other Potential solutions11

SECTION II: Regulation 12

Problems13

Potential actions for SEMASS13

Other Potential solutions17

SECTION III: Economics 18

Problems18

Other Potential solutions19

SECTION IV: Infrastructure 21

Problems21

Potential actions for SEMASS22

Other Potential solutions24

SECTION V:Background information on stakeholder groups and

propane regulatory structures.25

Characteristics/Interests of Selected Stakeholder groups25

Propane Life Cycle Flow Chart28

APPENDIX A:Project Summary

APPENDIX B:Contact/Stakeholder List

APPENDIX C:Interview Notes

APPENDIX D:Sample Educational Materials

APPENDIX E:Explosions or Accidents involving Propane Cylinders

Product Stewardship Institute1

Propane Tank Product Stewardship Project

July 15, 2003

INTRODUCTION

Used 20-pound propane tanks (typically used for barbecue grills) are a safety concern because the tanks often contain residual propane gas, which has the potential to cause fires or explosions. As a result, many municipalities hold special collections to divert the used tanks from disposal. Additional collection services are provided by companies that sell new tanks in exchange for old ones, or by companies that refill tanks with gas. The SEMASS Resource Recovery Facility, an approximately 3,000-ton per day combustion facility in southeastern Massachusetts owned by SEMASS Partnership, has also sponsored free tank drop-offs in some areas.

Despite these efforts, large numbers of tanks are discarded in the household waste stream, which is a serious problem for waste-to-energy facilities like SEMASS that shred waste prior to combustion. Shredding propane tanks can result in explosions that are often powerful enough to damage equipment and buildings, and place plant workers at risk of serious injury. SEMASS staff reported that the Massachusetts facility had 62 explosions from the shredding of propane tanks from January through November, 2002, and the average cost of repairs after an explosion was in excess of $12,500. Risks of exploding propane tanks also extend to operators of garbage trucks, transfer stations, landfills, and other waste-to-energy plants.

SEMASS has removed more than 2,300 20-pound propane tanks from the waste stream in 2001. That number increased significantly in 2002 due to Massachusetts’ adoption of the National Fire Protection Association (NFPA) codes that require all valves to have an Overfill Protection Device (OPD). The NFPA code, once adopted by state law, makes it illegal to fill non-OPD tanks and renders them obsolete. The first state laws (including in Massachusetts) went into effect on April 1 of 2002, after which many old tanks were improperly discarded by consumers. For the first seven months of 2002, the number of tanks removed from the waste stream was 74% higher than the first seven months of 2001.

The Product Stewardship Institute (PSI) designed this project as Phase I of a four-phase Action Plan to investigate questions regarding management of used propane tanks, associated risks, existing regulations, potential solutions, and stakeholder interest in a dialogue (see Appendix A). One primary goal of this overall project is to reduce the risk from explosion of propane tanks for waste handlers by reducing the number of tanks in the waste stream. Another significant and complementary goal is to recover a useful resource by increasing the number of tanks collected – either for refurbishing or for scrapping (recycling). Phase I – the Outreach and Assessment Phase – consisted of identifying stakeholders, conducting 44 interviews, identifying issues, recommending potential solutions, and attempting to reach basic agreements (see Appendix B for a list of stakeholders).

The interviews that PSI conducted have served to educate stakeholders. Many expressed surprise at learning of SEMASS’ difficulties, and expressed an interest in taking action to alleviate plant explosions. Some of the potential solutions derived from the interviews are ones that can be implemented immediately by SEMASS in the short term, while others will require the cooperation of other stakeholders over a longer time period. The Phase I budget did not include funds for face-to-face meetings, which is the essence of the Phase II dialogue. Nearly all stakeholders we interviewed expressed an interest in participating in the dialogue.

IDENTIFYING THE PROJECT AREA

The SEMASS partnership serves nearly 100 municipalities at its Rochester, Massachusetts, combustion facility. As SEMASS determines further actions it wants to take to reduce propane tanks in the waste stream based on this report, it may find it necessary to work closely with a limited number of communities. Clearly, it is most important to work with communities whose residents are likely to be improperly disposing of their propane tanks.

PSI conducted interviews with municipal officials or waste handlers in nine communities within the SEMASS service area. To learn about successful programs within that area, PSI targeted communities from the 2000 SEMASS propane tank survey that were reportedly collecting a large number of tanks. Based on information raised in those interviews (see #2 below), PSI categorized the nine communities into those likely to properly handle their tanks and those less likely to do so:

Likely to properly handle their tanks: Less likely to properly handle tanks:

YarmouthMartha’s Vineyard

PlymouthNew Bedford

MashpeeDuxbury

Truro

Harwich

Bourne

Kingston (not interviewed but discussed in another interview)

PSI recommends that SEMASS take the following steps to prioritize the remaining municipalities within its service area for targeted action:

(1)Contact Municipality: SEMASS’ 2000 propane tank survey provided useful contact information for municipal public works staff. An updated recycling contact list can be obtained from John Crisley of the MA Department of Environmental Protection, at (617) 556-1021, or .

(2)Evaluate Municipal Conditions: Through the interviews, PSI has determined that certain municipal conditions lead to proper management of used propane tanks. SEMASS should ask questions of each municipal contact to determine if the following conditions exist:

  • Multiple tank disposal options: Some municipalities hold semi-annual one-day household hazardous waste (HHW) drop-off events or staff a permanent HHW drop-off center. Other towns have tank exchange cages run by national businesses that accept outdated or extra tanks. Dispenser/Refill operations are not consistently a way to recycle or dispose of extra tanks. Different consumers prefer different ways to fill their propane tanks. If residents can dispose of their tanks in a way that mimics how they fill their tanks, whether that includes municipal drop-off locations or private exchange operations, they are less likely to dump tanks or hide them in the regular trash.

Sample Questions:

How many options for safe management exist in this area?

What are those options?

Where are they located?

  • Readily accessible information on tank management options: Even if exchange and recycling options exist in a municipality, consumers need to be informed about where to take their extra or outdated tanks. The absence of readily available educational information pertaining to end-of-life management options will lead to improper disposal.

Sample Questions:

What type of information do you provide to residents about collection options?

What additional information is available to them?

  • Free or inexpensive tank drop-off: Many municipalities reported running successful collection programs that were either free to the consumer or had a $1-3 surcharge per returned tank. However, when prices climb towards $10, residents are likely to look for alternative and improper disposal methods. Those interviewed suggested that, at some fee level, typically over $3, at least some residents would stick their tank in a black plastic bag and put it deep into their trash can, or toss it in a commercial dumpster. Refill stations often have high trade-in prices, as they are strapped for space and may not have efficient systems to manage tanks they collect.

Sample Question:

How much do the different management options cost?

  • Convenience of options: Some municipalities in the SEMASS service area have residents buy a sticker that allows them to drop off all their waste at a central facility. These people regularly make trips to dispose of their garbage, and would probably be less likely to discard their tanks improperly than residents with curbside trash service who need to travel solely to drop-off their tanks. In other areas, particularly in rural communities, facilities may be far away or open only by appointment. While residents may be accustomed to driving to dispose of regular trash, if special wastes (like propane tanks) are not collected at that same facility, residents might have incentive to dispose of the tanks improperly.

Sample Questions:

How convenient are the existing options?

How many days and hours are the options available each week/month, etc.?

Do residents find these options convenient?

  • Municipal involvement: Municipalities with at least one involved employee, who is aware of problems from used propane tanks, are more likely to communicate and coordinate with other departments in that same municipality (e.g., public works and fire officials) in an attempt to find safe and convenient local collection solutions. They are also more likely to educate their residents.

Sample Question:

Do you have an employee in your municipality who works on propane tank collection and recycling issues?

ISSUES AND POTENTIAL SOLUTIONS

PSI identified the following issues and potential solutions pertaining to 20-pound propane tanks in the waste stream through 44 interviews conducted between December 9, 2002, and March 5, 2003 (see Appendix C). The issues and potential solutions have been grouped into four categories – Education, Regulation, Economics, and Infrastructure. For each category, we identify several key problems, and then follow with short-term and targeted actions that SEMASS could take. Each section concludes with additional solutions that would require additional time and resources.

SECTION I: Education

This category covers strategies to educate consumers, propane gas handlers, and municipal officials.

PROBLEMS

  • Consumers are often unaware of local municipal and commercial collection and recycling options for propane tanks. If retailers or municipal officials have recycling information available, it is often inconsistent or confusing to residents.
  • There is a lack of communication regarding safety standards and tank recycling practices between retailers, municipal safety and public works officials, and state and local regulatory officials. As a result, propane tanks are, at times, inefficiently handled or not managed in a safe manner (see appendix E). For example, municipal officials often improperly vent the propane gas prior to having the tanks collected for recycling, or they store them improperly. Communication gaps can contribute to an overall sense of confusion about dealing with the product and a fear that they will be improperly handled, resulting in a lack of interest in collecting tanks. This fear contributes to a lack of disposal options.

POTENTIAL ACTIONS FOR SEMASS

PSI recommends that SEMASS take two basic approaches to educating consumers within its service area:

(1)Use Existing Nationwide Website and Hotline

(2)Conduct Targeted Education Campaign

Nationwide Website and Hotline

Earth’s 911 is a national website and hotline that provides local information on recycling and HHW management. PSI recommends partnering with Earth’s 911 to provide information to consumers on propane tank management.

Website (): Website users can enter their zip code and retrieve a range of environmental information, including nearby municipal and commercial (e.g., exchange) collection points for propane tanks, and whether there is a drop-off charge. More detailed information about propane tank recycling is found through the “Recycling Centers,” link although some information is also available through the “Household Hazardous Waste” link. Municipalities have the ability to update the information remotely and are responsible for any changes, so the amount of detail varies.

Telephone Hotline (1-800-CLEANUP): Callers can enter their zip code for recorded area-specific information on places to drop off their propane tanks, recyclables, and HHW. While the hotline is less user-friendly than the website, it is an important option for those without web access. The State of Massachusetts, through the Department of Environmental Protection, currently contracts with Earth’s 911 to provide environmental information to residents in the state.

PSI recommends that SEMASS take a multi-faceted approach to maximize the potential of this information source:

(1)Enhance the functions of the existing website and toll-free number;

(2)Encourage municipal officials to input information; and

(3)Encourage consumers to use the website and hotline.

Enhance System Function: Individual users of Earth’s 911 website may have a hard time locating propane tank recycling information. PSI recommends that SEMASS discuss with Earth’s 911 a process for developing a general propane tank Home Page, question and answer section, and more obvious references and links to that information, including making propane tank disposal information more accessible from the “Household Hazardous Waste” page as well as the “Recycling Centers” page. More specifically, PSI recommends that Earth’s 911 have a separate listing on the HHW section and that the Propane Tanks link in that section provide the same access to general information as is available in the Recycling Centers section.

PSI has interviewed and met personally with Earth’s 911 staff to determine the type of additional information that might be made available for propane tank recycling. PSI will create, in conjunction with Earth’s 911, a special content section on propane tanks that will be cross-referenced throughout the website. PSI will also discuss potential website improvements with Earth’s 911.

Earth’s 911 currently does not have website content where municipalities can compare costs of different tank recycling services within the SEMASS service area. PSI will provide this information on its own website( as well as provide links to Earth’s 911 and other tank recycling resources (such as commercial exchange companies). PSI will also provide and link to information about safe handling of tanks. SEMASS can publicize this web resource to its customers.

Encourage Data Input by Municipal Officials::

After the website format is adjusted, the next step is to ensure that the information on the site is as accurate and complete as possible. After all, the website is only as good as the information that municipal officials supply. While this process is time-consuming, it is the only way for the site to be accurate. Earth’s 911 makes available a template on its website into which municipal officials must enter specific data on the type of propane tank information available in the community. Currently, municipal contacts arrange for a user name and password with an Earth’s 911 staff member, which allows them to log on whenever they want to make a change. A box on the left-hand side of the web Home Page provides municipalities with detailed instructions and connects them directly to a contact who can help first-time users. (Contact: Ann Reichman, Earth’s 911 Director of State Coordination, 602-224-5444, ).

PSI suggests that SEMASS review the template that Earth’s 911 uses to receive information from municipal officials to ensure that it is user friendly. Any changes to the format should be made prior to contacting officials to encourage them to use the template.

PSI suggests that SEMASS take two approaches to reach the municipal se officials – one which will be statewide and another that will target specific communities. For the statewide approach, SEMASS can write a letter for the MA DEP to send to municipal officials across the state requesting that they take advantage of the Earth’s 911 service for their residents by inputting environmental data to the system, but particularly for propane tanks as Memorial Day looms. The upgraded features of the website pertaining to propane tanks provides justification for sending a letter. DEP may have alternative suggestions.

Alternatively, the National Propane Gas Association/New England could send a letter directly to municipal officials urging them to use the service. Another statewide organization that should be contacted to provide information to its members is MassRecycle.