Pollution Engineering - November 2008 - (Page 19)

ENVIRONMENTALMANAGEMENT By Norman Wei How to Manage Contaminated Rags and Wipes The EPA has been considering new rules for contaminated rags and wipes. Until they have completed their review, certain steps are required to avoid being ﬁned. U sing solvents to clean machinery usually requires cloth rags or wipes to mop up the spent substance. The issue of handling these solvent-contaminated rags and wipes is a tricky one because current Resource Conservation and Recovery Act (RCRA) regulations do not specifically address it. Management of such materials is subject to regulatory agencies’ interpretation. From the EPA’s standpoint, a solvent-contaminated rag is a RCRA solid waste. If it contains a listed spent solvent such as an F003 waste, it is a hazardous waste and must be disposed of as such. If it exhibits one or more of the four RCRA characteristics – ignitability, corrosivity, reactivity or toxicity – it is also a hazardous waste. Most states allow generators to send their contaminated rags and wipes out to a commercial laundry facility that is licensed to handle such material. If there is a tolling agreement or service contract with such a facility, most state agencies will exempt a facility from having to manage the rags and wipes as hazardous wastes if several important conditions are adhered to. The first stipulation is that a facility must have a service contract with the company that will be laundering the rags. The second condition is that there must be no freeflowing liquid in the rags and wipes. The third condition is that the rags and wipes need to be stored in a fireproof container prior to their being picked up for laundry. In its draft regulations of 2003, the agency proposed to exclude these rags from the definition of solid waste if they are being reused. If these regulations become final, reusable rags and wipes will no longer be hazardous wastes, since only RCRA solid wastes can become hazardous wastes. If the rags and wipes are being disposed of, EPA proposed to provide conditional exclusion from the definition of hazardous wastes. • These proposed exclusions are contingent on the following conditions: • The rags and wipes must be accumulated in nonleaking and covered containers. • They must be transported in containers that minimize releases to the environment. • There must be no free liquids in wipes or in containers when being transported except when transferred intra-company for solvent extraction. • The rags and wipes must contain no more than 5 grams of solvent or they must be treated via solvent extraction. • They cannot contain the following solvents: 2-nitropropane, nitrobenzene, methylene chloride, methyl ethyl ketone (MEK), pyridine, benzene, creoles (o,m,p), carbon tetrachloride, chlorobenzene, Tetrachloroethylene, trichloroethylene. Public hearings were held on March 9, 2004. The agency is in the process of undergoing peer review on the risk analysis of these proposed regulations. A notice of data availability on the risk analysis is expected in late 2008. The final rule will be issued pending the outcome of the risk analysis and peer review. Until EPA’s rules are finalized, it is recommended that solvent-contaminated rags and wipes be disposed as hazardous wastes. If the rags and wipes are reused through a commercial laundry facility, follow the state agency’s guidance. PE “ A notice of data availability on the risk analysis is expected in late 2008. ” Norman Wei is the founder and principal instructor at Environmental Management and Training LLC – a consulting firm based in Union, Wash. He conducts environmental regulations seminars throughout the country. He also consults for corporations and provides litigation support to law firms. He can be reached at Norman@proactenv.com. His company website site is www.proactenv.com and his blog is http://normanswei.wordpress.com. Visit www.pollutionengineering.com and electronically forward a copy of this article to a colleague or customer. NOVEMBER2008 www.pollutionengineering.com 19 http://www.proactenv.com http://normanswei.wordpress.com http://www.pollutionengineering.com http://www.pollutionengineering.com

Table of Contents Feed for the Digital Edition of Pollution Engineering - November 2008

Pollution Engineering - November 2008 Contents The Editor's Desk EnviroNews PE Events Legal Lookout Casebook Canada Environment Management The Green Files Waste Island Phase I ESAs and Vapor Intrusion Meeting the Mercury Target Wet ESPs - The Sky's the Limit Most Successful IFAT China Ever Thermoplastic to the Rescue Install a Trench Without Open Excavations Remediate Impacted Soils Without Accumulation of Metabolites Apply an Alternative to Wet ESP Solve These Common Pump Problems Minimize Risks Handling Ammonia Monitor International Regulatory Developments for Audits Skim Oil and Save Prevent Chemical Vapor Intrusion Spill Control and Containment Products Pumps and Systems Equipment PE Products Classified Marketplace Advertisers Index State Rules

Pollution Engineering - November 2008

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