Paint Booth Filters

["Richard Illig (717) 327-3568" <ILLIG.RICHARD@a1.pader.gov>]

    Mike,
    
    If the filters you referenced were determined to be hazardous 
    waste, baking them dry in an oven would most likely be considered 
    treatment.  (In my opinion) You should attempt to work with the 
    solid waste division of your environmental control agency (I know 
    ours will work to resolve a problem and not "bust your chops" if 
    you approach them, rather than they discover the activity during 
    an inspection) to clarify applicable regulations.  Potentially, 
    there might be a way to categorize the activity as a "recycling" 
    or "use as fuel"-type exemption.
    
    The presence or absence of free liquids may have a lot to do with 
    the hazardous waste determination performed by your facility.  
    Little "tricks" like leaving the filters in a booth until they dry 
    slightly could make a big difference.  If you place the filters in 
    a drum prior to baking and free ignitable liquids (hazardous) 
    accumulate you may have problems.  Again, I suggest you work with, 
    or at least run your hazardous waste determination past, your 
    state agency for some agreement prior to putting your neck on the 
    cutting block.
    
    Even if the filters are determined to be non-hazardous, there may 
    be regulations that address the processing of residual waste by 
    your facility.
    
    Ric