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heels in returnable totes



A paint supplier started shipping their product out in returnable totes.  It works great in that a lot of waste is abated, but there is a problem.  The totes often come back with some dried up residue in the bottom which they dispose of.  So, although a lot of the waste is abated for their customers, this suppliers hazwaste is increasing.  
Some of the ideas we have so far include:
1. Train the customers to drain the totes completely before returning.
2. Analyze the residue and see if solvent can be added to make it into a primer or other useful product.

Any other bright ideas?



Tomas Vinson
www.srwm.org

Fax: 512/239-3165
Phone: 512/239-3182

Engineering Specialist
TNRCC - Pollution Prevention
MC112
PO Box 13087
Austin, Tx 78711-3087
tvinson@tnrcc.state.tx.us


Disclaimer:  Regulatory guidance  e-mails are provided to quickly get you an answer to legal requirements.  They are not a substitute for compliance with the regulation, but guidance based on the best information available to the staff of TNRCC at the time.



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