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Solvent recycling question



Greetings:

Is solvent that is recycled on-site, counted towards a generators total
monthly hazardous waste generation in your state?

In Kansas, the regulations require that each time a solvent is dumped into a
still it must be counted towards the generators monthly hazardous waste
total.  Meaning that if the same 5 gallons of solvent is distilled six times
over that month, then the generator records a 30 gallon generation, not
simply a five gallon generation or the resulting still bottoms.  From a
regulatory burden standpoint, this is an obvious P2 disincentive and we are
researching ways to change this regulation.

How does your state handle this?

Thanks in advance for your time!

Nancy J. Larson, RS
Industrial Pollution Prevention Specialist
KSU Pollution Prevention Institute
7001 West 21st Street North
Wichita, KS 67205
316/722-7721 ext. 104
800/578-8898
www.sbeap.org
NLarson@ksu.edu


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