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Re: Solvent recycling question



In Iowa, per the federal RCRA regulations, I teach that the waste is counted
once during the calendar month. That a 5 gallon batch of solvent can be
used, recycled through distillation and reused in the same calendar month
and only count as 5 gallons of hazardous waste generated that month.

I go on to say that the time spent tracking the waste may be more costly to
the facility than just simply adding 5 gallons to the month hazardous waste
inventory each time a batch is distilled.

The System One mineral spirits parts washer currently distributed by
Safety-Kleen takes the tracking out of the process. Since the parts washer
and the distillation unit are packaged together the machine only has the
ability to generate as much waste as the holding capacity of the machine. I
guess in Kansas, the operator would have to tally the number of time the
recycle button was pushed.

Uni-Ram has a similar design for gun wash cleaning/thinner distillation.

And, so as not to be out of character, I will place a plug for the IWRC
website -
Our vendor database to locate makers of distillation unit can be found at:
http://www.iwrc.org/tools/tools.cfm

And the Cost calculators to help make a cost/benefit analysis for thinner
distillation can be found at:
http://www.iwrc.org/programs/calcs.cfm

Thanks,
Sue

Sue Schauls
Program Manager
Small Business Pollution Prevention Center
Iowa Waste Reduction Center
1005 Technology Parkway
Cedar Falls, Iowa 50613
1-800-422-3109
319/273-8905
Fax: 319/268-3733
Sue.Schauls@UNI.edu
----- Original Message ----- 
From: "Nancy Larson" <nlarson@ksu.edu>
To: "This is a mailing list for P2 providers in Region 7" <p2r7@p2ric.org>
Sent: Monday, October 20, 2003 11:28 AM
Subject: 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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