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re: Cayenne pepper sludge - Solvent Recycling Recordkeeping



Title:
I agree with Ms. Engel-Cox. People routinely spread cayenne pepper (store bought as a spice) around their gardens to keep out rodents, rabbits and such. But there is no product I'm aware of that can be bought at a gardening store in larger quantities (quart or gallon sized) to do the same. So this becomes a project for the company's marketing folks: how to take the by-product, convert it into a preferred form (dry or liquid) that can be packaged as a saleable product to gardeners, and sold through lawn and garden shops as a "natural, organic," pest- and rodenticide.
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The other thing I wanted to comment on is this "multiple counting" of recycled solvent issue, as delineated by Ms. Larsen in Kansas. There is something drastically wrong with the interpretation of this rule in calculating volume of generated waste. Usually, the amount purchased is a factor in this calculation: i.e.,

amount purchased - amount used in process - amount lost to other media [air emissions, etc.] + contaminants picked up in process = volume of haz waste generated .

How can you buy 5 gallons of a solvent and have it transformed into 30 gallons (on paper) of waste by the end of the month through 6 recyclings? The mass balance obviously doesn't work out. More to the point, if the client is recording 30 gallons of waste, but only shipping 5 gallons (plus a little sludge from the recycling process) off-site at the end of the month, doesn't anyone ask what happened to the other 25 gallons? Well, it never existed.

Either a formal regulatory interpretation / guidance document is called for, or the drafters need to get busy revising the regulation itself. It doesn't match physical reality.
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>> The request is from a company that uses cayenne pepper in the
>> manufacturing of
>> sore muscle rubs. Olive oil and the cayenne pepper are mixed together for
>> a
>> time - then after the pepper infuses the oil the olive oil is strained
>> out.
>> This leaves a cayenne pepper sludge as a by-product. Any ideas for use of
>> this
>> by-product to avoid disposal?

>> Thanks,
>> Judy Wlodarczyk
>> Environmental Management Specialist

>> CONNSTEP, Inc.
>> 1090 Elm St.
>> Suite 202
>> Rocky Hill, CT 06067
>>
www.connstep.org

>> Phone: 860-644-9718
>> Fax: 860-529-5001
>> Email:
jwlodarc@connstep.org



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