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Questions and Answers From PNEAC Shop Towel Webinar 2004


© PNEAC

NO FREE LIQUIDS/DRY CONDITION DEFINITION/SOLVENT REMOVAL

1. Q: How do you define “no free liquids”?

A: In the current proposed rule, the term “no free liquids” has been defined to mean that no liquid solvent drips from the contaminated wipe when moved from one container to another. Also, there can be no liquid solvent in the container holding the wipes.

2. Q: What other methods are acceptable for removing solvents besides centrifuge?

A: As a performance standard, for disposable towels, you can use any method that you wish as long as you meet the 5 grams of solvent per towel standard. This would be considered “dry” condition as outlined in the rule.

3. Q: What sample method is required for determining the 5 grams of solvent?

A: The proposal outlines several methodologies that can be used to meet this standard:

a. Removal by centrifuging or other high performance solvent extraction technology;
b. Use of normal business records;
c. Sampling to measure the amount of solvent used per wipe; and
d. Sampling to measure the amount of solvent remaining on the wipes when cleaning is completed.

4. Q: Are the "dry" condition tests either/or or must you meet all three?

A: The conditions listed in the proposal are an either/or scenario.

5. Q: How do you know that if a rag is centrifuged it contains less than 5 grams of solvents (does it not depend on size)?

A: In the process of developing the rule, EPA examined the common solvent removal techniques employed by printers and determined that a centrifuge will remove enough solvent, regardless of towel size, to meet the 5 gram limit. EPA is seeking comment on the efficiency of the other solvent removal techniques.

6. Q: How do we calculate the "dry" condition of less than 5 grams for disposable wipes when the wipes will also contain inks?

A: The weight of any solid or other materials is not to be taken into account when determining the amount of solvent remaining on a towel. One method to determine how much solvent remains on a towel after cleaning is to simulate the cleaning cycle with solvent, without actually cleaning the material such as ink, and weigh the towel before and after cleaning. The rule also allows for the use of business records to demonstrate compliance.

7. Q: Does the same requirement of no more than 5 grams of solvent apply to reusable wipes as a preparation for shipment?

A: No, the 5 grams of solvent requirement applies to only those towels that will be disposed in a landfill or sent to a municipal landfill and must meet the “dry” condition, assuming that none of the solvents found in Table 1 are present. Reusables, towels must meet the “no free liquid” standard.

8. Q: When calculating 5 grams of solvent when weighing, how do you account for solids that may have been picked up?

A: The weight of any solid or other materials is not to be taken into account when determining the amount of solvent remaining on a towel. One method to determine how much solvent remains on a towel after cleaning is to simulate the cleaning cycle with solvent, without actually cleaning the material such as ink, and weigh the towel before and after cleaning. The rule also allows for the use of business records to demonstrate compliance.

9. Q: What if I have been using a centrifuge to remove solvent, but technically the reusable rags would meet the dry condition before centrifuging? Would I be allowed to discontinue centrifuging?

A: According to the rule, yes. However, by centrifuging you will be removing more of the solvent which then, perhaps, you can recover and reuse.

10. Q: What happens if I let my rags air dry?

A: Even now, soiled shop towels are to be kept in covered containers to minimize air emissions. They can be dried by evaporation if the emissions are directed to an oxidizer or other control device.

11. Q: Can wipes be dried by evaporation if emissions controlled by oxidizer or other control device?

A: Yes

12. Q: You state removing solvents by hand...Do you mean hand wringing? If so, is this subjective meaning that people have different hand strength?

A: It is subjective regarding hand strength. Regardless, the towels must meet either the 5 gram standard for disposables, and the no free liquid standard for reusables.

13. Q: Is there a standard towel size?

A: No

14. Q: Will the size of wipes be considered in determining the 5 grams of solvent per wipe?

A: No, there is no consideration for the size of the towel as the risk assessment conducted on the solvents was based on the amount of solvent and not the size of the towel.

15. Q: Is there any de minimus level for use of the solvents identified in Table 1 that would still allow land disposal?

A: As currently proposed, any concentration of the solvents identified in Table 1 would disqualify the towels from being landfilled.

16. Q: Is there a % limit on these solvents on the rags or are does the % matter?

A: No, the requirements that apply to the disposable towels is a 5 gram per towel solvent weight and for reusable towels, they must meet the “no free liquids” requirement.

17. Q: What about free liquids that are not hazardous waste? How will this be dealt with?

A: If the solvents that you are using would not be classified as a hazardous waste, then the rule does not apply to the towels that are used to clean with the solvents. Also, liquid non-hazardous wastes are generally shipped off site as such.

18. Q: You are basically requiring all facilities to centrifuge, wring or test wipes to ensure no free liquids are in wipes - or are there other ways to ensure they do not contain free liquid?

A: Right now, the proposal states that to meet the “no free liquid” standard, a towel must not drip solvent when moved from one container to another. There are no removal technologies associated with meeting this standard.

To meet the “dry” standard, i.e. less than 5 grams of solvent per towel, there are more stringent removal technologies suggested, or you can use normal business records to show that less than 5 grams of solvent remain on the towel.

19. Q: If I hand wring a wipe, I'm assuming I can re-use the solvent to wipe down the press?

A: Yes, the recovered solvent can be used as many times as possible. The solvent only becomes a waste once it has been determined by the generator that it can no longer be used without some type of treatment.

20. Q: If a shop towel contains a petroleum solvent that is not a listed waste and the flash point is higher than 140°F, can the towels be sent to an industrial landfill?

A: Yes, because the towels would not be subject to the regulation, assuming that there are no other contaminants on the towel that would be classified as a hazardous waste; e.g. the solvent does not exhibit a characteristic of a hazardous waste or contain a listed solvent.

21. Q: Does benzene have to be used pure or as a component in any solution?

A: As currently proposed, any concentration of the benzene would disqualify the towels from being landfilled.

22. Q: The mineral spirits that we use has a flashpoint of 104°F, would the towels that we use with this solvent be covered under the rule?

A: Yes, since the solvent has a flashpoint less than 140°F, then it would be classified as an ignitable (D001) hazardous waste and the towels used with this solvent would be subject to the rule.

23. Q: If a solvent used with a disposable towel contains less than 1% of a listed or characteristic solvent that is identified on Table 1, is there an exclusion for that chemical from the hazardous waste classification, meaning that the shop towels could still be sent to a landfill?

A: If the solvents used to clean are not considered listed or characteristic, then the towel would not be subject to regulation as a hazardous waste. The classification of the towel as being a hazardous waste depends upon the classification of the solvent applied to the towel, not how much solvent remains on the towel after use.

24. Q: Can you describe other mechanical means besides centrifuge?

A: Mechanical means include, but are not limited to, microwave solvent recovery technology, mechanical wringing devices, or any other type of separation technology that involves devices other than hand wringing activities.

25. Q: How would a wipe contaminated with an acute hazardous waste be managed?

A: Disposable wipes contaminated with an acutely hazardous waste would need to be managed as acute hazardous waste. It is unclear at this time what standards reusables would need to meet.

26. Q: Why were those particular 11 solvents chosen? Might others be added to this list?

A: The 11 solvents were chosen based on their toxicity characteristics. As with other US EPA regulations, it might be possible to add other chemicals to the list through a petition process.

27. Q: For those 11 solvents excluded, why would they still be a listed hazardous waste not allowed under the exclusion if they meet the treatment standard?

A: We are working on providing an answer to this question.

28. Q: Do the exclusions apply to wipes contaminated with inks that contain lead, cadmium, or other hazardous constituents?

A: The rule specifically states that the mixture and derived from rules will continue to apply to solvent contaminated shop towels. So, a towel contaminated with a listed heavy metal must also pass the TCLP (toxicity characteristic leaching procedure).

29. Q: Does the 5 grams of solvent per wipe pertain only to disposables?

A: Yes, the limit applies to only those towels that are to be sent off-site to a municipal landfill or municipal incinerator.

30. Q: How does the amount of solvent left in a rag for landfilling compare to the residues left in a container meeting the definition of "empty?”

A: At this time there is no correlation between the two standards.

31. Q: Will the required dry condition of disposable wipes in landfills result in a greater volume of disposable wipes in landfills?

A: Though this is hard to predict, the general consensus is no. Facilities choose the type of towel to be used based on their manufacturing process, not necessarily on the ease of disposal.

32. Q: If you use a vendor to collect your shop towels, who is responsible for ensuring that the towels and containers meet EPA requirements?

A: The generator is responsible for ensuring that the requirements being established for the generator are being met (e.g., containers, labeling, no free liquids, less than 5 grams of solvent, no Table 1 solvents in disposable towels being sent to landfill or incinerator, etc.,), and the vendor is responsible for the requirements being met which are established for the vendor.

33. Q: I am currently keeping my reusable towels in open containers. They sit in open containers until the laundered service picks them up. I am currently not managing them as a hazardous waste. Am I currently in non-compliance?

A: It depends upon the classification of the solvent you are currently using and the state in which you are located. If the solvent is not classified as a hazardous waste when spent, then there are no compliance requirements. If the solvent is hazardous, then each state has its own policy as to what specific requirements must be followed for the towels to be considered exempt as a hazardous waste. Most states do require the removal of free liquid.

34. Q: Please comment on the "catch 22" that exists between trying to "dry" wipes before transporting, and yet trying to meet air regulations and hazardous waste regulations of closed containers? Our dry cleaning company will not take any rags that are damp, and yet it's impossible to get them dry without air drying.

A: Many states currently include requirements in their air standards that require facilities to keep shop towel containers covered. The requirement more often refers to the “no free liquid” standard. Companies do not want to transport drums of shop towels that contain free liquids.

CONTAINERS/LABELING/SHIPPING

1. Q: Do the drums have to be labeled by ARAMARK prior to them being transported out of our building?

A: Under the proposal, there is no requirement to label containers of contaminated reusables. However, there still may be a DOT labeling requirement that may be applicable.

2. Q: Do the drums used to collect used towels need to be labeled?

A: The only labeling provision in the proposal is for containers of disposable towels. The drums would be required to have a label that states “excluded contaminated solvent wipes.”

3. Q: What type of container is waste to be shipped in? Barrels, bags or boxes?

A: By waste, if you are referring to the solvent removed from the towels, then it must be shipped according to current hazardous waste standards, labeled and in closed containers. If you are referring to the rags themselves, it depends if the shop towels are destined for land disposal or if they are destined for a commercial launderer or dry cleaner.

If the rags are being sent to a landfill or incinerator, then they must be shipped in a labeled, covered container. If to a laundry or dry cleaner, the proposal seeks clarification on this issue. Currently the proposal allows the shipment of reusables in bags.

4. Q: Is a closed plastic bag acceptable as a shipping container?

A: The current proposal would allow the use of a closed plastic bag for contaminated reusables being sent to a commercial laundry or dry cleaner. The proposed requirement states that bags must minimize releases to the environment.

5. Q: Do covered containers have to meet any specifications?

A: The proposed rule does not contain any specific requirements.

6. Q: Should the containers be labeled to meet the DOT standards for shipping hazardous materials (i.e. ignitable)?

A: Labeling to meet DOT shipping requirements is the responsibility of the shipper.

7. Q: Could you describe a "closed container?"

A: EPA does not define what constitutes a "closed container" in its regulations. In the proposed shop towel regulation (68 FR 65597), is taking comment on what would be considered a closed container. The proposal states "By closed containers, we specifically mean containers with a lid that screws on to the top and must be sealed to be considered closed."

8. Q: What about DOT requirements for transported waste?

A: It is the shipper’s responsibility to determine how to properly label and placard for DOT shipping.

9. Q: How do DOT regulations apply to shipping of these wipers if they are hazardous materials? Especially the intra company transport before free liquids are removed.

A: DOT regulations do apply when shipping wipers offsite for treatment. We will be providing an answer soon regarding intra company transport and applicability of DOT regulations.

10. Q: When transporting solvent towels in plastic drums, they have to be covered. Does it also have to be sealed with a metal ring?

A: No, the proposal states that the containers are to be covered, not closed. Closed implies that the container must be sealed.

11. Q: Would I have to manage untreated rags (i.e. ones w/ free-liquids) as hazardous waste prior to treatment? In other words, would they have to be labeled as hazardous waste, kept in closed containers, be subject to inspections, etc.?

A: Based on the proposed language, no. Contaminated disposable wipes, if handled according to the provisions in the proposal, would never fall under the purview of the hazardous waste regulations. And, contaminated reusables would not either.

12. Q: Under the proposed rule, what type of liability will be involved for generators sending reusable wipes to drycleaners, etc.?

A: The only provision in the proposal that addresses this issue concerns the shipment of contaminated towels that might contain free liquids. If towels are accepted by the commercial laundry or dry cleaner, and found to have free liquids, the receiving facility can either remove the liquid and handle as a waste product. Or, the receiving facility can send the towels back to the generator.

13. Q: The same containers are not used for storage and transportation. In the rule you write about labeling containers used to transport but not containers used for storage/collection. So what of labeling at point of collection?

A: At this time, the rule does not address labeling at point of generation.

14. Q: If you use a vendor to collect your shop towels, who is responsible for ensuring that the towels and containers meet EPA requirements?

A: The generator is responsible for ensuring that the requirements being established for the generator (e.g., containers, labeling, no free liquids, less than 5 grams of solvent, no Table 1 solvents in disposable towels being sent to landfill or incinerator, etc.,) are being met and the vendor is responsible for the requirements being established for them.

DISPOSABLE VS. REUSABLE

1. Q: What is classified as a disposable wipe?

A: Any towel that is used once and destined for disposal. This would include woven and non-woven towels that might under some conditions be laundered or drycleaned.

2. Q: Could a reusable wipe be cleaned on-site (rather than commercial laundry)?

A: Yes, and the provisions that apply to reusables being sent off site, apply as well to facilities laundering on site.

TREATMENT DEFINITION

1. Q: Is distilling the waste to recover a reusable solvent considered treatment?

A: Right now, it depends on the state program requirements. The proposal seeks to change this by clearly indicating that removal of solvent from the shop towel should not be considered treatment under the RCRA program.

2. Q: If wipes were centrifuged and the spent solvents recycled by distillation, would the distillation process be covered under the "no permit needed" clause?

A: At this time, both centrifuging and recycling by distillation would be covered under the “no permit needed” clause.

INTRA-COMPANY TRANSFER

1. Q: Within what radius would an intra-company transfer be allowed?

A: This is not defined in the proposed rule.

2. Q: If I perform an intra-company transfer of rags with free-liquids to another sister facility for treatment, I would be shipping hazardous wastes to a non-designated facility. Thus, I would be circumventing hazardous waste permitting requirements. Would this be legal?

A: At this time, the proposed language allows facilities to ship containers of shop towels, with free liquids, to a central processing unit. The question has been raised regarding how far these towels could be shipped, and it is anticipated that this issue will be resolved once the rule becomes final.

3. Q: Will there be any restrictions on miles when referring to "Intra-Company transfers?

A: The US EPA has raised this as an issue within the proposal, and it is anticipated that it will be addressed in the final rule.

DISPOSAL

1. Q: Is a municipal trash to energy plant considered an incinerator?

A: Yes

2. Q: If dry wipes qualify to go to a municipal landfill, they should be ok to just put in the trash, not need separate labels. Why does the rule require separate accumulation containers?

A: The Agency requested comments on this issue in the proposal and it will be addressed in the final rule language.

3. Q: Are there restrictions regarding the use of energy recovery for management of disposable wipes?

A: No, the towels need to meet the requirements established for that route of disposal. The handling and disposal requirements are tied to the fate of the towel, not the type of towel.

4. Q: If we incinerate used towels onsite in an industrial boiler and if they are kept in covered containers, what is the no free liquid requirement for our towels? And can we collect them in bags since they are not going to be transferred offsite?

A: We are working on providing an answer to this question.

GENERAL RULE

1. Q: When will this rule come into effect?

A: The rule will become effective 90 days after it becomes final. However, as this rule is classified as a “deregulatory” action, states have discretionary authority as to whether or not they incorporate the rule into their RCRA standards.

2. Q: How does the proposed rule promote pollution prevention by printers?

A: The rule encourages printers to utilize solvents with flashpoints above the 140° F limit, which would exclude them as hazardous waste. Also, the rule encourages printers to seek out solvents that do not contain any of the listed solvents. Most importantly, the amount of solvent being sent in the towels to the laundry facility will be greatly reduced. If a printer is going to landfill towels, the rule encourages them to use less solvent and in order to meet the 5 gram standard, the recovery of solvent that can be recycled and reused.

3. Q: Is there a list of states that MUST automatically adopt EPA rules?

A: No states will be required to adopt these rules. There are a few states in which the solid waste program is managed by USEPA. Once this rule is promulgated by USEPA, it will apply in those states.

4. Q: Will the RCRA permit requirements for treatment be lifted by the states through this rule?

A: Since this rule is a deregulatory rule, states and local government authorities are not required to adopt the rule. While the rule will not require a RCRA permit, the requirement for a permit will be at the discretion of the individual state or local agency.

5. Q: Can outreach be done (by GATF/PIA) to encourage states to adopt the eventual final rule as written?

A: Yes, all of the associations GATF/PIA, SGIA, FTA, and GAA will be working with states to encourage them to adopt EPA’s rule when it is released in final form.

6. Q: If generators of wipes/towels contaminated with hazardous solvents are not required to obtain a permit, then how will the regulatory community be able to monitor the management of the wipes/towels unless we presume that all such generators would have a pre-existing permit for their other activities?

A: Right now, generators are not required to obtain a permit for the generation of any hazardous waste.

7. Q: How would this apply to college or universities art departments where wipes and rags with turpentine?

A: It is important to understand that colleges and universities are not exempt from hazardous waste regulations as this is a common misconception. Turpentine is a form of mineral spirits and if the flashpoint of the turpentine is less than 140oF, then the towels would be subject to this rule.

8. Q: Although intended primarily for the printing industry will this exclusion be applicable to all operations using handwipes?

A: This rule affects a number of other manufacturers in addition to printers. The rule would apply to any industry or facility that generates solvent laden used shop towels, either reusable or disposable.

9. Q: Is there any provisions being considered for those users that may be capturing the solvent from their wipers for recycling? Would they have to continue to handle the solvent when shipping it offsite as a hazardous waste?

A: This rule would not change the current requirements associated with the collected solvent. If the collected solvent would be classified as hazardous waste, it would be subject to the hazardous waste requirements that are applicable to it.

10. Q: Are "wash up mats" used on small litho presses included in the definition of disposable wipe?

A: No.

11. Q: Can wipes with inks be laundered?

A: Yes, this rule does not change how reusable wipes are cleaned.

12. Q: To what extent would cause another so-called "straw on the camels back" for the small mom & pop businesses across America?

A: The goal of this proposal is to help establish a clear regulatory direction for the handling and disposal of contaminated shop towels, either reusable or disposable. Currently, facilities are unaware of the requirements placed on them regarding disposal of shop towels, and the rule seeks to provide a strong, clear framework.

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