SOLVENT WASTE REDUCTION AND RECYCLING

Practical Advice for Small Business

Iowa Waste Reduction Center

University of Northern Iowa

I . .

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0 1992,

Iowa Waste Reduction Center

University of Northern Iowa

This manual was developed by Diane Gere, Technical Writer for the Eastern Iowa
Community College District and by David Foss, Ph.D., Environmental Department of the
Rock Island Arsenal for the Iowa Waste Reduction Center, University of Northern Iowa.
The manual includes material prepared by the Iowa Waste Reduction Center for small
business. Review and editing was performed by the staff of the Iowa Waste Reduction
Center.
Any trade names of commercial products referenced in this manual are not necessarily
endorsed or recommended by the Iowa Waste Reduction Center, Eastern Iowa Community
College District, or the Rock Island Arsenal.
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SOLVENT WASTE REDUCTION AND RECYCLING

Contents

PART I

BACKGROUND INFORMATION
Waste Reduction Incentives
Frequent Sources of Spent Solvent
- Documenting Waste Reduction
Financial Considerations
Important Terminology

PART 11

GOOD MANAGEMENWOPERAT~NG PRACTICES

Checklist 1 Personnel Practices '
Checklist 2 Procedural Measures
Checklist 3 Loss Prevention Measures
Checklist 4 Wastestream Segregation
Checklist 5 Material Handling and Storage
Checklist 6 Parts Cleaning
Checklist 7 Process Equipment Cleaning
Checklist 8 Surface Coating Applications

PART I11

PROCESS AND MATERIAL MODIFICATIONS

Abrasive Cleaninfltripping
Aqueous Cleaning of Equipment and Parts
Circulating Solvent-type Washers
Countercurrent Washing
Drag-out Reduction
Paint Spraying Techniques
,
Powder coating

PART IV

RECYCLING TECHNOLOGIES
Distillation
Ultrafiltration
Off-site Recycling Services

APPENDICES
A Endnotes, References, and Acknowledgments
B Conditionally Exempt Small Quantity Generator
Requirements
C Small Quantity Generator Requirements
D Used Oil Regulations
E TCLP Parameters; SWA Parameters
F Companies Distributing Alternative Solvents
G Analytical Laboratories
H Distillation Equipment Vendors
I EPA Notification of Regulated Waste Activity
J Hazardous Waste Label
K Uniform Hazardous Waste Manifest
. . ..
L Notification af Treatment Requirements
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PART I
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BACKGROUND INFORMATION

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Reducing any waste makes good business sense. Reducing hazardous waste isma necessity.
This manual is directed toward business owners, managers, and workers who are looking for
- ideas and guidance in reducing and recycling solvent waste. Whether you call it "waste
.minimization," "waste reduction," or "pollution prevention," the good news is that business
people who have engaged in a waste reduction program at their work places are quick to
- . point out "the bottom line"; in other words, waste reduction can save money! A manager
who reduces the generation of hazardous waste shows concern not only for that "bottom
line" of cost effectiveness but also for worker health and for the environment. The bonus
is that all of these factors contribute to a company's positive image in the community
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Incentives for solvent waste reduction can be categorized as:
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Costly off-site treatment technologies.
Raw material and manufacturing costs.
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Certification of a waste minimization program on the hazardous waste manifest.

Regulatory responsibilities and associated
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Liability:
1 Generator liability for environmental problems at both on-site and off-site treatment,
storage, and disposal facilities.
Employer liability for worker safety.
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Public Image and Environmental Concern:

Image in the community and with employees.
Concern for improving the environment.

Your motivation for studying this manual's solvent waste reduction strategies may be to
protect the community for your family and your neighbors; it may be to escape the
complexities of federal and state environmental regulations; or it may be to avoid the costs
of waste disposal. Whatever your motivation, you are likely to discover that waste reduction
is just plain good business!

FREQUENT SOURCES
OF SPENT SOLVENT
Solvents are commonly used in
these operations:
w Dry cleaning
w Cold cleaning (for example,

vehicle parts washing)

Vapor (hot) degreasing
Painting
w Printing (inks and press
cleaning)

Solvents are also used in the

production of:
Coatings
W Stains
w Wood-treatment chemicals
Printing inks
Pesticides
Agricultural chemicals
w Polyurethane foam
w Chemical and pharmaceutical
formulations
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Thefocus of this manual is the reduction and recycling of spent solvents resulting .
from equipment cleaning, parts degremng, and surface finishing.

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it& recybling'of sol~k~t~$ignificantly

reduces the' gdk&ition of hazard6ushaste. The
,,c:.examp]e below1 (see Appendix A, "Endnotes"), which is based on a business using 10 gallons
of solvent weekly, shows that hazardous waste generation decreases from 40 gallons of
solvent waste for a month to 13 gallons of solvent and still bottom waste (still bottoms are
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~y, DOCUMENTING WASTE REDUCTION

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Each' calendar month, the original volume of solvent waste must be counted. This means
that during the second month, the first ten gallons of hazardous waste generated must be
,counted even if it is derived from previously recycled solvent. This makes sense if you
'consider that some day the original 10 gallons must be counted as waste (theoretically or
actually).
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Week 1:
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Ten gallons of new thinner are used to clean gun lines and other equipment.
On Friday, the spent thinner is placed in the still and recycled. Nine gallons
are recovered as clean solvent while one gallon contains the contaminants.
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The hazardous waste generated so far is ten gallons (the original ten gallons
that was spent and needed to be recycled).
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Week 2:

Nine gallons of cleaned thinner are mixed with one gallon of new thinner so
that again we have ten gallons of thinner for the week. On Friday, the spent
thinner is placed in the still and recycled. Nine gallons are recovered as clean
solvent while one gallon contains the contaminants.
The TOTAL hazardous waste generated so far is eleven gallons (the original
ten gallons plus the one new gallon that became spent during the week).

Week 3:

Same as week 2; the TOTAL hazardous waste generated so far is now twelve
gallons.

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Week 4:

Same as weeks 2 and 3; the TOTAL hazardous waste generated in four weeks
(one calendar month) is now thirteen gallons.

Keep in mind throughout the examples of these few pages that disposal of still bottoms will
depend on the constituents that have been recycled (for example, thinner and paint). If the
constituents contain flammable liquids or "F-listed" solvents, then the still bottoms will be
considered hazardous waste and must be disposed of appropriately.
On the other hand, some businesses find potential uses for still bottoms. For example, if still
bottoms are extremely thick, they might be mixed with typical undercarriage coating material
and then used. This completely eliminates the need for disposal.

DOCUMENTING MANUFACTURING WASTE REDUCTIONS

In manufacturing, one method of documenting waste is to calculate the "actual quantity
change" of waste generated.2 Based upon Hazardous Waste Manifest data, simply subtract
the quantity generated in the current reporting year from the quantity generated in the
previous year.
(Note: The Hazardous Waste Manifest does not account for all waste generated;
VOC emissions and wastewater effluent, for example, are not accounted for in the
Manifest).

"adjusted quantity
Another method manufacturers use to calculate waste reduction-the
change indexu-is appropriate for businesses that increase their production output (of
products) compared to the previous reporting year. For example, suppose a small
manufacturing company begins a waste reduction program. In year one the company
produces 5 tons of hazardous waste and 15 tons of product. In year two it produces 7.5 tons
of waste and 25 tons of product. Although it appears, at first glance, that the company's
waste reduction program did not succeed, the quantity of waste actually decreases almost
10 percent when you consider it in proportion to the total output.

FINANCIAL CONSIDERATIONS
The payback period for a project is the amount of time it takes to recover the initial cash
outlay on the project. The formula for calculating the payback period on a pre-tax basis is
the following:3

PAYBACK PERIOD =

CAPITAL INVESTMENT
ANNUAL OPERATING COST SAVINGS

For example, suppose a waste generator installs a system at a total cost of $10,000. If the
piece of equipment is expected to save $4,000 per year, then the payback period is 2.5 years.

In figuring annual operating cost savings, focus on:

w Waste disposal,
W Waste transportation,
w Recordkeeping,
E Insurance,
E Regulatory requirements, and
w Lab analysis costs.
Other costs you may need to consider include utilities, labor, and maintenance.

RECYCLING SOLVENT - A FINANCIAL IMPACT SCENARIO

Based upon the sample business presented on page 7, let's look at the financial impact of
installing a distillation unit for recycling used s01vent.~
We will compare one month's operating expenses, first without distillation and second, with
distillation. Recall that the sample business uses 10 gallons of solvent each week. Next, we
will use the payback formula to analyze the time it takes to achieve a return on investing in
a small distillation unit.

Operating Cost Savings: The operating costs for purchasing virgin solvent and for disposing
of the solvent waste are as follows:
= $160 per month
Virgin solvent cost: $4/gallon
$200/drum or $4/gallon = $160 per month
Solvent disposal:
Total expenses without on-site recycling:
= $320 per month or $3840 per year

The operating costs for purchasing the original 10 gallons of virgin solvent plus the 1 gallon
of make-up virgin solvent for the next three weeks and for disposing of 4 gallons of still
bottoms at the end of the month are:
FIRST MONTH EXPENSES:
Virgin solvent cost first month:
$4/gallon (x 13 gal) = $52
Still bottom disposal: $400/drum or $8/gallon
= $32 month
Total expenses with on-site recycling:
= $84 first month
SUBSEQUENT MONTHLY EXPENSES:
Virgin solvent cost subsequent months: $4/gallon x 4 gal
Still bottom disposal: $400/drum or $8/gallon
Total expenses with on-site recycling:

= $16 month
= $32 month
= $48 in subsequent

months
Adding the first month's expenses ($84) to the next 11 months' expenses (11 x $48), the
annual total expenses with on-site recycling are $612 the first year and $576 in following
years. The annual operating cost savings of recycling solvent on-site is:
$3840 - $612 (first year expenses) = $3228 savings

Additional savings might also occur in other areas, such as decreased need for waste storage
or insurance.
Payback on Investment in Distillation Unit: A small-capacity distillation unit currently costs
about $3000. To calculate the payback period, divide the investment cost of the unit by the
annual operating cost savings. Recall that the sample business is saving $3228 during the
first year.

Cauital investment
Annual operating cost savings

$3000
$3228

0.9 years payback period

Part IV presents additional information about economic considerations for installing solvent
recycling units (see pages 46-52).

IMPORTANT TERMINOLOGY
Before you begin exploring strategies for reducing and recycling spent solvents, you need to
understand the meanings of commonly used terminology:

Waste Reduction
Recycling
Generator
Solvent
Nonhalogenated Hydrocarbon Solvent
Halogenated Hydrocarbon Solvent
Volatile Organic Compound (VOC)
Liability
EPA Definition of Hazardous Waste
EPA Identification of Hazardous Waste

WASTE REDUCTION
Reduction is the preferred method of waste management. Waste reduction is any
activity that reduces or eliminates the generation of hazardous waste at the source,
usually within a process. Waste reduction may be achieved by several methods:
product changes, source control, raw material changes, technology changes, and good
operating practices. Waste reduction can also be termed waste minimization, source
reduction, or pollution prevention.

RECYCLING
Second in preference after waste reduction is in-plant recycling. Recycling consists
of "use and reuse" of materials or "reclamation" of materials. Use or reuse means
returning a material to the original process or using the material in another process.
For example, solvent used by a paint manufacturer as an equipment wash might b e
used in mixing the next batch of paint of the same color.
Reclamation, on the other hand, subjects a spent solvent to some technology that
restores it for reuse. Examples of reclamation technology are distillation and
separation. On-site recycling involves the use of equipment such as "stills" to reclaim
waste solvent. Such recycling yields some waste, such as "still bottoms'' or "settled"

materials; however, the amount of waste left for disposal is greatly reduced.
In off-site recycling, the solvent supplier picks up a business's spent solvent for
distillation. The regenerated solvent is sold as new. solvent and the still bottoms
generally are used as a supplemental fuel, especially for cement kilns. The
disadvantage of out-of-plant recycling is that the generator remains responsible for
off-site accidents and contamination.

GENERATOR
A Conditionally Exempt Small Quantity Generator (CESQG) generates less than 220
pounds of hazardous waste, or 2.2 pounds of acute hazardous waste, per calendar
month and never accumulates more than 2200 pounds total of all nonacute hazardous
waste on-site (or 1 kg of acute hazardous waste).
A Small Quantity Generator (SQG) generates 220 to 2200 pounds of hazardous waste
per calendar month, and never accumulates more than 13,200 pounds. Storage time
is usually restricted to 180 days.
A Large Quantity Generator (LQG) generates more than 2200 pounds of hazardous
waste per calendar month. Storage time is restricted to 90 days.
See Appendices B and C for the requirements for CESQGs and SQGs.

SOLVENT
A solvent is a liquid capable of dissolving another substance. Although water is
capable of dissolving certain substances (e.g., salt), industrial cleaning usually involves
the removal of oils and greases, which is readily accomplished by using hydrocarbonbased solvents; in other words, solvents whose origin is petroleum and that
contain the chemical elements hydrogen and carbon. Two types of hydrocarbonbased solvents are nonhalogenated and halogenated.

NONHALOGENATED HYDROCARBON SOLVENT

Nonhalogenated hydrocarbon solvents are petroleum-based chemicals that d o not
contain chlorine or related elements. Nonhalogenated solvents such as benzene,

toluene, xylene, and hexane are used as cleaners, as coating thinners (for paints,
varnishes, etc.), and as chemical constituents in the manufacture of some products
(plastics, insecticides, fuels, etc.).
Because they typically
have low flashpoints and
low boiling points, the
nonhalogenated solvents
present fire and explosion
hazards and must be
handled carefully in the
work place and in
transportation.

Common Nonhalogenated Organic Solvents

Naphtha, mineral spirits, Stoddard solvent, and
Varsol
Toluene, xylene, phenols
Ethyl acetate, butyl acetate
Butyl cellosolve, carbitol
Acetone, methyl isobutyl ketone o r MIBK, methyl
ethyl ketone or MEK
Methyl alcohol, ethyl alcohol, isopropyl alcohol

The low boiling points of

the nonhalogenated
solvents make them "volatile" materials. Volatile means that at normal temperatures
and pressures, a liquid easily becomes a vapor. Therefore, a hydrocarbon cleaning
(or paint-thinning) solvent, used inside an industrial plant, will release vapor that is
potentially hazardous for two reasons: (1) the vapor may b e flammable and could
travel through the air to a source of ignition, causing a fire or explosion, and (2) the
vapor may harm the workers who inhale it. In addition to presenting potential
worker hazards, nonhalogenated solvent emissions are contributors to air pollution.

HALOGENATEDHYDROCARBON SOLVENT
The halogens are a group of five chemically related nonmetallic elements, including
fluorine, chlorine, bromine, iodine, and astatine. Halogenated solvents are
compounds of one or more of the halogens and a carbon element, as in the following
examples:

Halogenated C o m ~ o u n d Halogen Element Carbon Compound

l , l , 1-trichloroethane
perchloroethylene
chlorobenzene

chlorine
chlorine
chlorine

ethane
ethylene
benzene

The halogenated solvents are preferred for vapor degreasing operations because their
flashpoints are in a higher range than
those of the nonhalogenated solvents
and they are not usually ignitable.
Common Halogenated Organic Solvents
Halogenated solvents, in general, are
more toxic to humans and capable of
causing greater environmental damage
than the non-halogenated solvents.

trichloroethylene (TCE)
perchloroethylene (PERC)
l,l,l-trichloroethane (TCA)
carbon tetrachloride
methylene chloride (METH)
CFC-113

VOLATILE ORGANIC COMPOUND (VOC)

The low boiling points of the nonhalogenated and halogenated solvents place them
in the category of volatile organic compounds (VOC). Volatile means that the
material easily vaporizes. Most VOCs will be heavily regulated by new federal Clean
Air Act requirements during the 1990s.

LIABILITY
Such practices as dumping hazardous wastes on property, into the sewer system, or
into landfills are illegal. Because of "cradle to grave" liability under federal law,
industrial/commercia1generators of waste are liable forever for any damages resulting
from their wastes. Since generators have perpetual responsibility, they must make
careful hazardous waste management decisions. For example, selecting reputable
contractors for out-of-plant transporting, treating, and disposing of hazardous wastes
is as important as implementing proper in-plant practices.

EPA DEFINITION OF HAZARDOUS WASTE

Hazardous Waste - Solid waste, or combinations of solid waste, that because of its
quantity, concentration, or physical or chemical characteristics, may pose a hazard
to human health or the environment.
For EPA purposes, solid waste is any solid material, sludge, refuse, or liquid that is
discarded or recycled.

EPA IDENTIFICATION OF HAZARDOUS WASTE

E P A identifies a solvent waste as hazardous if it is a listed waste, a characteristic
waste, or a waste mixture:
Listed wastes: Solvent waste is considered hazardous if it appears on one of the four
E P A lists of specific materials:

The
list (Wastes from Nonspecific Sources listed in 40 CFR Section 261.31)
Of particular interest in solvent waste management, these are generic wastes,
commonly produced by business and industrial processes. Examples from this
list include spent halogenated solvents used in degreasing and used paint
thinners such as xylene and toluene.
'%I

The "K' wastes (Wastesfrom Spec@c Sources listed in 40 CFR 261.32)

The "P"acutely hazardous wastes (Wastesfrom Commercial Chemical Products
listed in 40 CFR Section 261.33e)
The "U" toxic hazardous wastes (Wastes from Commercial Chemical Products
listed in 40 CFR Section 261.33f)

Characteristic wastes: Even if a waste does not appear on one of the E P A lists, it
is considered hazardous if it has one or more of the following characteristics:

Ignitability - With a flashpoint of less than 140F, the waste is easily

combustible or flammable, such as paint wastes, certain degreasers, or other
solvents.
Corrosivity - The waste dissolves metals, other materials, or burns the skin,
such as waste rust removers, waste acid or alkaline cleaning fluids, and waste
battery acid. Corrosive wastes have a p H of 2 or less or of 12.5 or greater.
Reactivity - The waste is unstable or undergoes rapid or violent chemical
reaction with water or other materials, such as cyanide plating wastes, waste
bleaches, and other waste oxidizers.
Toxicity - Through the Toxicity Characteristic Leaching Procedure (TCLP),
a waste sample extract is determined to contain concentrations of heavy

metals (such as mercury, cadmium, or lead); certain solvents; or pesticides in

excess of corresponding regulatory parameters.

Waste Mixtures: E P A considers any mixture containing a specifically listed hazardous

waste (F, K, U, P lists) to be a hazardous waste itself, regardless of the concentration.
Without this regulation, generators could evade E P A requirements by simply mixing
listed wastes with nonhazardous wastes.

PART I1
GOOD MANAGEMENT/OPERATING PRACTICES

It is always important to a company's competitiveness in the market place to increase

efficiency in operating practices. The good news is that increased efficiency is also one of
the quickest and most cost-effective ways to reduce waste generation. The practices outlined
in Part I1 require little or no capital investment.
The format of Part I1 is a series of checklists listing strategies that many small businesses
have found to be effective for reducing or eliminating solvent waste. Most of the strategies
simply reflect good administrative and housekeeping practices in general.
The checklists are entitled:
Checklist 1

Personnel Practices

Checklist 2

Procedural Measures

Checklist 3

Loss Prevention Measures

Checklist 4

Wastestream Segregation

Checklist 5

Material Handling and Storage

Checklist 6

Parts Cleaning

Checklist 7

Process Equipment Cleaning

Checklist 8

Surface Coating Applications

As you read the checklists, darken the circles and squares by any items that might apply to
your situation. You can return to these marked items after reading the rest of the manual
to assess applicability for your operation. Part 111, "Process and Material Modifications," and
Part IV, "Recycling Technologies," will expand upon numerous Part I1 checklist items.

CHECKLIST 1
PERSONNEL PRACTICES
MANAGEMENT INITIATIVES are those first steps taken to institute a waste reduction
program.
o Make waste reduction part of the company's philosophy, mission, and policy.
o Design an employee incentive program to encourage positive companywide
involvement in practicing good housekeeping and in following procedures. Reward
employee solutions through bonuses, publicity (newsletters, bulletin boards, trade
journal articles), and/or praise.
o Design an employee suggestion program to encourage creative problem-solving.
o Begin data-gathering and financial analysis about possible recycling technologies for
your company (Part IV, "Recycling Technologies").

EMPLOYEE TRAINING should include a program of instruction and ongoing

communication.
o Make employees aware of the rationale for waste reduction: hazardous waste
disposal costs, potential hazards, and liabilities. Educate employees about solvent
reduction techniques so that they will be able to initiate action if a technique might
apply to their operation.
o With expert first-line workers and supervisors, conduct a waste audit of each
operation, identifying the points in each operation where waste is or might b e
generated. Recognize that sometimes we do things because "that's the way it has
always been done"; whereas new techniques and technologies can improve processes
while decreasing waste.
o Design training that addresses any new and improved techniques identified during the
waste audit.
o Include waste reduction policies and procedures in new employee orientation.
o Formalize your training program. Some employers consider training to be n o more
than putting an inexperienced worker with an experienced worker for on-the-job
instruction, which can result in omission of information as well as in inadequate
understanding. The result may be inefficient use of trainer and trainee time and even
trainerltrainee frustration. Formalized training turns your operation's waste reduction
into written procedures that a trainee can study and practice with trainer guidance.

CHECKLIST 2
PROCEDURAL MEASURES
WASTE AUDITS AND REVIEWS help you identify your wastestreams and whenlwhere they
occur.
o The Iowa Waste Reduction Center at the University of Northern Iowa offers small
businesses free and confidential advice in auditing and reducing wastes. Telephone
(319) 273-2079.

The Waste Management Assistance Division of the Iowa Department of Natural

Resources offers large companies a similar program. Telephone (515) 281-5145.

DOCUMENTATION (i.e., written records) contributes to waste reduction by establishing an

information base. As your waste reduction program matures, your information base enables
you to make informed decisions.
o Design written Standard Operating Procedures (SOPS) for equipment cleaning or
parts cleaning operations; for example:
to control drag-in of water, which contaminates solvent;
to control drag-out of solvent;
to reduce vapor emissions, which result in loss of solvent;
to prevent spills and leaks;
to maintain product quality control, thus eliminating rejects that must be
scrapped or reworked;
for materials handling, especially during transfer and storage; and
for hazard recognition and emergency response.
o Write job descriptions and maintain training verification records, so that employees
are accountable for their responsibilities.
o Keep preventive and corrective maintenance records (page 21, "Loss Prevention
Measures).
o Document spills and releases and their dollar values.
o Properly label containers.

MATERIAL/WASTE TRACKING AND INVENTORY CONTROL enable you to avoid the

problems of solvent-use excesses and the disposal of out-of-date and no-longer-used
materials.
o Try to standardize your solvent purchases. Purchasing one solvent in larger quantities
rather than several solvents in smaller quantities opens the possibility for recycling

technologies. It also reduces the number of waste containers and residual solvent.
o Develop procedures whereby all solvent purchase orders must be approved by your
purchasing agent, who should be trained in the principles of solvent reduction. One
company uses a chemical-purchase "paper trail," routing purchase orders through
several persons for their analysis and approval. For example, a proposed chemical
purchase would need the signatures of the production supervisor, the heahhisafety
manager, and the purchasing manager. The paper trail is inconvenient enough to
discourage thoughtless purchases, thus ensuring protection of employees and the
environment as well as appropriateness for the company's inventory.
o Buy smaller quantities of limited shelf-life materials. Check the manufacturer's policy
for returning unopened containers of materials. Organize the storage and inventory
systems for timely use of shelf-life materials.
o Some small or medium-sized manufacturers that manage many materials and
products track them with computer software especially designed for inventory control.
Such a program enabled one company to question a large difference between input
materials and output of wastes and products. An investigation of the process
revealed excessive vapor emissions from a leak. Although the same input and output
measurements are possible without a computer, the software did enable earlier
detection.

SCHEDULING of operations may contribute to solvent waste reduction; for example:

o Try adjusting the frequency of process equipment cleaning. Companies that save
equipment cleaning for the end of the day or for a particular shift may find that
cleaning requires less solvent if performed immediately after equipment use. On the
other hand, eliminating unnecessary cleaning also reduces solvent waste.
o If storage space permits, produce larger batches of similar items so that process
equipment cleaning may be performed once.
o In paint manufacturing or in some surface coating applications, sequence batches
from light to dark colors.
o Train workers to coordinate operations for efficient use of materials. For example,
the owner of one auto body repair shop trained his employees to coordinate body
work. The solvent-based compound they use, once it is mixed, has a shelf-life of only
three hours. By checking with other workers at the beginning of the day, they
manage to time their activities so that only one container of compound is mixed and
subsequently passed from worker to worker. Thus they use every bit of mixed
compound and have only one container to maintain.

CHECKLIST 3
LOSS PREVENTION MEASURES
A SPILLILEAK PREVENTION PROGRAM includes development of SOPs, employee
training, and an inspection program; and it includes proper selection of solvent storage
facilities. EPA and D O T consider spilled hazardous materials to be hazardous waste.
o Develop solvent handling procedures and spill prevention plans and train employees
in them. For example:
keep solvent containers and storage tanks properly covered to control vapor
emissions. One paint manufacturer has reduced emissions by covering process
vessels with plastic film.
in large solvent-volume operations, when transferring solvent from one
container into another, immerse the end of the hose as you fill the container.
Avoiding splashing the solvent can reduce emissions by 50 percent. Be certain
all components are grounded during solvent transfer.
develop and administer SOPs forbidding employees to bypass interlocks and
alarms or to alter equipment settings without authorization.
train employees to refer to Material Safety Data Sheet (MSDS) sections on
special precautions and spillbeak procedures.
Install
adequate
secondary containment structures to capture spills; for example, build
o
a curb around the solvent drum storage area and around cleaning or recycling
equipment. Place smaller solvent containers into overflow trays. These measures
enable recovered solvent to be recycled for use; whereas, absorbent material used to
soak spills must be disposed,.usually as a hazardous waste.
o Use proper storage and process vessels that are compatible with the solvent to
prevent vessel degradation. Large vessels should have overflow alarms.
o Ensure that container and process equipment gaskets and seals are compatible with
solvents t o prevent deterioration that leads to leaks. Use seal-less pumps and
bellows-seal valves.
o Operations that use compressed air should be kept away from solvent operations,
because increased air movement might aggravate "fugitive" (in other words,
unplanned or unaccounted for) emissions of vapor.

CHECKLIST 4
WASTESTREAM SEGREGATION
o D o NOT mix different solvent wastes; separating a solvent from its impurities through
recovery techniques is easier than separating two solvents. Also, some chemicals may
b e reactive and therefore dangerous if mixed with another chemical.
o D o NOT mix solvents with water; avoid creating solvent-contaminated rinse water,
and keep storage containers covered and sheltered from moisture and rainfall.
o Keep solvents separated from other waste; before equipment and parts cleaning with
solvents, remove excess dirt and metal filings by brushing, dry wiping, or beadlshot
blasting; also, avoid disposing of used wipes in dirty solvent.
o Paint and ink formulators as well as printers sometimes segregate equipment wash
solvent so that it may be reused later for thinning the same type and color of paint
o r ink. T o determine the cost effect of waste paint and ink storage, calculate the
expenses of worker time, storage equipment, and storage space costs versus the
savings from reuse, recycling, and reduced disposal.

CHECKLIST 5
MATERIAL HANDLING AND STORAGE
o Space rows of drums to allow inspections for corrosion and leaks and to make it
o
o
o

o
o
o

easier to move drums during transfer.

Ensure stability in stacking containers.
Maintain distance between different chemicals to prevent cross-contamination.
Provide adequate lighting. Insulate electrical circuitry and check it frequently for
corrosion and potential sparking.
Use pallets or similar devices to raise drums off the storage area floor to prevent
corrosion through concrete "sweating."
Store drums in such a way as to prevent possible puncture from surrounding
equipment.
Store wipe rags in a closed container and use them again wherever possible.

CHECKLIST 6
PARTS CLEANING
ELIMINATE THE USE OF SOLVENTS by using a less hazardous material in a production
process. This generally reduces the amount of hazardous waste produced. For example, a
diesel engine remanufacturing facility that replaced cleaning solvents and oil-based
metalworking fluids with water-based products reduced its coolant and cleaning costs by
about 40 percent5.
Note:
Substituting water-based products can increase wastewater volumes and
concentrations; check with your local wastewater treatment plant on discharge options.
0 Replace oil-based cutting fluids with water-soluble cutting fluids.
o Use peel coatings (such as plastic film) in place of oils for protecting metal parts
from rust and soil during storage or transport. Peel coatings require work time for
removal and create a wastestream of their own.
o Use aqueous cleaners instead of solvent (pages 30-37, "Aqueous Cleaning of
Equipment and Parts").
o Use nonsolvent-based paint stripping methods such as:
Caustic stripping (e.g., caustic soda) baths are generally effective in stripping
alkyl resins, oil paints, cellulosics, and phenolic/gum varnishes. A typical
immersion bath consists of a 40 percent caustic solution heated to about
200 " F.
Plastic bead blasting in which the mechanical action of flinging plastic shot at
the part "debonds" the coating.
Bead or shot blasting (pages 27-30, "Abrasive Stripping").
Hot air stripping blows superheated air onto a part, melting the coating so
that it may be scraped off. Open flame or torch stripping are alternative
thermal methods for stripping noncombustible parts. The parts must not be
heat sensitive. Thermal methods may be useful for large parts that cannot be
immersed in caustic solutions.

REDUCE SOLVENT USAGE

o Control vapor emissions from cold dip tanks by:
Installing and using lids, such as manually operated roll-type plastic or metal
covers. Avoid lids that swing down, as they create a "piston effect" that forces
the escape of solvent vapor.
Locating tanks away from heat and from air movement, which can increase
vapor loss.

Reducing solvent "drag-out" when removing parts from the tank (pages 38-39,
"Drag-out Reduction Strategy").
o Control vapor emissions from vapor degreasers by:
Installing and using lids.
Increasing freeboard height in open-top vapor degreasers (the distance from
the top of the liquid to the top of the tank). A freeboard that is equivalent
to 75% - 100% of the tank's width is recommended.
Installing freeboard chillers (refrigerated coils that cause the solvent vapors
to condense into a receiving tray, which in turn returns condensate to the
vapor degreaser tank. A possible disadvantage is that moisture from the air
may be condensed into the tank as well. Make certain that the water
separator is functioning.
Reducing solvent drag-out (pages 38-39).
o Replace single-stage with multi-stage countercurrent cleaning (page 37,
"Countercurrent Washing").

IMPROVE SOLVENT RECYCLABILITY

o Maintain solvent quality by:
Preventing contamination from other solvents.
Reducing "drag-in" of water. Water can contribute to the formation of
hydrochloric acid, which ruins the solvent and can cause equipment problems.
Removing sludge promptly from tank.
Monitoring stabilizer concentration. Some proprietary solvents may contain
chemical stabilizers to prevent acid formation; your chemical supplier can
advise you if make-up of stabilizers is necessary.
o Standardize the selection of a facility's solvents.

CHECKLIST 7
PROCESS EQUIPMENT CLEAN.ING
ELIMINATE THE USE OF SOLVENTS
o Reformulate product; for example, by using nonsolvent-based finishes such as powder
coating (page 41, "Powder Coating"), water-based coatings, a two-component
catalyzed coating, or radiation-cured (ultraviolet light) coatings.
o Use aqueous cleaning agents (pages 30-31, "Aqueous Cleaning of Equipment and
Parts").

REDUCE SOLVENT USAGE

o Dedicate process equipment to a particular use; for example, always mixing the same
formulation.
o Schedule production of like batches.
o Avoid unnecessary cleaning.
o Prevent deposits from building up in coatings tanks by scraping with a squeegee or
spatula or by installing a mechanical wiper.
o Allow sufficient drain time of process tanks or containers.
o Consider teflon-lined containers for preparation of small batches of coatings.
o Cover process tanks to prevent drying of material on interior of tank (also reduces
vapor emissions and prevents film formation on surface of material).
o Line spray booth; periodically dispose of and replace lining.
o Clean straight process pipelines by forcing a plastic or foam "pig" through the pipe.

IMPROVE SOLVENT REUSE

o Use in the next batch formulation.
o Use to make a lower grade product.

CHECKLIST 8
SURFACE COATING APPLICATIONS
ELIMINATE THE USE OF SOLVENTS The following coatings contain little or no solvent.
o Powder coating may be used on various surface types, such as wood, metal, and some
plastics (see page 41, "Powder Coating"). Powder coatings do not contain solvents
and may be cleaned with dry methods, such as vacuuming or brushing.
o Water-based coatings are used especially for architectural coatings.
o Two-component catalyzed liquid coatings are widely used for auto and appliance
painting. These separately packaged high solids components are mixed just before
application to a part. The two components chemically react on a surface, forming
a durable finish in only one coat. Solvents are used for equipment clean-up, which
should be done right away as a durable bond occurs rapidly.
o Radiation-curable coatings are subjected to ultraviolet, electron-beam, or infrared
radiation during the curing operation. Until the coating is cured, aqueous washing
is all that is necessary for cleanup.

REDUCE SOLVENT USAGE Preventive maintenance and good work practices in surface
finishing are quality control elements that reduce the probability of poor finishes. Poor
finishes necessitate stripping and reapplying coatings. Some quality control measures are:
o Choose proper coating equipment (e.g., dip tanks for small parts, roller equipment
for flat surfaces, and spray for large, irregularly shaped surfaces).
o Replace conventional spray units with electrostatic units (see page 40, "Electrostatic
Paint Spraying").
o Replace air-spray guns with airless air-assist spray guns (see page 40).
o Adopt good manual spraying techniques by following spray gun manufacturers7
suggestions and training painters.
o Avoid adding excess thinner.
o Avoid excessive air pressure for atomization of spray.
o Maintain equipment properly.
o Position equipment away from heat sources.
o Separate solvent-based spray units from water-based spray units so oversprays do not
mix.

IMPROVE SOLVENT RECYCLABILITYIREUSE

o Recycle paint overspray/sludge in a fuels program.
o Reclaim and reuse solvent'from wastes using ultrafiltration or distillation (see pages
46-52? "Distillation" and see pages 53-55, "Ultrafiltration").

PART I11
PROCESS AND MATERIAL MODIFICATIONS

Part I11 presents in alphabetical order some process and material modification techniques
and technologies introduced in the Part I1 checklists.

Abrasive CleaningIStripping
Aqueous Cleaning of Equipment and Parts
Circulating Solvent-type Washers
Countercurrent Washing
Drag-out Reduction
Paint Spraying Techniques
Powder Coating

ABRASIVE CLEANING/STRIPPING
Also called mechanical surface preparation and bead or shot blasting, abrasive cleaning is
a safe, economical way to clean or strip a part.
The principle of operation involves mechanical action in which abrasive media are blown or
hurled against the surface to be cleaned. That action may involve scrubbing, sanding,
grinding, tumbling or vibrating. The types of abrasives-depending upon the substrate
(substrate is the surface to be prepared)-may be silica or mineral sands, metal slags, nut
shells and pits, corncobs, glass beads, plastic beads, stainless steel wire, aluminum shot, iron
or steel shot, or dry ice (carbon dioxide) pellets.
Some abrasive media may be selected because they do not change the substrate (e.g., plastic

27

beads); whereas, other media may be selected to etch the substrate's surface to improve
adherence of finish (e.g., wire).
Two types of abrasive blasting equipment are air blast and centrifugal wheel blast. Air blast
(or nozzle blast) used to b e called sandblasting. Centrifugal wheel blasting hurls abrasive
against the workpiece at a high velocity.
Today's blasting technology includes:
E More types of abrasives
E Automatic positioning
E Work handling systems for positioning parts
E Enclosures and dust collectors
Recovery systems for reuse of abrasives

BASIC DESCRIPTION OF A BLASTING OPERATION

First, the parts enter a blast booth where air nozzles blast with steel shot t o remove surface
imperfections, such as rust or other soil. After blasting is completed, air hoses blow
remaining shot off the parts.
Next, the used shot is sucked through filters; shot that is still large enough to use is recycled
into the blast system. (Note: This manufacturer recycles worn shot by putting it into the
product frames as ballast.)
Note: Some operations may require first washing the parts to be blasted to remove
machining oils, so that the oils do not affect the recyclability of the shot.

ADVANTAGES OF ABRASIVE CLEANING

The advantages of mechanical over chemical cleaning are:
E No air pollution if the system is enclosed.
No hazardous waste generation (must still pass TCLP); media may be recycled.
Improved adhesion because of etching.
Workers may return to other tasks after activating the system.
E Energy consumption is lower compared to maintenance of temperatures for chemical
cleaning processes.

CALCULATING EXPENSES FOR INSTALLATION OF A BLASTING OPERATION

Air blast operating costs are higher than centrifugal wheel costs because of high energy
requirements in creating powerful air current. However, air blasting removes soil more
effectively and may be more flexible for use with certain parts (i.e., parts having nooks and
crannies). A company might use both systems.
To calculate your payback period for investing in a blasting system, consider the following
capital and operating costs:
Typical capital costs:

Start-up cost for a small blasting cabinet operation is about

$2000, excluding installation of a facility air supply. One small
blasting cabinet system (air or wheel) is 24 inches deep by 3
feet wide by 7 feet high. The system recycles the shot.

A medium-priced system averages $5000 to $10,000.

Construction and installation costs for a room-sized system for
large blasting applications can go up to about $250,000.
Typical operating costs per 8-hour shift:

One vendor estimates utility costs to average $15 per month.

Costs for making up worn shot are dependent upon your
operation. One vendor's estimate is an average of $100 per
year for make-up of shot.
Calculate labor cost for loading and unloading cabinet.

SELECTION OF A VENDOR AND A MANUFACTURER

The questions your vendor will need to ask you are:
What is the largest piece you will need to blast?
What is your current air supply?
What workpiece material(s) will you be blasting?

How clean must the workpiece be after cleaning (to determine adequacy of wheel
blasting rather than air blasting)?
What is the work load?
Ask your vendor if several soiled parts may be sent to the manufacturer to test blasting
technology for your situation. You might also take soiled parts to a custom blasting shop
to try the technology and various blasting media before investing in a system yourself.

AQUEOUS CLEANING OF EQUIPMENT AND PARTS

An alternative exists for those who clean parts in parts washers and vapor degreasers that
use solvent. "Aqueous" methods are demonstrating that they are able to clean and degrease
parts effectively in manufacturing applications as well as vehicle repair applications.
Aqueous, or water-based, cleaning of parts and equipment may use the following chemicals
and equipment:
Chemicals:
E Detergents, which are products made from petroleum-based emulsifying agents
Soaps, which are liquid products made of oils derived from grains or seeds or are dry
chemicals such as sodium hydroxide and sodium silicate
Caustics
New citrus-based products
Equipment:
High pressure hot water sprayers
E Steam cleaners
"Hot soap'' washers
Immersion tanks (which may or may not include the application of electric current)
Although parts might be simply immersed or wiped with detergent or soap solutions, the
most effective cleaning is accomplished with the added mechanical action provided by
equipment washers, which are described in this section, or by pressure sprayers, which are
described on pages 36 to 37.

CHEMICALS USED IN AQUEOUS CLEANING

Aqueous cleaning materials are usually neutral detergents or soaps or are mild caustics.
Neutral means a material is not acidic or alkaline. Acids and alkalies are measured in terms
of "pH," where a pH of 7 is neutral, a pH of 0 to 6 is acidic, and a pH of 8 to 14 is alkaline.

Caustics are alkaline materials that by chemical action may

burn, corrode, or dissolve other materials. They are usually
applied by wiping, by power spray, by immersion, or by
electrocleaning (electrocleaning is like immersion cleaning
plus application of an electric current).

Acids
Neutral
Alkalies

pH level
0 to 6
7
8 to 14

For a mildly caustic material of pH 8 or 9, rubber gloves are

recommended. Strong caustics, such as paint strippers, are referred to in federal hazardous
materials regulations as corrosives; as such, they must be properly packaged, stored, and
handled to protect people and the environment. You should check the cleaner's MSDS for
information about personnel protective equipment and handling procedures.
T o substitute solvents with an alkaline cleaning or stripping material, work with your
chemical and equipment vendors to select an appropriate chemical. Then, before you begin
using the caustic in your process, check with the local wastewater treatment plant about
discharging wastewater into the sewer.

ADVANTAGES OF AQUEOUS CLEANING SOLUTIONS

Detergent and soap increase worker safety. According to a sample MSDS for a
certain asphalt-removing detergent (one of the stronger detergents) that is used for
soaking and wiping parts, followed by rinsing or high pressure spraying, the detergent:
Gives off no flammable vapors in normal plant or shop conditions (the boiling
point of the asphalt-removing detergent is over 600F).
Is non-caustic (for example, the pH range of the detergent is 6 to 9, which is
considered neutral-that
is, neither an acid nor a base).
May be handled by workers wearing conventional rubber gloves and safety
glasses; after handling, workers wash exposed skin thoroughly with water.
Does not present an inhalation hazard to workers.
Detergent and soap replace hazardous solvents, thus helping to reduce or eliminate
hazardous waste generation.
Effective, consistent cleaning results.

CAUTION
Do NOT be confused by the promotion of certain petroleum-based products as
"nonhazardous solvents." These are NOT the same as detergents or soaps used in aqueous
washers. The so-called nonhazardous solvents that are petroleum-based have potentially
hazardous flashpoints. For example, one product promoted as having a "high 141F flash
point" fits the definition of a combustible liquid.
Since solutions in aqueous washers are heated to between 140F and 200F, making the
mistake of using these petroleum-based solvents advertised as nonhazardous would be very
dangerous. The use of the phrase "high 141F flash point" may lead those who are
uneducated about the properties of combustible liquids to believe that the product is safe,
while its vapors actually have the potential to cause fire or explosion.

"HOT SOAP" WASHERS - PRINCIPLE OF OPERATION

Equipment washers (or "tubs") are available in front loading or top loading versions to
accommodate differences in materials handling operations; for example, washers might be
loaded by workers or might be loaded automatically in conjunction with a hoist system.
The principle of operation involves a combination of detergent and mechanical actions:
Loaded parts rotate on a turntable through the washer.
Pressure nozzles aim at the parts from all directions, blasting soil off the surfaces.
E
The factors of pressure and rotation allow parts to be hit from every angle.
Heated solution (140F to 200F) softens grease.
Biodegradable soaps, detergents, or chemicals dissolve greases and oils.

BASIC OPERATION OF A HOT SOAP WASHER

The worker or hoist loads parts into the washer compartment; adds detergent and any other
additives (e.g., aluminum brightener); sets the time and temperature controls (each
according to the manufacturer's specifications); and activates the power. The washer does
not need to be attended by a worker during cleaning.
Through the principles described above, the washer cleans the parts in approximately one
to fifteen minutes. During the operation the solution is filtered and recycled.

Clean parts are immediately unloaded and usually flash dry in seconds.
After the cleaning operation, the oil separates from the washing solution as it cools to room
temperature. An oil-removing feature (optional in some models) deposits floating waste oil
from the washing solution into a collection receptacle. The oil-removing feature might b e
a weir that allows oil floating on the solution's surface to flow across a "dike" or tank wall
into a receptacle; o r it may be an oil skimming wheel that attracts floating oil and deposits
it in a receptacle.
Sediments such as metal filings and dirt are allowed to settle to the bottom of the sump and
are removed at regularly scheduled clean-out intervals.
T h e operator analyzes the recycled detergent solution once a week, according to the
manufacturer's specifications. Detergent, water, or additives are made-up as needed.

DISPOSAL OF SPENT CLEANING SOLUTION

Attention to good housekeeping practices, such as preliminary brushing of heavily soil-laden

parts and removal of oils through skimming, may keep the recycled solution useful for four
to six weeks before it is necessary to clean out the tank and replace the water. Some users
report even longer intervals before clean-out is necessary.
Operations that generate large quantities of skimmed oil may check with their equipment
vendors about Oil-Water Separator technology. Used oil may be burned on-site or may be
provided to a marketer for energy recovery; in either case, the burning is regulated under
federal hazardous waste regulations (see Appendix D).
Determine if the settled residue is a hazardous waste by sending a sample to a certified
laboratory for Toxicity Characteristics Leaching Procedure (TCLP) testing. Residue passing
the TCLP may be disposed in the landfill provided the waste meets Department of Natural
Resources requirements, including (see Appendix E, "TCLP and SWA Parameters"):
No free liquids,
Less than 1 percent hydrocarbons,
Flashpoint below 140F, and
Neutral pH.
Residue that demonstrates hazardous waste characteristics or is on an EPA list of hazardous
wastes must be properly disposed.
Wastewater, which retains approximately 15 percent of oil contaminants removed from parts,
may be disposed into the sewer system. If you plan to install an aqueous washer, be sure
to contact your local wastewater treatment plant to discuss your wastewater disposal.
Equipment vendors and washer users have found that the local wastewater plants are
generally favorable to disposal but want and need to collaborate about the quantity and
nature of the effluent. Wastewater testing might be involved, and permits might be required.
[Note: The ability of detergents to hold particles in suspension can affect sewer systems and
septic tanks. Also, detergents containing phosphates can affect plant growth in lakes and
rivers. Therefore, although detergents do not present the hazards of solvents such as
petroleum naphtha or trichloroethylene, they may still pollute water in certain ways. To
avoid contributing to pollution, cooperate with your local wastewater plant.]

CALCULATING EXPENSES FOR INSTALLING A HOT SOAP WASHING SYSTEM

To calculate your payback period for investing in a hot soap washing system, consider the
following capital and operating costs:
Typical capital costs:

The capital cost of a system depends on the brand, the unit's

capacity, and its operating features; for example, the cost of
aqueous washers produced by one firm ranges from
approximately $2000 for an 18-inch diameter basket, with a 250
pound load capacity to approximately $20,000 for a unit with a
5-foot diameter basket, with a 2000 pounds load capacity. The
washers require only water, power, and detergent.
Electrical costs for your facility may include the materials and
labor for installing wire, conduit, and fixtures.
Plumbing costs for water hook-up.
Typical operating costs per 8-hour shift:

To calculate utility costs, check the rates with your local water
and power companies. One manufacturer's example for
calculating utility costs is as follows: The operating detergent
and water solution is approximately $0.10 per gallon. This
manufacturer's smallest washer operates using 20 gallons of
water, which recycles for four to six weeks, depending upon the
nature of the cleaning and upon the housekeeping efforts.
Once any fresh solution is brought up to operating temperature
(approximately every four to six weeks), the cost is minimal for
maintaining that temperature.
Calculate labor at approximately 1 hour per cleaning.

SELECTION OF A VENDOR AND A MANUFACTURER

If you are in the market for an aqueous washer, send for information from several
manufacturers so that you can compare features and specifications (see Appendix F). Ask
the manufacturers for recommendations of excellent vendors in your locale. A reputable
vendor will be willing to supply you with their customers' names so that you can inquire
about seeing washers in operation and about information such as cost benefits and materials
handling.
Use the following checklist as you study the specifications and promotional literature for
each brand.
o Verify that equipment specifications indicate that the electric components meet or
exceed NEMA standards.
o Check that the detergent inhibits lime and soap build-up.
o Ask if the vendor helps to determine the water-detergent ratio for your application.
o Inquire about special detergent formulations: for example, for application to
aluminum alloy parts; for one-step cleaning and phosphatizing of metal in preparation
for paint operations; or for heavy duty applications such as carbon, tar, or asphalt
removal.
o Inquire if the vendor will test-clean a few of your soiled parts so that you may
determine if the cleaning is adequate for your requirements. Ask if the vendor will
place the aqueous washer in your facility for a one-week trial.

OTHER AQUEOUS CLEANING EQUIPMENT

Other types of equipment used for aqueous cleaning are portable high pressure sprayers and
portable low pressure steam cleaners. Portable sprayers, which are useful for cleaning large
equipment or parts that do not fit into washers, may be used with or without soaps or
detergents.
High pressure sprayers are available with oil-fired or LP gas-fired water heaters. Power is
supplied by a 112 HP to 16 HP gasoline engine or electric motor. Water pressure may be
generated at 120 - 180 psi for steam units or 500 - 3000 psi for hot water spray units.

A third type of pressure spray operation occurs in a tunnel, through which parts move on
a conveyer. The principle of operation of a spray tunnel is as follows:
Parts suspended on a conveyor move through the tunnel, which is equipped with
many spray nozzles.
Cleaning solution (sometimes heated) is pumped from a holding tank and sprayed
under pressure.
Solution flows onto the parts, runs off into a sump, and is recirculated.
The operator periodically checks the recirculating solution and adds make-up materials as
needed. The sump is periodically cleaned out and fresh solution is added.

CIRCULATING SOLVENT-TYPE WASHERS

The practice of manually cleaning paint spray guns by flushing solvent through them into an
open container is wasteful of solvent and is detrimental to worker safety and health as well
as t o the environment. Circulating gunlequipment washers are closed systems that reduce
solvent consumption compared to manual cleaning (by 75 to 90 percent according to one
manufacturer of solvent-type washers).
T h e principle of operation of a circulating solvent-type spray gunlequipment washer is as
follows:
E
Load spray guns and parts into mounting stations of the washer, close the lid, and
activate the power.
E
Solvent is sprayed around and through the guns. At the cycle's conclusion, the
solvent returns to the tank for reuse. The contaminants settle to the bottom and are
periodically removed for disposal. Clean make-up solvent is added when needed.
The entire procedure takes only minutes; yet guns are cleaned consistently while employee
exposure to potentially hazardous health effects is greatly reduced.
If you own your washer and use more than 10 gallons of solvent per week, consider installing
a still to recycle used solvent. Although washers may b e leased from commercial solvent
recyclers (see page 55, "Off-Site Recycling Services"), the generator still has perpetual
liability for disposition of hazardous wastes.

COUNTERCURRENT WASHING
Solvent life may be extended by washing small parts and equipment in a modification of the
metal plating industry's "countercurrent rinse" sequence. For example, to clean a paint
brush, pour some solvent into each of three containers.
Clean the brush in the first container; this container will now
contain the most paint waste.
Next, clean the brush additionally in the second container; this
container will contain considerably less paint waste than the first
container.
Finally, clean once more in the third container; this container
will have very little paint waste.
Follow the same procedure for cleaning subsequent parts, brushes, or equipment.
Eventually, when the third (cleanest) container of solvent becomes dirtier, use it as make-up
solvent for the first two containers and use fresh make-up solvent to replenish the third
container.
Devise a way (e.g., a basket) to keep the parts or equipment above the settled sediment in
the first and second containers. Periodically remove the sediment for proper disposal.
Check a safety supplies catalog for "safety bench cans" that meet OSHA requirements for
safer cleaning of small parts and equipment. Depending upon sizes and features, safety
bench cans range from about $30 to $100. Safety bench can covers should be open as
briefly as possible during cleaning to minimize vapor emissions. When not in use, store the
containers properly by labeling them and by keeping them in a flammable materials safety
cabinet.

DRAG-OUT REDUCTION
"Drag-out" refers to the volume of solution carried over the edge of a cleaning or process
tank as a workpiece is taken out or put in. Several factors influence drag-out amount:
Velocity of withdrawal of workpieces from tanks. Withdrawing partslequipment too
quickly from solvent not only may cause drag-out of solution but also may contribute
to increased vapor emissions.

w
w
w
w

Shape of the workpieces.

Rack or material-handling position of workpieces.
Drainage time allowed over the process vessel.
Nature of the solution (such as thickness and temperature).

Experiment to determine the best ways to control drag-out in your operations; for example6:
For flat parts:
First, place parts on the rack so that the surfaces (or planes) are as vertical
as possible.
Second, the longest dimension of the part should be horizontal but slightly
tilted to allow for run-off during removal from the tank. In other words,
solutions should drain from a corner rather than the entire edge of the part.
For parts with cup-shaped recesses:
Rack or handle the workpieces so that they tilt during withdrawal.
In some manufacturing situations, holes may be drilled in parts to aid draining.

PAINT SPRAYING TECHNIQUES

Industrial spray painting operations can vary widely in the amount of paint waste generated
through overspray (referred to as "transfer efficiency"). Conventional air spray equipment,
which is widely used, usually has low transfer efficiency. "Electrostatic air-assisted airless
spray" equipment is considered to have the best transfer efficiency. Transfer efficiency is
proportional to the amount of solvent needed for clean-up operations.
Recommended waste reduction measures for a surface coating operation are7:
w Maintain 50 percent overlap between spray pattern.
w Maintain 6 to 8 inches distance between spray gun and the workpiece.
Maintain a gun speed of about 250 feet per second.
w Hold gun perpendicular to surface.
w Trigger gun at the beginning and end of each pass.
w Properly train the operators to reduce waste.

Avoid excessive air pressure for coating atomization.

Recycle overspray.
Use electrostatic spray systems.
Use air-assisted airless spray guns in place of air-spray guns.

AIR-ASSISTED AIRLESS SPRAY GUNS

In air-assisted airless spray, paint is hydraulically forced through a tiny opening and is
stressed t o the point of atomization (the "airless" component). Upon leaving the opening,
the atomized paint is patterned by focused air pressure (the "air-assisted" component).
Under normal conditions, air-assisted airless spray can achieve nearly twice the transfer
efficiency of conventional air spray.

ELECTROSTATIC SPRAY GUNS

Considered the most efficient among spray. finishing methods, electrostatic spray systems
charge the paint with a negative electrical charge as it leaves the gun. T h e negatively
charged paint is attracted to any conductive target. Therefore, if the object t o b e painted
is either positively charged or neutrally charged and grounded, the paint is attracted to the
target object. The electrostatic attraction increases transfer efficiency and greatly reduces
overspray.
Combining air-assisted airless with electrostatic technologies can achieve a transfer efficiency
as high as 85 percent.

OTHER FACTORS AFFECTING TRANSFER EFFICIENCY

Operator technique plays a large role in avoiding spray painting waste. Therefore, worker
training in efficient spraying is vital. Other factors include:
Booth air conditions; humidity
Paint viscosity
Size and shape of the part to be painted
Spray gun cleanliness/maintenance

H
H

Proper fluid flow rate and air atomizing pressure

Air cap cleanliness
Target's conductivity in electrostatic spraying

POWDER COATING
Powder coating is replacing conventional industrial paint operations in some manufacturing
processes. The absence of solvent in powder systems means an absence of VOC emissions
and solvent waste. Unapplied powder is recycled through the system.
The principle of operation is as follows:
H Dry powder is pneumatically fed from a'hopper to a spray gun.
H The spray gun charges the powder electrically. Parts are electrically grounded so that
charged sprayed powder is attracted to their surfaces.
H Parts are then conveyed to an oven (about 400F) for melting and fusing into the
finished coating.
Process sophistication ranges from manual operations (can be used by a small manufacturer)
to large computerized robotic applications.
Surface finishing applications include these industries: appliance, automotive components,
electrical components, metal and office furniture, building and architectural, farm, garden
and industrial machinery, and fabricated metal products.

BASIC DESCRIPTION OF A POWDER COATING OPERATION

First, a worker places metal parts on conveyor racks.
Second, the conveyor moves the parts through a spray wash tunnel where they are sprayed
with a phosphatizing solution that cleans and etches the surfaces. The phosphatizing
solution drains from a sloped floor into a tank where it may be recirculated.
Third, the parts exit the spray cleaning tunnel and move several feet to the entry of a drying
tunnel.

Fourth, the conveyor moves the parts from the drying tunnel to the coating spray booth,
where two workers manually operate electrostatic spray guns to apply the powder coating
to the grounded parts. Powder coating overspray is drawn through a cyclone and then
through a filter system. Every 20 seconds a blast of compressed air hits the filters, knocking
the powder into a receiving vessel. The powder collects to be reused later in an application
where color does not matter.
Next, several feet from the spray booth is the entry to a room-sized curing oven which
operates at about 400F. The conveyor snakes through the curing oven so that the parts
reside there long enough for curing to take place.
Finally, upon exiting the curing oven the parts are conveyed through a tunnel of fans that
cool them so that a worker may safely remove them from the conveyor.

ADVANTAGES OF POWDER COATING

The advantages of powder coating are:

Absence of sags, runs, drips and bubbles.
w Finishes can be smooth or textured, gloss, mat or metallic.
Finishes are durable (impact resistant) and may be extremely thin or extremely thick
as desired.
E Powder coating may be used on metals, glass, and even plastic.
w No venting and air make-up is needed as there are no solvent fumes.
Labor costs may be reduced because of faster clean-up. The process is efficient (no
dryingflash-off time; can rack closer together on conveyer. Reject rates have been
lower).
Powder coating is easily recycled; no waste disposal or pollution.
It is reported that in many cases, finishers are experiencing one year or less payback period
upon installing a powder coating system.8 The critical figure in evaluating the economics of
powder coating compared to liquid coating is the net cost per square foot or per item. For
example, one business determined that the cost of applying a high solids liquid coating to
would be $.0364 per square foot, and the cost of applying a powder coating would be $.0320
per square foot.

Powder technology is competitive with high solids liquid technology for the following
additional reasons:
The total energy cost in terms of gas dollars per hour is $19.73 for high solids liquid
and $17.90 for powder.
The hourly labor and maintenance costs for high solids liquid are $66.83 and for
powder are $45.13.
E Considering these and other data, the annualized cost per square foot is $.0508 for
high liquid solids and $.0425 for powder.

PART IV
RECYCLING TECHNOLOGIES

Part I11 explored strategies for reducing solvent waste through modifications of processes and
materials-often referred to as "source reductionH-which is the preferred method of waste
management. Part IV presents strategies for the next preference-reducing solvent waste
through recycling, especially on-site at your own plant or shop. Two technologies that have
found favor in industries of all sizes are distillation and ultrafiltration. Each technology
presents its own advantage, and each has a record of providing a cost benefit to its user, by
reducing the purchase of virgin solvent and by reducing the volume of hazardous waste that
must be managed for disposal.
Although other technologies exist for solvent recovery (evaporation, sedimentation,
decantation, centrifugation, and solvent extraction), distillation and ultrafiltration systems are
available commercially to the average business engaging in equipment and parts cleaning.

ADVANTAGES OF ON-SITE RECYCLING

On-site recycling:
Often pays for itself in less than one year by reducing virgin or reclaimed solvent
purchases, and by reducing waste disposal or off-site recycling costs,
Reduces the potential liability of improper disposal or transportation accidents by an
out-of-plant recycler.
Eliminates cross-contamination with other solvents, which is more likely with out-ofplant recyclers.
May reduce your waste generator status; for example, from large quantity to small
quantity or conditionally exempt small quantity generator status.
May reduce potential for spills of contaminated solvents during storage while waiting
for a waste hauler.
Distillation units:
Yield up to 99 percent pure solvent, which may be necessary for solvent reuse in
certain operations.

Require only minimal operating costs (the most expensive being employee refresher
training) after the initial capital investment for equipment and for room
modifications.
Are available in a 5-gallon capacity for small generators of dirty solvent.

Ultrafiltration units:
E Yield a cleaned solvent, which retains dissolved additives.
E D o not apply heat to solvents and thus do not create the hazards associated with
increasing vapor pressure through boiling.

DISTILLATION
If you generate at least ten gallons of spent solvent per week, it may b e worth investigating
purchase of a distillation system (also referred to as a "still"). Capacities of stills range from
small units that reclaim about 3 to 5 gallons within 8 hours to large units able to produce
over 100 gallons per hour.
The principle of simple distillation is this: When a liquid is heated to boiling, it vaporizes
(becomes a vapor); when the vapor is subsequently cooled, it condenses back into the liquid
state. Impurities remain in the boiling vessel as still bottoms, and the liquid resulting from
condensing the vapors is very nearly pure solvent.
Note: Paint thinners are blends of solvents, formulated to meet specific
volatility and solubility requirements. Solvent reclaimed by distillation
probably would not meet the precise requirements for thinning high quality
paints, such as those used in automobile repair.
Stills designed for reclaiming solvents must meet stringent U.S. industry standards to protect
safety and health of personnel. The standards for distillation units require such features as
explosion-proof electrical components, electrical grounding components, and tightness of
construction to control hazardous vapors.9
Through atmospheric distillation or through vacuum distillation, many common solvents may
b e reclaimed; for example, methylene chloride; l,l,l-trichloroethane; acetone; mineral
spirits; xylene; methyl ethyl ketone; and toluene.
Solvents with boiling points from 320F (160C) to 500F (260C) are distilled with a
vacuum distillation system. Examples of solvents with boiling points in this range are

mineral spirits, Stoddard solvent, kerosene, Varsol, ink solvent, m-cresol, trichlorobenzene,
carbitol, and the terpenes (turpentine). Operators of vacuum distillation systems are trained
to use the vacuum gauge for the solvents being distilled at their facility.10

BASIC OPERATION OF AN ATMOSPHERIC BATCH DISTILLATION SYSTEM

First, the operator pumps or pours dirty solvent from a grounded pan into the still's boiling
chamber, seals the lid, and activates the power. Supplied by 1lOV or 220V electrical service,
the heating element gradually heats the insulated, seamless vessel. The operator may return
to other duties.
As the contaminated solvents reach their boiling temperature, the solvent changes into a
vapor state. The solvent vapors rise to be channeled through a water-cooled condensor (in
one small-capacity model, the water is supplied to the condensor through a garden hose).
The condensor cools the vapors, thus changing them back to a liquid solvent state.
The renewed solvent (condensate), which can approach 99 percent purity, flows into a
receiving vessel. Residue left in the still ("still bottoms") is all that is left for waste disposal
(some vessels may be lined with a bag to aid the removal of still bottoms.)"
Diagram of a Simple Batch Distillation System

Source: North Carolina Department of Natural Resources Pollution Prevention Pays Program: Pollutiotl kevenfion Tips: Small
Solvent Recotwy Sysrm, 1974.

47

CALCULATING EXPENSES OF A SOLVENT DISTILLATION SYSTEM

T o calculate your payback period for investing in a distillation system, consider the following
capital and operating costs:
Typical capital costs:

The capital cost of a system depends on the brand, the unit's

capacity, and its operating features; for example, the cost of
stills produced by one firm ranges from $3000 for a 5-gallon
capacity system to $15,000 for a 55-gallon system. T h e stills
require only water, electricity and, in some cases, compressed
air for operation.
Electrical costs for your facility may include the materials and
labor for installing wire, conduit, and explosion-proof
components and for electrically interlocking the still with the
ventilation system (see pages 49-51, "Safety Requirements...).
Plumbing costs for your facility may include materials for
installing piping, valves, and fittings. Check with your local
building department regarding the necessity of installing the still
in a diked area.
Ventilation costs for your facility may include materials for
installing the ventilation unit and ductwork.
Secondary containment costs (for example, a concrete curb
surrounding the still) if required by your state fire code.
Sprinkler system or other fire suppression costs, if required by
your state fire code.
Typical operating costs per 8-hour shift:

T o calculate utility costs, check the rates with your local water
and power companies. One manufacturer's example for
calculating utility costs is as follows: The operating cost of the
manufacturer's stills is approximately $0.13 per gallon processed.
Multiply $0.13 times the number of gallons processed per shift.

For example, processing 5 gallons at $0.13 per gallon equals

$0.65 per shift for utility costs.
Calculate labor at approximately 1 hour per shift.
Optional-obtain
the cost of disposable boiling vessel liners
(available for some units).
Include the disposal cost of off-site incineration of the still
bottoms.
Note: Still bottoms are F-listed wastes in many cases and
therefore require hazardous waste disposal. If not F-listed,
arrange with a certified laboratory (Appendix G) to run TCLP
(Toxicity Characteristic Leaching Procedure) and flashpoint
tests on samples of the first still bottoms you generate.
Other costs:

Expense of expertly "training the trainer." This person will

subsequently train any new operators and refresh the training
of other employees. Training is inadequate when it consists of
little more than expecting current employees to teach new
employees. Ask your vendor about the manufacturer's or
vendor's training program for the purchaser of a distillation
unit.
Time spent on initial training of employees, periodic refresher
training (e.g., as part of the yearly update of the company's
OSHA Hazard Communication Program).

SAFETY REQUIREMENTS FOR SOLVENT DISTILLATION SYSTEMS

Hydrocarbon solvents classified as flammable or combustible liquids produce vapors
that explode if ignited. Therefore, a distillation system must meet the State Fire
Codes, which usually has adopted the National Fire Protection Association (NFPA)
standards: NFPA 30, "Flammable and Combustible Liquids Code" and NFPA 70,
"National Electric Code."

rn

Secondary containment costs (for example, a concrete curb surrounding the still) if
required by your local fire code.

rn

Sprinkler system or other fire suppression costs, if required by your local fire code.
Additionally, distillation units must be installed and located in accordance with local
building codes, such as installing the system in an environment that:
contains explosion-proof electrical components (meeting Class I, Division 1,
Group D standards of the National Electrical Code),
meets certain building standards for explosion hazards, and
has a ventilation system large enough to prohibit ignitable concentrations of
solvent vapors. The ventilation system must be interlocked with the operation
of the still. That is, the ventilation blower must operate whenever the still
operates.I2

rn

All components of the solvent reclamation equipment must be properly bonded and
grounded to prevent occurrences of static electricity, which could ignite flammable
vapors (for example, while pouring spent solvent into the still). During material
handling, use only groundable components (that is, conductive or static-free material)
such as pans and hoses, or make the entire system groundable.

Select highly qualified professionals to handle the installation of your distillation unit,
including the equipment vendor, the electrician, and the ventilation contractor. For
large recovery systems or more complex building situations, engage the services of a
mechanical engineer. For all these professionals, ask for and verify their knowledge
and experience in distillation unit installations.

rn

Notify your insurance agent about your prospective installation. The insurance
industry covers distillation units under the category of "pressure vessels and boilers."
Your agent will select an insurance company that specializes in such coverage. It is
likely that the insurer will inspect your system upon installation and periodically
thereafter.

Warnings and Cautions

Warning: Do NOT, under any conditions, process reactive chemicals in a still; for
example, do NOT distill solvents contaminated with nitrocellulose, which is an
extremely reactive component of some lacquers .and inks. Nitrocellulose is an

explosive more powerful than TNT. Your distributor should ask you what
contaminants are in your spent solvent and should warn you about any containing
reactive chemicals. If you suspect your vendor is not knowledgeable of or cautious
about such chemical reactions, find another vendor!

Caution: If you plan to distill a chlorinated (halogenated) solvent (such as 1,1,1trichloroethane), b e aware that even a small amount of water vapor in the solvent
can react with solvent to create hydrochloric acid, which can destroy steel in the
distillation unit, even over a short time. Your equipment vendor usually can conduct
a chemical analysis and advise you on the acid content of your first still bottom of
processed solvent. If the dirty solvent is on the acidic side, your vendor or
manufacturer might suggest that you try adding baking soda until it tests neutral.
Caution: Filling the still to the top with spent solvent to b e processed may b e a
problem.
Boiling of solvent produces bubbles that contain contaminant.
Contaminated bubbles close to the outlet in the still lid can enter the condenser and
end up in the solvent collection pan, thus contaminating the reclaimed solvent. Try
distilling less spent solvent at a time.
Caution: Petroleum-based solvents may be toxic if inhaled. Check your Material
Safety Data Sheets (MSDS) for recommended practice regarding personnel
protective equipment. Check also on the use of an air monitoring device in areas
subject to vapor release.

SELECTION OF A DISTILLATION SYSTEM VENDOR OR MANUFACTURER

If you a r e in the market for a distillation unit, send for information from several
manufacturers so that you can compare features and specifications (see Appendix H or
check the Thomas Register at your library). Ask the manufacturers for recommendations of
excellent vendors. Reputable vendors will b e willing to supply you with their customers'
names so that you can arrange to see stills in operation and can discuss with the customers
such topics as cost benefits, training, and materials handling.
Mark the following checklist as you study the specifications and promotional literature for
each brand.

Check that the still's design includes:

o Explosion-proof electrical components.

o A pressure relief valve.

o

o
o

A still lid specially designed to release additional pressure beyond the capacity of the
vapor relief valve in case vapor build-up occurs.
Ease of residue removal (e.g., must residue be dug out?)
Electric heating element (conductive heating) rather than oil heat (heat transfer) to
avoid periodic management of waste oil and to avoid possible danger of running the
unit without oil.

Check that the still:

o Is rated for a processing temperature of NOT more than 350F for an atmospheric
still. For solvents with boiling points above 350F) vacuum stills or attachments are
necessaly.
o Complies with NFPA National Electric Code rating of Class I, Division 1, Group D
and the NFPA 30 Standards for Combustible and Flammable Liquids.
Beware of manufacturers that:
o Claim a still can be adapted for continuous, automatic operation instead of batch
operation, even though the still uses a bag that must b e removed after a run.
o Claim that a still does NOT need explosion-proof electrical components.
Check that the manufacturer or vendor offers:
o Manufacturer's safety literature that warns agaiizst processing solvent contaminated
with reactive materials; for example, nitrocellulose.
o Certification of vendor's training by manufacturer.
o A customer training program.
o Future customer service (check with customers about their satisfaction with vendor's
customer service).
o T o run a test batch of your contaminated solvent at the distributorship.
o Site visits with other customers using the still.
o Consultation with you about your processes, asking questions such as:
What is the solvent?
What is the contaminant?
What is the volume (daily or weekly) of spent solvent for processing?
What will you use reclaimed solvent for?
Can it go back into process?
Will reclaimed quantity fit your needs for equipment cleaning?

A good vendor will counsel you about your needs, including whether a distillation unit is
even feasible for your operation. Most importantly, a good vendor will emphasize safety
issues.

ULTRAFILTRATION
Ultrafiltration, once in the domain only of very large filtering applications, is a technology
now available to service shops and smaller industrial plants for recycling petroleum-based
solvents that have flashpoints above 105F.
Ultrafiltration involves passing dirty solvent through a series of successively finer filters.
About 96 percent of the solvent can be reclaimed, with about 4 percent remaining in the
residue.
Where distillation results in a nearly pure solvent (distillate), ultrafiltration simply cleans
dirty solvent by removing suspended dirt, grease, and oil. The reclaimed solvent retains
certain dissolved additives or contaminants introduced during your manufacturing or service
processes.

BASIC OPERATION OF AN ULTRAFILTRATION SYSTEM

First, the operator uses a solvent-transfer pump to place dirty solvent into the ultrafiltration
tank, closes the cover, and activates the power. Supplied by llOV electrical service, a pump
within the unit drives the fluids through the filter system. The operator may return to other
duties.
Next, the dirty solvent passes through three filters: first, a 100 micron filter; second, a 5
micron filter; and third, a 1/100 micron filter.
Finally, the operator discharges the cleaned solvent into a receiver vessel.
Periodically the operator removes residue that has collected in the tank.

CALCULATING EXPENSES OF AN ULTRAFILTRATION SYSTEM

To calculate your payback period for investing in an ultrafiltration system, consider the
following capital and operating costs:

Typical capital costs of one ultrafiltration system:

The cost of one vendor's ultrafiltration system is $5900 for a 30gallon capacity system and $8300 for a 60-gallon system.
The electrical requirement is a 110V receptacle. Note: The
manufacturer states that no additional room ventilation or
wiring is necessary. It is recommended, however, that air b e
monitored to ensure compliance with OSHA permissible
exposure levels.
A 314 inch hose is required for circulating water to cool the unit
during operation.
Secondary containment costs (for example, a concrete curb
surrounding the still) if required by your local fire code.
Sprinkler system or other fire suppression costs, if required by
your local fire code.
Typical operating costs per 8-hour shift:

T o calculate utility costs, check the rates with your local water
and power companies. One unit's utility costs are based upon
2 112 Gallons Per Minute (GPM) of water for the first hour of
operation and less than 114 GPM during subsequent hours;
electrical usage is 1.3 kilowatts per hour.
Worker time for transferring dirty solvent from a parts washer
t o the ultrafiltration tank is about 10 minutes.
Include the disposal cost of off-site incineration of the filtration
residue.
Note: Filtration residue is an F-listed waste in many cases and
therefore requires proper hazardous waste disposal. If not Flisted, arrange with a certified laboratory (Appendix G) to run
TCLP (Toxicity Characteristic Leaching Procedure) and
flashpoint tests on samples of the first still bottoms you
generate.

Other costs:

The filters are periodically replaced: the 100 micron filter,

every two years at approximately $89 to $99; the 5 micron filter,
every 125 to 150 gallons at approximately $12; and the 1/100
micron filter (membrane, every two to three years at
approximately $680. Spent filters should be TCLP tested to
determine proper disposal.

OFF-SITE RECYCLING SERVICES

"Off-site recycling is best suited for generators that lack the resources to procure and
operate an on-site recycling unit, or whose solvent waste generation rates and patterns do
not justify the capital and operating costs for an on-site recycling system. Off-site recycling
has the disadvantage of potentially high transportation and liability costs as a result of
potential clean-up problems associated with the recycler.""
Some businesses elect to contract with off-site recycling companies or with solvent vendors
that provide off-site recycling as a service. This approach attracts certain business owners
because they prefer to have someone else manage their wash/cleaning solvents from delivery
of fresh solvent to removal of the spent solvent. An off-site recycler might offer a few or
all of the following services:
H
Supplies cleaning equipment (for example, parts washers and spray gun washers).
Replenishes clean solvent during regular visits.
H
Cleans and maintains the washer equipment for you.
H
Removes spent solvent from your facility.
H
Transports your materials/wastes in compliance with Department of Transportation
regulations.
H
Maintains data for your annual Right-to-Know reports.
One off-site recycler states in promotional literature that through distillation it recycles 90
percent of spent solvents for reuse in parts cleaners. The still bottoms that are not fit for
recycling are stated to be used in a fuel blending program; waste is not disposed in landfills.
The recycler reminds its clients that hazardous wastes remain the original generator's
"cradle-to-grave" responsibility but claim that if a spill occurs, the recycler pledges to pay all
costs for clean up.

One advantage of using an off-site recycler is that it helps a company comply with EPA's
regulations for handling hazardous waste. A disadvantage is that off-site recyclers very often
mix waste solvent from several customers for processing, therefore yielding a mixed
reclaimed solvent. A company that purchases reclaimed solvent needs to decide if the
quality is adequate for its purposes. Another disadvantage lies in potential liabilities that
could b e associated with actions of a commercial recycler.
When deciding whether to contract the services of an off-site recycler, consider the following:
O n e commercial recycler's charges average $75 for approximately one month,
which includes services for maintaining solvent in a drum-mounted equipment
washer.
Research a commercial recycler's reputation and service. Ask the sales
vendor for references. You should contact several recyclers to compare costs
of services; if a vendor's charges are considerably lower than competitors'
charges, ask why. You must be certain that your spent solvents are being
properly managed by the vendor, because your liability never ends.
If doubts arise, you may check with a U.S. EPA regional office about the
recycler's compliance record.
D o NOT rely on a sales vendor's assessment of your hazardous waste
management situation. Contract with a recycler as a result of making your
own informed decision, not as a result of depending on a sales presentation.
An informed decision is based upon your own knowledge of the federal and
state regulations that apply to your situation as well as upon a financial
analysis of that situation.
Your analysis may indicate that an off-site recycling program is appropriate for your present
situation. Reputable vendors can provide recycling services that meet the needs of clients
who choose not to manage their own recycling on-site.

APPENDICES

A Endnotes, References, and Acknowledgments

B Conditionally Exempt Small Quantity Generator
Requirements
C Small Quantity Generator Requirements
D Used Oil Regulations
E TCLP Parameters; SWA Parameters
F Companies Distributing Alternative Solvents
G Analytical Laboratories
H Distillation Equipment Vendors
I EPA Notification of Regulated Waste Activity
J Hazardous Waste Label
K Uniform Hazardous Waste Manifest
L Notification of Treatment Requirements

For information about federal waste management regulations, EPA offers two hotlines. The
Small Business Ombudsman Hotline representatives are especially helpful and prompt in
answering questions and sending information.
Small Business Ombudsman (SBO) Hotline

800-368-5888

RCRAiSuperfund Hotline:

800-424-9346

For information about state regulations, call the Iowa Department of Natural Resources
Waste Management Division.
Iowa Department of Natural Resources

515-281-5145

The Iowa Waste Reduction Center at the University of Northern Iowa offers free,
confidential waste management advice to small businesses.
Iowa Waste Reduction Center

ENDNOTES, REFERENCES, AND ACKNOWLEDGMENTS

ENDNOTES
The distillation calculation is from an Iowa Waste Reduction Center information
sheet, "Disposal of Still Bottoms."
Methods of calculating manufacturing waste reduction are demonstrated in
Alternatives for Measuring Hazardous Waste Reduction, a document available from the
Illinois Hazardous Waste Research and Information Center.
Environmental Protection Agency's Waste Minimization Opportunity Assessment
Manual, page 22.
The calculations are from Iowa Waste Reduction Center's information sheet,
"Disposal of Still Bottoms."
ICF Consulting Associates, Incorporated (Prepared for California Department of
Health Services Toxic Substances Control Division). Guide to Solvent Waste
Reduction Alternatives Final Report, 1986.
Ibid.
Dove Equipment Company and Graco Company.
Association for Finishing Processes of the Society of Manufacturing Engineers. User's
Guide to Powder Coating, Second Edition, 1987.
NFPA 30, Flammable and Combustible Liquids Code and NFPA 70, National
Electrical Code.
ICF Consulting Associates, Incorporated.
Mike McGee, City of Davenport Building Inspector
ICF Consulting Associates, Incorporated.
ICF Consulting Associates, Incorporated.

REFERENCES
Association for Finishing Processes of the Society of Manufacturing Engineers. User's Guide
to Powder Coating, Second Edition.
Baker et a1 of the Center for Economics Research. Alternatives for Measuring Hazardous
Waste Reduction. Champaign: Illinois Hazardous Waste Research and Information Center,
1991.
Environmental Protection Agency. Waste Minimization Opportunity Assessment Manual,
1988.

ICF Consulting Associates, Incorporated (Prepared for California Department of Health

Services Toxic Substances Control Division). Guide to Solvent Waste Reduction Alternatives
Final Report, 1986.
Kohl et a1 of the Industrial Extension Service. Managing and Recycling Solvents. Raleigh:
North Carolina State University School of Engineering, 1984.
Oregon Department of Environmental Quality.
Recycling, 1989

Guidelines for Waste Reduction and

Gere, Diane. Hazardous Materials Industrial Processes. Davenport: Hazardous Materials

Training and Research Institute (EICCD), 1991.

ACKNOWLEDGMENTS

The following individuals contributed generously of their time and expertise in assuring
accuracy of the manual's information.
Arnold, John (Arnold's Body Shop, Davenport, Iowa)
Blake, Judy (Dove Equipment Company, Inc., Moline, Illinois)
Brandt, Don (Brandt Printing, Davenport, Iowa)
DeSmet, Debra (Moline Paint Company, Inc., Moline, Illinois)
Douglas, Joe (Douglas Industries, Inc., Eldridge, Iowa)
Holgerson, Bill (Logan Contractors Supply, Inc., Davenport, Iowa)
Hopkins, Ben (Emeis Automotive, Davenport, Iowa)
Melvin, Robert (Dove Equipment Company, Inc., Moline, Illinois)
Salz, Doug (Hotsy Cleaning Systems, Inc., Des Moines, Iowa )
Strutzenberg, Jim (Hotsy Cleaning Systems, Inc., Des Moines, Iowa)

CONDITIONALLY EXEMPT
SMALL QUANTITY GENERATOR

CONDITIONALLY EXEMPT SMALL QUANTITY GENERATOR

REQUIREMENTS

A.

Apply to facilities that:

Generate less than 100 kgfcalendar month hazardous waste.
Generate less than 1 kg of acute hazardous waste per calendar month.
Never accumulate more than 1,000 kg total of all (non-acute)
hazardous waste on-site.
Never accumulate more than 1 kg of all acute hazardous waste on-site.
Do not generate or accumulate more than 100 kg of residue,
contaminated soil, waste, or other debris resulting from an acute
hazardous waste spill.

r 100 kg
r 1 kg
r 1000 k
r 1 kg

B.

Hazardous Waste Quantity Determination DOES NOT include:

Used oil, provided it has not been mixed with a hazardous waste.
Spent lead acid batteries that are being reclaimed.
Hazardous Waste Quantity Determination DOES include:
W

Recyclable materials stored before being recycled.

Hazardous waste burned for energy recovery (fuel blending for cement
kilns).
Recyclable materials used for precious metal recovery (photographic
developing solutions, especially fixer).

Very Small Quantity Generator Requirements

E.

Determine whether waste(s) are hazardous.

Stay below generation and storage cutoff limits, and document that the
facility is under the limits.
Treatment/disposal must occur at a RCRA facility or a legitimate
recycling facility.
Conditionally Exempt Small Quantity Generator waste cannot go to a
state permitted solid waste landfill under state law.

Concerns/Complications

Small amounts may need to be accumulated over long periods of time

to make pickup by commercial hazardous waste firm feasible.

Large amount of waste with reduced regulation (e.g. silver containing
waste) may mean a very small amount of other hazardous wastes must
be managed by strict regulations.
- 200 kg/month fixer
- 1 gallonlmonth solvent
- Fixer --> only manifest requirements apply
- Solvent --> all SQG requirements apply

SMALL QUANTITY GENERATOR*

REQUIREMENTS
100-1,000 kg of hazardous waste per calendar month = 220-2,200 lbs/month.

A.

EPA Identification Number

An Environmental Protection Agency (EPA) Identification Number must be
1.
obtained from U.S. EPA Region VII in Kansas City, Kansas using
"Notification of Regulated Waste Activity" form (Appendix I).
If the facility has an EPA ID Number, it can continue to use that number.
2.
The
EPA ID Number is used in shipping waste off-site.
3.

B.

Waste Generation Accumulation, and Storage

Waste is generated at a rate of 100-1,000 kdcalendar month on a regular
1.
intermittent basis.
2.
If waste is generated at a rate greater than 1000 kgJcalendar month (2,200
Ibs.), then the generator immediately becomes subject to large quantity
generator regulations.
Quantity of waste accumulated on-site may never exceed 6000 kilograms
3.
(13,200 Ibs.).
4.
Up to 6,000 kilograms may be stored on-site for 180 days (or 270 days if the
waste must be transported more than 200 miles).
5.
If waste is accumulated in quantities exceeding 6,000 kilograms or stored for
more than 180 days (or 270 days, if applicable), then the generator is an
operator of a storage facility subject to hazardous waste permit requirements.
Packaging, Marking and Placarding
1.
Before transporting waste off-site the waste must be packaged, labeled and
marked according to Department of Transportation (DOT) hazardous
materials transport regulations.
2.
Each container for transport must be marked with the following:
(Commercially available labels can be used; see Appendix J)
HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If
found, contact the nearest policy or public safety authority or the U.S.
Environmental Protection Agency.
Generator's Name and Address
Manifest Document Number
3.
Before transporting, the generator must offer the appropriate placards to the
transporter according to DOT regulations (the transporter may also use his
own appropriate placards).

D.

Uniform Hazardous Waste Manifest

All shipments of hazardous waste must be accompanied by a Uniform
1.
Hazardous Waste Manifest (Appendix K).
The manifest must consist of copies for the generator, transporter, and
2.
operator of the designated facility; and a copy to be returned to the generator
by the designated facility.
The generator must receive a signed copy from the designated facility within
3.
60 days -- if not received, then the generator must submit a copy of the
manifest to EPA and indicate that waste delivery was not confirmed.
Manifest requirements do not apply to hazardous waste where
4.
Waste is reclaimed under a contractual agreement, and
w Type of waste, frequency of shipments are specified in the agreement,
and
w Transport vehicle used to transport the waste to the recycling facility
and to deliver regenerated material back to the generator is owned and
operated by the reclaimer, and
Generator maintains a copy of the agreement for three years after
termination.
A "Treatment Standard Notification" (TSN) for wastes subject to Land Ban
5.
restrictions must accompany the manifest, and a copy of the TSN should be
kept on file. An example TSN is included as Appendix L. Wastes which
commonly require a TSN include:
w Chlorinated solvents: methylene chloride, dichlorobenzene, etc.,
designated as F001, F002.
w Non-chlorinated solvents: toluene, xylene, methanol, etc., designated
as F003, F004, or F005.
Liquid waste with heavy metals such as cadmium, chromium, lead, or
mercury.
Liquid waste with Ph <2.

E.

Satellite Storage
U p to 55 gallons may be accumulated at one or several individual generation
1.
points (satellite storage areas).
2.
Containers must be kept closed and marked to identify contents.
3.
When more than 55 gallons are accumulated at any one site, it must be moved
to the designated storage area within three (3) days.

F.

Use and Management of Containers

1.
Containers must be in good condition and not leaking.
2.
Containers must be compatible with the waste.

3.
4.

5.
6.

Containers must be stored closed.

Container storage area must be inspected weekly and record of inspection
kept on file.
Incompatible wastes must not be placed in same container or stored in close
proximity.
If tanks are used to store hazardous waste, then management standards in 40
CFR 265 Subpart J must be followed.

G.

Container Marking
The date when waste accumulation in the container begins must be clearly
1.
marked on the stored container.
2.
The stored container must be marked with the words HAZARDOUS
WASTE.

H.

Preparedness and Prevention

Storage facilities must be maintained and operated to minimize the possibility
1.
of fire, explosion or release of hazardous waste.
Facilities must be equipped with or provide immediate access to the following:
2.
W Internal communications or alarm system,
W Device (e.g., telephone) to summon emergency assistance from local
authorities,
w Fire extinguisher and control equipment,
W Spill control equipment,
w Water to supply hoses, or sprinkler systems.
All equipment must be tested and maintained to assure proper operation.
3.
4.
When hazardous waste is handled, all personnel involved must have
immediate access to an internal alarm or emergency communication device.
5.
If just one employee is present, he must have immediate access to a device
capable of summoning external assistance (e.g. telephone).
6.
Aisle space must be maintained to allow for fire protection and spill control
in an emergency.
7.
The generator must make the following arrangements with local authorities:
IO Arrangements to familiarize police, fire departments, and emergency
response teams with the layout of the facility, properties of hazardous
waste handled at the facility and associated hazardous, places where
facility personnel would normally be working, entrances to roads inside
the facility, and possible evacuation routes;
Where more than one police and fire department might respond to an
emergency, agreements designating primary emergency authority to a
specific police and a specific fire department and agreements with any
others to provide support to the primary emergency authority;

8.

Arrangements with state emergency response teams, emergency

response contractors and equipment suppliers; and
Arrangements to familiarize local hospitals with the properties of
hazardous waste handled at the facility and the types of injuries or
illnesses which could result from fires, explosions or releases at the
facility.
Where authorities decline to enter into arrangements, documentation of the
attempt to make arrangements (e.g., certified letter requesting arrangements)
must b e kept on file.

I.

Contingency Requirements
At all times, there must be at least one employee available or on call with the
1.
responsibility for coordinating all emergency response measures (emergency
coordinator).
2.
The following information must be posted at the telephone closest to the
storage area:
W Name and telephone number of emergency coordinator(s);
w Location of fire extinguisher, spill control material and fire alarm; and
Telephone number of the fire department.
3.
All employees involved in waste handling and management must b e
thoroughly familiar with proper waste handling and emergency procedures
(Records of training should b e kept on file).
4.
The emergency coordinator must respond appropriately to emergencies as
follows:
Fire; call the fire department andlor attempt to extinguish it.
Spill; contain the flow of waste and clean up waste and contaminated
materialslsoil to prevent or minimize release to the environment.
W Release threatening human health outside the facility of spill reaching
surface water; notify the National Response Center. (1-8001424-8802).
5.
A Contingency plan can be written and kept on file to document compliance
with these requirements.

J.

Recordkeeping
Signed manifest copies must be kept on file for three years.
1.
2.
Records of waste test results or analyses must be kept for three years from the
date that the waste was last sent to treatment, storage or disposal.
3.
Records to document compliance with other sections (e.g. weekly inspection
log) should be kept on file.

SUMMARY OF MANAGEMENT STANDARDS FOR GENERATORS OF USED OIL

Management of used oil is regulated under 40 CFR part 279 of the federal hazardous waste
regulations. The regulations establish requirements for generators of used oil, and burners,
marketers and processors of used oil fuel. They also establish requirements for used oil
collection centers and for the management of materials contaminated with used oil. General
requirements are:
w Use of used oil for road oiling and dust suppression purposes is specifically banned.
W

There are no accumulation time limits or amounts.

Farmers generating less than 25 gallons of used oil per month are considered DIY (do-ityourselfers).

Recycling options for generators of used oil include the following:

1.
2.

3.

Provide to a marketer-the generator is not required to test the oil for used oil fuel
specifications.
Provide directly to a burner-the generator becomes a marketer and must follow
marketer requirements including testing of used oil for specification parameters.
Burn used oil on-site in an oil fired space heater provided that:
a. Oil is generated on-site or collected from DJY generators.
b. The heater is designed to have a maximum BTU capacity of not more than 0.5
million BTU/hr.
c. The heater is vented to the outside air.

Off-site shipment of used oil by a generator to a collection center, a marketer or a burner must
conform to one of the following methods:
1.

2.

3.

Commercial Transport-Used oil can be picked up only by transporters that have an EPA
identification number.
Self-Transport-Less than 55 gallons of used oil can be transported by the generator to a
used oil collection center that has been recognized or licensed by a government agency to
manage used oil. The vehicle used to transport the oil must be owned by the company or
an employee of the company.
Less than 55 gallons of used oil can be transported by the generator to an aggregation
point which is owned and/or operated by the generator. The vehicle used to transport the
oil must be owned by the company or an employee of the company.

4.

Used oil can be picked up by a transporter without an EPA identification number

provided that a "tolling arrangement" is in place. To accomplish this a contract must be
in place that indicates:
a. The type of used oil and frequency of shipments;
b. That reclaimed oil will be returned to the generator; and
c. The vehicle used for pickup and delivery is owned and operated by the used oil
recycler.

On-site storage of used oil must meet the following standards as follows:
1.

2.
3.
4.

Containers and aboveground tanks used for used oil storage must be in good condition
and not leaking. Leaking containers must be repaired or replaced.
Containers must be labeled or marked clearly with the words "Used Oil."
Fill pipes for underground used oil storage tanks must be labeled with the words "Used
Oil."
Releases of oil must be stopped by the generator, the released oil contained and properly
managed.

APPENDIX E
TCLP PARAMETERS; SWA PARAMETERS

TCLP PARAMETERS
Toxicity Characteristic Leaching Procedure
Regulatory
.. . .
.
.
Level
Parameter
5.0 mg/l
Arsenic
. ' .
100.0
mg/l
Barium
..
. . -. . . .
0.5
mg/l
Benzene
..
.
1.0 mg/l
Cadmium
0.5
mg/l
Carbon tetrachloride .;. , . ' . ... . .. . . .

....

'

.- . -

. ,

Chlordane . - - .
.,
Chlorobenzene . .
.
Chloroform . ,. . .. . ...t . ' , ...
.
Chromium . , . - .. . - ....
.
.,
.
m-Cresol

....,.

;-

. .
$ .

>

.T

,,.
.

o-Cresol . ' .' .. . .. , .. . . . .

p-Cresol
Cresols (total)
1,4-Dichlorobenzene
1,2-Dichloroethane

0.03 mgll
100.0 mgll
6.0 mg/l
5.0 mg/l
200.0 mg/l

1,l-Dichloroethylene
2,4-Dinitrotoluene
.. ,
Endrin
., , . .
Heptachlor
Hexachlorobenzene

'

Hexachloro-l,3-butadiene
Hexachloroethane
Lead
Lindane
Mercury

*
*
*

Methoxychlor
-Methyl ethyl ketone
' Nitrobenzene
Pentachlorophenol
Pyridine

10.0 m g .
200.0
2.0 mg/l
100.0 mg/l
5.0 mgll

Selenium
Silver
Tetrachloroethylene
Toxaphene
Trichloroethylene

1.0 mg/l
5.0 mgll
0.7 mg/l
0.5 mgll
0.5 mgll

Vinyl chloride
2,4-D
2,4,5-TP
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol

Former EP Toxicity Parameters

mu.

0.2 mg/l
10.0 mg/l
1.0 mgll
400.0 mg/l
2.0 mg/l

-'

.-

EPA Hazardous Waste

Number
D004
D005
- DO18
D006
DO19

SWA PARAMETERS
The following lab analysis must be performed and a copy of the results submitted with the
SWA application to the DNR.

1.

Toxicity Characteristic Leaching Procedure (TCLP)

Only those constituents suspected to be present must be tested for. Documentation
of the rationale for parameter selection may be required. The eight metals must be
tested for regardless. If a virgin product is being disposed, a MSDS may be
substituted for the TCLP test. Contact the DNR at (515) 281-3426 prior to deleting
any constituents.
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver

2.

5.0 mg/l
100.0 mg/l
1.0 mg/l
5.0 mgjl
5.0 mg/l
0.2 mgjl
1.0 mg/l
5.0 mg/l

Initial pH of the waste

pH must be between 2 and 12.5

3.

Paint Filter Liquids Test

This is a passlfail test to determine if there are any free liquids in the waste material.
If there are no free liquids, the material passes the test.

4.

Total Extractable Hydrocarbon

This test is only required for paint, varnish, and stain wastes. The result must be less
than 1% or 10,000 mg/kg for disposal in an Iowa landfill.

COMPANIES DISTRIBUTING ALTERNATIVE SOLVENTS

American Metal Wash, Inc.
360 Euclid Avenue
P.O. Box 265
Canonsburg, PA 15317
412/746-4203
Barton Solvents
Dave Richard
P.O. Box 221 D
1920 N.E. Broadway
Des Moines, IA 50301
5 151265-7900
Bidall Chemical
Dave Fisher
1199 W. 1st St.
Ankeny, IA 50021
5 151944-1332
Chemical Finishing
Westfield Industrial Park Road
Westfield, MA 01085
4 131562-7066
Chemsearch
Curt Rechkemmer
612 Stanley St.
Cedar Falls, IA 50613
3 191266-9982
Environmental Technology
Richard Gion
(Will provide sample)
1511 Kastner P1.
Sanford, FL 3277 1
4071321-7910

GAF chemicals Corporation

St. Regis Office Center
Suite 124
1919 S. Highland Ave.
Lombard, IL 60148
7081932-4022
Hotsy Cleaning Systems, Inc.
Jim Strutzenberg, Doug Salz
(Will provide demos)
3100 N.W. lOlst St.
Des Moines, IA 50322
5151278-8800 or 8001532-2407
ISP
Tony Durante
1361 Alps Road
Wayne, NJ 07470
2011628-3913
Lewis Corporation
324 Christian Street
Oxford, CT 06483
2031264-3100
Quaker Chemical Corporation
Elm & Lee Streets
Conshohocken, PA 19428
2151828-4250

ANALYTICAL LABORATORIES

A & L Mid West Laboratories, Inc.

13611 "B" Street
Omaha, NE 68144
4021334-7770
Donna LaMura
Groundwater Technology, Inc.
5158 Park Avenue
Des Moines, IA 50321
5151282-9132
Deanne Geile
Keystone Laboratories, Inc.
501 West Third Street North
Newton, IA 50208
5151792-8451
Dr. Jeff King
National Environmental Testing
Cedar Falls, IA 50613
3191277-2401
Mike McGee
QCML, Inc.
Davenport, IA 52804
3 191386-7827
Lori Korsen
State Hygienic Lab
Iowa City, IA 52240
3191355-4500

DISTILLATION EQUIPMENT VENDORS

Acra Electric Corp.*
3801 N. 25th Avenue
Schiller Park, IL 60176-2187
3121678-8870
Baron-Blakeslee
J.M. Bowman
2001 North Janice Ave.
Melrose Park, JL 60160
3 121450-4015
Corning Process Systems
William T. Jackson
Corning Glass Works
Big Flats Plant
Corning, NY 14830
6071974-0299
DCI International
Robert M. Zopf
1229 Country Club Rd.
Indianapolis, IN 46234
3171271-4001
Detrex Corporation
P.O. Box 5111
Southfield, MI 48086-5111
3 131358-5800

* Also drum dewatering

equipment

** Barrel Distiller (55-gal

drum can be put in still)

Dove Equipment Co., Inc.

Don Thiessen
24 12 4th Avenue
Moline, IL 61265
309/797-0977
FAX 309/797-4118
Dowmar Solvent Recovery
Systems
James Dowd
P.O. Box 740953
Orange City, FL 32774
9041774- 1311
Environmental Safety
Products
Arlos E. Fisher
1521 Washington Street
Cedar Falls, IA 50613
3 191232-8289
Finish Engineering Co.
Peter B. Scantlebury
921 Greenyard Rd.
Erie, PA 16501-1591
8 141455-4478
Interel Cop.**
Paris R. Briscoe
P.O. Box 4676
Englewood, CO 80155
303/773-0753

Lenape Sales & Service, Inc.

James J. Mastrain, Jr.
P.O. Box 285
Manasquan, NJ 08736
201168 1-2442
McVinua & Assoc., Inc.
Doug McVinua
75 17 Douglas Ave.
Suite 12
Urbandale, IA 50322
5 15/276-7577
PBR Industries, Inc.
400 Farmingdale Rd.
West Babylon, NY 11704
5 161422-0057
Progressive Recovery, Inc.
Joe Miller
1020 North Main St.
Columbia, IL 62236
618-281-7196
Recyclene Products, Inc.
Refus Williams
404 Eccles Ave.
S. San Francisco, CA 94080
4151589-9600
Seneca Corp.
Marvin Cooley
5636 N.E. 17th Street
Des Moines, IA 50313
8001362-2910

EPA Form 8700-12 (07-90) Previous edition is obsolete.

Please pnnt or type with ELITE type (12 characters per ~ n c h in

) the unshaded a r m only

lnqulry of those lndlvlduals lmmedlately responsible for

d intormatlon Is true, accurate, and complete. I am aware
false information, lncludlng the posslbillty of flnes and

EPA Form 8700-12 (07-90) Previous edltion Is obsolete.

FEDERAL LAW PROHIBITS IMPROPER DISPOSAL

IF FOUND, CONTACT THE NEAREST POLICE, OR
.
PUBLIC SAFETY AUTHORITY, OR THE
U.S. ENVIRONMENTAL PROTECTION AGENCY
PROPER D.O.T.
SHIPPING NAME

UN OR NAlr

GENERATOR INFORMbTION:

S T A T E L I P
EPk
ACCUMULATION

MANIFEST
DOCUMENT NO

HANDLE WITH CARE!

CONTAINS HAZARDOUS OR TOXIC WASTES

PrlnlM Dy LABELMASTER. DV d AMERICAN USELMARK

CO . INC . CHICAGO

IL -6

pw,

II

p u n t a (yps.

/form k&

lor u w on &a

/ I Z-picch) w i l w . )

For,..

. a w e d OH8 Nu 2QW-0039. E w e s

Wl

16. GENERATOR'S CERTIFICATION: I h

aw docure that rhe eontents d thla m n m e n t are f u l h and accurately desalbod abovs by
proQer s
h
m
n
g rume and are c l a u i t d W
m
d
.marked. a n d hbe(ed. and n e m all r u p o c t r I n
c o o d ~ t t o nf a t r a m by h-y
according to a m a b l e t n t a n a t ~ o o a and
l
n a l m l povwnment r b g u b l u n r
ll I a m a large qumnttw generatw. lc e n t t y t h a Ihws a p o p r a m I n pkca t o r x h m t h d u m a n d t o r ~ c n yof w e r t e generated to the d q r w I h a w determunod t o be
ummmr~lhpraa~~
a nMd al h n Ih w s a d u t o d t h e p m ~
W o 4 wutment a a . g s . o ~ ~ currently
I
a v a ~ b b l eto m e w t ~ muntmuesthepresent
h
snd
iuIur.thmat t o h u m a n health and t h o a m r o n m m t . OR. IIl a m a v r u l l q r u n t y gmma,Ihmnuds a pood faulh e f l o n to mtnlmlza m y wanegeneratton a n d wlm
t h . beat w a n e management msthcd that IS rnlW t o me a n d t M Io n a M
Prtntd/Typed Name
slpnnure
Monrh Day
Year

I
T

I I I I I I .
1 7 . T r a n w e r 1 h n o w l b b g e m e n t of R . c s t p (

d Merauh

Slg"nure

Rtnled/Typed Name

Month

Day

Year

I I I I I I
18 T r a n w a 2 Acknowiodgemenl

Rtnted/Typed Name

d R e c s ~ p ld h b t a i a l s
m u r e

I I I I I I ,
1 9 Durcrsp.ncy Indtcatmn SWW

2O.Factlu1y Ovmei a Operalor. C e n l i a t m n d r e c s l d d hazardous matertals w e d bv this manliest except as w e d In hem 19.
R ~ n t e d A y p e dName

Svpature

Monrh

Day

Year

Generator
Waste Stream #

EPA ID#
Manifest #

; no

Waste Analysis data available: yes

If yes, please attach copy. (TSDFonly)

treatmentstandard
concentration(m~/I)
F001-FU05 spent solvents

X if
contained
in waste

other
spent solvent
wastes

wastewater
containing
spent solven ts

Ace tone (F003)

n-Butyl alcohol (FO03)
Carbon disulfide (F005)
Carbon tetrachloride(l;r)Ol)
Chlorobenzene(F002)
Cresols (and cresylic acid) (FO04)
Chlorohexanone(Ij003)
1,2-Dichlorobenzene (F002)
Ethyl acetate (F003)
Ethyl benzene (FO03)
Ethyl ether(FO03)
Isobutanol (F005)
Methanol (F003)
Methylene chloride (FUOl,F002)
Methyl ethyl ketone(FOO5)
Methyl isobutyl ketone (FD03)
Nitrobenzene(FOM)
Pyridine (F005)
Tetrachloroethylene(F001,FU02)
Toluene (F005)
l,l,l-Trichloroethane (F001,FO02)
1,2,2-Trichloro-l,l,2trifluoroethane(~1,F002)
Trichloroethylene(~l,F002)
Trichlorofluoromethane(FOO1,F002)
Xylene (F003)

This is to notify you that this shipmentof hazardouswaste containsa waste that is restricted from land disposal and requires treatmentprior
to land disposal. This notificationis provided in fulfillment of 40 CFR Part 268 Subpart A, section 268.7. The informationabove pertains
to the restrictedwaste in this shipment.

I believe that the information1 submittedis true, accurateand complete. 1 am aware that there are significant penaltiesfor submittinga false
notification, including the possibility of a fine and imprisonment.

Signature of Authorized Representative- date

Printed Name and Title of Representative

Copies to be sent to: TSDF; transporter;generator
SQGLAND ,BAN
(6/92)