Technical
Background
Document
Proposed
Exclusions
from
the
Definition
of
Hazardous
Waste
and
Solid
Waste
for
Solvent­
Contaminated
Industrial
Wipes
August
20,
2003
Contents
List
of
Acronyms
Used.......................................................................
3
I
Statement
of
Purpose........................................................................
5
II
Characteristics
of
Waste
and
Waste
Handlers.................................
16
III
Current
Regulatory
Environment......................................................
29
IV
Provisions
of
the
Proposed
Rule......................................................
45
V
Summary
of
Risk
Screening
Analysis...............................................
86
VI
References.....................................................................................
138
3
ACRONYMS
4
Acronym
Definition
APA
............................................................
ASTSWMO..............................................
...

ATCA.......................................................
...
BIF............................................................
..
BRS..........................................................
...
CAA..........................................................
..
CAS
No.......................................................
CBI...........................................................
...
CESQG.....................................................
..
CFR..........................................................
...
CSF...........................................................
..
CSI............................................................
..
CWA.........................................................
..
DAF..........................................................
...
DOT..........................................................
..
DSS...........................................................
..
ELG..........................................................
...
EPA..........................................................
...
FR..........................................................
......
HAP..........................................................
...
HCS..........................................................
...
HSWA......................................................
...
HQ............................................................
...
HWC.........................................................
..
Administrative
Procedures
Act
Association
of
State
and
Territorial
Solid
Waste
Management
Officials
Alliance
of
Textile
Care
Associations
Boiler
or
Industrial
Furnace
Biennial
Report
System
Clean
Air
Act
Chemical
Abstracts
Service
Registry
Number
Confidential
Business
Information
Conditionally
Exempt
Small
Quantity
Generator
Code
of
Federal
Regulations
Cancer
Slope
Factor
Common
Sense
Initiative
Clean
Water
Act
Dilution
Attenuation
Factor
Department
of
Transportation
Domestic
Sewage
Study
Effluent
Limitation
Guidelines
Environmental
Protection
Agency
Federal
Register
Hazardous
Air
Pollutants
Hazard
Communication
Standard
Hazardous
and
Solid
Waste
Amendments
Hazard
Quotient
Hazardous
Waste
Combustor
Information
Collection
Request
Integrated
Risk
Information
System
Integrated
Waste
Services
Association
Land
Disposal
Restrictions
Large
Quantity
Generator
Maximum
Achievable
Control
Technology
Methyl
Isobutyl
Ketone
Material
Data
Safety
Sheet
Municipal
Solid
Waste
Municipal
Solid
Waste
Landfill
Municipal
Waste
Combustor
National
Ambient
Air
Quality
Standards
National
Emission
Standards
for
Hazardous
Air
Pollutants
National
Fire
Incident
Reporting
System
National
Pollution
Discharge
Elimination
System
Natural
Resources
Defense
Council
Acronym
Definition
5
NSPS........................................................
...
NTTAA.....................................................
..
OECA.......................................................
...
OMB.........................................................
..
OPPE........................................................
...
OSHA.......................................................
...
OSW.........................................................
...
PBMS.......................................................
...
PCB..........................................................
...
POTW.......................................................
..
RCRA.......................................................
...
RFA..........................................................
...
RfC...........................................................
...
RfD...........................................................
...
RIC...........................................................
...
SBREFA...................................................
..
SIC............................................................
..
SQG..........................................................
...
TC.............................................................
..
TCLP........................................................
...
TBD..........................................................
...
TDD..........................................................
..
UMRA......................................................
...
URF..........................................................
...
New
Source
Performance
Standards
National
Technology
Transfer
and
Advancement
Act
Office
of
Enforcement
and
Compliance
Assurance
Office
of
Management
and
Budget
Office
of
Policy,
Planning
and
Evaluation
Occupational
Safety
and
Health
Administration
Office
of
Solid
Waste
Performance
Based
Measurement
System
Polychlorinated
Biphenyls
Publicly
Owned
Treatment
Works
Resource
Conservation
and
Recovery
Act
Regulatory
Flexibility
Act
Reference
Air
Concentrations
Reference
Doses
for
Exposure
through
Ingestion
RCRA
Information
Center
Small
Business
Regulatory
Enforcement
Fairness
Act
Standard
Industry
Code
Small
Quantity
Generator
Toxicity
Characteristic
Toxicity
Characteristic
Leaching
Procedure
Technical
Background
Document
Telecommunications
Device
for
the
Deaf
Unfunded
Mandates
Reform
Act
Unit
Risk
Factor
United
States
Fire
Administration
Volatile
Organic
Compound
6
Technical
Background
Document
for
Proposed
Rule
to
Conditionally
Exclude
Solvent­
Contaminated
Industrial
Wipes
from
the
Definition
od
Hazardous
Waste
and
the
Definition
of
Solid
Waste
I.
Statement
of
Problem
I.
A.
Background
The
Environmental
Protection
Agency
(
EPA)
is
proposing
to
amend
its
regulations
under
the
Resource
Conservation
and
Recovery
Act
(
RCRA).
The
proposal
is
(
1)
to
conditionally
exclude
from
the
definition
of
hazardous
waste
disposable
industrial
wipes
that
are
contaminated
with
hazardous
solvents
and
are
going
to
disposal,
and
(
2)
to
conditionally
exclude
from
the
definition
of
solid
waste
reusable
industrial
shop
towels
and
rags
that
are
contaminated
with
hazardous
solvents
and
are
sent
for
laundering
or
dry
cleaning.
The
affected
universe
of
waste
for
this
proposed
rule
encompasses
disposable
and
reusable
industrial
wipes
(
e.
g.,
towels,
wipes,
rags)
that
industry
uses
to
clean
surfaces,
parts,
accessories,
and
equipment
in
conjunction
with
solvents
that
when
spent
are
hazardous
wastes.
Industrial
wipes
are
distinguished
by
their
respective
make­
up,
durability,
uses,
and
disposal
method.
Once
industrial
wipes
are
used
and
are
no
longer
suitable
for
their
intended
purpose,
they
become
solid
wastes
and
potentially
hazardous
wastes,
depending
upon
the
type
of
solvent
used
in
conjunction
with
the
wipes.

Many
solvents
used
by
industry
can
pose
unacceptable
risks
to
human
health
and
the
environment
if
improperly
managed.
The
proposed
conditional
exclusions
will
apply
to
(
1)
industrial
wipes
contaminated
with
solvents
that
exhibit
a
hazardous
characteristic
(
i.
e.,
7
ignitability,
corrosivity,
reactivity,
or
toxicity)
and
(
2)
industrial
wipes
contaminated
with
F001­
F005
spent
F­
listed
solvents
or
comparable
P­
and
U­
listed
commercial
chemical
products
that
are
spilled
and
cleaned
up
with
industrial
wipes.

Essentially,
EPA
is
proposing
to
exclude
industrial
wipes
contaminated
with
solvents
that
are
determined
to
be
a
hazardous
waste
from
RCRA
subtitle
C
regulations.
The
exclusions
would
be
applicable
only
when
specified
conditions
are
met.
This
proposal
responds
to
two
manufacturer
petitions
as
well
as
requests
for
regulatory
clarification
from
the
user
community,
particularly
from
industry
representatives
in
EPA's
Printing
Common
Sense
Initiative
(
CSI).

I.
A.
1.
Descriptions
and
Definitions
of
Affected
Wastes
For
purposes
of
this
document
and
the
Agency's
proposed
rule,
we
will
use
the
term
"
industrial
wipes"
to
refer
to
the
following
types
of
wipes
and
cloths:

An
industrial
shop
towel
is
a
woven
textile
consisting
of
cotton
or
polyester
blends.
These
materials
are
reusable
items
and
are
primarily
laundered
or
dry
cleaned
a
number
of
times
before
they
have
outlived
their
useful
life
and
must
be
discarded.
Shop
towels
are
rented
by
industrial
laundries
to
manufacturing,
automotive,
chemical,
and
other
similar
facilities
to
use
for
heavy­
duty
cleaning
and
wiping.
Soiled
shop
towels
are
either
washed
or
dry
cleaned
at
commercial
laundry
facilities.

An
industrial
wipe
is
a
non­
woven
towel
consisting
of
wood
pulp,
polyester
blends
or
100
percent
polypropylene.
These
materials
come
in
all
sizes
and
thicknesses.
They
generally
are
designed
for
one­
time
use
and
are
used
to
wipe
small
quantities
of
solvents
off
hands,
tools,
equipment,
or
floors.

An
industrial
rag
is
a
non­
homogeneous
material
consisting
of
cotton
or
polyester
blends.
Rags
are
made
from
old
clothing
or
from
cloth
remnants
from
textile
mills,
and
vary
in
size
and
type
of
fabric.

Paper
towels
also
are
sometimes
used
in
conjunction
with
solvents
in
the
workplace.
These
materials
are
made
from
wood
pulp
with
binders.

I.
A.
2.
Description
of
Affected
Universe
When
investigating
current
management
practices
for
solvent­
contaminated
industrial
wipes,
EPA
found
tremendous
variability
in
the
uses
of
industrial
wipes
and
their
management
across
and
within
industries.
A
wide
range
of
industries
and
a
large
number
of
firms
use
significant
amounts
of
solvents
on
industrial
wipes
and
could
be
eligible
for
and
subject
to
the
conditions
of
the
proposed
exclusions.
Some
of
these
industrial
sectors
include
printing
manufacturing;
industrial
laundries;
automobile
repair
and
maintenance;
aircraft
manufacturing
and
maintenance,
circuit
board
manufacturing;
furniture
manufacturing;
and
coating
and
adhesive
testing
and
production.
These
industries
use
a
range
of
solvents
and
varying
types
of
industrial
wipes
at
their
facilities.
Chapter
II
of
this
document
summarizes
the
Agency's
current
information
on
the
types
of
establishments
that
use
reusable
or
disposable
industrial
wipes
in
conjunction
with
solvents.
8
The
types
of
facilities
visited
during
the
data
gathering
efforts
of
this
proposed
rule
included
printing
(
flexographic
and
screen
printing),
automobile
body
repair,
aircraft
manufacturing
and
maintenance,
circuit
board
manufacturing,
and
coating
and
adhesive
testing
and
production.
Other
industrial
sectors
that
use
significant
quantities
of
solvents
in
conjunction
with
industrial
wipes
include
furniture
manufacturing
and
automobile
manufacturing
and
maintenance.
From
site
visits
conducted
at
17
facilities,
including
nine
sites
where
data
was
collected,
EPA
determined
the
following:


The
RCRA
regulatory
status
of
facilities
visited
included
small
quantity
generators
(
SQGs)
and
large
quantity
generators
(
LQGs).
In
some
cases,
solventcontaminated
industrial
wipes
appeared
to
be
the
primary
basis
for
a
facility
being
classified
as
an
SQG
rather
than
a
Conditioanlly
Exempt
Small
Quantity
Generator
(
CESQG).


Reusable
industrial
wipes,
disposable
paper
and
disposable
cloth
wipes
all
were
found
to
be
used
in
the
site
visits;
sometimes
firms
used
both
reusable
shop
towels
and
disposable
industrial
wipes
in
their
operations.


Approximately
half
the
facilities
visited
reported
using
their
wipes
more
than
once
before
discarding
and
sending
them
for
off­
site
management.


The
amount
of
solvent
placed
on
individual
wipes
varied
from
very
small
amounts
(
a
fraction
of
shop
towel/
wipe
weight)
to
multiples
of
the
wipe's
weight.


Reusable
and
disposable
industrial
wipes
were
managed
off­
site
at
hazardous
waste
treatment
(
incineration)
facilities,
fuel
blending/
burning
for
energy
recovery
facilities,
and
disposal
facilities,
as
well
as
municipal
landfills,
industrial
landfills
and
industrial
laundries.


Storage
of
spent
reusable
and
disposable
industrial
wipes
occurred
in
either
RCRA­
compliant
covered
storage
containers,
open
containers,
porous
bags
or
on
shelves.


Advanced
solvent­
extraction
technologies
EPA
observed
included
centrifugation,
mechanical
wringing
and
use
of
screen­
bottom
drums.
These
technologies
are
used
by
generators
to
remove
solvent
primarily
from
reusable
industrial
wipes
(
but
are
also
used
with
disposable
industrial
wipes)
to
ensure
that
free
liquids
are
not
sent
off­
site
to
an
industrial
laundry,
as
well
as
to
assist
industrial
laundries
in
meeting
their
permit
conditions
from
the
local
POTW.


Most
of
the
facilities
visited
had
state
or
county
air
permits.

I.
B.
Overview
of
Current
Regulations
The
applicability
of
the
RCRA
hazardous
waste
management
standards
to
solventcontaminated
industrial
wipes
has
been
the
subject
of
changing
regulatory
interpretations.
9
I.
B.
1.
Current
Federal
Regulations
Under
the
federal
RCRA
program,
a
solid
waste
is
a
hazardous
waste
if
it
(
a)
is
listed
as
a
hazardous
waste
in
40
CFR
Part
261,
subpart
D;
(
b)
exhibits
one
or
more
of
the
characteristics
of
hazardous
waste
identified
in
40
CFR
Part
261,
subpart
C;
(
c)
is
a
mixture
of
a
solid
waste
and
a
hazardous
waste
that
is
listed
in
subpart
D;
or
(
d)
is
a
mixture
of
a
solid
waste
and
a
characteristic
hazardous
waste
(
or
a
listed
hazardous
waste
that
is
listed
solely
because
it
exhibits
one
or
more
of
the
characteristics
of
hazardous
waste
identified
in
Part
261
subpart
C),
unless
the
resultant
mixture
no
longer
exhibits
any
characteristic
of
hazardous
waste
identified
in
subpart
C
(
See
40
CFR
261.3(
a)(
2)).

Therefore,
solvent­
contaminated
industrial
wipes
meet
the
definition
of
hazardous
waste
due
to
the
applicability
of
the
hazardous
waste
mixture
rule
or
because
they
exhibit
a
characteristic
of
hazardous
waste.
The
current
federal
policy
is
to
defer
the
determination
of
whether
solvent­
contaminated
industrial
wipes
must
be
managed
as
a
solid
or
hazardous
waste
to
the
regional
EPA
offices
and
state
agencies
due
to
case­
specific
circumstances
(
e.
g.,
type
of
solvent
used,
degree
of
hazard,
when
a
spent
solvent
is
generated,
and
whether
the
hazardous
waste
mixture
rule
applies
to
a
particular
waste).
The
federal
policy
deferring
the
regulatory
determination
for
solvent­
contaminated
industrial
wipes
was
first
articulated
in
a
January
23,
1991
letter
from
Sylvia
K.
Lowrance,
Director,
Office
of
Solid
Waste,
to
Lance
R.
Miller,
Director
of
New
Jersey's
Hazardous
Waste
Management
Division.
Ms.
Lowrance
responded
to
a
petition
from
Kimberly­
Clark
Corporation
and
Scott
Paper
Company,
stating
that
until
EPA
could
make
a
"
more
comprehensive
interpretation
in
this
rulemaking
context
[
solvent­
contaminated
industrial
wipes] 
Regions
and
States
[
should]
continue
to
use
the
current
case­
by­
case
approach
on
this
subject."
This
policy
was
reaffirmed
in
a
February
14,
1994
memorandum
to
the
EPA
Regional
Waste
Management
Directors
from
Michael
Shapiro,
Director,
Office
of
Solid
Waste.

A
majority
of
states
have
developed
their
own
policies
governing
the
management
of
solvent­
contaminated
industrial
wipes
(
pending
EPA
action).
However,
a
few
states
have
deferred
regulatory
decisions
regarding
the
management
of
solvent­
contaminated
industrial
wipes
to
their
respective
EPA
regional
offices.

I.
B.
2.
State
Regulations
The
majority
of
states
have
developed
management
requirements
for
solventcontaminated
industrial
wipes;
the
remaining
states
have
deferred
such
decisions
to
their
EPA
regions.
A
review
of
state
policies
regarding
the
regulation
of
solvent­
contaminated
industrial
wipes
indicates
that
most
states
have
similar
management
requirements
in
place.
The
majority
of
states
have
policies
that
generally
apply
the
hazardous
waste
mixture
rule
to
disposable
industrial
wipes
that
are
contaminated
with
hazardous
waste
solvents.

Currently,
all
states
regulate
industrial
wipes
as
a
hazardous
waste
when
they
are
contaminated
with
a
listed
solvent
or
exhibit
a
hazardous
waste
characteristic
and
are
destined
for
disposal.
Forty­
six
states
provide
regulatory
relief
for
solvent­
contaminated
shop
towels
that
are
10
sent
to
an
industrial
laundry
and
subsequently
reused.
The
remaining
four
states
(
Hawaii,
Idaho,
New
Mexico
and
South
Dakota)
regulate
reusable
solvent­
contaminated
shop
towels
as
hazardous
waste
if
they
contain
a
listed
hazardous
waste
or
exhibit
a
hazardous
waste
characteristic,
regardless
of
whether
the
towels
are
being
laundered.

The
majority
of
state
programs
consider
laundering
to
be
a
form
of
recycling
and
subsequently
exempt
reusable
shop
towels
from
RCRA
regulation.
Other
states
provide
conditional
exclusions
from
the
hazardous
waste
regulations
for
laundered
shop
towels.
In
either
case,
the
contaminated
shop
towels
only
are
exempt
from
regulation
if
the
following
criteria
are
met:


the
towels/
wipes
do
not
contain
free
liquids;
and

the
industrial
laundry
discharges
to
a
publicly
owned
treatment
works
(
POTW)
or
is
otherwise
permitted
under
the
Clean
Water
Act.

Some
states
allow
on­
site
laundering
of
solvent­
contaminated
shop
towels
by
generators,
provided
that
there
is
an
agreement
on
file
with
the
state
agency
that
allows
the
facility
to
discharge
to
the
sanitary
sewer.
In
addition,
at
least
three
states
require
contractual
agreements
between
generators
and
laundries
for
the
generator
to
qualify
for
an
exemption
from
RCRA
regulation.
In
most
cases,
state
and
regional
policies
and
regulatory
programs
differentiate
between
reusable
and
disposable
industrial
cloths
when
determining
regulatory
status.

While
the
majority
of
state
policies
include
the
above­
mentioned
policies
and
regulatory
components,
there
are
some
notable
variations
such
as
Hawaii,
New
Mexico,
Idaho,
and
South
Dakota.
In
Hawaii,
solvent­
contaminated
industrial
wipes
must
be
managed
as
hazardous
waste
up
until
the
point
at
which
they
are
laundered.
Industrial
laundries
in
New
Mexico
are
subject
to
permitting
requirements
unless
the
towels
are
placed
directly
into
the
laundry
process
(
i.
e.,
within
24
hours).
In
Idaho,
industrial
wipes
must
be
managed
as
hazardous
waste
if
they
are
contaminated
with
a
listed
waste
or
exhibit
a
characteristic.
Reusable
towels
cannot
be
laundered
unless
they
are
treated
to
meet
the
specified
LDR
treatment
standard
for
the
wastes
with
which
they
are
contaminated.
Finally,
South
Dakota
requires
that
if
a
listed
solvent
is
applied
to
a
part
and
then
cleaned
off
with
a
wipe,
the
wipe
is
considered
to
be
a
listed
hazardous
waste
(
because
the
solvent
is
"
spent"),
must
be
managed
as
a
hazardous
waste,
and
cannot
be
laundered.
Similarly,
if
the
solvent­
contaminated
industrial
wipe
exhibits
a
characteristic,
the
material
is
hazardous
and
cannot
be
laundered.
However,
if
the
wipe
is
contaminated
with
a
listed
solvent
that
was
applied
directly
to
the
wipe,
the
wipe
is
not
considered
to
meet
a
hazardous
waste
listing
description
and
can
be
laundered
without
being
managed
as
a
hazardous
waste.
A
more
detailed
discussion
of
state
regulatory
programs
governing
solvent­
contaminated
industrial
wipes
is
provided
in
section
III.

I.
C.
Scope
of
Wastes
Included
in
Proposed
Rule
The
scope
of
the
proposed
rulemaking
includes
the
universe
of
contaminated
industrial
wipes
being
sent
to
both
landfill
and
non­
landfill
(
e.
g.,
laundries
and
combustion)
facilities
and
is
applicable
to
industrial
wipes
(
1)
contaminated
with
solvents
that
exhibit
a
hazardous
characteristic
and
(
2)
contaminated
with
F001­
F005
spent
F­
listed
hazardous
waste
solvents
or
comparable
P­
or
U­
listed
commercial
chemical
products
when
spilled
and
cleaned
up
with
11
industrial
wipes.

I.
D.
Rationale
for
Proposed
Rule
I.
D.
1.
Current
Regulatory
Program
Based
upon
Policy/
Regulatory
Interpretation
For
several
years,
industry,
particularly
the
disposable
industrial
wipes
industry,
requested
that
EPA
address
the
issue
of
whether
the
current
federal
rules
are
over­
regulating
the
management
of
solvent­
contaminated
industrial
wipes
that
are
disposed.
More
specifically,
industry
has
expressed
concern
that
often
only
small
amounts
of
solvent
are
applied
to
a
wipe,
and,
therefore,
by
the
time
the
wipe
is
disposed,
little
or
no
risks
to
human
health
and
the
environment
exist
from
management
of
the
wipe
because
little
solvent
remains
on
the
wipe.
However,
as
described
above,
these
wipes
may
be
regulated
as
a
hazardous
waste
because
they
contain
a
listed
hazardous
solvent.
Under
their
own
policies,
most
states
subject
disposable
industrial
wipes
contaminated
with
hazardous
waste
solvents
to
the
hazardous
waste
mixture
rule
and
require
that
they
be
managed
as
hazardous
waste
if
the
mixture
is
defined
under
RCRA
as
a
hazardous
waste.

The
feedback
that
EPA
received
on
this
issue
as
part
of
regulatory
reform
outreach
efforts
and
from
industry
representatives
in
the
Printing
CSI
encourages
the
Agency
to
address
the
regulatory
status
of
solvent­
contaminated
industrial
wipes
within
the
context
of
the
federal
RCRA
program,
and
to
determine
whether
changes
in
the
federal
regulatory
program
governing
the
management
of
these
materials
are
appropriate.

EPA
framed
its
study
of
solvent­
contaminated
industrial
wipes
to
answer
the
following
questions
and
to
develop
a
proposed
regulation
that
would
address
the
issues
raised
by
stakeholders.
The
primary
concern
was
whether
EPA
and
the
states
are
regulating
disposable
and
reusable
industrial
wipes
effectively
to
ensure
protection
of
human
health
and
the
environment.
The
following
questions
were
integral
to
the
development
of
the
proposed
rulemaking:


Are
solvent­
contaminated
industrial
wipes
over­
regulated
in
some
cases?


How
can
EPA
improve
on
current
regulations
and
policies
affecting
solventcontaminated
industrial
wipes?


What
environmental
policies
does
EPA
want
to
pursue
to
derive
better
waste
management
and
environmental
results
for
solvent­
contaminated
industrial
wipes?

I.
D.
2.
Petitions
In
1985,
Kimberly­
Clark
Corporation
filed
a
petition
with
EPA
requesting
that
the
Agency
exclude
disposable
solvent­
contaminated
industrial
wipes
from
regulation
as
a
hazardous
waste
under
subtitle
C
of
RCRA.
Kimberly
Clark
and
Scott
Paper
Company
submitted
data
to
EPA
to
help
support
a
conclusion
that
little
risk
to
human
health
and
the
environment
exists
from
the
disposal
of
solvent­
contaminated
industrial
wipes.
Kimberly­
Clark
asserted
the
following
in
its
petition:

Disposable
industrial
wipes
contaminated
with
certain
solvents
listed
in
Subpart
D
of
Part
261
may
be
considered
a
hazardous
waste
pursuant
to
the
mixture
rule
(
See
40
CFR
12
261.3(
a)
(
2)
(
iv)....
Kimberly­
Clark
believes
that
solvent­
contaminated
disposable
industrial
wipes
do
not
present
any
meaningful
environmental
hazards
when
disposed
of
as
part
of
the
regular,
non­
hazardous
solid
waste
stream.
Indeed,
we
believe
that
subjecting
such
contaminated
disposable
industrial
wipes
to
regulation
as
a
hazardous
waste
would
[
not]
result
in
increased
environmental
hazard.
Therefore,
we
believe
that
disposable
industrial
wipes
contaminated
with
solvents
need
not
and
should
not
be
regulated
as
a
hazardous
waste.

In
addition,
to
support
its
petition,
Kimberly­
Clark
made
four
main
points:

(
1)
The
amount
of
solvent
contained
in
disposable
solvent­
contaminated
industrial
wipes
is
insignificant.
The
petition
estimated
that
the
amount
of
solvent
contained
in
the
wipes
represented
less
than
.032
percent
(
7.1
million
pounds
or
approximately
1
million
gallons)
of
the
total
volume
of
solvent
waste
disposed
annually;

(
2)
Virtually
no
solvent
would
be
added
to
subtitle
D
landfills
as
a
result
of
an
exclusion;

(
3)
Solvent­
contaminated
industrial
wipes
do
not
exhibit
any
of
the
characteristics
of
hazardous
waste;
and
(
4)
Disposable
solvent­
contaminated
industrial
wipes
are
not
capable
of
posing
a
substantial
present
or
potential
hazard
to
human
health
and
the
environment
even
if
improperly
managed
because
the
small
quantity
of
solvent
contained
in
disposable
wipes
that
are
contaminated
as
a
result
of
normal
use
is
likely
to
evaporate
before
disposal
in
a
landfill
Therefore,
disposable
wipes
pose
no
threat
to
groundwater.
In
addition
no
damage
cases
have
been
reported
from
improper
handling
of
these
materials.

A
second
petition
was
submitted
to
EPA
by
Scott
Paper
Company,
another
manufacturer
of
disposable
wipes,
on
May
27,
1987.
Scott
Paper's
petition
made
virtually
all
of
the
same
points
as
Kimberly­
Clark
with
the
following
additions:

(
1)
The
commercial
disposable
wipe
market
consists
of
about
ten
million
cases
of
wipes
per
year
used
by
approximately
one
million
businesses;

(
2)
In
a
typical
commercial
establishment,
soiled
wipes
comprise
approximately
one
percent
of
the
total
annual
solid
waste
stream
and
that
only
a
small
percentage
of
soiled
wipes
are
contaminated
with
hazardous
waste;

(
3)
The
principal
methods
of
disposal
include
incineration
and
land
disposal.
Because
wipes
are
made
of
cellulosic
material
(
i.
e.,
wood
fiber),
they
contribute
significant
heat
value
and
therefore
are
frequently
incinerated.
The
petition
states,
"
a
modern
incinerator
tends
to
destroy
the
material
held
by
the
disposable
wipe.
Incineration
is
an
excellent
treatment
for
destroying
cellulosic
towels
and
solvents
and
such
wastes
are
beneficial
to
the
operation
of
incinerators;"

(
4)
Contaminated
disposable
wipes
are
handled
in
a
manner
that
prevents
release
of
hazardous
waste
to
the
environment.
They
are
stored
for
short
periods,
are
picked
up
regularly
by
solid
waste
transporters,
are
transported
relatively
short
distances
(
i.
e.,
50
miles
or
less),
and
are
13
disposed
quickly.

A
third
petition
was
submitted
to
EPA
by
the
now­
defunct
Alliance
of
Textile
Care
Associations
(
ATCA),
on
March
10,
1987.
ATCA
also
requested
an
exclusion
from
RCRA
regulation
and
emphasized
that
its
member
companies
recycle
their
solvent­
contaminated
textiles
through
laundering
or
dry
cleaning.
These
soiled
textiles
are
typically
accumulated
by
generators
in
55­
gallon
drums;
the
drums
are
picked
up
weekly
by
laundry
service
trucks
and
transported
relatively
short
distances
to
the
laundry
or
dry
cleaning
facilities;
the
textiles
are
held
(
stored)
for
only
short
periods
of
time
(
48
hours)
before
cleaning;
and
after
cleaning,
the
textiles
are
returned
to
the
client
for
reuse.
In
2000,
the
Uniform
Textile
Services
Association,
formerly
a
member
of
ATCA,
requested
EPA
to
remove
this
petition
from
consideration.

I.
D.
3.
Risks/
Damages
I.
D.
3.
a.
Risk
Analyses
Prior
to
developing
the
proposed
rule
for
solvent­
contaminated
industrial
wipes,
EPA
conducted
a
risk
screening
analysis
to
identify
potential
risks
to
human
health
from
the
management
of
solvent­
contaminated
industrial
wipes.
A
summary
of
the
results
of
the
Agency's
risk
screening
analyses
is
provided
below.
More
detailed
information
on
the
results
of
these
risk
analyses
is
presented
in
section
V
of
this
document
and
in
"
Risk
from
the
Disposal
of
Solvent­
Contaminated
Shop
Towels
and
Wipes
in
Municipal
Landfills,"
October,
1998.

EPA
conducted
a
risk
screening
analysis
to
better
understand
the
risks
from
disposal
of
solvent­
contaminated
industrial
wipes
in
a
landfill.
The
purpose
of
the
risk
screening
analysis
was
to
determine
constituent­
specific
risks
from
the
disposal
of
solvent­
contaminated
industrial
wipes
in
a
municipal
solid
waste
landfill.
The
results
of
the
risk
assessment
can
be
applied
to
the
following
questions:
(
1)
which
constituents
present
the
most
risk?
(
2)
using
reasonable
assumptions,
do
circumstances
exist
where
disposables
can
be
managed
in
landfills
and
result
in
negligible
risk?
and
(
3)
can
the
quantity
of
solvent
resulting
in
negligible
risk
be
quantified?

The
results
of
the
risk
screening
analysis
included
the
identification
of
F­
listed
solvents
that
could
be
disposed
in
a
municipal
solid
waste
landfill
without
posing
an
unacceptable
risk.
This
evaluation
was
conducted
for
the
30
constituents
that
are
part
of
the
F001
to
F005
hazardous
waste
listings.
The
risk
analysis
results
show
that
11
of
the
compounds
may
present
risk
using
certain
disposal
assumptions,
while
19
of
the
compounds
did
not
present
a
risk
using
the
methodology
employed.

EPA
estimated
the
daily
F­
listed
sludge
residue
loadings
from
industrial
laundry
wastewater
treatment
processes
using
a
different
approach.
EPA's
Office
of
Water
conducted
sampling
at
numerous
industrial
laundries
as
part
of
effluent
guidelines
development
for
the
1997
proposed
rule.
Using
concentrations
of
the
30
F­
listed
solvents
in
washwater
from
industrial
laundry
processes,
EPA
first
estimated
the
amount
of
F­
listed
solvent
that
could
be
contained
in
the
sludge
using
a
mass
balance
model
that
also
accounted
for
emissions
to
the
air
and
water
(
e.
g.,
by
a
public
sewer).
Since
the
washwater
concentration
data
was
limited
to
only
11
F­
listed
solvents,
EPA
made
assumptions
for
the
other
19
F­
listed
solvents
using
the
maximum
concentration
found
for
one
of
the
solvents,
methyl
ethyl
ketone
(
MEK).
MEK
was
selected
14
because
it
is
a
frequently
used
solvent
and
other
solvents
would
be
expected
to
be
present
at
levels
no
higher
than
for
MEK.
EPA
then
repeated
the
same
comparative
analysis
as
above
to
determine
which
solvent
sludge
residues
could
be
disposed
in
a
municipal
landfill
without
posing
a
significant
risk
to
human
health
and
the
envirnoment.
No
solvents
posed
a
problem,
except
2­
nitropropane,
which
has
not
been
found
in
use
by
any
generator.

With
respect
to
ash
from
combustion
units
containing
solvent
residues,
EPA
used
assumptions
consistent
with
those
outlined
above
for
the
direct
landfilling
of
disposable
wipes
to
first
derive
total
daily
loadings
to
a
municipal
waste
combustor.
EPA
then
assumed
a
99.99
percent
destruction
rate
to
derive
a
landfill
loading
for
each
of
30
F­
listed
solvents.
As
with
the
above
landfill
analysis,
EPA
compared
the
estimated
total
daily
landfill
loadings
to
the
risk
loading
threshold
to
determine
which
F­
listed
solvents
could
be
managed
in
a
municipal
waste
combustor,
with
ash
subsequently
disposed
in
a
municipal
landfill,
without
posing
a
significant
risk
to
human
health
and
the
environment.
No
solvents
were
found
to
pose
a
problem.

In
addition,
EPA
examined
the
ecological
risks
from
exposure
to
ten
F­
listed
solvent
constituents
for
which
ecological
benchmark
data
was
available.

Conducting
the
above
risk
screening
analyses
required
the
use
of
numerous
assumptions
and
estimations.
These
included
how
many
industrial
wipes
are
used
annually;
how
much
solvent
is
contained
on
each
wipe;
how
the
solvent­
contaminated
industrial
wipes,
ash
or
sludges
behave
once
in
the
landfill;
and
what
levels
of
solvent
may
pose
a
risk
to
human
health.
In
conducting
these
analyses,
EPA
sometimes
used
conservative
assumptions
to
account
for
a
lack
of
data
and
possible
inaccuracies
in
the
existing
data.
More
details
about
these
assumptions
and
the
reasons
for
them
are
discussed
in
section
V.

I.
D.
3.
b.
Summary
Results
indicate
that
solvent­
contaminated
industrial
wipes
do
not
pose
an
air
emissions
problem
when
managed
in
a
municipal
solid
waste
landfill
(
MSWLF)
or
municipal
waste
combustor.
However,
after
conducting
a
risk
screening
analysis
of
the
potential
risks
associated
with
disposing
solvent­
contaminated
industrial
wipes
in
a
municipal
solid
waste
landfill,
the
Agency
concludes
that
11
F­
listed
solvents
used
in
conjunction
with
disposables
could
pose
potential
health
risks
at
levels
of
concern.
Surface
water
runoffs
from
a
MSWLF
or
from
ground
water
to
a
surface
water
body
also
were
found
not
to
pose
an
adverse
risk
to
human
health
and
the
environment.

I.
E.
Overview
of
Proposed
Rule
Based
upon
the
results
of
the
Agency's
risk
screening
analyses
and
its
investigation
into
potential
damages
from
the
management
of
solvent­
contaminated
industrial
wipes,
as
well
as
a
review
of
the
issues
and
questions
raised
by
stakeholders
regarding
the
Agency's
current
policy
governing
the
regulation
of
these
materials,
the
Agency
has
decided
to
propose
(
1)
a
conditional
exclusion
from
the
definition
of
hazardous
waste
for
disposable
industrial
wipes
that
are
contaminated
with
hazardous
solvents
and
are
going
to
disposal,
and
(
2)
a
conditional
exclusion
from
the
definition
of
solid
waste
for
reusable
industrial
wipes
that
are
contaminated
with
hazardous
solvents
and
are
sent
for
laundering
or
dry
cleaning.
The
proposed
rule
both
clarifies
1For
the
purposes
of
the
preamble
and
background
documents
for
this
proposal,
we
will
use
the
term
other
non­
hazardous
landfill
to
denote
Part
257
Subpart
B
compliant
non­
hazardous
waste
landfills.
If
a
nonhazardous
landfill
that
is
not
a
municipal
landfill
accepts
this
waste,
it
must
meet
the
minimum
standards
of
40
CFR
Part
257
Subpart
B.

15
the
federal
regulations
governing
solvent­
contaminated
industrial
wipes
and
establishes
a
set
of
performance­
based
management
conditions
for
the
exclusions
for
both
diposable
and
reusable
industrial
wipes.

The
proposed
rule
provides
a
conditional
exclusion
from
the
definition
of
hazardous
waste
and
a
conditional
exclusion
from
the
definition
of
solid
waste.
The
proposed
conditions
for
attaining
either
exclusion
include
requirements
for
generator
facilities
and
for
handling
and
processing
facilities.

I.
E.
1.
Generator
Conditions:
Exclusion
from
the
Definition
of
Hazardous
Waste
For
disposable
solvent­
contaminated
industrial
wipes
that
will
be
managed
at
a
non­
landfill
facility
to
meet
the
exclusion
from
the
definition
of
hazardous
waste,
generators
would
be
required
to
(
1)
accumulate
and
store
solvent­
contaminated
wipes
on
site
in
non­
leaking
covered
containers;
(
2)
ensure
that
the
solvent­
contaminated
wipes
do
not
contain
free
liquids,
except
as
noted
below,
when
transported
off
site
to
a
handling
facility;
and
(
3)
transport
the
solventcontaminated
industrial
wipes
off
site
in
containers
designed,
constructed,
and
managed
to
minimize
solvent
loss
to
the
environment
and
labeled
"
Excluded
Solvent­
Contaminated
Wipes."

The
proposed
rule
would
require
that
disposable
solvent­
contaminated
industrial
wipes
managed
at
municipal
landfills
or
other
non­
hazardous
waste
landfills
that
meet
the
standards
under
40
CFR
Part
257
Subpart
B
(
the
disposal
standards
applicable
to
the
receipt
of
CESQG
wastes
at
non­
municipal,
non­
hazardous
waste
disposal
units)
1
(
1)
must
be
"
dry"
(
i.
e.,
contain
less
than
five
grams
of
solvent
each),
and
(
2)
must
not
contain
any
of
the
11
F­
listed
spent
solvents
that
the
Agency
has
determined
may
pose
adverse
risks
to
human
health
and
the
environment
when
disposed
in
a
landfill,
even
if
the
wipe
is
"
dry."
Industrial
wipes
contaminated
with
the
solvents
listed
in
Table
1
would
not
be
allowed
in
municipal
landfills
or
other
non­
hazardous
waste
landfills
under
the
provisions
of
this
proposal.

Table
1
F­
listed
Solvents
Ineligible
for
Municipal
or
Other
Non­
Hazardous
Landfill
Disposal
2­
Nitropropane
Nitrobenzene
Methyl
Ethyl
Ketone
(
MEK)
Methylene
Chloride
Pyridine
Benzene
Cresols
(
o,
m,
p)
Carbon
Tetrachloride
Chlorobenzene
Tetrachloroethylene
Trichloroethylene
In
addition,
EPA
is
proposing
that
transporters
be
allowed
to
carry
industrial
wipes
with
free
liquids
to
other
facilities
within
the
same
company
under
the
hazardous
waste
exclusion
when
16
they
are
transporting
them
to
a
solvent
recovery
facility
that
will
remove
enough
solvent
to
meet
either
the
"
no
free
liquid"
or
the
"
dry"
condition,
provided
the
other
conditions
of
the
exclusion
are
met.

I.
E.
2.
Generator
Conditions:
Exclusion
from
the
Definition
of
Solid
Waste
For
reusable
solvent­
contaminated
industrial
wipes
to
meet
the
exclusion
from
the
definition
of
solid
waste
when
they
are
going
to
be
reclaimed
and
reused,
generators
would
be
required
to
(
1)
accumulate
and
store
solvent­
contaminated
industrial
wipes
on­
site
in
non­
leaking
covered
containers;
(
2)
ensure
that
the
solvent­
contaminated
industrial
wipes
do
not
contain
free
liquids
when
laundered
on­
site
or
transported
off­
site
to
a
handling
facility,
except
as
noted
below;
and
(
3)
transport
the
solvent­
contaminated
industrial
wipes
off­
site
in
containers
designed,
constructed,
and
managed
to
minimize
losses
to
the
environment
(
e.
g.,
plastic
bags,
55­
gallon
drums,
or
other
containers).
The
exclusion
from
the
definition
of
solid
waste
would
be
applicable
only
to
industrial
wipes
that
are
being
reclaimed
for
reuse
through
a
cleaning
process.

EPA
is
also
proposing
that
industrial
wipes
can
be
transported
with
free
liquids
to
facilities
within
the
same
company
under
the
exclusion
when
they
are
transporting
them
to
a
solvent
recovery
facility
that
will
remove
enough
solvent
to
meet
either
the
"
no
free
liquid"
or
the
"
dry"
condition,
provided
the
other
conditions
are
met.

I.
E.
3.
Handling
Facility
Conditions:
Exclusion
from
the
Definition
of
Hazardous
Waste
For
disposable
industrial
wipes
to
continue
to
meet
the
exclusion
from
the
definition
of
hazardous
waste,
combustors
and
facilities
that
handle
disposable
solvent­
contaminated
industrial
wipes
to
remove
solvent
from
them
prior
to
disposal
would
be
required
to
manage
the
industrial
wipes
(
a)
in
containers
designed,
constructed
and
managed
to
minimize
losses
to
the
environment
that
meet
the
transportation
requirements
in
the
proposed
rule
or
(
b)
in
non­
leaking
covered
containers
that
would
meet
the
generator
accumulation
conditions
in
the
proposed
rule.
Unless
the
industrial
wipes
are
being
transported
under
the
intra­
company
provision
of
the
exclusion,
if
a
handler
discovers
any
free
liquid
accompanying
the
used
solvent­
contaminated
industrial
wipes,
it
would
be
required
either
to
remove
the
free
liquid
and
manage
it
properly
as
a
hazardous
waste,
if
applicable,
or
to
return
the
container
with
the
wipes
and
free
liquid
to
the
generator.

I.
E.
4.
Handling
Facility
Conditions:
Exclusion
from
the
Definition
of
Solid
Waste
For
reusable
industrial
wipes
to
continue
to
meet
the
exclusion
from
the
definition
of
solid
waste,
industrial
laundries
and
dry
cleaners,
as
well
as
facilities
that
handle
solvent­
contaminated
industrial
wipes
to
remove
solvent
from
them
prior
to
cleaning,
would
be
required
to
manage
the
industrial
wipes
in
containers
designed,
constructed
and
managed
to
minimize
losses
to
the
environment
(
i.
e.,
the
proposed
transportation
condition),
or
in
non­
leaking
covered
containers
that
would
meet
the
generator
accumulation
conditions
in
this
proposal.
Unless
the
industrial
wipes
are
being
transported
under
the
intra­
company
provision
of
the
exclusion,
if
a
handler
discovers
any
free
liquid
accompanying
the
used
solvent­
contaminated
industrial
wipes,
it
would
be
required
either
to
remove
the
free
liquid
and
manage
it
properly
or
to
return
the
container
with
the
industrial
wipes
and
free
liquid
to
the
generator.
17
II.
Characteristics
of
Waste
and
Waste
Handlers
II.
A.
Description
of
Industrial
Wipes
and
Their
Uses
Industrial
wipes
come
in
a
wide
variety
of
sizes
and
materials
to
meet
a
broad
range
of
applications.
For
the
purposes
of
this
proposed
rule,
EPA
is
distinguishing
between
two
categories
of
industrial
wipes:
reusables,
which
are
laundered
and
used
again;
and
disposables,
which
are
managed
in
a
landfill
or
combustor.
Although
this
rulemaking
does
not
distinguish
between
the
types
of
disposable
and
reusable
wipes,
this
chapter
of
the
background
document
describes
some
of
the
details
of
the
waste
stream.

Wipes
are
most
likely
to
come
in
contact
with
hazardous
solvents
when
wiping
up
spills
of
hazardous
materials
or
oil,
cleaning
machinery
or
equipment,
and
wiping
off
metals
or
other
components
in
the
manufacturing
process.
The
type
of
wipe
suitable
for
each
application
depends
on
a
number
of
factors.
The
amount
of
lint
a
wipe
generates
can
play
a
large
role
because
some
processes,
such
as
those
in
electronic
or
printing
applications,
cannot
tolerate
any
lint,
while
others,
such
as
cleaning
automobile
parts,
can
tolerate
large
amounts.
Absorbency
is
also
an
important
factor
in
some
tasks,
but
not
in
others.
Likewise,
durability
is
important
in
some
tasks,
such
as
those
with
heavy
scrubbing,
but
is
often
not
important
in
task
for
which
lint
or
absorbency
is
more
important.
Durability
does
not
only
refer
to
the
physical
strength
of
the
wipe,
but
also
to
its
ability
to
withstand
strong
solvents.

The
industrial
wipes
market
consists
of
an
estimated
471,000
facilities
in
13
economic
subsectors,
using
approximately
9.6
billion
wipes
annually.
Approximately
3.8
billion
wipes
contaminated
with
solvent
are
used
annually
by
over
200,000
of
these
facilities.
This
chapter
provides
background
information
and
sources
on
how
EPA
derived
these
estimates
and
provides
a
breakdown
by
disposable
and
reusable
industrial
wipes
categories.
18
The
"
Economics
Background
Document"
for
this
rulemaking,
available
from
the
RCRA
Docket,
also
provides
information
on
this
topic.

II.
A.
1
Disposables
II.
A.
1.
a.
Non­
wovens
Non­
woven
disposable
industrial
wipes
are
spun
from
synthetic
fibers
and
are
often
combined
with
wood
pulp,
although
they
are
not
solely
paper­
based.
These
wipes
are
used
in
all
the
industries
where
reusables
are
used,
but
are
often
used
for
tasks
where
absorbency
and
low
lint
are
higher
priorities
than
durability.
Nevertheless,
there
are
a
wide
range
of
types
available,
from
delicate
wipes
designed
for
work
with
electronics
or
optics
to
heavy­
duty
wipes
designed
for
use
with
heavy
machinery
or
in
metal
fabrication.
The
1997
Economic
Census
reports
20
nonwoven
wipes
manufacturers.
The
industry
has
recently
experienced
some
consolidation,
in
which
the
four
leading
companies
merged
into
two.

Non­
wovens
range
in
price
from
4
to
17
cents
per
wipe
(
median
price
of
9
cents).

II.
A.
1.
b.
Wovens
Woven
cloths
or
rags
have
a
somewhat
smaller
share
of
the
disposables
market
than
nonwoven
wipes.
Rags
are
recycled
textiles,
made
from
leftover
textile
manufacturing
scraps
or
secondhand
clothing.
Therefore,
they
come
in
a
wide
variety
of
materials,
shapes,
colors
and
sizes.
Since
the
materials
are
usually
inexpensive
for
producers
to
obtain,
rags
are
often
less
expensive
than
a
comparable
amount
of
non­
wovens.

The
woven
rag
industry
is
characterized
by
488
establishments
(
1997
Economic
Census)
that
obtain
the
materials,
sort
them,
cut
them
to
size,
and
package
and
distribute
them
according
to
orders.
Orders
are
often
assembled
on
demand
according
to
the
specific
needs
of
a
customer
(
e.
g.,
large,
white,
terry
cloth
rags
only).
When
not
produced
to
a
specific
order,
a
bundle
of
rags
consists
of
mixed
materials,
colors,
and
sizes,
and
is
less
expensive.

Rags
are
usually
used
in
applications
where
inconsistency
is
not
an
issue,
such
as
wiping
up
a
spill.
The
amount
of
lint
in
rags
is
highly
variable,
so
they
are
often
used
in
applications
where
lint
is
not
an
issue,
either.
Rags
are
often
very
durable,
so
they
can
be
used
multiple
times
before
ultimate
disposal.

II.
A.
2.
Reusables
Manufacturers
of
reusable
industrial
wipes,
often
called
shop
towels,
usually
sell
their
wipes
to
uniform
and
linen
rental
services
(
industrial
laundries),
who
then
rent
them
to
their
customers.
The
rental
services
typically
pick
up
the
reusable
wipes
once
a
week
from
their
customers
and
deliver
fresh
ones
at
the
same
time.
Industrial
laundries
are
usually
small
companies
dispersed
geographically,
each
serving
an
area
with
a
radius
of
less
than
100
miles.
However,
some
industrial
laundries
operate
in
multiple
states.
There
are
1,175
industrial
laundry
establishments
that
supply
reusable
industrial
wipes
(
1997
Economic
Census).
19
Although
customers
can
usually
specify
which
kind
of
reusable
wipe
they
want,
they
do
not
get
the
same
wipes
they
used
the
week
before.
Therefore
the
wipes
can
be
contaminated
with
small
amounts
of
residual
solvents,
soil,
or
metal
chips
from
use
by
another
business.
Some
businesses,
when
asked,
indicated
that
they
had
discontinued
or
restricted
reusable
wipe
use
because
metal
chips
in
the
wipes
were
scratching
their
product.
This,
in
addition
to
theie
high
level
of
lint,
restricts
reusables'
usefulness
on
delicate
applications.
Their
high
durability,
however,
makes
them
very
useful
in
heavy
duty
applications.

Reusable
wipe
services
cost
about
five
cents
per
wipe
per
week
to
rent
(
national
average
price).
Reusable
industrial
wipes
are
typically
between
14"
x14"
and
18"
x18"
in
size,
and
weigh
about
one
ounce.
Wipes
range
from
65
to
90
percent
cotton,
with
the
balance
being
composed
of
polyester,
rayon,
or
acrylic.
There
are
many
different
brands
of
reusable
in
use,
and
at
least
four
companies
that
make
them
(
1997
Economic
Census).

II.
B.
Types
of
Solvents
Used
in
Conjunction
With
Industrial
Wipes
and
Regulatory
Status
II.
B.
1.
Study
Results
The
hazardous
solvents
used
by
industry
in
conjunction
with
industrial
wipes
vary
by
company;
firms
tend
to
have
unique
usage
patterns.
Sometimes
the
amounts
of
solvent
used
on
each
wipe
is
small
but
other
times
it
is
two
or
more
times
the
weight
of
the
dry
wipe.
Also,
some
firms
use
small
numbers
of
wipes
on
a
daily
basis,
while
others
use
hundreds,
if
not
thousands,
daily.
Finally,
the
types
and
concentration
of
solvent
used
is
often
unique
to
the
firm.
Most
often
the
solvents
used
represent
a
blend
of
two
or
more
chemical
constituents.
Some
of
these
spent
solvents
are
hazardous
because
of
their
toxicity
or
ignitability,
whereas
others
have
been
listed
by
EPA
as
a
hazardous
waste
(
i.
e.,
F001­
F005
listed
solvents
found
in
40
CFR
261.33).
Many
firms
could
be
directly
affected
by
the
proposed
rule
depending
upon
the
variables
described
above.

According
to
data
provided
to
EPA
by
trade
associations,
site
visits,
previous
EPA
rulemaking
efforts,
and
a
review
of
publicly
available
data
and
published
reports,
the
types
of
solvents
applied
to
industrial
wipes
(
and
therefore
potentially
affected
by
this
proposed
rulemaking)
varies
considerably
across
numerous
industry
sectors.
As
displayed
in
Table
2,
at
least
13
economic
sub­
sectors
representing
113
different
industries
generate
solvent­
contaminated
industrial
wipes.
Even
within
the
same
industry,
as
witnessed
by
EPA
during
site
visits,
the
type
and
quantity
of
solvent
used
in
conjunction
with
industrial
wipes
varies
significantly
from
one
facility
to
the
next.

Table
2
NAICS
Codes
and
Associated
Economic
Sub­
Sectors
Using
Industrial
Wipes
Item
Economic
Sub­
Sector
(
Entity
Type)
NAICS
Code
20
1
2
3
4
5
6
7
8
9
10
11
12
13
Printing
manufacturing
(
mfg)
Chemical
&
allied
products
mfg
Plastics
&
rubber
products
mfg
Fabricated
metal
products
mfg
Industrial
machinery
&
eqpt
mfg
Electronics
&
computers
mfg
Transportation
eqpt
mfg
Furniture
&
fixture
mfg
Auto
dealers
(
retail
trade)
Publishing
(
printed
matter)
Business
services
(
photocopy
shops)
Auto
repair
&
maintenance
services
Military
bases
323
325
326
332
333
3344
336
337
4411
5111
561439
8111
92812
21
Unfortunately,
definitive
data
on
the
types
of
solvents
used
in
conjunction
with
industrial
wipes
is
scarce
and
highly
variable.
However,
the
most
commonly
identified
solvents
used
in
conjunction
with
these
wipes,
based
on
available
data
analyzed
for
this
proposed
rulemaking,
are
presented
in
Table
3.
Given
the
number
of
different
solvents
used
in
industrial
operations,
this
list
is
not
intended
to
include
all
possible
solvent
uses
and
is
intended
for
illustrative
purposes
only.
Note
that
several
of
the
solvents
presented
in
Table
3
are
included
in
the
EPA
list
of
hazardous
waste
solvents
F001­
F005
in
40
CFR
Part
261
subpart
C.
Others,
however,
are
not
and
would
probably
be
considered
hazardous
wastes
only
if
they
exhibited
one
or
more
of
the
characteristics
of
hazardous
waste
(
e.
g.,
ignitability)
defined
in
40
CFR
261
subpart
D,
when
spent.

Table
3
Solvents
Used
in
Conjunction
with
Industrial
Wipes
Solvent
Source
of
Data
Potential
Waste
Code(
s)
Principal
Use
Toluene
EPA
Site
Visit,
EPA
ORDa,
EPA
OWb
D001,
F005c
­
cleaning
paint
guns
­
parts
cleaning
­
general
equipment
cleaning
and
preparation
­
cleaning
screening
boards
Isopropyl
alcohol
EPA
Site
Visit
D001
­
cleaning
screening
boards
­
polishing
and
paint
removal
­
general
parts
cleaning
Methyl
ethyl
ketone
EPA
Site
Visit,
EPA
ORD
D001,
F005
­
cleaning
rollers
­
adhesive
­
cleaning
airplane
propellors
­
polishing
and
paint
removal
­
cleaning
screening
boards
­
surface
preparation
Methanol
EPA
Site
Visit
D001,
F003
Methyl
isobutyl
ketone
EPA
Site
Visit
D001,
F003
­
adhesive
­
cleaning
rollers
Ethyl
acetate
EPA
Site
Visit
D001,
F003
Acetaldehyde
EPA
Site
Visit
D001
Acetone
EPA
Site
Visit,
EPA
ORD
D001,
F003
­
cleaning
paint
guns
­
polishing
and
paint
removal
Diacetone
alcohol
EPA
Site
Visit
D001
­
cleaning
screening
boards
n­
by\
butyl
alcohol
EPA
Site
Visit
D001,
F003
Propyl
acetate
EPA
Site
Visit
D001
Ethanol
EPA
Site
Visit,
EPA
ORD
D001
­
dilute
inks
­
general
cleaning
n­
propyl
alcohol
EPA
Site
Visit
D001
­
dilute
inks
­
general
cleaning
Solvent
Source
of
Data
Potential
Waste
Code(
s)
Principal
Use
22
Petroleum
naphtha
EPA
ORD
D001
Xylenes
Printer,
EPA
ORD
D001,
F003
­
equipment
cleaning
and
preparation
­
parts
cleaning
Mineral
spirits
EPA
ORD
D001
­
screen
cleaning
Acetates
EPA
ORD
D001,
F003
1,1,1­
trichloroethane
EPA
OW
D001,
F001/
F002
­
painting
operations
Chlorobenzene
EPA
OW
D001,
F002
Degreaser
Ethylbenzene
EPA
OW
D001,
F003
Methylene
chloride
EPA
OW
D001,
F001/
F002
Degreaser
Tetrachloroethylene
EPA
OW
D001,
F001/
F002
Degreaser
Trichloroethylene
EPA
OW
D001,
F001/
F002
Degreaser
Cresol
EPA
OW
D001,
F002
ORD
=
Office
of
Research
and
Development
OW
=
Office
of
Water
a
EPA
Office
of
Research
and
Development,
"
Environmental
Assessment
of
Shop
Towel
usage
in
the
Automotive
and
Printing
Industry,"
November
1996.
b
EPA
Office
of
Water,
"
Technical
Development
Document
for
Proposed
Pretreatment
Standards
for
Existing
and
New
Sources
for
the
Industrial
Laundries
Point
Source
Category,"
EPA
821­
R­
97­
007,
November
1997.
c
Waste
codes
for
listed
solvents
(
F001­
F005)
are
provided
if
the
solvent
is
included
in
the
respective
listed
waste
code
definition.
The
ignitable
waste
code
(
D001)
is
included
for
solvents
that
usually
have
a
flash
point
below
140

F
before
use.
Note
that
any
solvent­
contaminated
industrial
wipe
may
exhibit
this
or
any
other
characteristic
of
hazardous
waste
after
use
if
the
waste
meets
any
of
the
characteristic
waste
definitions
in
40
CFR
261
subpart
C.

II.
B.
2.
Study
Methodology
Numerous
sources
of
information
were
reviewed
to
identify
which
solvents
are
more
likely
to
appear
in
solvent­
contaminated
industrial
wipes.
Based
on
the
information
collected,
no
single
source
provides
comprehensive
information
on
the
types
of
solvents
used
across
multiple
industries.
The
sources
used
as
references
for
this
study
are
described
below.

Biennial
Report
Data
The
1997
Biennial
Report
System
(
BRS)
was
searched
for
data
on
large
quantity
generators
(
LQGs)
of
hazardous
waste
solvents
reported
as
generated
in
a
form
similar
to
solvent­
contaminated
industrial
wipes.
This
query
was
conducted
specifically
for
generators
of
listed
hazardous
solvent
wastes
(
F001­
F005)
who
used
form
code
B310
(
absorbents)
on
the
BRS
GM
form.
This
search
identified
numerous
facilities
across
many
industries
that
potentially
generate
solvent­
contaminated
industrial
wipes.
This
search
allowed
for
identification
of
specific
23
groupings
of
solvents
through
listed
solvent
waste
codes,
although
identification
of
which
specific
solvent
within
each
waste
group
was
generally
not
possible.
Other
limitations
on
this
search
are
described
below.

The
BRS
query
is
probably
inexact
about
the
number
of
generators
and
the
quantity
of
solvent­
contaminated
industrial
wipes
generated.
First,
as
form
code
B310
is
defined
as
inorganic
solid
spent
filters
and
adsorbents,
it
could
include
other
types
of
absorbent
materials
besides
wipes
(
e.
g.,
laboratory
wastes).
Thus,
the
BRS
data
probably
includes
some
number
of
waste
streams
that
are
outside
the
scope
of
this
rulemaking.
Also,
BRS
data
for
characteristically
hazardous
solvent­
contaminated
industrial
wipes
reported
as
D001
cannot
be
differentiated
from
other,
non­
solvent
D001
wastes;
no
attempt
was
made
to
identify
from
BRS
data
solvent
usage
that
resulted
in
the
generation
of
characteristic­
only
wastes.

However,
BRS
data
does
not
include
generation
information
for
small
quantity
generators
(
SQGs)
or
conditionally
exempt
small
quantity
generators
(
CESQGs).
As
both
SQGs
and
CESQGs
are
known
from
other
data
sources
to
generate
solvent­
contaminated
industrial
wipes,
BRS
data
probably
understates
generation
quantities
for
smaller
facilities.
Also,
as
some
states
may
not
regulate
reusable
industrial
wipes
as
hazardous
wastes,
these
wastes
may
not
be
reported
in
BRS;
therefore,
queries
probably
do
not
represent
this
part
of
the
generating
universe.

Trade
Associations
Several
trade
associations
provided
information
to
EPA
concerning
the
types
of
solvents
used
by
facilities
in
different
industries
associated
with
solvent­
contaminated
industrial
wipes.
EPA
also
collected
and
received
information
from
manufacturers
of
these
solvent
manufacturers/
distributors
and
industrial
laundry
facilities,
including
the
Association
of
Nonwoven
Fabrics
Industry,
and
the
Kimberly­
Clark
Corporation.
In
1997,
the
Screenprinting
&
Graphic
Imaging
Association
conducted
a
survey
of
member
firms
in
the
printing
industry
and
found
that
the
printing
industry
uses
the
following
solvents
most
often:
methyl
ethyl
ketone
(
18
percent),
acetone
(
27
percent),
xylene
(
19.5
percent),
toluene
(
20
percent),
and
mineral
spirits
(
25
percent).
Results
of
a
1997
survey
conducted
by
the
Flexographic
Technical
Association
indicate
that
the
following
solvents
are
used
most
often
by
members
of
this
industry:
ethanol,
normal
propanol
and
fast
blends,
as
well
as
acetates
and
water­
based
cleaners.

Office
of
Water
Study
of
Industrial
Laundries
To
support
their
investigation
of
the
national
need
for
pretreatment
standards
for
industrial
laundries,
EPA's
Office
of
Water
conducted
an
extensive
study
in
the
mid­
1990s
of
contaminants
present
in
discharges
from
industrial
facilities
that
launder
industrial
textile
items,
including
reusable
industrial
wipes,
specifically
printer
wipes.
Although
direct
linkage
to
solventcontaminated
industrial
wipes
is
not
certain
at
all
facilities
investigated
by
EPA
for
this
rulemaking,
and
there
is
no
certainty
that
other
items
outside
the
scope
of
the
proposed
rulemaking
are
not
laundered
at
these
facilities,
EPA
knows
from
site
visits
that
the
effluent
from
industrial
laundries
does
contain
concentrations
of
solvents
expected
to
be
used
in
conjunction
with
wipes
by
the
industries
identified
as
generators
of
solvent­
contaminated
industrial
wipes
in
section
II.
A.
Extensive
data
on
contaminants
(
both
solvent
and
non­
solvent)
is
presented
in
the
Technical
Development
Document
for
the
Final
Action
Regarding
Pretreatment
Standards
for
24
the
Industrial
Laundries
Point
Source
Category
(
EPA­
821­
R­
00­
006,
March
2000).

Site
Visits
In
1996
and
1997,
EPA
visited
17
facilities
that
use
industrial
wipes
in
different
industry
sectors:
printing;
auto
body
repair,
aerospace
manufacturing
and
maintenance;
circuit
board
manufacturing;
ship
maintenance;
and
coating
and
adhesive
testing
and
production.
EPA
collected
sampling
data
on
solvent­
contaminated
industrial
wipes
from
several
of
these
facilities
on
types
and
amounts
of
solvent
applied
to
the
wipe.
The
solvents
reported
to
be
used
at
the
sites
included
the
following
chemicals:
toluene,
isopropyl
alcohol,
methyl
ethyl
ketone,
methanol,
methyl
isobutyl
ketone,
ethyl
acetate,
acetaldehyde,
acetone,
diacetone
alcohol,
n­
butyl
alcohol,
propyl
acetate,
ethanol,
and
n­
propyl
alcohol.
The
solvents
were
applied
to
the
wipes
primarily
through
spraying,
dipping,
or
pumping.

Publicly
Available
Information/
Literature
Search
EPA
conducted
a
literature
search
for
chemicals
in
solvent
blends
used
by
industries
on
industrial
wipes.
EPA
also
reviewed
previous
studies
on
this
topic,
including
a
report
from
the
EPA
National
Risk
Management
Research
Laboratory:
Environmental
Assessment
of
Shop
Towel
Usage
in
the
Automotive
and
Printing
Industries.

Information
on
solvent
use
at
facilities
was
compiled
through
site
visits
and
Internet
searches
of
Materials
Safety
Data
Sheets
(
MSDSs)
for
solvents
used
in
the
target
industries
(
e.
g.,
printers,
automobile
manufacturers,
auto
body
repair
and
maintenance
shops,
furniture
manufacturers,
aircraft
manufacturers)
The
facilities
identified
through
the
Internet
search
specified
the
task
(
e.
g.,
blanket
wash,
stripper)
for
which
the
solvent
was
intended.
The
task
determined
whether
it
was
likely
that
the
solvents
were
being
used
with
industrial
wipes.

A
third
literature
search
included
the
Stanford
Research
Institute's
listings
of
cleaning/
degreasing
solvents
in
the
Chemical
Economics
Handbook
(
1997
edition).
Although
not
specific
to
industrial
wipes
applications,
this
source
revealed
that
there
are
at
least
26
different
chemicals
used
as
cleaning/
degreasing
solvents,
with
the
top
five
by
annual
volume
representing
85
percent
of
all
solvents
used
for
cleaning/
degreasing
(
naphtha,
acetone,
methanol,
toluene,
trichloroethylene).
The
"
Economics
Background
Document"
presents
the
results
of
this
data
search.

EPA
did
not
identify
any
single
data
source
that
provides
a
comprehensive
list
of
solvents
used
in
conjunction
with
solvent­
contaminated
industrial
wipes.
Based
on
analysis
of
data
collected
from
the
cited
sources,
the
following
generalizations
are
possible:


Solvents
in
the
workplace
are
used
for
cleaning
equipment,
cleaning
up
small
spills,
and
other
industrial
applications.
As
there
is
generally
a
direct
correlation
between
the
type
of
equipment
that
must
be
cleaned
and
the
type
of
solvents
required
to
adequately
clean
the
equipment,
some
equipment
may
require
solvents
that
contain
constituents
with
relatively
strong
cleaning
capabilities,
while
other
types
of
equipment
may
require
less
powerful
chemical
constituents
in
the
solvent
(
cleaning
agent).
25

Worker
preferences
can
affect
the
type
of
solvent
used
even
within
the
same
facility
due
to
personal
experiences
with
what
solvent
products
work
better
than
others.


Solvent
manufacturers
continue
to
create
new
products
that
offer
more
effective
cleansing
agents
but
have
reduced
health
and
environmental
damage
risks
(
i.
e.,
lower
volatile
organic
compound
emissions
and
water­
based
solvents).
Additionally,
numerous
parties
during
site
visits
and
in
public
comments
to
proposed
rulemakings
cite
a
long­
term
trend
for
reduction
in
the
use
of
halogenated
solvents,
particularly
in
military
applications,
by
solvent
substitution
with
petroleum
naphtha
or
isopropyl
alcohol­
based
solvents.
However,
EPA
does
not
have
conclusive,
quantified
evidence
that
such
reductions
are
occurring.

II.
C.
Affected
Universe
of
Generators
of
Spent
Industrial
Wipes
and
Off­
site
Management
Facilities
Because
users
and
user
characteristics
of
solvent­
contaminated
industrial
wipes
are
so
diverse,
the
methodology
used
to
estimate
the
universe
of
facilities
using
these
materials
is
eclectic
in
nature.
The
first
step
involved
identifying
potential
industry
sectors.
This
was
accomplished
through
a
literature
search,
and
discussions
with
key
stakeholders
and
industry
contacts
who
could
further
describe
industry
demographics
with
respect
to
solvent­
contaminated
industrial
wipes.
An
important
source
in
identifying
industrial
sectors
was
EPA's
Office
of
Enforcement
and
Compliance
Assistance
(
OECA)
Industry
Profile
Series
that
identified
potential
users
of
solventcontaminated
industrial
wipes
by
four­
digit
standard
industry
code
(
SIC).
This
source
also
identified
industry,
regional
EPA,
and
state
contacts
who
further
assist
in
describing
the
universe
of
users.

Table
4
provides
an
estimate
of
the
number
of
facilities
potentially
affected
by
the
proposed
rule.
This
estimate
is
displayed
by
industrial
sector
and
by
RCRA
regulatory
status
(
i.
e.,
CESQG,
SQG,
and
LQG).
As
stated,
EPA
has
identified
13
economic
sub­
sectors
that
use
solvents
in
conjunction
with
industrial
wipes
for
wiping
or
cleaning
operations.
In
some
cases,
we
believe
large
numbers
of
establishments
are
involved,
such
as
printing
and
auto
body
repair.
We
believe
other
sectors
also
might
use
hazardous
solvents
in
conjunction
with
industrial
wipes
but,
for
example,
we
were
unable
to
collect
sufficient
information
about
the
transportation
equipment
industry
or
general
building
contractor
sectors
to
include
them
in
our
analysis.

In
total,
we
estimate
that
as
of
2001,
approximately
159,000
firms
use
solvents
in
conjunction
with
industrial
wipes.
Of
this
total,
approximately
32
percent
are
CESQGs
who
will
not
be
affected
by
this
rule.
The
remaining
68
percent
(
109,000
establishments)
could
potentially
be
affected
by
this
rule.
These
establishments
are
mostly
SQGs
(
66
percent),
although
there
are
some
LQGs
(
2
percent).

Other
variables
are
the
types
of
industrial
wipes
that
might
be
prevalent
in
an
industrial
sector,
as
well
as
whether
small
or
large
numbers
of
these
wipes
might
be
used
on
a
daily
basis.
EPA
relied
on
industry
contacts
familiar
with
this
issue,
site
visits,
information
provided
by
industry,
and
discussions
with
inspectors
to
provide
this
information.

Table
5
summarizes
the
results
of
this
effort.
Tremendous
variability
exists
both
in
terms
26
of
usage
patterns
and
quantities
of
industrial
wipes
used
daily.
For
instance,
the
Printing
Sector
primarily
uses
reusable
industrial
wipes;
however,
within
this
diverse
sector,
up
to
40
percent
of
screenprinters,
approximately
16,000
firms,
use
disposables.
Similarly,
the
frequency
of
usage
varies
tremendously
depending
on
the
size
of
the
firm.
Smaller
firms
may
use
50
industrial
wipes
a
day,
while
large
printers
or
newspapers
can
use
more
than
1,000
industrial
wipes
a
day.

Table
4
Entities
Potentially
Affected
by
the
Proposed
Rule
Item
Economic
Sub­
Sector
(
Entity
Type)
NAICS
Code
SIC
Code
Number
of
Affected
Establishmentsa
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Printing
manufacturing
(
mfg)
Chemical
&
allied
products
mfg
Plastics
&
rubber
products
mfg
Fabricated
metal
products
mfg
Industrial
machinery
&
eqpt
mfg
Electronics
&
computers
mfg
Transportation
eqpt
mfg
Furniture
&
fixture
mfg
Auto
dealers
(
retail
trade)
Publishing
(
printed
matter)
Business
services
Auto
repair
&
maintenance
Military
bases
Solid
waste
services
Industrial
launderers
323
325
326
332
333
3344
336
337
4411
5111
561439
8111
92812
562
812332
275
to
279
28
30
34
352
to
356
367
37
25
5511
&
5521
271
to
274
7334
753
9721
4953
7218
18,700
to
42,000
1,100
to
2,900
1,400
to
3,700
4,900
to
13,000
2,400
to
6,300
550
to
1,500
1,100
to
3,000
1,600
to
4,300
4,000
to
10,700
10,600
to
23,600
2,900
to
6,400
13,500
to
35,900
50
to
130
4,800
to
9,650
590
to
1,175
Total
=
68,000
to
164,000
a
Establishment
counts
above
do
not
necessarily
represent
all
establishments
in
each
industry;
counts
represent
EPA's
estimate
of
establishments
which
use
solvent
industrial
wipes
and
to
which
the
conditional
exclusions
may
apply.
27
Table
5
Daily
Usage
Statistics/
Trends
Industrial
sector
Average
Daily/
Weekly
Usage
Trends
Printing
Reusables:
200
to
2,000
per
week,
per
facility;
Disposables:
300­
800
per
week
Auto
Body
Repair
Between
50
and
100
per
day,
depending
on
size
of
facility
Furniture
Manufacturers
Large
firms:
up
to
25
55­
gallon
drums;
Smaller
firms:
7
55­
gallon
drums
Aerospace
Manufacturers
Tremendous
variability.
Smaller
users:
25
industrial
wipes
or
less
per
day;
Larger
users:
up
to
1,000
or
more
per
day
Automobile
Manufacturers
Several
hundred
wipes
per
day
(
if
not
more)
appear
to
be
used
at
large
assembly
plants
Electronics
&
Computers
Large
semiconductor
facility
can
use
several
thousand
wipes
per
day;
printed
wire
board
facilities
use
approximately
100
industrial
wipes
per
day
(
mostly
disposable)

Military
Bases/
Facilities
Varies
by
operation.
Depot
maintenance
facilities
probably
use
hundreds
per
day;
other
operations,
such
as
on
ships,
fewer
Fabricated
Metals
No
statistics
available,
but
we
believe
relatively
small
numbers
used
daily
per
facility
primarily
for
wiping
operations
Industrial
Machinery
No
statistics
available,
but
we
believe
relatively
small
numbers
used
daily
per
facility
primarily
for
wiping
operations
Plastics/
Rubber
No
statistics
available,
but
we
believe
relatively
small
numbers
used
daily
per
facility
primarily
for
wiping
operations
Chemical
&
Allied
Products
and
Inorganic
Chemicals
No
statistics
available,
but
we
believe
relatively
small
numbers
used
daily
per
facility
primarily
for
wiping
operations
Other
sectors
using
large
numbers
of
industrial
wipes
per
day
include
automobile
manufacturers,
large
furniture
manufacturers,
and
parts
of
the
defense
industry.
Sectors
using
small
numbers
of
industrial
wipes
per
day
include
auto
body
repair
shops,
fabricated
metals,
and
organic
and
inorganic
chemical
manufacturers.
On
the
whole,
there
appear
to
be
more
industries
that
use
smaller
numbers
of
industrial
wipes
on
a
daily
basis
than
that
use
large
numbers
of
wipes.

EPA
obtained
industry
information
to
determine
the
fraction
of
wipe
uses
associated
with
solvents,
as
opposed
to
other
materials.
Kimberly­
Clark
Corporation,
a
major
manufacturer
of
non­
woven
wipes
provided
EPA
with
estimates
of
the
percentage
of
uses
associated
with
solvents
in
the
printing
industry
and
in
all
other
sectors.
These
percentages
were
applied
to
the
data
to
derive
an
estimate
of
the
number
of
disposable
industrial
wipes
used
each
year
in
conjunction
with
solvents.
28
According
to
the
industry
source,
10
percent
of
the
solvents
used
in
the
industry
are
nonhazardous
when
spent.
Additionally,
80
percent
of
the
solvents
used
in
the
printing
industry
are
characteristic
hazardous
wastes
when
spent
and
10
percent
are
listed
hazardous
wastes
when
spent.
EPA
then
assumed
that
50
percent
of
the
wipes
contaminated
with
solvents
that
are
characteristic
hazardous
wastes
when
spent
continue
to
exhibit
a
characteristic
of
hazardous
waste
after
contamination.

Disposable
industrial
wipes
are
used
by
themselves
for
wiping,
spill
cleanup,
degreasing
and
other
applications,
but
EPA
is
particularly
concerned
about
applications
in
which
they
are
used
in
conjunction
with
solvents.
In
certain
industries
like
printing,
a
majority
of
wipe
uses
involve
solvents,
whereas
in
some
other
industries,
the
use
of
solvents
may
be
less
common.

The
Agency
estimates
that
316
million
disposable
industrial
wipes
are
used
in
conjunction
with
RCRA­
regulated
solvents
each
year,
making
up
28
percent
of
the
1.13
billion
disposable
wipes
used
annually.
EPA
notes
that
many
individuals
representing
trade
associations
and/
or
industrial
users
of
disposable
industrial
wipes
and
solvents
told
the
Agency
that
generators,
especially
larger
ones,
avoid
using
disposable
industrial
wipes
with
hazardous
waste.
Knowing
that
hazardous
waste
disposal
adds
significantly
to
the
effective
cost
of
using
disposables,
many
firms
opt
for
reusable
industrial
wipes
instead
for
applications
involving
solvents
that
ultimately
will
be
hazardous
waste.
Therefore,
the
overall
use
of
disposables
with
hazardous
waste
may
be
less
than
estimated.

II.
D.
Description
of
Generator
Waste
Management
Practices
for
Spent
Wipes
EPA
found
much
variability
in
the
uses
of
solvent­
contaminated
industrial
wipes
and
management
practices
regarding
them
across
and
within
industries.
In
addition,
there
are
significant
differences
in
management
practices
depending
on
whether
the
cloths
are
reusable
or
disposable.

Waste
management
of
solvents
and
solvent
contaminated
industrial
wipes
has
several
steps.
The
first
is
the
application
of
the
solvent
and
the
use
of
the
wipe.
Solvents
are
applied
in
varying
amounts
depending
on
their
use,
the
type
of
solvents,
and
the
environmental
awareness
of
the
business.
Some
businesses
in
the
printing
industry,
for
example,
are
trying
to
cut
back
on
the
amount
of
hazardous
solvents
used
and
the
amount
of
solvent
used
on
each
wipe.
There
are
various
incentives
for
reducing
solvent
use,
particularly
in
the
case
of
solvents
used
with
reusable
industrial
wipes.
Many
laundries
will
not
accept
shipments
of
wipes
that
contain
free
liquids.
Other
users,
such
as
metal
finishers,
do
not
apply
solvent
to
the
wipe,
but
submerge
the
component
they
are
working
on
in
a
solvent
bath,
and
then
use
the
wipe
to
dry
the
component
off.
The
wipe
may
be
used
in
this
manner
repeatedly
until
it
is
saturated.
Some
users
soak
their
industrial
wipes
in
a
solvent
before
use,
while
others
rarely
use
any
solvents
at
all
with
their
wipes.
Unfortunately,
from
this
wide
array
of
practices,
it
is
difficult
to
draw
any
conclusions
about
the
prevalence
of
any
one
practice.

After
an
industrial
wipe's
use
is
served,
the
next
step
is
the
temporary
storage
of
the
spent
wipe
by
the
user.
Where
wipe
usage
is
high,
there
is
often
a
container
at
each
work
station
for
that
worker's
used
wipes.
One
commonly
used
container
is
a
closed
metal
container
with
a
foot
pedal
to
open
the
top
of
the
container.
When
the
container
is
full,
or
at
the
end
of
the
day,
these
29
containers
are
usually
emptied
into
a
central
container
at
the
facility.
In
smaller
facilities
with
lower
wipe
usage,
there
may
only
be
one
container
in
the
facility
for
accumulating
the
wipes
prior
to
off­
site
management.
Prior
to
discarding
spent
wipes
in
the
container,
generators
may
sometimes
store
their
wipes
on
shelves
(
or
other
storage
mechanism)
for
pickup
at
the
end
of
the
day.

EPA
has
found
that
solvent
removal
technologies
are
primarily
practiced
by
generators
of
reusable
industrial
wipes.
Many
states
exempt
reusable
industrial
wipes
from
regulation
as
a
hazardous
waste
if
the
wipes
do
not
contain
free
liquids
when
shipped
from
the
generator
site.
Solvent
removal
technologies
include
the
use
of
screen
bottom
drums,
hand
wringing,
mechanical
wringing,
and
centrifuging.

The
central
container
at
a
generator's
establishment
can
vary
in
size
from
a
small
bucket
to
a
large
bin
on
wheels.
It
is
usually
covered
and
air
tight,
although
one
manufacturing
plant
that
was
visited
by
EPA
used
a
cloth
laundry
bag
to
accumulate
reusable
industrial
wipes.
An
official
of
one
large
print
shop
who
was
interviewed
for
this
study
had
a
different
approach
to
wipe
management.
At
this
print
shop,
reusable
industrial
wipes
are
collected
from
cans
at
each
work
station
and
put
in
a
large
laundry
bin
on
wheels,
which
is
lined
with
a
plastic
bag.
The
bins
of
wipes
are
then
wheeled
to
an
on­
site
centrifuge.
Centrifuged
wipes
then
are
put
in
a
lined
laundry
bin
that
is
covered
with
a
stainless
steel
top
that
was
fashioned
by
the
shop
owners
themselves.
This
facility
is
not
typical,
however,
as
most
generators
do
not
currently
appear
to
practice
solvent
extraction.

When
solvent­
contaminated
industrial
wipes
are
accumulated
and
stored
in
containers,
the
solvents
in
the
wipes
tend
to
percolate
from
the
top
to
the
bottom
of
the
container
over
time.
This
is
particularly
noticeable
when
large
amounts
of
solvent
are
applied
to
the
wipes.
Free
liquids
occur
at
the
bottom
of
the
containers,
and
generators
can
easily
violate
a
"
no
free
liquids"
transportation
condition
if
the
containers
are
not
examined
and
the
free
liquids
are
not
removed
from
the
container
prior
to
shipping
the
cloths
off
site.
For
this
reason,
many
generators
use
screen
bottom
drums
to
accumulate
used
or
spent
industrial
wipes
and
to
segregate
and
collect
the
free
liquids
that
percolate
to
the
bottom
of
the
container.
Other
generators
may
extract
solvents
from
spent
or
used
wipes
by
hand
wringing,
mechanical
wringing,
or
centrifuging
the
wipes
prior
to
storing
them
or
shipping
them
off
site.
In
the
case
of
disposable
industrial
wipes,
some
generators
may
not
employ
any
solvent­
extraction
technologies
prior
to
shipping
the
materials
off
site
due
to
the
fact
that
most
states
regulate
disposal
wipes
contaminated
with
hazardous
wastes
solvents
as
hazardous
wastes,
regardless
of
the
amount
of
solvent
present
in
the
wipes.

The
next
step
in
waste
management
at
generator
facilities
is
to
transfer
reusable
industrial
wipes
to
the
laundry
service
and/
or
transfer
disposable
industrial
wipes
to
off­
site
hazardous
waste
management
facilities.
In
the
case
of
reusable
industrial
wipes,
some
generators
transfer
the
whole
storage
container
to
the
launderer,
while
other
generators
transfer
the
wipes
to
a
new
container
before
they
are
picked
up
by
the
laundry.
At
some
facilities,
the
container
of
wipes
is
emptied
out
on
to
a
large
launderable
cloth
on
the
floor,
such
as
a
fender
cover
at
an
auto
body
shop.
The
wipes
are
then
counted
by
the
rental
service,
and
the
wipe
with
everything
on
it
is
then
picked
up
and
put
in
the
laundry
truck.
This
way
the
laundry
service
not
only
shows
the
customer
that
they
are
being
honest
in
their
counting,
but
the
service
employee
can
also
see
if
there
are
any
30
free
liquids
in
the
laundry
before
accidentally
transporting
hazardous
waste
without
a
permit.

During
site
visits
to
generators
of
disposable
industrial
wipes,
EPA
found
that
generators
send
their
disposable
industrial
wipes
off­
site
for
management
at
hazardous
waste
landfills,
industrial
landfills,
municipal
landfills,
fuel
blenders,
and
hazardous
and
municipal
waste
incinerators.

The
overall
management
practices
of
wipes
vary
by
industry,
state,
rental
service,
and
facility.
Unfortunately,
with
such
a
diverse
customer
base,
it
is
difficult
to
quantify
the
prevalence
of
each
practice.
Some
of
the
variation
in
practices
is
due
to
the
lack
of
regulations
on
wipes.
With
more
defined
federal
regulations,
practices
may
become
more
standard.
31
III.
Current
Regulatory
Environment
III.
A.
Federal
Regulations
The
generation
and
management
of
solvent­
contaminated
industrial
wipes
are
currently
regulated
under
several
statutes
and
regulatory
programs
at
the
federal
level,
as
discussed
in
detail
below.

III.
A.
1.
Resource
Conservation
and
Recovery
Act
(
RCRA)

III.
A.
1.
a.
Hazardous
Waste
Regulations
Although
there
are
currently
no
federal
regulations
under
RCRA
that
specifically
establish
national
guidelines
for
the
management
of
solvent­
contaminated
industrial
wipes,
numerous
regulations
established
under
the
authority
of
RCRA
do
currently
apply
to
generators
and
handlers
of
these
materials
if
they
are
hazardous
wastes.

The
most
stringent
interpretation
of
the
federal
RCRA
program
would
subject
all
solventcontaminated
industrial
wipes
to
the
hazardous
waste
mixture
rule.
Under
RCRA,
a
solid
waste
is
a
hazardous
waste
if
it
(
1)
is
listed
as
a
hazardous
waste
under
40
CFR
Part
261,
Subpart
D;
(
2)
exhibits
one
or
more
of
the
characteristics
of
hazardous
waste
identified
in
40
CFR
Part
261,
Subpart
C;
(
3)
is
a
mixture
of
a
solid
waste
and
a
listed
hazardous
waste;
or
(
4)
is
a
mixture
of
a
solid
waste
and
a
characteristic
hazardous
waste
and
the
resultant
mixture
exhibits
one
or
more
of
the
characteristics
of
hazardous
waste.

Under
the
federal
RCRA
program,
industrial
wipes
contaminated
with
listed
hazardous
waste
solvents
(
i.
e.,
hazardous
waste
codes
F001­
F005)
would
be
considered
listed
hazardous
wastes,
and
they
would
have
to
be
managed
in
accordance
with
all
applicable
hazardous
waste
management
requirements
(
e.
g.,
storage
standards,
recordkeeping,
hazardous
waste
manifest).
Those
wipes
contaminated
with
spent
solvents
that
are
hazardous
wastes
because
they
exhibit
one
or
more
of
the
characteristics
of
hazardous
waste
would
also
be
hazardous
wastes.
In
addition,
solvent­
contaminated
industrial
wipes
that
exhibit
any
characteristic
of
hazardous
waste
would
have
to
be
managed
in
accordance
with
all
applicable
RCRA
hazardous
waste
management
standards.

Currently,
EPA
is
not
applying
the
federal
hazardous
waste
management
program
to
the
management
of
solvent­
contaminated
industrial
wipes.
The
current
federal
policy
with
respect
to
the
regulatory
status
of
solvent­
contaminated
industrial
wipes
has
been
to
defer
hazardous
waste
determinations
to
the
EPA
regions
and
states.
This
policy
is
due
primarily
to
the
site­
specific
nature
of
the
use
and
characterization
of
solvent­
contaminated
industrial
wipes
and
was
first
articulated
in
a
January
23,
1991
letter
from
Sylvia
K.
Lowrance,
Director,
Office
of
Solid
Waste,
to
Lance
R.
Miller,
Director
of
New
Jersey's
Hazardous
Waste
Management
Division,
regarding
the
petitions
submitted
by
the
Kimberly­
Clark
Corporation
and
Scott
Paper
Company.
She
stated:

We
believe
that
the
best
course
of
action
is
to
make
a
more
comprehensive
interpretation
in
this
rulemaking
context
[
solventcontaminated
wipes].
However,
given
our
current
resource
levels
and
32
competing
high­
priority
projects,
we
cannot
select
a
particular
target
date
for
the
final
evaluation
of
this
petition.
In
the
meantime,
Regions
and
states
continue
to
use
the
current
case­
by­
case
approach
on
this
subject.

The
policy
was
reaffirmed
in
a
February
14,
1994
memorandum
to
the
EPA
Regional
Waste
Management
Directors
from
Michael
Shapiro,
Director,
Office
of
Solid
Waste,
stating:

Because
there
are
many
applications
of
wipes,
we
cannot
at
this
time
make
any
generic
statements
that
all
wipes
are
hazardous
waste,
or
that
all
are
not.
A
material
that
is
a
solid
waste
is
by
definition
a
hazardous
waste
if
it
either
1)
meets
one
of
the
listings
in
40
CFR
Part
261,
Subpart
D,
or
2)
exhibits
one
or
more
of
the
characteristics
described
in
40
CFR
Part
261,
Subpart
C.
Because
there
are
no
explicit
listings
for
"
used
wipes"
in
Part
261,
Subpart
D,
a
wipe
can
only
be
defined
as
listed
hazardous
waste
if
the
wipe
either
contains
listed
waste,
or
is
otherwise
mixed
with
hazardous
waste.
Whether
or
not
a
used
wipe
contains
listed
hazardous
waste,
is
mixed
with
hazardous
waste,
only
exhibits
a
characteristic
of
hazardous
waste,
or
is
not
a
waste
at
all,
is
dependent
on
site­
specific
factors;
this
is
not
a
new
policy.
As
a
result,
any
determinations
or
interpretations
regarding
this
diverse
and
variable
waste
stream
should
be
made
by
the
regulatory
agency
(
i.
e.,
EPA
Region
or
State)
implementing
the
RCRA
program
for
a
particular
State.
This
has
been
our
longstanding
policy.

The
majority
of
states
and
EPA
regional
offices
have
created
policies
dictating
that
disposable
wipes
contaminated
with
a
listed
or
characteristically
hazardous
spent
solvent
should
be
managed
as
a
hazardous
waste,
while
reusable
wipes
that
are
managed
at
industrial
laundries
or
industrial
dry
cleaners
need
not
be
managed
as
a
hazardous
waste
as
long
as
specific
conditions
are
met.
These
conditions
primarily
require
that
generators
ensure
that
shipments
of
wipes
sent
to
industrial
laundries
do
not
contain
free
liquids
and
that
industrial
laundries
be
in
compliance
with
applicable
Clean
Water
Act
(
CWA)
regulations.
A
few
states
require
generators
to
extract
solvent
from
reusable
wipes
prior
to
sending
them
off
site
to
ensure
that
free
liquids
are
not
transported
off
site.
Industrial
laundries
also
often
urge
their
customers
to
remove
solvents
from
the
wipes
prior
to
being
transported
off
site
to
ensure
compliance
with
DOT
hazardous
materials
transportation
requirements
and
pretreatment
requirements
from
the
local
Publicly
Owned
Treatment
Works
(
POTW).

III.
A.
1.
b.
Land
Disposal
Restrictions
Under
the
land
disposal
restrictions
(
LDRs),
listed
or
characteristic
hazardous
wastes
must
meet
stringent
treatment
standards
prior
to
land
disposal.
These
treatment
standards
are
either
a
numerical
concentration
limit
for
hazardous
constituents
in
the
waste
or
the
application
of
a
particular
treatment
technology
to
the
waste
(
40
CFR
Part
268).
In
addition,
"
treatment,
storage,
or
disposal
of
hazardous
waste
by
any
person
who
has
not
applied
for
or
received
a
RCRA
[
Subtitle
C]
permit
is
prohibited"
(
40
CFR
§
270.1(
b)).
Furthermore,
owners
and
operators
of
hazardous
waste
management
facilities
must
comply
with
both
the
general
facility
and
unitspecific
operating
requirements
and
performance
standards
of
Part
264
(
for
permitted
facilities)
or
Part
265
(
for
interim
status
facilities),
as
appropriate.
2
For
purposes
of
the
LDRs,
land
disposal
includes
any
placement
of
hazardous
waste
into
a
landfill,
surface
impoundment,
waste
pile,
injection
well,
land
treatment
facility,
salt
dome
formation,
salt
bed
formation,
or
underground
mine
or
cave
(
RCRA
§
3004(
k)).

33
A
wipe
contaminated
with
a
listed
hazardous
waste
solvent
is
a
hazardous
waste
subject
to
the
LDRs
by
virtue
of
EPA's
hazardous
waste
mixture
rule.
Specifically,
a
mixture
of
a
solid
waste
and
one
or
more
listed
hazardous
wastes
is
a
hazardous
waste
unless
specifically
excluded
from
regulation
(
40
CFR
§
261.3(
a)(
2)(
iv)).
A
mixture
of
a
solid
waste
and
a
hazardous
waste
that
is
listed
solely
because
it
exhibits
a
hazardous
waste
characteristic
(
as
with
F003)
is
also
a
hazardous
waste
if
the
mixture
exhibits
one
or
more
of
the
characteristics
of
hazardous
waste
(
§
261.3(
a)(
2)(
iii)).
Therefore,
under
the
current
regulations
a
wipe
that
is
contaminated
with
a
listed
hazardous
waste
solvent
and
that
is
discarded
or
intended
to
be
discarded
(
i.
e.,
is
a
solid
waste)
must
be
managed
as
a
hazardous
waste.
In
addition,
as
with
any
solid
waste,
a
discarded
wipe
that
exhibits
one
or
more
of
the
characteristics
of
hazardous
waste
(
ignitability,
corrosivity,
reactivity,
or
toxicity)
is
a
hazardous
waste
and
subject
to
subtitle
C
regulation.

For
solvent­
contaminated
wipes
that
are
not
intended
to
be
discarded
(
i.
e.
not
a
solid
waste,
such
as
reusable
wipes
sent
to
an
industrial
laundry),
it
could
be
argued
that
the
hazardous
waste
mixture
rule
technically
does
not
apply
because
that
rule
applies
only
to
mixtures
of
solid
wastes
and
hazardous
wastes.
Nonetheless,
solvent­
contaminated
reusable
wipes
could
be
subject
to
subtitle
C
regulation
pursuant
to
EPA's
"
contained­
in"
policy,
which
has
been
upheld
as
a
reasonable
interpretation
of
the
mixture
rules
(
Chem
Waste
v.
EPA,
869
F.
2d
at
1539­
40).

Under
the
contained­
in
policy,
EPA
requires
non­
waste
materials
(
e.
g.,
soil,
groundwater,
and
debris)
to
be
managed
as
a
hazardous
waste
if
they
contain
hazardous
waste
or
exhibit
a
characteristic
of
hazardous
waste
(
see,
e.
g.,
63
FR
28621,
May
26,
1998,
LDR
Phase
IV
final
rule
and
57
FR
37194,
Aug.
18,
1992,
LDR
final
rule
for
hazardous
debris).
However,
under
the
current
policy
of
deferring
to
the
states
for
interpretation
of
a
wipes
regulatory
status,
most
reusable
wipes
are
conditionally
excluded
from
the
definition
of
solid
waste
or
the
definition
of
hazardous
waste.

A
wipe
contaminated
with
a
listed
hazardous
waste
solvent
must
meet
all
the
LDR
treatment
standards
applicable
to
that
solvent
prior
to
being
land
disposed.
For
example,
an
F001­
contaminated
wipe
must
meet
the
same
treatment
standards
that
would
apply
to
a
"
pure"
(
unmixed)
F001
waste.
The
existing
LDR
treatment
standards
for
the
non­
wastewater
forms
of
F001­
F005
wastes
are
set
forth
in
the
table
at
40
CFR
§
268.40,
and
consist
of
numerical
(
concentration­
based)
standards
for
27
different
hazardous
constituents.

The
LDRs
generally
attach
to
hazardous
wastes
when
the
wastes
are
first
generated
(
i.
e.,
at
the
point
of
generation).
Once
the
restrictions
attach,
the
standards
must
be
met
before
the
wastes
can
be
placed
into
any
land
disposal
unit
(
other
than
a
unit
which
has
been
granted
a
no
migration
variance).
2
In
addition
to
chemicals
included
in
the
F001­
F005
hazardous
waste
listings,
other
chemicals
can
be
used
as
solvents
in
conjunction
with
wipes,
such
as
acetonitrile,
isophorone
and
phenol,
and
can
cause
the
wipes
to
exhibit
one
or
more
characteristics
of
hazardous
waste.
Such
contaminated
wipes
must
be
managed
as
characteristic
hazardous
wastes
and
must
meet
3
Of
course,
in
the
case
of
a
wipe
contaminated
with
a
listed
solvent,
the
wipe
would
remain
a
listed
hazardous
waste
subject
to
the
LDRs
unless
and
until
the
wipe
is
excluded
from
subtitle
C
regulation
by
EPA
or
an
authorized
state.
40
CFR
§
261.3(
a)(
2)(
iv).
The
one
exception
to
this
rule
is
where
the
solvent
is
contaminated
solely
with
an
F003
solvent,
which
is
listed
because
the
solvent
exhibits
the
ignitability
characteristic,
and
the
wipe
no
longer
exhibits
any
hazardous
waste
characteristics.
§
261.3(
a)(
2)(
iii).

34
applicable
LDR
treatment
standards
prior
to
any
land
disposal.

Importantly,
because
the
LDRs
attach
at
the
point
of
generation,
treatment
standards
must
be
met
fully
even
if
the
wipe
no
longer
exhibits
any
hazardous
waste
characteristics
at
the
point
of
land
disposal
or
at
the
point
the
wipes
are
sent
for
off­
site
management
(
61
FR
15566­
15568,
April
8,
1996;
LDR
Phase
III
final
rule);
Chemical
Waste
Management,
Inc.
v.
EPA,
976
F.
2d
2,
12­
14
(
D.
C.
Cir.
1992).
Assume,
for
instance,
that
a
spent
wipe
is
not
mixed
with
a
listed
solvent
but
exhibits
the
ignitability
characteristic.
Assume
further
that
the
characteristic
is
removed
from
the
wipe
through
wringing
or
centrifuging
after
the
wipe
has
become
spent
but
prior
to
sending
the
wipe
off
site
for
treatment
or
disposal.
In
this
case,
the
LDRs
must
still
be
met
prior
to
any
land
disposal
of
the
wipe,
even
though
the
wringing
or
centrifuging
has
removed
the
characteristic.
3
In
the
case
of
solvent­
contaminated
wipes
that
exhibit
a
characteristic
of
hazardous
waste
and
are
sent
to
an
industrial
laundry,
the
wipes
clearly
are
not
wastewaters
that
could
take
advantage
of
the
LDR
exemption
for
treatment
in
CWA
systems.
The
LDR
exemption
states
that
characteristic
wastes
are
not
prohibited
from
land
disposal
"
if
they
are
managed
in
either
a
treatment
system
whose
ultimate
discharge
is
regulated
under
the
CWA
(
including
both
direct
and
indirect
discharges),
a
CWA­
equivalent
treatment
system,
or
a
Class
I
nonhazardous
injection
well
regulated
under
the
SDWA
[
Safe
Drinking
Water
Act],
provided
that
the
wastes
no
longer
are
hazardous
(
i.
e.,
no
longer
exhibit
a
characteristic)
at
the
point
land
disposal
occurs"
(
61
FR
15660,
April
8,
1996,
amendment
of
LDR
Phase
III
final
rule
in
response
to
the
Land
Disposal
Program
Flexibility
Act
of
1996).
The
wastewater
discharge
from
the
laundry
itself,
however,
could
be
eligible
for
the
LDR
exemption.

LDRs
for
Sludges
Under
RCRA,
any
solid
waste
generated
from
the
treatment,
storage,
or
disposal
of
a
hazardous
waste,
including
any
sludge,
spill,
residue,
ash,
emission
control
dust,
or
leachate,
is
a
hazardous
waste
(
see
40
CFR
§
261.3(
c)(
2)(
i)).
Therefore,
the
strict
interpretation
of
the
federal
regulatory
program
governing
the
management
of
wipes
contaminated
with
listed
solvents
results
in
the
hazardous
waste
listing
(
e.
g.,
F001­
F005)
carrying
through
to
the
sludges
generated
from
the
management
of
such
wipes
at
industrial
laundries.
These
sludges
therefore
are
subject
to
the
LDR
requirements,
and
the
LDR
treatment
standards
must
be
met
before
the
sludges
can
be
placed
into
any
land
disposal
unit.
Of
course,
in
the
case
of
those
solvents
listed
solely
because
they
exhibit
a
characteristic
of
hazardous
waste
(
e.
g.,
F003)
if
the
resultant
solvent­
contaminated
wipe
does
not
exhibit
a
characteristic,
the
"
mixture"
no
longer
retains
that
listing
and
the
listing
does
not
carry
through
to
sludges
generated
from
treatment
of
the
wipe.
35
III.
A.
2
Clean
Water
Act
The
Clean
Water
Act
was
enacted
to
restore
and
maintain
the
chemical,
physical,
and
biological
integrity
of
the
nation's
waters.
Through
this
authority,
EPA
implements
the
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permitting
program
to
control
discharges
of
industrial
wastewaters
directly
to
waters
of
the
U.
S.
Indirect
discharges
to
POTWs
are
controlled
through
the
National
Pretreatment
Program.

Pursuant
to
a
1976
settlement
agreement
and
the
1977
Clean
Water
Act
Amendments,
EPA
was
required
to
develop
a
program
and
adhere
to
a
schedule
in
promulgating
effluent
limitation
guidelines
(
ELGs)
and
pretreatment
standards
for
65
"
toxic"
pollutants
and
classes
of
pollutants,
generated
across
21
major
industries.
The
Auto
and
Other
Laundries
industrial
category,
of
which
industrial
laundries
is
a
subcategory,
was
one
of
the
categories
required
to
be
studied
under
the
1976
Settlement
Agreement
for
the
possible
development
of
ELGs
and
standards.
Several
studies
were
undertaken
from
1977
to
1980
to
collect
more
information
about
the
industrial
laundries
industry,
including
two
surveys
(
1977
and
1979)
and
wastewater
sampling
and
analysis
programs
conducted
in
1978
(
screening
and
verification
study).

Following
these
original
studies,
additional
data
was
collected
by
EPA's
Industrial
Technology
Division
in
conjunction
with
the
Agency's
Office
of
Solid
Waste
from
1985
to
1987.
In
1986,
EPA
published
its
Domestic
Sewage
Study
(
DSS),
which
identified
industrial
laundries
as
potential
contributors
of
large
amounts
of
hazardous
pollutants
to
POTWs.
Based
on
information
gathered
to
that
point,
the
Agency
compiled
a
profile
of
the
industrial
laundry
industry
that
was
published
as
a
Preliminary
Data
Summary
in
1989.

According
to
Section
304(
m)
of
the
CWA,
added
by
the
Water
Quality
Act
of
1987,
EPA
is
required
to
establish
schedules
for
promulgating
new
or
revised
ELGs
and
standards.
On
January
2,
1990,
EPA
published
an
Effluent
Guideline
Plan
(
January
2,
1990;
55
FR
80),
in
which
schedules
were
established
for
developing
new
and
revised
ELGs
and
standards
for
several
industrial
categories.
The
Effluent
Guideline
Plan
also
listed
several
industrial
categories
that
were
to
be
studied
to
determine
whether
rulemakings
to
develop
ELGs
and
standards
should
be
initiated.
One
of
those
categories
was
the
Industrial
Laundries
Point
Source
Category,
based
on
the
results
of
the
DSS.

Natural
Resources
Defense
Council,
Inc.
(
NRDC)
and
Public
Citizen,
Inc.
challenged
the
Effluent
Guidelines
Plan
in
a
suit
filed
in
U.
S.
District
Court
for
the
District
of
Columbia
(
NRDC
et
al.
v.
Reilly,
Civ.
No.
89­
2980).
The
plaintiffs
charged
that
EPA's
plan
did
not
meet
the
requirements
of
section
304(
m).
A
consent
decree
in
this
litigation
was
entered
by
the
Court
on
January
31,
1992
(
57
FR
19748),
that
established
schedules
for,
among
other
things,
EPA's
proposal
and
promulgation
of
ELGs
and
standards
for
a
number
of
categories,
including
the
Industrial
Laundries
Point
Source
Category.

Under
the
requirements
of
the
consent
decree,
EPA
proposed
ELGs
and
standards
for
the
Industrial
Laundries
Point
Source
Category
(
December
17,
1997;
62
FR
66182).
The
proposed
rule
limited
the
discharge
of
pollutants
into
POTWs
from
existing
and
new
industrial
laundries
by
establishing
Pretreatment
Standards
for
Existing
and
New
Sources.
EPA
did
not
establish
ELGs
or
standards
applicable
to
industrial
laundries
discharging
directly
to
waters
of
the
U.
S.
because
36
EPA
did
not
identify
any
direct
dischargers
and
did
not
identify
any
available
information
with
which
to
accurately
determine
technology­
based
limitations
for
direct
dischargers.
The
proposed
rule
applied
to
industrial
laundries,
defined
as
"
any
facility
that
launders
industrial
textile
items
from
off
site
as
a
business
activity.
Industrial
textile
items
include,
but
are
not
limited
to,
industrial
shop
towels,
garments
and
uniforms,
printer
towels,
mops,
and
mats."
EPA
did
not
propose
regulations
for
discharges
from
on­
site
laundering
at
industrial
facilities,
laundering
of
industrial
textile
items
originating
from
the
same
business
entity,
and
facilities
that
exclusively
launder
linen
items,
denim
prewash
items,
new
items,
any
other
laundering
of
hotel,
hospital,
or
restaurant
items
or
any
combination
of
these
items.
The
proposed
rule
did
apply
to
hotel,
hospital,
or
restaurant
laundering
of
industrial
textile
items.

On
August
18,
1999,
EPA
published
a
Federal
Register
Notice
withdrawing
its
proposed
rule
to
establish
ELGs
and
standards
for
the
industrial
laundry
sector.
EPA's
primary
basis
for
the
withdrawal
is
that
indirect
discharges
from
industrial
laundries
contain
very
small
amounts
of
toxic
pollutants
that
are
not
removed
by
POTWs.
Comments
on
the
proposed
rule
and
subsequent
data
collection
resulted
in
the
following
conclusions:
(
1)
laundry
discharges
are
not
as
toxic
as
estimated
at
proposal;
(
2)
POTWs
provide
better
treatment
of
the
toxic
pollutants
remaining
in
laundry
discharges
than
estimated
at
proposal;
and
(
3)
individual
problems
are
not
prevalent
with
past
problems
having
been
resolved
by
local
pretreatment
authorities.

EPA
concluded
that,
to
the
extent
isolated
problem
discharges
occur,
existing
pretreatment
authority
allows
local
POTWs
to
respond
to
problems
effectively.
Local
POTWs
have
the
authority
to
set
local
limits
for
individual
indirect
dischargers
to
prevent
(
1)
pass­
through
of
pollutants
into
waters
of
the
U.
S.,
and
(
2)
interference
both
with
POTW
operations
and
sludge
disposal
options.
EPA's
pass­
through
analysis
for
the
rulemaking
determined
that
there
is
not
significant
pass­
through
of
pollutants
from
industrial
laundries
to
waters
of
the
U.
S.
EPA
also
concluded
that
a
better
way
to
control
effluent
discharges
of
certain
organic
pollutants,
including
solvents,
is
to
remove
them
before
they
are
washed.

III.
A.
3
Clean
Air
Act
The
Clean
Air
Act
(
CAA)
establishes
a
national
framework
for
the
attainment
and
maintenance
of
air
quality
standards.
The
national
ambient
air
quality
standards
(
NAAQS)
establish
national
standards
for
six
"
criteria"
pollutants:
carbon
monoxide,
nitrogen
oxides,
sulfur
dioxide,
particulate
matter,
lead
and
ozone.
Air
pollutants
are
released
from
both
small
stationary
sources,
such
as
dry
cleaners
and
auto
paint
shops,
and
major
sources,
such
as
chemical
factories
and
incinerators.
Although
the
CAA
regulates
major
sources
more
strictly,
EPA
is
required
to
regulate
small
sources
of
hazardous
air
pollutants
as
well.
Under
the
1990
CAA
Amendments,
EPA
is
required
to
study
ways
to
reduce
pollutant
emissions
from
small
neighborhood
sources.

To
reduce
air
pollution,
EPA
first
identifies
the
toxic
pollutants
whose
release
should
be
reduced.
The
1970
CAA
gave
EPA
authority
to
list
air
toxics
and
then
create
regulations
for
those
listed
pollutants.
By
1990,
EPA
had
listed
and
regulated
seven
air
pollutants.
The
1990
CAA
Amendments
greatly
expanded
the
list
and
includes
189
hazardous
air
pollutants
(
HAPs),
which
were
selected
by
Congress
on
the
basis
of
potential
health
and/
or
environmental
hazard.
The
1990
Amendments
also
allow
EPA
to
add
new
chemicals
to
the
list
as
necessary.
To
regulate
HAPs,
EPA
is
required
to
identify
categories
of
sources
that
release
the
189
chemicals.
The
air
37
toxics
producers
are
then
identified
as
major
or
area
sources
and
promulgate
regulations
specific
to
those
categories.

Once
HAP
regulations
are
established,
sources
are
to
use
the
Maximum
Achievable
Control
Technology
(
MACT)
to
reduce
pollutant
releases
to
a
level
considered
technically
achievable.
In
some
cases,
EPA
specifies
the
method
required
to
reduce
air
pollutants;
however,
in
most
cases,
companies
have
the
flexibility
to
choose
how
they
meet
the
requirements.

Many
solvents
commonly
used
in
conjunction
with
wipes
are
included
on
the
list
of
HAPs
in
Section
112
of
the
CAA.
These
solvents
include:
benzene,
carbon
disulfide,
carbon
tetrachloride,
cresol,
ethyl
benzene,
methanol,
methyl
isobutyl
ketone,
methylene
chloride,
nitrobenzene,
2­
nitropropane,
tetrachloroethylene,
toluene,
1,1,2­
trichloroethane,
trichloroethylene,
and
xylene.
These
solvents
may
also
meet
the
definition
of
a
Volatile
Organic
Compound
(
VOC
),
a
precursor
of
ozone,
which
is
also
regulated
under
the
CAA.
Overall,
facilities
which
either
generate
or
handle
solvent­
contaminated
wipes
would
be
subject
to
regulation
under
the
CAA
depending
upon
the
types
of
solvents
used
and
the
amount
of
emissions
released
to
the
air.

The
Uniform
and
Textile
Service
Association,
a
trade
association
representing
textile
supply
and
service
companies,
estimated
in
their
guidance
Reusable
Wipes:
A
Synopsis
that
most
industrial
laundries
would
not
be
regulated
as
a
major
source.
Some
industrial
laundries,
however,
may
be
subject
to
the
CAA
regulations
for
industrial
dry
cleaners
for
reasons
unrelated
to
industrial
wipes.

III.
A.
4
Occupational
Safety
and
Health
Administration
(
OSHA)
Standards
The
Occupational
Safety
and
Health
Administration
(
OSHA),
an
agency
of
the
U.
S.
Department
of
Labor,
is
responsible
for
creating
standards
to
protect
the
health
and
safety
of
individuals
in
the
workplace.
In
1970,
Congress
passed
the
Occupational
Safety
and
Health
Act
in
an
effort
to
decrease
personal
illnesses
and
injuries
resulting
from
work
situations,
which
place
a
substantial
burden
on
commerce
due
to
loss
of
production,
loss
of
wages,
medical
expenses,
and
disability
compensation
payments.
The
intent
of
the
act
was
to
ensure
safe
and
healthy
work
environments
by
authorizing
the
Secretary
of
Labor
to
set
mandatory
occupational
safety
and
health
standards
applicable
to
businesses
affecting
interstate
commerce
(
29
CFR
Parts
1900­
1999).

The
OSHA
standards
are
generally
applicable
to
all
workers
in
all
workplaces,
although
possible
exceptions
include
miners,
transportation
workers,
public
employees,
and
the
selfemployed
The
Occupational
Health
and
Safety
Standards
in
part
1910
provide
both
general
and
specific
requirements
with
which
facilities
must
comply
when
applicable.
Specifically,
subpart
H
of
part
1910
contains
standards
for
the
management
of
hazardous
materials,
including
4
Flammable
liquids
are
defined
as
any
liquid
having
a
flash
point
below
100
°
F
(
37.8
°
C)
except
any
mixture
having
components
with
flash
points
at
100
°
F
or
higher,
the
total
of
which
make
up
99%
or
more
of
the
total
volume
of
the
mixture.

5
Combustible
liquids
are
any
liquids
having
a
flash
point
at
or
above
100
°
F
(
37.8
°
C).

6
According
to
Mike
Marshall
at
OSHA,
wipes
are
most
likely
regulated
by
the
§
1910.106
container
regulations
under
(
e)(
9)(
iii),
which
state
that
"
combustible
waste
material
and
residues
in
a
building
or
unit
operating
area
shall
be
kept
to
a
minimum,
stored
in
covered
metal
receptacles,
and
disposed
of
daily."

38
requirements
for
the
management
of
flammable4
and
combustible5
liquids
(
§
1910.106).
Many
facilities
which
either
generate
solvent­
contaminated
industrial
wipes
or
launder
such
materials
may
be
subject
to
these
standards.
6
The
requirements
of
§
1910.106
outline
management
and
storage
practices
for
facilities
that
handle
flammable
or
combustible
liquids.
Several
solvents
that
are
listed
or
characteristic
hazardous
wastes
when
spent
and
that
are
used
in
conjunction
with
wipes
meet
the
definition
of
a
flammable
liquid
(
e.
g.,
acetone,
ethyl
acetate,
ethyl
benzene,
methyl
ethyl
ketone,
petroleum
naphtha).

According
to
OSHA
standards,
flammable
liquids
must
be
stored
in
approved
containers
that
meet
the
requirements
of
§
1910.106(
d).
Metal
containers
and
portable
tanks
meeting
Department
of
Transportation
standards
(
see
49
CFR
Parts
173
and
178)
are
acceptable.
Section
1910.106
also
specifies
standards
for
the
areas
where
containers
holding
flammable
liquids
are
stored,
including
requirements
for
storage
cabinets,
rooms,
buildings,
storage
outside
of
buildings,
and
industrial
plants.
The
requirements
for
industrial
plants
may
be
most
applicable
to
generators
or
launderers
of
solvent­
contaminated
wipes
because
the
regulations
apply
to
the
portions
of
an
industrial
plant
where
the
"
use
and
handling
of
flammable
and
combustible
liquids
is
incidental
to
the
principal
business"
(
e.
g.,
solvents
used
for
cleaning
presses
at
printing
facilities).
At
industrial
plants,
flammable
liquids
must
be
stored
in
tanks
or
closed
containers.

For
purposes
of
the
OSHA
regulations,
a
closed
container
is
defined
as
a
container
that
is
sealed
with
a
lid
or
other
device
to
prevent
the
release
of
liquids
or
vapors
at
ordinary
temperatures
(
§
1910.106(
a)(
9)).
Facilities
managing
solvent­
contaminated
wipes
may
be
subject
to
other
OSHA
requirements
including
standards
for
personal
protective
equipment
(
§
1910.132­
136)
and
hazard
communications
(
§
1910.1200).
In
addition,
facilities
may
need
to
comply
with
the
standards
for
air
contaminants
under
§
1910.1000,
which
set
limits
on
employee
exposure
to
toxic
and
hazardous
substances
in
the
air.
Many
of
the
solvents
used
in
conjunction
with
wipes
are
included
in
OSHA's
listing
of
air
contaminants
for
which
regulatory
exposure
limits
have
been
set
(
e.
g.,
acetaldehyde,
acetone,
MEK,
ethyl
acetate).

III.
A.
5.
Department
of
Transportation
(
DOT)
Requirements
The
federal
Hazardous
Materials
Transportation
Act
regulates
transportation
of
hazardous
materials.
The
purpose
of
the
law
is
to
provide
adequate
protection
against
the
risks
to
life
and
property
inherent
in
transporting
hazardous
materials
in
commerce.
According
to
the
act,
a
material
or
a
group
or
class
of
materials
is
designated
as
hazardous
if
it
is
determined
that
transporting
the
materials
in
commerce
in
a
particular
amount
and
form
may
pose
an
unreasonable
39
risk
to
health
and
safety
or
property.
The
Secretary
is
then
responsible
for
issuing
regulations
for
the
safe
transportation
of
hazardous
materials:
the
Hazardous
Materials
Regulations
(
HMR)
are
found
in
49
CFR
Parts
171­
180.

According
to
the
DOT
regulations,
any
person
who
offers
a
material
for
transportation
in
commerce
must
determine
whether
the
material
is
classified
as
a
hazardous
material.
In
most
cases,
reusable
solvent­
contaminated
industrial
wipes
are
classified
as
"
solids
containing
flammable
liquid,
not
otherwise
specified"
(
see
49
CFR
§
172.101).
Under
§
172.102,
mixtures
of
solids
and
flammable
liquids
may
be
transported
as
"
solids
containing
flammable
liquid,
not
otherwise
specified,"
without
first
being
classified
as
flammable
solids,
provided
there
is
no
free
liquid
visible
at
the
time
the
material
is
loaded
or
at
the
time
the
packaging
or
transport
unit
is
closed
(
see
49
CFR
§
173.124(
a)).
Each
package
must
correspond
to
a
design
type
that
has
passed
a
leakproof
test
at
the
Packing
Group
II
level.
Containers
which
are
authorized
for
transporting
hazardous
materials
in
Packing
Group
II
are
listed
under
49
CFR
§
173.212.

Hazardous
materials
in
Class
4.1,
Packing
Group
II
are
eligible
to
be
shipped
under
the
limited
quantity
provisions
of
§
173.151(
b)(
1)
in
inner
packagings
not
over
1.0
kg
(
2.2
pounds)
net
capacity
each,
and
are
exempt
from
labeling
and
specification
packaging
requirements,
provided
the
materials
are
not
shipped
via
air.
The
maximum
gross
weight
of
a
limited
quantity
package
is
66
pounds.
Materials
shipped
under
the
limited
quantity
provisions
remain
subject
to
the
marking
and
shipping
paper
requirements
of
subparts
C
and
D
of
Part
172.

According
to
DOT's
Office
of
Hazardous
Materials
Standards,
if
free­
flowing
liquid
can
be
seen
surrounding
materials
that
are
to
be
shipped,
the
materials
may
meet
the
definition
of
a
flammable
liquid
in
49
CFR
173.120.
If
the
materials
do
not
include
free
liquids,
they
may
meet
the
definition
of
a
flammable
solid.
Ultimately,
it
is
the
shipper's
responsibility
to
properly
classify
a
hazardous
material.

III.
B.
State
Regulations
III.
B.
1.
RCRA
Delegation
As
mentioned
previously,
EPA's
current
policy
with
respect
to
the
regulatory
status
of
solvent­
contaminated
wipes
is
to
defer
the
determination
of
regulatory
status
to
state
agencies
and/
or
the
EPA
regional
offices.
In
response,
most
states
have
developed
regulatory
programs
that
either
provide
conditional
relief
for
these
materials
from
solid
waste
or
hazardous
waste
regulations
or
that
set
management
standards
for
handlers
of
solvent­
contaminated
wipes.
An
overview
of
current
state
policies
and
programs
is
provided
below.

III.
B.
2
State
Standards
and
Practices
A
review
of
state
policies
regarding
the
regulation
of
solvent­
contaminated
wipes
indicates
that
most
states
have
developed
their
own
policies
(
pending
EPA
action).
However,
a
few
states
have
deferred
regulatory
decisions
regarding
the
management
of
solvent­
contaminated
wipes
to
their
respective
EPA
regional
office.
Currently,
all
states
regulate
industrial
wipes
as
hazardous
waste
when
they
are
contaminated
with
a
listed
solvent
or
exhibit
a
hazardous
waste
characteristic
and
the
wipes
are
destined
for
disposal.
Forty­
six
states
provide
regulatory
relief
for
contaminated
40
wipes
that
are
sent
to
an
industrial
laundry
and
subsequently
reused.
The
remaining
four
states
(
Arkansas,
Idaho,
South
Dakota,
and
West
Virginia)
regulate
reusable
wipes
as
hazardous
waste
if
they
contain
a
listed
hazardous
waste
or
exhibit
a
hazardous
waste
characteristic,
even
though
they
are
being
laundered.

The
majority
of
state
programs
consider
laundering
to
be
a
form
of
recycling
and,
subsequently,
exclude
reusable
industrial
wipes
from
RCRA
regulation
based
on
the
state
agency's
interpretation
of
the
definition
of
solid
waste.
Other
states
provide
conditional
exclusions
from
the
hazardous
waste
regulations
for
laundered
wipes.
In
either
case,
to
meet
the
exclusion,
the
contaminated
wipes
must
meet
at
least
the
following
criteria:


the
wipes
contain
no
free
liquids;
and

the
industrial
laundry
discharges
to
a
Publicly
Owned
Treatment
Works
(
POTW)
or
is
otherwise
permitted
under
the
Clean
Water
Act.

States
have
different
policies
on
what
constitutes
no
free
liquids.
However,
the
majority
of
states
use
the
Paint
Filter
Liquids
Test
(
SW­
846
Method
9095)
to
make
such
determinations.
Other
specified
methods
include
the
Liquids
Release
Test
(
SW­
846
Method
9096),
the
TCLP
(
SW­
846
Method
1311),
and
either
physical
or
mechanical
wringing
until
the
wipe
meets
the
"
no
drip"
criterion.
Only
a
few
states
identify
wringing
or
solvent­
extraction
processes
conducted
by
generators
to
remove
free
liquids
as
a
form
of
treatment,
and
it
is
unclear
whether
any
state
defines
this
activity
as
regulated
hazardous
waste
treatment.
Several
state
programs
specify
that
removing
free
liquids
through
evaporation
or
intentional
drying
is
not
allowed.

In
many
states,
the
burden
of
determining
whether
a
solvent­
contaminated
industrial
wipe
should
be
managed
as
a
hazardous
waste
is
placed
on
the
generator.
However,
some
state
programs
specifically
state
that
launderers
are
obligated
to
accept
only
contaminated
wipes
that
meet
specified
criteria;
otherwise,
the
laundry
is
considered
a
regulated
disposal
facility.
Some
states
allow
on­
site
laundering
of
wipes
by
generators,
provided
there
is
an
agreement
on
file
with
the
state
that
allows
the
facility
to
discharge
to
the
sanitary
sewer.
However,
the
majority
of
states
discourage
on­
site
laundering.
In
addition,
at
least
three
states
require
contractual
agreements
between
generators
and
launderers
for
the
generator
to
qualify
for
an
exclusion
from
RCRA
regulation.

While
the
majority
of
state
policies
are
the
same,
there
are
some
states
with
notable
variations
including:

Hawaii
­
Reusable
wipes
must
be
managed
as
hazardous
waste
up
until
the
point
at
which
they
are
laundered.

New
Mexico
­
Industrial
laundries
are
subject
to
permitting
requirements
unless
the
wipes
are
placed
directly
into
the
laundry
process
(
i.
e.,
within
24
hours).

Idaho
­
Wipes
must
be
managed
as
hazardous
waste
if
they
are
contaminated
with
a
listed
waste
or
exhibit
a
characteristic.
Reusable
wipes
cannot
be
laundered
unless
they
are
treated
to
meet
the
specified
LDR
treatment
standard
for
the
wastes
with
which
they
are
contaminated.
41
South
Dakota
­
If
a
listed
solvent
is
applied
to
a
part
and
then
removed
with
a
wipe,
it
is
considered
to
be
listed
(
because
the
solvent
is
"
spent"),
must
be
managed
as
a
hazardous
waste
and,
thus,
cannot
be
laundered.
If
the
wipe
exhibits
a
characteristic,
it
is
a
regulated
hazardous
waste
and
cannot
be
laundered.
If
the
wipe
is
contaminated
with
a
listed
solvent
that
was
applied
directly
to
the
wipe,
the
wipe
is
not
considered
to
meet
the
listing
description
and
can
be
laundered
without
being
managed
as
a
hazardous
waste.

Table
6
below
provides
a
general
overview
of
current
state
programs
regarding
the
regulatory
status
of
solvent­
contaminated
reusable
and
disposable
wipes.
Table
7
provides
more
specific
information
on
a
subset
of
state
programs
governing
the
management
of
wipes.
42
Table
6
State
Policies
on
Reusable
Wipes
State
Reusable
Wipes
Non­
Hazardous
If
Water
Washed
Or
Dry
Cleaned
Disposable
Wipes
Considered
Hazardous
(
Qualified)
Why
Reusable
Wipes
Are
Non­
Hazardous
Not
a
Solid
Not
a
Hazardous
Waste
Waste
Alabama
Yes
Yes
Alaska**
Yes
Yes
Yes
Arizona
Yes
Yes*
Yes
Arkansas
No
Yes
No
California
Yes
Yes
Yes
Colorado
Yes
Yes
Yes
Connecticut
Yes
Yes
Yes
Delaware
Yes
Yes
Yes
Florida
Yes
Yes
Yes
Georgia
Yes
Yes
Yes
Hawaii
Yes*
Yes
Yes
Idaho
No
Yes
No
No
Illinois
Yes
Yes
Yes
Indiana
Yes
Yes*
Yes
Iowa**
Yes
Yes
Yes
Kansas
Yes
Yes*
Yes
Kentucky
Yes
Yes
Yes
Louisiana
Yes
Yes
Yes
Maine
Yes
Yes
Maryland
Yes
Yes
Yes
Massachusetts
Yes
Yes
Yes
Michigan
Yes
Yes
Yes
Minnesota
Yes*
Yes*
Yes
Table
5:
State
Policies
on
Reusable
Shop
Wipes
(
cont.)

State
Reusable
Wipes
Non­
Hazardous
If
Water
Washed
Or
Dry
Cleaned
Disposable
Wipes
Considered
Hazardous
(
Qualified)
Why
Reusable
Wipes
Are
Non­
Hazardous
Not
a
Solid
Not
a
Hazardous
Waste
Waste
43
Mississippi
Yes
Yes
Missouri
Yes
Yes
Yes
Montana
Yes
Yes
Yes
Nebraska
Yes
Yes
Yes
Nevada
Yes*
Yes
Yes
New
Hampshire
Yes*
Yes
New
Jersey
Yes*
Yes
Yes
New
Mexico
Yes*
Yes*
Yes
New
York
Yes*
Yes*
Yes
North
Carolina
Yes
Yes
Yes
North
Dakota
Yes
Yes*
Yes
Ohio
Yes
Yes
Yes
Oklahoma
Yes
Yes*
Yes
Oregon
Yes*
Yes
Yes
Pennsylvania
Yes*
Yes
Yes
Rhode
Island
Yes*
Yes
Yes
South
Carolina
Yes*
Yes
Yes
South
Dakota
No
Yes
No
No
Tennessee**
Yes
Yes
Yes
Texas
Yes
Yes
Yes
Utah
Yes
Yes
Vermont
Yes
Yes
Yes
Table
5:
State
Policies
on
Reusable
Shop
Wipes
(
cont.)

State
Reusable
Wipes
Non­
Hazardous
If
Water
Washed
Or
Dry
Cleaned
Disposable
Wipes
Considered
Hazardous
(
Qualified)
Why
Reusable
Wipes
Are
Non­
Hazardous
Not
a
Solid
Not
a
Hazardous
Waste
Waste
44
Virginia
Yes
Yes*
Yes
Washington
Yes
Yes
Yes
West
Virginia
No
Yes
No
No
Wisconsin
Yes
Yes
Yes
Wyoming**
Yes
Yes
Yes
*
Note:
Refer
to
individual
state
policies
for
qualifications.
**
Note:
Refer
to
regional
policies
for
qualifications.
45
Table
7
Summary
of
Selected
State
Programs
State
Description
of
Policy
Alabama
Contaminated
industrial
wipes
bound
for
laundering
and
reuse
are
considered
products
in
use
and
are
not
solid
wastes,
and,
therefore,
not
hazardous
wastes.
The
state
position
is
based
upon
the
policy
stated
by
Region
4.

Arkansas
Reusable
industrial
wipes
that
contain
a
listed
waste,
that
are
mixed
with
a
listed
waste,
or
that
exhibit
a
characteristic
are
regulated
as
hazardous
waste.

Florida
Reusable
industrial
wipes
that
are
laundered
at
facilities
which
discharge
to
a
POTW
or
are
subject
to
the
CWA
are
not
solid
wastes
and
are
not
regulated
under
the
state's
RCRA
program.
Florida
bases
its
policy
on
the
Region
4
position.

Georgia
Laundered
industrial
wipes
are
not
regulated
because
they
are
being
recycled
and
used
as
effective
substitutes
for
new
products
according
to
40
CFR
§
261.2(
e).
Generator
storage
prior
to
laundering
is
subject
to
the
same
accumulation
requirements
as
hazardous
waste
(
§
262.34).

Massachusetts
Non­
saturated,
solvent­
contaminated
industrial
wipes
are
eligible
for
a
conditional
exemption
that
allows
them
to
go
to
laundries
without
a
manifest,
provided
they
meet
the
specified
criteria.
The
"
one
drop
test"
is
used
to
determine
what
is
non­
saturated
(
i.
e.,
a
wipe
is
considered
saturated
if
a
drop
of
solvent
can
be
wrung
out
of
it).
Saturated
industrial
wipes
must
be
managed
as
hazardous
waste
until
they
meet
the
"
one
drop
test."

Minnesota
Free
liquids
must
be
wrung
from
disposable
industrial
wipes
and
must
be
managed
as
hazardous,
if
appropriate.
Free
liquids
must
be
wrung
from
reusable
industrial
wipes
and
they
must
be
managed
as
hazardous
waste
on­
site.
If
the
wipes
are
sent
to
an
industrial
launderer,
the
shipment
does
not
require
a
manifest
and
the
laundry
does
not
need
to
be
permitted
under
RCRA.

Missouri
Contaminated
industrial
wipes
used
in
cleaning
and
degreasing
operations
are
not
regulated
as
solid
or
hazardous
wastes
when
laundered.
Industrial
wipes
used
to
clean
up
spills
are
regulated
as
hazardous
waste
if
they
contain
a
listed
waste
or
exhibit
a
characteristic
and
laundering
may
be
considered
improper
treatment.
Contaminated
industrial
wipes
that
are
destined
for
disposal
must
be
managed
as
hazardous
wastes
if
appropriate.

Nebraska
Industrial
wipes
used
for
cleaning
that
are
contaminated
with
listed
or
characteristic
solvents
are
not
regulated
as
hazardous
waste
provided
that
they
are
being
laundered
(
recycled)
and
that
no
free
solvent
is
present
at
the
time
they
are
sent
for
recycling.
State
Description
of
Policy
46
New
Jersey
Solvent­
contaminated
industrial
wipes
that
are
sent
for
disposal
are
regulated
according
to
the
mixture
rule
and
have
different
standards
depending
on
how
the
wipe
came
into
contact
with
the
solvent
and
the
type
of
solvent
used.
If
a
hazardous
contaminated
industrial
wipe
is
being
laundered,
it
is
not
regulated
as
hazardous
waste
provided
there
are
no
free
liquids.
Any
storage
at
generator
facilities
prior
to
laundering
is
regulated
in
the
same
manner
as
hazardous
waste
storage.

New
York
Contaminated
industrial
wipes
are
not
hazardous
wastes
when
sent
to
industrial
laundries
provided
they
are
not
saturated
(
i.
e.,
they
pass
the
Paint
Filter
Test).
Prior
to
laundering,
all
industrial
wipes
must
be
managed
in
accordance
with
specified
accumulation
standards.
Generators
also
must
file
a
one­
time
notice
under
LDR
when
sending
industrial
wipes
to
be
laundered.

Virginia
Solvent­
contaminated
industrial
wipes
that
are
intended
for
disposal
are
regulated
as
hazardous
wastes.
Industrial
wipes
that
are
hazardous
wastes
and
sent
to
launderers
are
not
regulated
as
solid
or
hazardous
wastes
provided
there
are
no
free
liquids.

Washington
Reusable
industrial
wipes
that
would
be
hazardous
wastes
are
not
regulated
as
hazardous
waste
if
they
are
managed
according
to
the
established
best
management
practices
(
i.
e.,
no
free
liquids,
closed
container,
permitted
laundry
facility,
etc.).
Hazardous
waste
wipes
that
are
sent
for
disposal
are
subject
to
regulation.

West
Virginia
Industrial
wipes
contaminated
with
a
listed
hazardous
waste
or
that
exhibit
a
characteristic
are
subject
to
regulation
as
solid
wastes.
Industrial
wipes
are
viewed
as
spent
materials
and
as
such
are
solid
wastes
when
reclaimed.
47
IV.
Provisions
of
the
Proposed
Rule
This
section
of
the
Technical
Background
Document
is
designed
to
provide
supplemental
information
to
the
discussion
of
the
provisions
of
the
proposed
rule
available
in
the
Preamble.
All
the
provisions
and
conditions
are
outlined
here,
but
if
there
is
no
discussion
in
addition
to
what
is
in
the
Preamble,
the
appropriate
Preamble
section
is
simply
referenced
to
avoid
unnecessary
repetition.

IV.
A
Proposal
Summary
In
response
to
public
comment,
regulatory
interpretation
requests,
several
regulatory
petitions,
and
issues
raised
during
the
Printing
Sector
meetings
of
EPA's
Common
Sense
Initiative
(
CSI),
EPA
is
proposing
to
clarify
the
regulatory
status
of
solvent­
contaminated
industrial
wipes.
The
Agency
is
proposing
to
modify
the
RCRA
hazardous
waste
management
regulations
for
certain
solvent­
contaminated
materials,
including
reusable
shop
towels,
rags,
disposable
wipes,
and
paper
towels.
This
proposed
rule
would
encourage
resource
conservation
and
responsible
solvent
management
and
would
remove
potential
regulatory
impediments
to
solvent
recovery.
Specifically,
EPA
proposes
to
 
(
1)
Conditionally
exclude
from
the
definition
of
hazardous
waste
disposable
industrial
wipes
that
are
contaminated
with
hazardous
solvents
and
are
sent
for
disposal
to
a
municipal
or
other
non­
hazardous
waste
landfill
or
a
combustion
facility.

(
2)
Conditionally
exclude
from
the
definition
of
solid
waste
reusable
industrial
wipes
that
are
contaminated
with
hazardous
solvents
and
are
sent
for
laundering
or
dry
cleaning.

The
conditions
that
would
be
required
for
the
exclusions
are
discussed
later
in
this
section
of
the
technical
background
document.

The
proposed
rule
affects
contaminated
wipes
that
are
sent
to
both
landfills
and
nonlandfill
facilities
(
e.
g.,
laundries
and
combustion)
and
applies
to
(
1)
industrial
wipes
exhibiting
a
hazardous
waste
characteristic
(
i.
e.,
ignitability,
corrosivity,
reactivity,
or
toxicity)
due
to
use
with
solvents
and
(
2)
industrial
wipes
contaminated
with
F001­
F005
spent
solvents
or
comparable
Pand
U­
listed
commercial
chemical
products
that
have
been
spilled
and
cleaned
up.

IV.
B
Intent
of
the
Proposed
Rule
Current
federal
policy
enables
EPA
regional
officials
and
state
program
officials
to
make
case­
specific
interpretations
of
the
regulatory
status
of
solvent­
contaminated
industrial
wipes.
This
policy
has
resulted
in
some
states
and
regions
invoking
the
hazardous
waste
mixture
rule
or
the
contained­
in
policy
to
interpret
the
status
of
these
industrial
wipes.
However,
many
states
provide
a
conditional
exclusion
from
the
definition
of
solid
waste
for
reusable
wipes
that
are
managed
at
industrial
laundries
or
industrial
dry
cleaners.
Many
state
programs
provide
that
solvent­
contaminated
industrial
wipes
sent
off
site
to
be
managed
at
an
industrial
laundry
or
industrial
dry
cleaner
are
not
a
hazardous
waste
(
or
even
a
solid
waste
in
some
states)
as
long
as
the
wipes
do
not
contain
free
liquids
and
are
sent
to
a
facility
that
is
permitted
to
discharge
to
a
48
publicly
owned
treatment
works
(
POTW).

Through
this
proposed
rule,
EPA
aims
to
resolve,
at
the
federal
level,
some
long­
standing
issues
associated
with
the
management
of
solvent­
contaminated
industrial
wipes.
One
important
way
the
proposal
attempts
to
do
this
is
by
facilitating
pollution
prevention
and
waste
minimization,
including
the
recycling
of
spent
solvents
extracted
from
contaminated
industrial
wipes.
The
proposed
rule
also
 
(
5)
Fosters
improved
solvents
management
by
generators
and
handling
facilities;

(
6)
Reduces
compliance
costs
for
many
facilities
using
these
materials;

(
7)
Increases
consistency
in
the
regulations
governing
solvent­
contaminated
industrial
wipes
across
the
U.
S.
and
clarifies
existing
federal
rules
and
their
interpretations;

(
8)
Addresses
longstanding
industry
petitions
to
EPA;
and
(
9)
Creates
flexibility
for
generators
to
work
with
industrial
laundries,
as
appropriate,
to
ensure
compliance
with
local
pretreatment
standards
established
by
publicly
owned
treatment
works
(
POTWs).

This
rule
would
foster
pollution
prevention
and
waste
minimization
opportunities
by
encouraging
users
of
industrial
wipes
who
desire
less
stringent
management
requirements
to
use
alternative
solvents,
use
less
solvent,
or
remove
solvents
from
the
wipes
to
meet
the
"
no
free
liquids"
or
"
dry"
conditions,
as
discussed
later
in
this
section.
For
instance,
generators
who
want
to
dispose
wipes
containing
listed
solvents
or
wipes
exhibiting
a
hazardous
characteristic
in
a
landfill
must
either
use
alternative
solvents
or
reduce
the
amount
of
solvent
contained
in
the
wipe
to
a
dry
state.
Because
opportunities
exist
for
recycling
and
reusing
hazardous
solvents
contained
on
disposable
or
reusable
wipes,
in
many
instances,
advanced
solvent
extraction
and
recovery
technologies
can
result
in
opportunities
to
reduce
pollution
and
increase
profits
for
generators
and
handlers.
Pollution
prevention
opportunities
are
discussed
further
in
section
IV.
B.
1.

Industrial
wipes
are
a
versatile
product.
Thousands
of
facilities
use
hundreds
of
millions
of
wipes
containing
hazardous
solvents
every
year.
EPA
estimates
that
3.1
billion
wipes
containing
approximately
75,000
to
100,000
tons
of
solvent
are
used
annually.
This
rule
is
intended
to
foster
greater
understanding
of
the
regulations
and
improvements
in
management
of
solventcontaminated
wipes
by
generators
and
handling
facilities.

By
reducing
compliance
costs,
this
rule
would
also
provide
regulatory
relief.
In
some
situations,
current
federal
rules
appear
to
over­
regulate
these
materials,
such
as
when
very
small
amounts
of
hazardous
solvent
are
applied
to
industrial
wipes.
Therefore,
EPA
believes
an
alternative
regulatory
program
can
be
designed
specifically
for
these
materials
that
makes
more
sense
in
their
market
without
compromising
human
health
and
the
environment.

The
proposed
rule
clarifies
problems
with
existing
federal
rules
and
state
policies.
Current
rules
and
policies
associated
with
solvent­
contaminated
industrial
wipes
are
inconsistent
and
49
sometimes
result
in
mismanagement
of
these
materials.
For
instance,
some
regions
and
states
have
interpreted
RCRA
rules
to
say
that
solvent­
contaminated
reusable
industrial
wipes
are
not
solid
wastes
(
under
RCRA,
a
secondary
material
cannot
be
a
hazardous
waste
without
first
being
a
solid
waste).
As
a
result,
these
materials
are
not
subject
to
RCRA
regulation
at
all,
and
therefore
can
potentially
be
managed
in
ways
that
are
not
environmentally
sound.

Prior
to
initiating
a
proposed
rulemaking,
EPA's
Office
of
Solid
Waste
(
OSW)
conducted
screening
analyses
to
determine
the
potential
risks
to
human
health
and
the
environment
from
the
potential
mismanagement
of
solvent­
contaminated
industrial
wipes.
In
addition,
EPA
investigated
the
potential
number
of
facilities
that
may
be
impacted
by
any
regulatory
change
and
the
potential
changes
in
compliance
costs
that
may
be
associated
with
any
regulatory
modifications.
A
summary
of
the
results
of
the
risk
analysis
is
presented
in
section
5
of
this
technical
background
document
and
the
risk
report
and
the
economics
background
document
are
available
in
the
docket
for
this
proposal.
The
results
of
the
Agency's
investigation
into
risks
from
solvent­
contaminated
industrial
wipes
indicate
that
industrial
wipes
containing
some
F­
listed
solvents
may
pose
potential
risks
to
human
health
when
managed
in
an
unlined
landfill.
However,
the
Agency
found
that
other
types
of
F­
listed
solvents
may
pose
very
little
or
no
risk
if
disposed
in
small
quantities
in
municipal
solid
waste
landfills.

The
proposed
rule
would
allow
generators
more
flexibility
to
work
with
industrial
laundries,
as
appropriate,
to
ensure
compliance
with
local
pretreatment
standards
established
by
publicly
owned
treatment
works
(
POTWs).
EPA
concluded
that,
to
the
extent
isolated
problem
discharges
occur,
existing
pretreatment
authority
allows
local
POTWs
to
respond
to
problems
effectively.

Finally,
the
proposal
provides
a
tentative
response
to
petitions
filed
by
the
Kimberly­
Clark
Corporation
in
March
1985
and
Scott
Paper
Company
in
May
1987
regarding
the
application
of
the
federal
regulations
to
disposable
wipes
containing
hazardous
waste
solvents.

IV.
B.
1.
Pollution
Prevention
Facilities
using
hazardous
solvents
in
conjunction
with
disposable
or
reusable
wipes
can
use
various
industry
and
government
sources
to
assist
them
in
identifying
alternative
solvent
sources
that
are
effective
substitutes
with
no
risks
to
human
health
and
the
environment
(
see,
for
instance,
EPA's
Design
for
the
Environment
website:
<
www.
epa.
gov/
dfe>).
In
fact,
research
may
yield
alternatives
to
solvents
that
are
cheaper
to
purchase
than
the
original,
or
for
which
the
total
life­
cycle
management
of
the
alternative
solvent
is
cheaper
than
the
original
when
compliance
with
air,
water,
and
waste
regulations
is
factored
in.

Another
option
is
for
firms
using
hazardous
solvents
in
conjunction
with
industrial
wipes
to
evaluate
whether
particular
processes
can
be
modified
or
re­
engineered
to
eliminate
the
need
for
wiping
or
cleaning
operations.
Again,
various
resources
exist
for
companies
to
examine
the
possibility
of
eliminating
or
modifying
existing
operations
such
that
the
need
for
solvent
wipes
disappears.

EPA
noticed
at
a
few
site
visits
that
the
amount
of
solvent
applied
to
a
wipe
far
exceeded
7
Descriptions
of
companies
or
technologies
found
in
this
technical
background
document
are
for
descriptive
purposes
only
and
are
not
an
endorsement
of
the
products
themselves.

8Solvent­
contaminated
industrial
wipes
that
are
co­
contaminated
with
another
material
that
makes
them
characteristically
hazardous
for
corrosivity,
reactivity,
or
toxicity
would
not
be
eligible
for
the
exclusion
from
the
definition
of
hazardous
waste
or
the
exclusion
from
the
definition
of
solid
waste.
If
the
industrial
wipes
are
co­
contaminated
with
a
material
that
makes
them
characteristically
hazardous
for
ignitability,
they
would
remain
eligible.
For
more
discussion
of
this
provision,
see
Section
V.
B.
11
of
the
proposed
rule.

50
the
amount
of
solvent
actually
needed
to
perform
a
particular
cleaning
operation.
If
a
facility
must
use
a
hazardous
solvent,
potential
risks
to
human
health
and
the
environment,
as
well
as
potential
compliance
costs,
can
be
reduced
by
applying
less
solvent
and
possibly
reusing
the
wipe.
Both
approaches
reduce
solvent
usage
and,
therefore,
reduce
solvent
purchasing
costs
and
waste/
material
management
costs.
Firms
should
examine
their
solvent
use
practices
to
determine
if
less
solvent
and
fewer
industrial
wipes
can
be
used
to
perform
particular
cleaning
operations.

If
pollution
prevention
techniques
are
not
feasible,
generating
facilities
might
be
able
to
recycle
and
reuse
the
spent
solvent
contained
on
their
wipes
in
other
ways.
First,
several
existing
facilities
such
as
Brent
Industries,
and
Industrial
Towel
and
Uniform
can
clean
contaminated
or
soiled
wipes
and
recycle
the
solvent
extracted
or
distilled
from
their
cleaning
processes.
7
Brent
Industries
operates
a
distillation
process
that
can
produce
(
regenerate)
solvents
meeting
the
product
specifications
of
the
originating
companies.
Second,
integrated
industrial
wipe
cleaning/
solvent
recovery
technologies
can
be
installed
by
firms
such
as
Maratek.
Used
primarily
by
high­
volume
wipe­
generating
firms,
such
as
printers
and
newspapers,
solvent
recovery
technologies
can
yield
a
return
on
investment
within
two
years
for
some
firms
by
reducing
solvent
purchasing
and
waste
management
costs.
Another
solvent
recovery
technology
is
microwave,
where
the
solvent
is
dried
down,
captured
and
introduced
back
into
the
manufacturing
process.
Some
firms
have
the
flexibility
of
installing
their
process
on
site
or
adjacent
to
an
industrial
laundry
where
solvent
can
be
extracted
from
soiled
reusable
wipes,
regenerated,
and
returned
to
the
originating
company.
The
soiled
wipes
(
minus
the
solvent)
can
then
be
washed
and
returned
to
the
originating
company.

As
with
pollution
prevention,
economics
plays
an
important
part
in
determining
whether
to
recycle
the
solvent
or
maintain
current
operating
practices.
However,
if
a
facility
uses
a
large
number
of
wipes
and
applies
considerable
amounts
of
solvent
to
each
wipe,
it
is
likely
that
pollution
prevention
can
increase
profit
and
reduce
pollution,
particularly
if
the
cost
of
purchasing
the
solvent
is
considerable.

IV.
C.
Eligibility
for
Exclusions
To
be
eligible
for
the
proposed
exclusions,
a
facility
must
meet
a
number
of
conditions.
As
long
as
the
specified
conditions
are
met,
the
Agency
proposes
that
both
exclusions
apply
to
the
following:

(
1)
Industrial
wipes
exhibiting
a
hazardous
waste
characteristic
(
i.
e.,
ignitability,
corrosivity,
reactivity,
or
toxicity)
8
due
to
use
with
solvents;
and
51
(
2)
Industrial
wipes
contaminated
with
F001­
F005
spent
solvents
or
comparable
P­
and
Ulisted
commercial
chemical
products
that
are
spilled
and
cleaned
up.

This
proposal
would
not
affect
the
regulatory
status,
under
federal
regulations,
of
conditionally
exempt
small
quantity
generators
(
CESQGs)
 
those
that
generate
no
more
than
100
kilograms
of
hazardous
waste
or
no
more
than
one
kilogram
of
acutely
hazardous
waste
in
a
month
and
who
accumulate
no
more
than
1000
kilograms
of
hazardous
waste
or
no
more
than
one
kilogram
of
acutely
hazardous
waste
at
one
time.

EPA's
concern
surrounding
the
use
of
both
disposable
and
reusable
industrial
wipes
is
based
on
the
hazardous
solvent
contained
in
the
used
wipes,
not
the
industrial
wipes
themselves.
This
proposed
rule
would
not
apply
to
industrial
wipes
contaminated
with
solvents
that,
when
spent,
are
not
hazardous
wastes.
EPA
recommends
that
generators
examine
the
feasibility
of
substituting
non­
hazardous
solvents
for
hazardous
solvents
in
order
to
avoid
concerns
regarding
management
of
hazardous
waste.

IV.
D.
Proposed
Conditions
for
Exclusion
from
Definition
of
Hazardous
Waste
for
Disposable
Solvent­
Contaminated
Industrial
Wipes
IV.
D.
1.
Proposed
Conditions
for
Initial
Storage
and
Accumulation
Proposal
The
proposed
conditional
exclusion
from
the
definition
of
hazardous
waste
would
apply
to
solvent­
contaminated
disposable
industrial
wipes
at
the
point
when
the
wipes
are
discarded
by
the
generator.
If
the
wipes
are
managed
according
to
the
proposed
conditions,
they
will
not
be
considered
hazardous
waste.
EPA's
proposal
establishes
a
condition
for
the
on­
site
accumulation
and
storage
of
solvent­
contaminated
wipes
that
requires
the
use
of
non­
leaking,
covered
containers.
Generators
must
accumulate
and
store
solvent­
contaminated
wipes
in
covered
containers
that
do
not
allow
solvent
to
be
released
from
the
container.
The
container
must
not
leak
liquids
and
must
protect
against
fugitive
air
releases
of
solvents
when
not
in
use.
These
conditions
provide
flexibility
while
reducing
the
threat
of
fire
and
protecting
the
environment
and
health
and
safety
of
workers.

Discussion
Site
visits
conducted
by
EPA
in
1997
provided
evidence
that
both
open
and
closed
containers
are
used
for
the
accumulation
of
solvent­
contaminated
industrial
wipes.
The
most
common
management
practices
involved
the
use
of
a
wide
variety
of
containers,
ranging
from
approximately
five
gallons
in
size
(
e.
g.,
safety
cans)
to
55­
gallon
drums.
Some
sites
also
used
safety
cans
as
satellite
accumulation
units
from
which
the
wipes
were
later
transferred
to
a
centralized
accumulation
unit.
Many
facilities
stored
solvent­
contaminated
industrial
wipes
in
screen­
bottom
drums
to
reduce
the
amount
of
free
liquids
in
the
materials.
Some
facilities
also
used
plastic
bags
as
on­
site
accumulation
units.
The
performance­
based
condition
proposed
by
EPA
accommodates
the
needs
of
workers
constantly
needing
to
open
the
drum
and
provides
flexibility
by
allowing
generators
to
accumulate
solvent­
contaminated
industrial
wipes
in
any
of
52
these
containers
that
prevent
air
releases
when
not
being
used.
Under
the
proposed
rule,
generators
may
take
innovative
approaches
to
meet
the
performance
standard
being
sought
rather
than
being
required
to
use
a
specific
design.
A
performance
standard
also
provides
a
degree
of
flexibility
in
terms
of
allowing
different
approaches
that
minimize
the
length
of
time
required
for
workers
to
place
a
used
industrial
wipe
in
a
storage
container.
This
requirement
also
reflects
the
spirit
and
intention
of
OSHA
regulations.
Generators
who
already
meet
OSHA
container
standards
should
meet
the
proposed
requirement
for
the
safe
on­
site
storage
of
solventcontaminated
industrial
wipes.

Requiring
the
use
of
covered
containers
during
on­
site
accumulation
and
storage
of
solvent­
contaminated
wipes
should
significantly
reduce
any
health
and
safety
risks
associated
with
worker
exposure
to
vapors
through
volatilization
from
solvent­
contaminated
wipes.
Many
trade
associations
encourage
their
clients
to
use
covered
containers
for
the
on­
site
storage
of
solventcontaminated
industrial
wipes.
Similarly,
some
states
require
the
use
of
closed
containers
and
may
specify
more
stringent
container
management
standards.
In
the
case
of
disposable
solventcontaminated
industrial
wipes,
almost
all
states
currently
regulate
these
materials
as
hazardous
waste;
therefore,
containers
used
to
accumulate
these
wipes
at
generator
facilities
are
currently
subject
to
the
hazardous
waste
container
standards
in
40
CFR
part
265,
subpart
I.

Alternate
Option
 
Accumulation
Time
Limit
EPA
is
considering
including
a
condition
that
establishes
a
time
limit
for
accumulation
of
solvent­
contaminated
disposable
wipes
at
a
generator
facility,
so
they
cannot
be
kept
on
site
indefinitely
without
management.
This
condition
would
be
that
solvent­
contaminated
disposable
wipes
being
accumulated
at
the
generator
under
the
conditions
proposed
must
also
follow
the
accumulation
time
limits
in
40
CFR
262.34
that
are
applicable
for
their
generator
category
(
i.
e.,
90
days
for
large
quantity
generators
(
LQGs)
and
180
days
for
small
quantity
generators
(
SQGs)).
In
addition
to
following
the
time
limits
in
262.34,
generators
would
have
to
mark
any
container
in
which
solvent­
contaminated
disposable
industrial
wipes
were
being
accumulated
with
a
label
stating
that
it
holds
excluded
solvent
­
contaminated
wipes
and
stating
the
date
accumulation
started.
Although
this
option
would
require
generators
to
follow
the
appropriate
time
limit
for
their
generator
size,
because
the
industrial
wipes
are
excluded
from
the
definition
of
hazardous
waste
from
the
point
of
generation,
they
would
not
have
to
be
added
to
the
generators
counting
of
hazardous
waste.
In
other
words,
generating
solvent­
contaminated
wipes
under
the
conditions
of
the
proposal
would
not
cause
a
facility
to
move
from
being
an
SQG
to
being
an
LQG.

Alternate
Option
­
No
RCRA­
Specific
Condition
The
Agency
also
is
considering
not
establishing
a
specific
accumulation
condition
under
RCRA,
but
relying
on
other
regulatory
statutes,
like
the
Occupational
Safety
and
Health
Act
(
OSHA).

OSHA's
occupational
health
and
safety
standards,
found
under
29
CFR
part
1910,
provide
both
general
and
specific
requirements
for
the
storage
of
hazardous
materials
in
the
workplace.
The
following
discussion
provides
an
overview
of
OSHA
regulations
and
the
applicability
of
each
53
regulation
to
solvent­
contaminated
wipes.

OSHA's
Hazard
Communication
Standard,
29
CFR
1910.1200
OSHA's
Hazard
Communication
Standard
(
HCS)
was
promulgated
to
ensure
that
pertinent
information
regarding
the
risks
from
hazardous
materials
in
the
workplace
is
conveyed
to
the
workers
whose
responsibility
it
is
to
handle
or
come
in
contact
with
these
hazardous
materials.
29
CFR
1910.1200(
d)(
1)
requires
"
chemical
manufacturers
and
importers
to
evaluate
chemicals
produced
in
their
workplaces
or
imported
by
them
to
determine
if
they
are
hazardous.
Employers
are
not
required
to
evaluate
chemicals
unless
they
choose
not
to
rely
on
the
evaluation
performed
by
the
chemical
manufacturer
or
importer
for
the
chemical
to
satisfy
this
requirement."
Similarly,
29
CFR
1910.1200(
d)(
2)
states
that
"
chemical
manufacturers,
importers
or
employers
evaluating
chemicals
shall
identify
and
consider
the
available
scientific
evidence
concerning
such
hazards."

29
CFR
1910.1200(
e)(
1)
requires
employers
to
develop,
implement,
and
maintain
a
written
hazard
communication
program
at
each
workplace.
The
program,
at
a
minimum,
must
describe
how
the
criteria
associated
with
labeling,
Material
Safety
Data
Sheets
(
MSDSs),
and
employee
information
and
training
shall
be
met.
The
premise
of
this
regulation
is
that
workers
who
understand
the
hazards
associated
with
a
material
will
be
more
likely
to
handle
the
material
in
a
safe
manner.

Each
chemical
product
used
in
a
facility,
whether
it
is
hazardous
or
contains
hazardous
chemicals,
has
an
MSDS
associated
with
it.
MSDSs
give
detailed
information
about
products,
chemicals
in
the
products,
hazards,
and
handling
specifications.
Chemicals
must
be
handled
in
accordance
with
MSDS
information,
and
under
the
HCS,
employees
are
required
to
be
educated
about
the
MSDS
information.
MSDSs
may
require
that
particular
chemicals
or
products
be
stored
in
closed
containers
and/
or
stored
in
a
cool
place.
Almost
all
solvents
that
are
RCRA
listed
or
characteristic
hazardous
wastes
when
they
are
spent
would
probably
require
an
MSDS.

All
facilities
that
use
hazardous
chemicals
are
required
to
conduct
employee
hazard
training.
The
comprehensive
hazard
communication
programs
disseminate
any
health
or
physical
hazard
information
associated
with
chemicals
and
products
used
at
the
facility.
These
programs
also
include
information
about
container
labeling
requirements,
MSDSs,
and
other
employee
safety
training.
According
to
the
OSHA
interpretation
of
the
HCS
regulations,
all
containers
of
hazardous
chemicals
in
the
workplace
must
be
labeled
either
as
hazardous
or
with
a
description
of
the
specific
contents
of
the
container.

OSHA
Permissible
Exposure
Limit
Regulations
OSHA
regulations
under
29
CFR
1910
subpart
Z
support
and
reinforce
the
HCS.
These
regulations
address
exposure
to
numerous
chemicals
that
pose
unacceptable
health
risks
to
workers
(
usually
based
on
an
8­
hour
shift
in
a
40­
hour
work
week).
OSHA
currently
has
470
permissible
exposure
limits
for
various
forms
of
approximately
300
chemical
substances.
Facilities
managing
solvent­
contaminated
industrial
wipes
may
be
subject
to
these
requirements
and
exposure
limits.
9
Flammable
liquids
are
defined
as
any
liquids
having
a
flash
point
below
100
°
F
(
37.8
°
C).

10
Combustible
liquids
are
any
liquids
having
a
flash
point
at
or
above
100
°
F
(
37.8
°
C).

11
Discussion
with
Mr.
Matt
Stein
of
OSHA's
Hotline
on
January
22,
2002.

54
OSHA
29
CFR
1910.106
­
Management
Standards
for
Flammable
and
Combustible
Liquids
29
CFR
1910.106
requires
the
proper
management
and
storage
of
flammable9
and
combustible10
liquids
in
the
workplace.
The
requirements
for
flammable
and
combustible
liquids
are
based
on
the
National
Fire
Protection
Association's
Flammable
and
Combustible
Liquids
Code
­
NFPA
30.

According
to
OSHA
standards,
flammable
liquids
must
be
stored
in
approved
containers
which
meet
the
requirements
of
29
CFR
1910.106(
d).
Metal
containers
and
portable
tanks
meeting
Department
of
Transportation
standards
(
see
49
CFR
part
173
and
178)
are
acceptable.
Section
§
1910.106
also
specifies
standards
for
the
areas
where
containers
holding
flammable
liquids
will
be
stored,
including
requirements
for
storage
cabinets,
rooms,
buildings,
storage
outside
of
buildings,
and
industrial
plants.
11
However,
the
management
of
solvent­
contaminated
wipes
is
most
likely
subject
to
container
regulations
under
29
CFR
1910.106(
e)(
9)(
iii),
which
state
that
"
combustible
waste
material
and
residues
in
a
building
or
unit
operating
area
shall
be
kept
to
a
minimum,
stored
in
covered
metal
receptacles
and
disposed
of
daily."

Industry­
Specific
OSHA
Standards
OSHA
also
has
developed
specific
industry
regulations
for
the
protection
of
worker
health
and
safety.
For
example,
29
CFR
part
1926
provides
health
and
safety
standards
for
construction.
The
standards
apply
to
activities
associated
with
"
construction,
alteration,
and/
or
repair,
including
painting
and
decorating."
OSHA
mandates
that,
when
disposing
of
waste
materials,
"
all
solvent
waste,
oily
rags,
and
flammable
liquids
shall
be
kept
in
fire­
resistant,
covered
containers
until
removed
from
the
worksite."

Similarly,
29
CFR
part
1915
provides
Occupational
Safety
and
Health
Standards
for
Shipyard
Employment.
subpart
F
regulates
General
Working
Conditions
and,
specifically,
"
Housekeeping."
These
standards
mandate
that
for
ship
repairing
and
shipbuilding,
"
all
oils,
paint
thinners,
solvents,
waste,
rags,
or
other
flammable
substances
shall
be
kept
in
fire­
resistant,
covered
containers
when
not
in
use."

Finally,
OSHA
Section
4(
b)(
1)
defers
to
other
statutes
the
storage
and
management
of
hazardous
materials
or
hazardous
waste
when
regulations
are
in
place.
Thus,
DOT
and
RCRA
regulations
supersede
OSHA
regulations,
where
applicable.

EPA
believes
there
may
be
gaps
in
coverage
if
the
proposed
regulation
were
to
rely
strictly
on
the
OSHA
regulations.
For
example,
the
OSHA
container
standards
may
not
apply
to
contaminated
wipes
with
no
free­
flowing
liquids
or
when
wipes
are
contaminated
with
solvents
55
that
would
be
RCRA
hazardous
but
not
meet
the
OSHA
definition
of
flammable
or
combustible.
Many
facilities
either
generating
or
handling
solvent­
contaminated
wipes
should
already
be
subject
to
these
standards
and,
as
a
result,
deferring
to
OSHA
standards
would
be
simple.
For
them,
however,
the
OSHA
regulations
might
mandate
that
containers
be
sealed,
removing
some
of
the
flexibility
of
EPA's
proposal.

IV.
D.
2.
Proposed
Conditions
for
Containers
Used
for
Transportation
EPA
is
proposing
a
container
condition
for
generators
who
transport
solventcontaminated
industrial
wipes
off
site
under
the
conditional
exclusion.
This
condition
will
ensure
that
transporting
the
wipes
without
full
RCRA
hazardous
waste
requirements
will
still
protect
against
risks
posed
by
these
materials
to
human
health
and
the
environment.
Under
this
proposal,
generators
must
transport
industrial
wipes
in
containers
that
are
designed,
constructed
and
managed
to
minimize
loss
to
the
environment.
In
proposing
this
condition,
EPA
envisions
containers
that
do
not
leak
liquids
and
that
provide
for
control
of
air
emissions.

EPA
would
consider
hazardous
solvents
that
are
spilled
or
leaked
during
transportation
to
be
disposed.
Therefore,
the
party
managing
the
industrial
wipes
at
the
time
the
spill
occurred
would
be
responsible
for
cleaning
up
the
spill
and
managing
those
materials
appropriately.

Discussion
This
condition
is
designed
to
minimize
loss
of
solvent
to
the
environment
during
transportation
and,
therefore,
to
minimize
environmental
risk
as
well.
Minimizing
loss
through
evaporation
or
leakage
also
makes
it
more
likely
that
larger
quantities
of
solvent
will
be
recycled
or
otherwise
properly
managed.
This
provision,
implementation
questions,
and
other
options
are
discussed
in
the
preamble
to
this
proposal.

IV.
D.
3
Proposed
Labeling
Condition
for
Containers
Used
to
Transport
Disposable
Wipes
Proposal
EPA
is
proposing
a
labeling
requirement
that
would
require
the
use
of
specific
language
or
a
pre­
made
label,
such
as
"
Excluded
Solvent­
Contaminated
Wipes,"
to
be
applied
to
each
container
used
to
accumulate
and/
or
store
solvent­
contaminated
industrial
wipes,
unless
the
wipes
are
being
recycled.
This
type
of
requirement
is
comparable
to
the
used
oil
labeling
requirement
in
40
CFR
part
279.

Discussion
56
A
label
also
informs
workers
of
what
materials
they
are
handling,
so
that
they
can
use
proper
handling
procedures.
To
accomplish
this
at
the
point
of
generation,
during
transport,
and
during
management,
the
container
in
which
the
wipes
are
placed
and
transported
should
be
labeled.
In
addition
to
accumulation
at
the
point
of
use,
wipes
may
also
come
in
contact
with
other
containers
at
the
generator
location
or
in
subsequent
handling,
on
site
or
off
site.
Labeling
containers
helps
ensure
that
the
materials
inside
can
be
easily
identified
and,
therefore,
managed
properly.

This
option
provides
a
simple
solution
to
labeling
while
allowing
generators
to
indicate
that
the
condition
is
met.
It
would
allow
handlers
to
differentiate
between
regulated
and
excluded
industrial
wipes
and
handle
them
accordingly.
However,
the
"
excluded"
designation
added
to
the
containers
raises
a
question
of
whether
a
hazardous
waste
stigma
would
remain
attached
to
the
industrial
wipes,
regardless
of
their
status,
and
still
render
them
subject
to
more
expensive
waste
management
and
handling
after
they
leave
the
generator
site.

Alternate
Option
­
No
RCRA­
Specific
Labeling
Condition
Another
option
EPA
is
considering
is
not
to
impose
a
specific
labeling
requirement.
Under
this
approach,
designation
of
the
disposable
industrial
wipes
as
hazardous
materials
under
DOT
regulations
might
still
require
placarding
or
other
marking
for
transportation
of
some
fraction
of
these
materials,
as
described
previously.
However,
for
the
reasons
explained
above,
we
do
not
expect
that
the
DOT
provisions
would
apply
to
all
solvent­
contaminated
industrial
wipes
covered
by
the
proposal.
This
option
is
simple
to
implement
and
easy
for
generators
to
understand
because
it
follows
current
labeling
requirements
without
introducing
a
new
designation
for
the
wastes.
Once
the
contaminated
materials
meet
the
performance
standards
and
the
materials
are
excluded
from
regulation
as
a
hazardous
waste,
RCRA
labeling
requirements
would
no
longer
apply.

Existing
regulatory
programs
administered
by
DOT
and
OSHA
already
prescribe
labeling
requirements
for
container
storage
and
transportation.
Title
40
CFR
(
Environmental
Protection)
parts
260­
264,
Title
49
(
Transportation)
parts
171­
173,
and
Title
29
(
Labor)
section
1910.1200
all
contain
regulations
pertaining
to
management
of
hazardous
materials,
including
labeling
requirements.
Most
of
the
labeling
requirements
(
e.
g.,
40
CFR
262.31)
relate
to
conditions
for
hazardous
waste
transportation
and
many
refer
to
the
DOT
regulations
found
in
49
CFR
172,
which
require
marking
(
written
information
that
varies
depending
on
the
characteristics
of
the
waste),
labeling
(
where
the
specific
wording
and/
or
label
is
provided)
and
placarding
(
where
specific
placards
are
used
on
the
outside
of
vehicles).

The
OSHA
standards
in
29
CFR
1910.1200
require
containers
in
the
workplace
to
be
marked
with
the
identity
of
the
hazardous
chemicals
contained
within
and
appropriate
hazard
warnings
that
clearly
convey
the
risks
that
the
chemicals
pose
before
the
containers
are
offered
for
transport.
Some
states
also
require
that
containers
with
solvent­
contaminated
wipes
be
marked
with
the
date
of
the
beginning
of
accumulation.
In
addition,
OSHA
standards
state
that
"
Unlabeled
drums
and
containers
shall
be
considered
to
contain
hazardous
substances
and
handled
12For
the
purposes
of
this
proposal,
EPA
uses
the
term
other
non­
hazardous
landfill
to
denote
part
257
subpart
B
compliant
non­
hazardous
waste
landfills.
If
a
non­
hazardous
landfill
that
is
not
a
municipal
landfill
accepts
this
waste,
it
must
meet
the
minimum
standards
of
40
CFR
part
257
subpart
B.

57
accordingly
until
the
contents
are
positively
identified
and
labeled"
(
29
CFR
1910.1200(
j)(
1)(
ii)).

EPA
could
emphasize
this
regulation
in
its
proposed
rulemaking,
which
would
avoid
the
establishment
of
duplicative
regulations.
On
the
other
hand,
DOT's
regulations
for
all
non­
bulk
hazardous
materials
being
transported
require
the
following:


A
generator
who
offers
hazardous
waste
for
transportation
must
mark
each
package,
freight
container,
and
transport
vehicle
in
a
specific
manner.
Many
pre­
made
stickers
and
placards
describe
the
dangerous
characteristics
of
hazardous
materials.
The
labels
must
be
displayed
prominently
and
clearly,
and
to
the
specifications
laid
out
for
each
container
or
vehicle
in
49
CFR
172.


The
proper
shipping
and
ID
number
must
be
included
with
each
package
for
the
hazardous
material
being
transported
as
shown
in
the
table
in
49
CFR
172.101.
If
more
than
one
hazardous
substance
is
being
carried
in
the
same
package,
at
least
two
materials,
those
with
the
lowest
reportable
quantities,
must
be
identified.
Technical
names
of
the
hazardous
materials
must
be
included.


Exempt
packages
must
be
marked
"
DOT­
E,"
along
with
the
assigned
exemption
number.


The
cosigner
or
cosignee's
name
and
address
must
be
marked
on
the
package,
except
for
in
certain
circumstances
(
see
49
CFR
172.301(
d)).


A
generator
must
mark
each
hazardous
waste
container
of
110
gallons
or
less
with
a
warning,
the
generator's
name
and
address,
and
the
manifest
number
before
transport
off
site.

°
All
vehicles
transporting
hazardous
materials,
except
those
materials
classified
as
"
Other
Regulated
Materials,"
must
have
placards
in
specified
places
in
accordance
with
the
characteristics
of
the
transported
hazardous
wastes.
A
vehicle
used
to
transport
two
or
more
hazardous
materials
that
require
different
placards
may
instead
use
a
DANGEROUS
placard,
so
long
as
a
total
of
less
than
2,268
kg
(
5,000
lbs.)
of
hazardous
material
is
carried.
Vehicles
carrying
less
than
454
kg
(
1,000
lbs.)
aggregate
gross
weight
of
hazardous
materials
are
not
required
to
have
a
placard.

IV.
D.
4.
Proposed
Condition
for
Transportation
to
a
Municipal
or
Other
Non­
Hazardous
Landfill
Proposal
This
proposed
rule
allows
solvent­
contaminated
wipes
to
be
disposed
in
a
municipal
subtitle
D
landfill
or
other
non­
hazardous
waste
landfill12
if
they
meet
a
condition
for
being
"
dry,"
meaning
that
each
wipe
contains
less
than
5
grams
of
solvent.
Because
of
the
risks
of
certain
58
Benzene*
2­
Nitropropane
Carbon
tetrachloride*
Nitrobenzene*
Chlorobenzene*
Pyridine*
Cresols
(
o,
m,
p)*
Tetrachloroethylene*
Methyl
ethyl
ketone
(
MEK)*
Methylene
chloride
Trichloroethylene*

Ethyl
Ether
Acetone
Methanol
Butanol
Toluene
Carbon
Disulfide
Xylenes
Cyclohexanone
2­
Ethoxyethanol
Ethyl
benzene
Isobutyl
Alcohol
Ethyl
Acetate
Trichlorofluoromethane
Methyl
Isobutyl
Ketone
Dichlorodifluoromethane
1,2­
Dichlorobenzene
1,1,2­
Trichlorotrifluoroethane
1,1,1­
Trichloroethane
1,1,2­
Trichloroethane
highly
toxic
F­
listed
solvents,
however,
EPA
is
proposing
to
make
11
F­
listed
solvents
ineligible
for
this
option,
meaning
that
wipes
containing
these
constituents
cannot
be
disposed
in
a
municipal
landfill
even
if
they
meet
the
"
dry"
condition.
Because
of
these
concerns,
EPA
is
proposing
that
industrial
wipes
that
are
contaminated
with
the
F­
listed
solvents
specified
in
Table
8
cannot
be
disposed
in
municipal
or
other
non­
hazardous
waste
landfills.

Table
8
F­
Listed
Solvents
That
May
Not
Be
Disposed
in
Municipal
or
Other
Non­
Hazardous
Waste
Landfills
*
Solvent
meets
the
toxicity
characteristic.

Table
9
contains
the
19
F­
listed
solvents
that
were
evaluated
in
EPA's
risk
screening
analysis
and
that
would
be
allowed,
under
this
proposal,
to
be
disposed
in
a
municipal
or
nonhazardous
waste
landfill
if
they
meet
the
"
dry"
condition.
See
section
5
for
additional
details
on
the
results
of
EPA's
risk
screening
analysis.

Table
9
F­
listed
Solvents
That
May
Be
Disposed
in
a
Municipal
or
Other
Non­
Hazardous
Waste
Landfill
Discussion
In
developing
this
option,
EPA
realized
that
the
hazardous
constituents
present
in
F­
listed
solvents
each
have
different
toxic
effects,
as
detailed
in
the
risk
screening
analysis
presented
in
Section
5
of
this
technical
background
document.
This
risk
screening
suggests
to
EPA
that
materials
contaminated
with
certain
solvents
can
be
disposed
safely
in
municipal
landfills,
that
additional
caution
is
required
for
others,
and
that
a
third
category
of
contaminants
is
sufficiently
toxic
that
solvents
containing
them
should
be
ineligible
for
disposal
in
municipal
landfills.
59
The
results
of
the
risk­
screening
analysis
suggest
that
situations
exist
where
disposable
wipes
contaminated
with
some
F­
listed
hazardous
waste
solvents
could
be
managed
in
a
municipal
solid
waste
or
other
non­
hazardous
waste
landfill
without
posing
a
risk
to
human
health,
particularly
if
some
level
of
solvent
removal
is
achieved
prior
to
disposal.
However,
other
F­
listed
solvents
used
in
conjunction
with
disposables
(
see
Table
8)
pose
potential
health
risks
even
in
small
amounts.
EPA
has
tentatively
concluded
that
the
solvents
listed
in
Table
8
may
pose
an
unacceptable
risk
to
human
health
and
the
environment
when
disposed
in
such
landfills.

Nine
of
the
solvents
in
Table
8
are
toxicity
characteristic
constituents,
as
defined
in
40
CFR
261.24.
EPA's
analysis
finds
that
the
levels
of
these
solvents
in
contaminated
industrial
wipes,
even
when
they
have
been
through
solvent
extraction
and
contain
less
than
five
grams
of
solvent
per
wipe,
are
likely
to
be
higher
than
the
regulatory
levels
indicated
in
40
CFR
261.24.
Therefore,
these
TC
solvents
are
ineligible
for
disposal
in
municipal
and
other
non­
hazardous
waste
landfills
because
of
their
potential
risk,
as
determined
when
they
were
originally
identified
by
EPA
as
TC
wastes.
Six
of
these
nine
are
ineligible
just
due
to
their
status
as
TC
wastes.
The
other
three
(
methyl
ethyl
ketone,
nitrobenzene,
and
pyridine),
in
addition
to
being
TC,
triggered
an
ineligible
rating
on
EPA's
risk
screening
analysis.
If
land­
disposed,
industrial
wipes
contaminated
with
these
11
solvents
would
have
to
continue
to
be
managed
in
full
compliance
with
RCRA
subtitle
C
hazardous
waste
management
standards,
including
the
land
disposal
restrictions.

EPA
is
proposing
that
disposable
wipes
contaminated
with
F­
listed
solvents
other
than
those
in
Table
8
can
be
managed
in
municipal
solid
waste
landfills
once
the
wipes
meet
the
"
dry"
condition.
However,
if
the
wipe
is
contaminated
by
a
listed
hazardous
waste
other
than
F001
through
F005,
the
wipe
cannot
be
disposed
in
a
non­
hazardous
waste
landfill.
EPA
is
limiting
the
exclusion
because
insufficient
data
exists
at
this
time
to
show
that
wipes
contaminated
with
such
materials
would
not
pose
a
significant
threat
to
human
health
and
the
environment
if
managed
in
a
municipal
solid
waste
landfill.

"
Dry"
Condition
Generators
transporting
their
disposable
industrial
wipes
to
a
municipal
or
other
nonhazardous
waste
landfill
must
ensure
that
the
wipes
are
dry.
For
purposes
of
this
proposed
rule,
an
industrial
wipe
is
considered
"
dry"
when
it
contains
less
than
five
grams
of
solvent.
EPA
chose
five
grams
because
it
falls
within
the
range
found
in
our
risk
screening
analysis
to
be
protective
of
human
health
and
the
environment.
Five
grams
is
also
within
the
range
of
what
is
achievable
through
use
of
advanced
solvent­
extraction
processes.
Generators
can
meet
this
condition
either
by
using
less
than
five
grams
of
solvent
on
each
wipe
or
by
putting
used
industrial
wipes
through
a
solvent
extraction
process
capable
of
removing
sufficient
solvent
to
meet
the
5­
gram
condition.

EPA
considered
requiring
centrifuging
as
the
only
method
to
meet
the
dry
condition.
However,
EPA
was
concerned
that
simply
requiring
centrifuging
could
allow
poorly
operated
or
poorly
constructed
units
to
be
used
to
meet
the
requirements.
EPA's
data
on
centrifuges
indicates
that,
in
general,
they
allow
for
high
solvent
extraction.
EPA
has
analyzed
data
demonstrating
removal
efficiencies
for
hand
wringing,
mechanical
wringing,
screen
bottom
drums,
and
centrifuging.
Centrifuging
was
found
to
remove
the
greatest
quantity
of
solvent.
EPA's
13
Descriptions
of
these
technologies
in
the
Technical
Background
document
are
for
descriptive
purposes
only
and
is
not
an
endorsement
of
the
products
themselves.

60
demonstration
data
showed
that
a
properly
operated
centrifuge
results
in
removal
efficiencies
of
76
to
99
percent.
This
is
much
more
efficient
than
the
next­
most
efficient
technology
tested
by
EPA,
mechanical
wringing,
where
removal
efficiency
seldom
exceeded
30
percent.
However,
EPA
only
observed
centrifuges
in
use
in
the
printing
industry,
with
only
a
small
percentage
of
generators
using
the
technology.
Additionally,
although
centrifuging
is
reported
to
be
used
for
both
launderable
and
disposable
wipes,
EPA
lacks
specific
data
on
all
of
the
types
of
disposable
wipes
that
could
be
used
by
industry.
However,
based
on
site
visits,
EPA
is
confident
that
a
welloperated
centrifuge
will
meet
the
5­
gram
condition
in
this
proposal.

The
Agency
also
recognized
that
there
may
be
other
high­
efficiency
solvent
removal
technologies
currently
on
the
market
or
under
development
that
could
achieve
removal
efficiencies
similar
to
or
better
than
centrifuging.
The
Agency
wants
to
provide
generators
with
flexibility
to
employ
effective
technologies
and
is
proposing
to
allow
the
use
of
other
technologies
that
can
achieve
high
rates
of
solvent
removal.
Generators
who
do
any
of
the
following
will
be
considered
to
have
met
the
"
dry"
condition:

°
Remove
excess
solvents
by
centrifuging
or
other
high­
performance
solvent
extraction
or
removal
technology,
for
example,
microwave
solvent
recovery
processes
or
the
Petro­
Miser
or
Fierro
processes;
13
°
Use
normal
business
records,
such
as
the
amount
of
solvent
used
per
month
for
wiping
operations
divided
by
the
number
of
wipes
used
per
month
for
solvent
wiping
operations,
to
show
they
are
under
the
threshold;

°
Conduct
sampling
to
measure
the
amount
of
solvent
applied
per
wipe
before
use;
or
°
Sample
to
measure
the
amount
of
solvent
remaining
on
wipes
when
use
is
completed.

Testing
and
extraction
technologies
are
described
in
greater
detail
in
Section
IV.
F.
5,
in
discussion
of
the
free
liquids
condition.

IV.
D.
5.
Proposed
Condition
for
Transportation
to
Non­
Land
Disposal
Facilities
Proposal
EPA
is
proposing
a
"
no
free
liquids"
condition
for
solvent­
contaminated
industrial
wipes
sent
for
disposal
at
a
non­
land
disposal
unit
such
as
a
municipal
waste
combustor
(
MWC)
or
other
combustion
unit,
including
use
as
a
fuel.
This
condition
would
also
apply
to
solvent­
contaminated
industrial
wipes
sent
to
an
intermediate
handler
for
further
processing
to
meet
the
"
dry"
condition
before
disposal
in
a
municipal
or
other
non­
hazardous
waste
landfill.
This
condition
is
meant
to
minimize
the
likelihood
of
solvent
loss
into
the
environment,
as
well
as
to
encourage
solvent
recovery
and
pollution
prevention
by
generators.
61
To
meet
the
"
no
free
liquids"
condition,
no
liquid
solvent
may
drip
from
the
wipes
before
they
are
sent
off
site
or
while
they
are
in
transit
to
a
handler
or
disposal
site
and
there
may
be
no
free
liquids
in
the
drum.
In
this
proposal,
EPA
intends
for
compliance
with
the
"
no
free
liquids"
condition
to
be
determined
by
a
practical
test.
That
is,
does
liquid
drip
from
a
wipe
when
it
is
held
for
a
short
period
of
time
(
e.
g.,
when
being
transferred
from
one
container
to
another)?
This
and
other
tests
are
described
in
detail
below.

The
proposed
rule
contains
the
provision
that,
if
free
liquids
are
discovered
at
the
handling/
combustion
facility,
the
solvent­
contaminated
wipes
would
remain
excluded
from
the
definition
of
hazardous
waste
as
long
as
the
handler
either
removes
the
solvent
and
manages
it
properly
or
returns
the
shipment
to
the
generator
as
soon
as
reasonably
practicable,
as
described
in
Section
V.
B.
10.
a.
of
the
preamble.

Note
that
handlers
would
be
required
to
determine
whether
the
solvent
which
has
been
removed
from
the
industrial
wipes
is
listed
as
a
hazardous
waste
or
exhibits
a
characteristic
as
defined
in
40
CFR
part
261.
Any
hazardous
waste
solvent
removed
from
the
wipes
would
have
to
be
managed
in
accordance
with
hazardous
waste
requirements
found
at
40
CFR
parts
260­
268
and
40
CFR
part
270.
However,
for
purposes
of
this
proposed
regulation,
techniques
or
technologies
used
by
generators
to
remove
solvent
from
the
wipes
would
not
be
considered
treatment
and
would
not
be
subject
to
permitting.

Discussion
One
concern
certain
stakeholders
have
expressed
with
this
proposed
condition
is
that
once
in
a
container,
either
at
the
generator
site
or
in
transit,
industrial
wipes
can
compress
and
solvent
can
percolate
through
them,
collecting
at
the
bottom
of
a
container.
This
means
that,
while
there
may
not
have
been
free
liquids
in
the
container
at
the
generator
site,
some
may
be
generated
during
transportation.
EPA
acknowledges
that
compression
can
result
in
free
liquids
percolating
to
the
bottom
of
a
container.

Determining
Whether
the
"
No
Free
Liquids"
Condition
Has
Been
Met
Under
the
option
proposed,
the
"
no
free
liquids
"
condition
can
be
met
by
employing
any
of
the
following
practices:
hand­
wringing;
use
of
a
properly
operated
screen­
bottom
drum;
mechanical
wringing;
centrifuging;
use
of
an
enclosed,
controlled
air
dryer
with
exhaust
vents
to
recycle
the
recovered
solvent;
solvent
removal
and/
or
recycling
using
low­
pressure
evaporation;
microwave
or
elevated­
temperature
technology;
combinations
of
these
techniques/
technologies;
or
any
technology
or
process
that
assures
free
liquids
will
not
be
released
from
the
wipes
or
released
into
the
environment
during
the
process.
These
technologies
are
more
thoroughly
described
below.
In
addition,
generators
who
know,
in
their
best
professional
judgement,
that
their
processes
do
not
use
enough
solvent
per
wipe
to
produce
free
liquids
can
rely
on
that
knowledge.
The
use
of
air
drying
to
pass
the
test
is
not
allowed.
If
alternative
technologies
are
used,
the
generator
is
responsible
for
determining
that
no
solvent
drips
from
the
wipe
and
that
containers
do
not
have
free
liquids
in
them,
as
described
above.

This
option
will
allow
generators
to
select
the
most
appropriate
solvent
removal
62
technology
for
their
particular
solvent­
contaminated
industrial
wipes.
Generators
would
be
able
to
demonstrate
that
their
solvent­
contaminated
wipes
do
not
contain
free
liquids
through
 
°
Physical
examination
of
wipes
stored
in
containers
prior
to
being
sent
off
site;

°
Examination
of
on­
site
technologies;
or
°
Inspection
of
contractual
agreements
with
outside
parties
who
travel
to
work
sites
and
use
solvent­
extraction
technologies
on
wipes.

Promulgation
of
this
option
is
consistent
with
existing
state
guidance,
which
often
requires
generators
to
ensure
that
shipments
of
solvent­
contaminated
wipes
do
not
contain
free
liquids,
although
some
states
require
the
use
of
the
Paint
Filter
Liquids
Test
(
SW­
846
Method
9095)
or
other
state­
developed
tests.

Existing
Tests
for
Determining
"
No
Free
Liquids"

RCRA
regulations
include
a
number
of
definitions
which
rely
on
the
term
"
liquid."
One
definition
is
set
forth
within
the
context
of
the
hazardous
waste
identification
criteria
of
40
CFR
part
261.
In
using
the
Toxicity
Characteristic
Leaching
Procedure
(
TCLP)(
Method
1311),
generators
can
determine
whether
their
waste
is
a
"
liquid"
by
evaluating
certain
results
of
SW­
846
Method
1310.
"
Liquid"
refers
to
the
portion
of
the
waste
sample
that
is
expressed
from
the
waste.
If
the
solid
residue
obtained
after
the
separation
step
is
less
than
0.5
percent
of
the
original
weight
of
the
sample,
then
the
generator
must
treat
the
liquid
portion
of
the
waste
as
the
extract.
Under
40
CFR
258.28,
wastes
are
prohibited
from
disposal
in
a
municipal
solid
waste
landfill
if
the
waste
contains
free
liquids.
40
CFR
Section
258.28
directs
generators
to
use
the
Paint
Filter
Liquids
Test
to
determine
whether
a
waste
contains
free
liquids.
RCRA
also
prohibits
the
placement
of
hazardous
wastes
containing
free
liquids
in
a
hazardous
waste
landfill
and
prohibits
the
use
of
sorbents
to
solidify
a
liquid
waste
if
the
solidified
waste
releases
the
contained
liquids
under
landfill
pressures.
40
CFR
Sections
264.314
and
265.314
require
the
use
of
the
Paint
Filter
Liquids
Test
as
the
determinative
method
for
releasable
liquids.

With
respect
to
reusable
wipes,
the
states
have
different
policies
on
what
constitutes
no
free
liquids;
however,
the
majority
of
states
require
the
Paint
Filter
Liquids
Test
for
such
determinations.
Other
specified
methods
include
the
Liquids
Release
Test
(
SW­
846
Method
9069)
and
the
TCLP.
The
following
sections
describe
these
analytical
tests
for
determining
"
no
free
liquids,"
and
provide
some
discussion
on
the
applicability
of
these
tests
to
solvent­
contaminated
wipes.

Physical
Examination
The
simplest
technique
that
many
facilities
use
is
to
examine
a
sample
of
wipes
stored
in
the
bottom
of
the
container
immediately
prior
to
subsequent
handling
 
either
on
site
or
off
site.
If
the
amount
of
solvent
applied
to
the
wipe
is
small
(
five
to
ten
grams),
then
there
is
a
very
good
chance
that
no
free
liquids
will
be
present
on
the
wipe
or
in
the
container.
Therefore,
generators
using
small
amounts
of
solvent
can
check
their
compliance
with
physical
examination
of
their
63
wipes.

Paint
Filter
Liquids
Test
The
Paint
Filter
Liquids
Test,
SW­
846
Method
9095,
is
a
laboratory
method
used
to
determine
the
presence
of
free
liquids
in
a
waste
sample.
The
waste
sample
is
placed
in
a
conical
paint
filter
suspended
in
a
ring
stand.
The
paint
filters
are
typically
fine
meshed
size.
To
test
for
the
removal
of
free
liquids,
the
waste
sample
is
weighed
prior
to
testing
to
determine
the
amount
of
absorbed
liquid
and
then
placed
in
the
paint
filter.
If
liquid
begins
to
drip
from
the
waste
sample
in
less
than
5
minutes,
the
sample
fails
and
the
test
is
terminated.

To
gain
accurate
and
dependable
results,
tests
must
be
conducted
at
temperatures
above
the
freezing
point
of
all
liquids
in
the
sample.
Tests
may
also
be
performed
above
room
temperature,
25

C.
Exposure
to
alkaline
materials
may
cause
the
filter
media
to
separate
from
the
filter
cone.
However,
if
the
sample
is
not
disturbed,
results
remain
accurate.

If
the
test
is
performed
long
in
advance
of
shipment
off
site,
free
liquids
may
percolate
through
the
container
because
of
the
weight
of
the
wipes
on
top,
and
this
may
result
in
free
liquids
at
the
bottom
of
the
container.
Because
there
must
be
no
free
liquids
in
the
containers
at
the
time
they
are
sent
off
site,
the
generator
would
be
in
violation
of
the
no
free
liquids
condition
if
free
liquids
were
found
in
the
container
ready
to
be
shipped,
even
if
those
wipes
had
previously
passed
the
no
free
liquid
test.

Liquids
Release
Test
The
Liquids
Release
Test
is
a
laboratory
method
that
determines
whether
or
not
liquids
will
be
released
from
a
waste
sample
when
subjected
to
the
overburden
pressures
of
a
landfill.
The
waste
sample
is
placed
between
two
stainless
steel
screens
supported
by
two
stainless
steel
grids
on
opposite
sides.
The
grids
are
followed
by
absorptive
filter
paper
while
a
piston
presses
down
on
the
top
screen
with
a
force
of
50
pounds
per
square
inch.
Any
release
of
liquid
to
the
filter
paper
underneath
the
bottom
supporting
grid
or
above
the
top
supporting
grid
indicates
potential
release
if
the
waste
were
subjected
to
landfill
conditions.

Although
this
test
simulates
landfill
conditions,
there
are
several
sources
of
error.
Effects
of
liquids
from
external
sources,
such
as
rain
and
snow,
have
not
been
estimated
and,
therefore,
are
not
considered.
Also,
because
some
waste
samples
contain
volatile
solvents
that
may
quickly
evaporate
after
migrating
to
the
filter
paper,
samples
must
quickly
be
examined
as
soon
as
tests
are
completed.
In
a
limited
study,
EPA
found
that
many
disposable
paper
wipes
pass
this
test
even
when
considerable
amounts
of
solvent
are
applied
to
samples.
When
solvent
is
applied
at
50
percent
of
the
wipe
weight,
most
samples
passed
this
test.
When
solvent
is
applied
at
25
percent
of
the
wipe
weight,
all
samples
passed
this
test.
For
solvents
applied
at
100
percent
of
the
wipe
weight,
88
percent
(
15
out
of
17)
of
samples
passed
this
test
(
SAIC
1997).
Experiments
yielded
varying
results
when
they
tested
disposable
cloth
wipes
due
to
the
method
of
and
materials
used
in
cloth
wipe
construction.

One­
Drop
Test
64
The
One­
Drop
Test
was
developed
by
the
Massachusetts
Department
of
Environmental
Protection
and
is
used
by
generators
in
Massachusetts
to
determine
whether
industrial
wipes
contaminated
with
waste
oil
are
saturated
and/
or
hazardous.
To
pass
the
one­
drop
test,
the
wipe
must
not
release
"
one
drop"
of
solvent
when
hand­
wrung.
Use
of
a
mechanical
wringing
machine
is
also
recommended
to
guarantee
meeting
this
standard.
If
one
drop
occurs,
the
solventcontaminated
industrial
wipes
must
be
managed
as
a
hazardous
waste,
in
accordance
with
310
CMR
30.000
until
samples
pass
the
One
Drop
Test.
Air­
drying
of
wipes
to
satisfy
the
one­
drop
test
is
prohibited.

Solvent
Removal
Techniques
to
Meet
the
"
No
Free
Liquids"
Condition
In
the
course
of
developing
this
proposed
rule,
EPA
found
numerous
techniques
and
technologies
that
can
be
used
to
meet
the
"
no
free
liquids"
condition
and
the
"
dry"
condition
discussed
in
Section
IV.
F.
4.
The
decision
to
apply
these
techniques
and
technologies
depends
on
several
site­
specific
factors,
including
°
The
amount
of
solvent
placed
on
wipes;

°
The
number
of
wipes
used
daily;

°
The
amount
of
capital
investment
available
to
purchase
advanced
technologies;
and
°
The
need
to
comply
with
other
environmental
regulations,
such
as
Clean
Air
Act
(
CAA)
National
Emissions
Standards
for
Hazardous
air
Pollutants
(
NESHAPs),
and
Clean
Water
Act
(
CWA)
effluent
guidelines.

The
following
sections
describe
physical
and
mechanical
wringing
methods
and
other
nonthermal
treatment
technologies
that
are
currently
used,
or
can
be
used,
to
remove
solvents
from
industrial
wipes.
These
sections
also
provide
some
discussion
on
the
applicability
and
efficiency
of
these
treatment
methods.
Table
10
summarizes
the
experiments
conducted
with
these
technologies,
as
well
as
with
combinations
of
these
technologies.
14Hand
wringing
may
only
be
needed
for
wipes
stored
in
the
lower
portion
of
the
container
if,
because
of
percolation
effects,
the
wipes
in
the
higher
portions
of
a
drum
do
not
contain
much
solvent.

15
Descriptions
of
companies
or
technologies
found
in
this
Technical
Background
document
are
for
descriptive
purposes
only
and
are
not
an
endorsement
of
the
products
themselves.

65
Table
10
Summary
of
Experiments
with
Solvent­
Removal
Technologies
(
Solvent
Weight
Two
Times
Dry
Weight
of
Wipe)

Technology
Screen­
bottom
drum
Mechanical
wringing
Hand
wringing
Mechanical
wringing
+
hand
wringing
Hand
wringing
+
mechanical
wringing
Mechanical
wringing
+
screen
bottom
Hand
wringing
+
screen
bottom
drum
Centrifuging
Percent
Solvent
Removal
4­
28
12.9­
55.8
4.6­
68
9.8­
43.8
5.8­
42.3
10.8­
51.5
8.8­
52.7
76­
99
Source:
SAIC,
Use
and
Management
Practices
of
Solvent­
Contaminated
Industrial
Shop
Towels
and
Wipes,
December
23,
1997
Hand
Wringing
Hand
wringing
can
be
used
to
remove
any
free
liquids
or
contaminating
solvents
from
reusable
wipes
and
disposable
paper
and
cloth
wipes.
Wipes
are
twisted
by
hand
until
no
solvent
appears.
To
test
removal
efficiency,
the
wipe
can
be
weighed
before
and
after
twisting
or
wringing.
Because
of
varying
factors,
such
as
the
strength
of
the
person
wringing
the
wipe
and
the
fabric
type
of
the
cloth
wipe,
solvent
removal
will
not
be
as
consistently
effective
as
other
techniques
or
technologies.
Hand
wringing
can
be
very
inexpensive
unless
large
numbers
of
wipes
must
be
hand­
wrung,
in
which
case
labor
costs
must
be
considered.
14
This
technique
requires
the
use
of
personal
protective
equipment.

Based
on
the
results
of
a
1997
study,
mean
removal
efficiency
ranged
from
5
percent
to
24
percent
for
reusable
wipes
and
disposable
paper
wipes
when
the
applied
solvent
was
2
times
the
weight
of
the
wipe.
For
reusable
wipes
specifically,
mean
removal
efficiency
was
3.45
percent
when
the
applied
solvent
was
half
the
weight
of
the
wipe
and
11.3
percent
when
the
applied
solvent
weighed
twice
as
much
as
the
wipe.
Removal
efficiency
ranged
from
1.6
percent
to
68
percent
for
disposable
cloth
wipes
when
the
applied
solvent
weighed
twice
as
much
as
the
wipe.
Studies
also
show
that
mean
removal
efficiency
is
usually
greater
when
more
solvent
is
on
the
wipe
(
SAIC
1997).

Screen­
Bottom
Drums15
Screen­
bottom
drums
can
be
used
to
remove
free
liquids
from
both
reusable
and
16Prices
referenced
in
this
section
reflect
costs
at
the
time
EPA
did
research
on
these
technologies
in
1998­
1999
and
have
not
been
updated
to
reflect
2003
costs.

66
disposable
wipes.
Screen­
bottom
drums
are
steel
drums
equipped
with
a
screen
or
sieved­
plate
near
the
drum
bottom.
The
screen
or
sieved­
plate
supports
the
contents
of
the
drum,
and
is
used
to
separate
the
industrial
wipes
from
the
liquids
that
have
percolated
to
the
bottom
of
the
drum.

From
site
visits
and
experiments,
EPA
has
found
that
wipes
stored
immediately
above
the
screen
tend
to
be
saturated
with
large
amounts
of
solvent
as
they
can
act
as
a
dam
and
hold
back
solvent
moving
downward.
Handlers
must
be
careful
to
address
this
situation.
This
can
be
accomplished
by
hand­
wringing
the
relatively
small
number
of
wipes
sitting
immediately
above
the
screen
or
by
transferring
the
wipes
to
another
container
with
wipes
already
stored
in
it
to
start
the
percolation
process
again.
This
technology
requires
use
of
personal
protective
equipment
for
those
handling
the
wipes.

Efficiency
of
screen­
bottom
drums
appears
to
be
dependent
on
the
solvent
being
used
and
the
type
of
wipe.
Based
on
a
1997
study,
mean
removal
efficiency
ranged
from
4
percent
to
28
percent
for
all
types
of
industrial
wipes.
A
linear
increase
in
wipe
weight
also
exists
as
wipes
from
top
to
bottom
are
re­
weighed
after
24
hours
of
packing.
Although
this
technology
is
not
very
efficient,
it
may
be
more
useful
if
employed
along
with
mechanical
wringing
or
hand­
wringing
technologies.

Mechanical
Wringing
Explosion­
proof
mechanical
wringers
can
be
used
to
remove
any
free
liquids
or
contaminating
solvents
from
reusable
wipes
and
disposable
paper
and
cloth
wipes
by
using
a
mechanical
device
in
a
similar
manner
as
the
hand­
wringing
method.
Mechanical
wringers
should
have
squeeze
rollers
made
of
materials
that
will
not
deteriorate
when
exposed
to
solvents.
To
test
removal
efficiency,
wipes
can
be
weighed
before
and
after
wringing.
This
technology
requires
use
of
personal
protective
equipment
for
persons
handling
wipes.

Removal
efficiencies
for
mechanical
wringing
vary
depending
upon
the
type
and
makeup
of
disposable
paper
or
reusable
wipes.
Based
on
the
results
of
a
1997
study,
mean
removal
efficiency
ranged
from
13
percent
to
30
percent
when
solvent
applied
was
twice
the
weight
of
the
reusable
wipes
or
disposable
paper
wipes.
Removal
efficiency
ranged
from
11
percent
to
56
percent
for
disposable
cloth
wipes.
Mean
removal
efficiency
ranged
from
7.5
percent
to
19
percent
when
solvent
applied
was
half
the
weight
of
the
disposable
paper
wipe.
Mechanical
wringing
removed
as
much
as
30%
of
solvent
from
spent
disposable
paper
wipes
and
reusable
wipes
and
as
much
as
50%
of
solvent
from
some
types
of
disposable
cloth
wipes
(
SAIC
1997).

Hand­
operated
mechanical
wringers
require
a
small
capital
investment
and
may,
therefore,
be
most
valuable
for
small
quantity
generators.
EPA
found
these
models
priced
from
$
600
to
$
2700.16
Centrifuging
67
Centrifuging
is
another
solvent
removal
technology
appropriate
for
disposable
and
reusable
cloth
wipes.
Specially
designed
centrifuges
remove
solvent
from
wipes;
over
a
hundred
wipes
are
placed
in
a
container
and
the
centrifuge
is
operated
for
a
few
minutes,
removing
the
solvent
and
leaving
a
dry
wipe.
Due
to
their
complexity,
centrifuges
have
a
much
higher
capital
cost
and
a
generator
can
either
purchase
the
unit
directly
or
use
a
contract
centrifuge
service.
Centrifuging
machines
should
be
explosion­
proof.
Also,
this
technology
requires
use
of
personal
protective
equipment
for
those
handling
the
industrial
wipes.
Centrifuges
are
manufactured
with
a
self­
balancing,
perforated
basket
allowing
solvents
to
drain
through
the
outer
containment
shell.
It
is
estimated
that
a
four­
minute
cycle
can
extract
between
2.5
and
3.5
gallons
of
solvent
for
every
load
of
225
wipes
processed.

EPA
collected
data
on
removal
efficiencies
of
centrifuges,
some
of
which
is
presented
in
Use
and
Management
Practices
of
Solvent­
Contaminated
Industrial
Shop
Towels
and
Wipes,
EPA,
December
1997,
found
in
the
docket
for
the
proposed
rule.

One
set
of
EPA
tests
led
the
Agency
to
estimate
solvent
removal
efficiency
to
be
about
50
percent.
During
these
tests,
the
weight
of
the
used
wipe
prior
to
centrifuging
ranged
from
2.3
to
3.9
times
the
weight
of
the
unused
wipe.
Subsequent
discussions
with
the
company
conducting
the
test
found
that
the
centrifuge
was
not
operating
properly
and
that
removal
efficiencies
were
regularly
about
75
percent.

Other
removal
efficiency
data
supplied
to
EPA
includes
the
following:
(
1)
a
centrifuge
vendor,
Maratek,
indicates
solvent
removal
efficiency
of
85
percent
(
Newspaper
Association
of
America
TechNews,
January
1997);
(
2)
a
Wisconsin
printer
indicates
a
removal
efficiency
of
76
percent.
EPA
also
conducted
controlled
tests
of
a
centrifuge
operation
with
a
Minnesota
printer,
John
Roberts,
and
obtained
solvent­
removal
efficiencies
of
95
to
100
percent
using
a
variety
of
disposable
wipes
and
various
solvents.
Results
of
experiments
conducted
by
Bock
Engineering,
a
manufacturer
of
centrifuges,
also
found
solvent­
removal
efficiencies
in
the
95
to
100
percent
range.

The
use
of
centrifuging
is
relatively
uncommon.
An
industry
survey
of
printing
facilities
indicated
that
about
three
percent
use
centrifuging
(
SGIA
1994b).
This
is
consistent
with
observations
made
during
EPA's
site
visits
in
1997.
Centrifuges
can
require
a
substantial
capital
investment.
EPA
found
centrifuges
processing
35,
60,
100,
or
130
pounds
per
load
to
cost
between
$
21,000
to
$
30,000.
They
are
also
available
as
a
contracting
service.
Some
services
charge
about
$
65/
hour;
about
1,500
to
1,800
wipes
can
be
processed
during
this
time.
One
contractor
who
uses
a
mobile
centrifuging
technology
charges
between
3
and
11
cents
per
wipe,
depending
upon
the
volume
of
wipes
treated.

High­
Volume
Air
Drying
The
High­
Volume
Air
Drying
method
uses
laboratory
hoods
with
high
velocity
air
transport
to
achieve
removal
of
contaminating
solvents
from
disposable
and
reusable
wipes.
This
technology,
however,
requires
the
use
of
expensive,
carbon
canister
devices
or
other
solvent
vapor
absorption
devices
and
requires
use
of
personal
protective
equipment
for
those
handling
68
wipes.

High­
volume
air
drying
is
extremely
efficient,
regardless
of
wipe
type
or
solvent,
resulting
in
nearly
100
percent
efficiency
with
the
use
of
a
control
device
like
a
carbon
canister
to
absorb
solvent
vapors.
This
technology
is
restricted,
however,
since
inexpensive
commercial
devices
needed
for
solvent
vapor
absorption
are
not
readily
available.

Microwave
Technology
MicroChem,
L.
L.
C.
has
developed
a
microwave
technology
similar
in
principle
to
household
microwave
ovens.
With
this
system,
solvent­
contaminated
industrial
wipes
are
exposed
to
microwave
power
under
a
vacuum.
The
solvent
is
vaporized
off
of
the
wipes
and
captured
as
clean
solvent
which
is
returned
to
the
generating
facility
for
reuse.
This
process
has
a
solvent
recovery
efficiency
of
98
percent.
Generating
facilities
using
several
hundred
wipes
per
day
can
recover
their
investment
costs
by
substituting
recovered
solvents
for
new
solvent
purchases.
The
cost
of
this
system
was
unavailable
but
MicroChem
is
examining
the
feasibility
of
building
mobile
units.

Maratek
Shop
Towel
On­
Site
Recycling
System
The
Shop
Towel
On­
Site
Recycling
System
is
an
integrated
on­
site
dry
cleaning/
solvent
recovery
system
designed
primarily
for
organizations
using
at
least
1,000
industrial
wipes
per
day
and
large
amounts
of
solvent
on
each
wipe.
At
a
cost
of
$
177,000,
this
system
can
clean
wipes
and
recover
and
reuse
over
95
percent
of
the
solvent
contained
on
them.
Again,
cost
savings
are
obtained
by
reusing
solvent,
thereby
reducing
purchasing
costs
for
new
solvents.

Industrial
Laundry
Solvent
Recovery
Systems
Brent
Industries
and
Industrial
Towel
and
Uniform,
Inc.
(
ITU),
among
others,
use
petroleum­
based
solvents
to
process
the
industrial
wipes,
as
well
as
to
extract
solvents
contained
on
them
for
recovery
and
reuse.
In
both
cases,
any
excess
solvent
recovered
is
either
reused
on
site
or
sold
to
external
customers.

Fierro
Technologies
Fierro
has
developed
a
patented
process
in
which
totally
enclosed
vacuum
extractors
vaporize
solvents
out
of
woven
and
non­
woven
products
to
be
recycled.
Once
the
solvent
is
vaporized,
the
solvents
are
recondensed
back
into
a
liquid
state
for
reuse
by
the
generating
facility.
Solvent
recovery
rates
are
almost
100
percent,
based
on
data
generated
by
Fierro
at
the
request
of
EPA.

IV.
D.
6.
Exotic
Solvents
Proposal
In
the
proposed
rule,
EPA
requests
information
and
comments
on
"
exotic"
solvents,
such
69
as
terpenes
and
citric
acids,
and
how
they
are
presently
managed.
Specifically,
EPA
asks
for
information
and
comments
on
the
following
to
help
the
Agency
develop
a
final
rule.

°
Which
solvents
that
would
currently
be
considered
hazardous
wastes
are
viewed
as
"
exotic?"

°
For
which
solvents
do
commenters
believe
a
"
no
free
liquids"
condition
would
be
problematic?

°
Information
on
documented
cases
of
combustion
caused
by
a
lack
of
free
liquids.

°
Comments
on
whether
the
final
rule
should
give
special
consideration
to
wipes
contaminated
with
exotic
solvents,
particularly
allowing
the
solvents
to
be
wetted
down
with
water
during
accumulation
and
transport.

Discussion
In
the
process
of
developing
this
proposed
rulemaking,
the
Agency
learned
that
there
are
new,
"
exotic"
solvents
on
the
market,
such
as
terpenes
and
citric
acids,
which,
while
labeled
as
non­
hazardous,
could
actually
be
flammable.

Although
the
solvents
do
not
exhibit
the
ignitability
characteristic
in
40
CFR
261.21,
stakeholders
have
told
us
that,
under
certain
conditions
that
have
yet
to
be
determined,
oxygen
can
mix
with
the
industrial
wipes
that
contain
these
exotic
solvents
and
spontaneously
combust.
According
to
some
fire
marshals
and
representatives
of
industrial
laundries,
resulting
fires
have
caused
major
damage
to
facilities.
Some
stakeholders
have
suggested
that
EPA
propose
that
generating
facilities
be
allowed
to
transport
their
industrial
wipes
off
site
with
free
liquids
if
the
facility
is
using
one
of
these
"
exotic"
solvents
that
could
react
or
spontaneously
combust,
so
that
generators
can
wet
down
the
wipes
with
water
prior
to
sending
them
off
site.

IV.
D.
7.
Proposed
Condition
for
Generators
who
Remove
Solvent
from
Industrial
Wipes
Proposal
Any
solvent
removed
from
an
industrial
wipe
may
be
subject
to
regulation
as
a
hazardous
waste.
Therefore,
the
generating
facility
would
be
required
to
determine
whether
the
solvent
removed
from
the
industrial
wipe,
if
it
is
not
reused,
is
listed
as
a
hazardous
waste
or
exhibits
a
characteristic
of
hazardous
waste
and,
if
so,
manage
the
solvent
according
to
prescribed
RCRA
regulations
under
40
CFR
parts
260­
268
and
270.

Under
EPA's
proposed
exclusion
from
the
definition
of
hazardous
waste,
the
solventcontaminated
industrial
wipes
would
not
be
hazardous
waste
at
the
time
they
undergo
solvent
removal.
Therefore,
solvent
removal
technologies
would
not
be
considered
treatment
of
hazardous
waste
under
RCRA
and
such
operations,
whether
they
are
conducted
by
generators
or
handling
facilities,
would
not
be
considered
to
be
treating
hazardous
waste
and
would
not
require
a
RCRA
permit.
70
Discussion
A
number
of
facilities
generating
solvent­
contaminated
wipes
that
meet
the
definition
of
hazardous
waste
perform
solvent
extraction
processes,
such
as
hand
wringing,
mechanical
wringing
or
centrifuging,
all
of
which
separate
the
spent
solvent
from
used
wipes.
The
resulting
spent
solvent
is
then
sent
to
be
recycled
or
disposed
in
compliance
with
RCRA
subtitle
C,
if
applicable.

EPA's
proposed
regulatory
structure,
which,
if
conditions
are
met,
makes
solventcontaminated
industrial
wipes
not
hazardous
waste
at
the
time
of
solvent
removal,
thereby
makes
the
solvent
recovery
process
not
treatment
of
hazardous
waste.
This
structure
is
meant
to
encourage
removal
and
recycling
of
solvents.
Because
the
proposed
rule
does
not
impose
RCRA
requirements
on
solvent
extraction,
generators
may
be
more
likely
to
recover
solvent
for
reuse
and
reduce
the
amount
of
solvent
that
they
purchase.
The
provisional
also
makes
the
rule
a
more
realistic
option
for
smaller
businesses
which
may
be
unwilling
to
undertake
the
RCRA
permit
process,
but
would
like
to
be
able
to
remove
solvents
from
industrial
wipes
to
meet
the
conditions
of
the
proposed
rule.

IV.
D.
8.
Proposed
Conditions
for
Intra­
Company
Transfers
Proposal
To
encourage
recovery
and
recycling
of
the
solvents
in
the
wipes,
EPA
is
proposing
to
allow
generators
to
continue
to
qualify
for
the
exclusion
from
the
definition
of
hazardous
waste
if
they
transfer
solvent­
contaminated
industrial
wipes
containing
"
free
liquids"
between
their
own
facilities
and
if
the
receiving
facility
has
a
solvent
extraction
and/
or
recovery
process
that
will
remove
sufficient
solvent
to
ensure
the
wipes
meet
either
the
"
dry"
condition
or
the
"
no
free
liquids"
condition
before
being
sent
off
site.

To
be
eligible
for
the
exclusion,
generators
must
meet
the
other
conditions
described
in
this
notice.
Specifically,
the
generator
would
be
required
to
accumulate
the
wipes
and
solvents
in
non­
leaking
covered
containers
and
to
transport
the
industrial
wipes
in
containers
that
are
designed,
constructed
and
managed
to
minimize
loss
to
the
environment
and
labeled
"
Excluded
Solvent­
Contaminated
Wipes."
EPA
is
proposing
the
same
performance
standard
for
intracompany
transfers
of
wipes
as
for
wipes
meeting
the
"
dry"
and
the
"
no
free
liquids"
conditions.
Note
that
because
of
the
free
liquids
transported
with
these
wipes,
not
all
types
of
containers
are
likely
to
be
appropriate
(
e.
g.,
cloth
bags
are
not
likely
to
minimize
loss
for
wipes
containing
free
liquids).
The
solvent,
once
extracted,
would
have
to
be
managed
as
a
RCRA
hazardous
waste
if
going
to
disposal.
EPA
believes
this
option
would
result
in
substantial
savings
for
generators
of
solvent­
contaminated
industrial
wipes
as
well
as
in
increased
solvent
recovery
by
generators.

Discussion
Several
stakeholders,
particularly
those
who
use
large
numbers
of
wipes
daily
with
large
amounts
of
solvent
on
each
wipe,
would
like
to
transfer
their
wipes
to
an
intra­
company
facility
that
would
extract
the
solvents
from
the
wipes
without
meeting
the
"
no
free
liquids"
condition.
71
Several
states
already
allow
these
kinds
of
transfers
to
be
made
when
both
the
generating
facility
and
the
extracting
facility
are
part
of
the
same
company.
Under
the
proposed
condition,
the
solvent
extracted
at
this
point
could
either
be
returned
to
the
originating
customer
or
sold
to
another
manufacturer
for
reuse
as
a
feedstock
in
a
manufacturing
or
service
operation.
Alternatively,
when
the
economics
of
solvent
recycling
are
not
favorable,
the
extracted
solvents
could
be
disposed
as
hazardous
wastes.

The
potential
benefits
to
allowing
such
shipments
under
the
conditional
exclusion
from
the
definition
of
hazardous
waste
include
additional
opportunities
for
increased
recycling,
because
some
generating
facilities
would
find
it
more
profitable
to
recycle
solvents
when
not
having
to
meet
the
"
no
free
liquids"
condition
before
sending
industrial
wipes
to
a
facility
with
extracting
capability.
In
this
case,
it
is
inefficient
to
remove
the
free
liquids
and
then
ship
them
to
the
centrifuge
for
more
solvent
extraction.
As
a
result,
many
wipes
go
untreated.
EPA
hopes
that,
by
taking
advantage
of
the
proposed
provision,
the
companies
in
this
situation
would
be
able
to
reduce
total
solvent
use
through
recovery
and
reuse,
and,
therefore,
save
money.
As
stated
elsewhere
in
this
proposal,
several
technologies
already
exist
to
extract
and
recover
the
spent
solvent
contained
on
industrial
wipes
both
economically
and
safely.
In
addition,
there
are
likely
to
be
environmental
benefits
because
solvent
that
would
have
been
sent
to
combustion
or
disposal
in
a
landfill
would
be
recovered
and
reused.

A
potential
disadvantage
of
allowing
intra­
company
transfers
without
assuring
that
the
containers
do
not
contain
free
liquids
is
that
it
increases
the
risk
of
a
hazardous
waste
incident
during
transportation.
Companies
taking
advantage
of
this
would
be
required
still
to
transport
their
wipes
in
DOT­
approved,
non­
leaking
containers
and
would
not,
as
EPA
sees
it,
be
transporting
the
wipes
very
far.
EPA
is
not
proposing
a
specific
distance
that
wipes
can
be
transported
under
this
provision,
but
is
requesting
comment
on
the
issue.

Other
Options
The
specifics
of
other
options
for
this
provision
aer
laid
out
in
the
preamble
for
this
rule.

IV.
D.
9.
Proposed
Conditions
for
Management
at
Handling
Facilities
Proposal
Of
all
the
handlers,
generators
have
the
primary
responsibility
for
assuring
that
the
industrial
wipes
they
transport
off
site
meet
the
conditions
for
the
exclusion,
but
non­
landfill
facilities
that
receive
disposable
industrial
wipes,
such
as
combustors
or
handling
facilities
that
perform
further
solvent
removal,
would
also
need
to
meet
certain
minimum
conditions
for
the
wipes
to
remain
excluded
from
the
definition
of
hazardous
waste.
First,
during
the
time
between
when
the
wipes
arrive
and
when
the
facility
first
introduces
them
into
their
process
(
e.
g.,
when
the
wipes
are
removed
from
their
container
and
placed
in
a
solvent
extractor),
these
facilities
must
store
solvent­
contaminated
industrial
wipes
either
 
(
a)
In
containers
that
are
designed,
constructed
and
managed
to
minimize
loss
to
the
environment
(
i.
e.,
that
would
meet
the
transportation
condition
in
the
proposed
rule);
or
72
(
b)
In
non­
leaking
covered
containers
that
would
meet
the
generator
conditions
in
the
proposed
rule.

The
second
condition
is
that
if
facilities
(
other
than
those
intra­
company
facilities
where
solvent
is
removed)
receive
solvent­
contaminated
industrial
wipes
with
free
liquids,
in
order
to
retain
the
exclusion
from
the
definition
of
hazardous
waste,
they
would
have
to
 
(
a)
Recover
and
properly
manage
any
liquid
solvent
that
arrives
at
the
facility
under
federal
or
state
hazardous
waste
regulations,
as
applicable;
or
(
b)
Return
the
container
(
with
the
wipes
and
liquid)
to
the
generator
as
soon
as
reasonably
practicable
(
e.
g.,
with
the
next
scheduled
delivery).
When
returning
the
wipes
and
liquid
to
the
generator,
the
facility
would
have
to
transport
them
in
containers
that
meet
the
original
shipment
conditions,
but
would
not
need
to
use
a
hazardous
waste
manifest.

Discussion
The
objective
of
this
condition
is
to
address
situations
where
free
liquids
arrive
with
industrial
wipes
at
a
handling
facility
through
no
fault
of
the
handling
facility.
Rather
than
subject
these
materials
to
RCRA
hazardous
waste
requirements,
EPA
is
proposing
that
these
materials
be
allowed
to
be
further
processed
to
ensure
that
the
conditions
of
the
exclusion
are
met.
We
believe
this
can
be
done
safely
and
we
also
believe
that
this
will
provide
additional
incentive
for
solvent
recovery.
At
any
time
that
hazardous
solvents
are
spilled
or
leaked,
we
would
consider
this
to
be
disposal
and
the
handling
facility
managing
the
solvents
would
be
responsible
for
cleaning
up
the
spill.

EPA
believes
there
is
no
reason
for
handlers
to
open
containers
with
solvent­
contaminated
wipes
before
the
wipes
enter
the
handling
process.
By
not
opening
these
containers,
the
potential
for
fires,
exposure
to
workers
and
the
general
public
decreases
considerably.
If
free
liquids
are
found
once
the
container
is
opened,
EPA
would
provide
flexibility
in
what
the
handler
can
do.
Currently,
the
handler
is
managing
a
hazardous
waste
if
containers
holding
free
liquids
arrive.
Under
the
proposal,
EPA
would
provide
flexibility
to
handlers
in
that
they
have
two
options
to
avoid
a
hazardous
waste
classification.
They
can
either
remove
the
solvent
from
the
container
themselves,
continue
to
send
the
wipes
through
their
process,
and
manage
the
solvent
as
a
hazardous
waste,
or
they
can
send
the
container
with
all
materials
enclosed
back
to
their
customer
for
them
to
manage
properly.

This
proposed
condition
fosters
compliance
without
creating
unnecessary
burdens
on
either
the
generator
or
handler.
Whether
the
handler
removes
the
free
liquids
or
sends
the
container
back
to
the
generator,
additional
costs
are
incurred
that
should
be
passed
back
to
the
generator
S
hopefully
fostering
changes
in
their
process
so
that
free
liquids
no
longer
arrive
at
the
handling
facility.

IV.
D.
10.
Management
of
Industrial
Wipes
Containing
Co­
Contaminants
Proposal
73
Solvent­
contaminated
industrial
wipes
that
exhibit
a
characteristic
of
hazardous
waste
due
to
co­
contaminants
also
are
not
eligible
for
the
exclusion,
unless
the
characteristic
is
ignitability.
Specifically,
EPA
is
proposing
that
industrial
wipes
that
exhibit
the
characteristics
of
toxicity,
corrosivity,
or
reactivity
because
of
wastes
with
which
they
are
co­
contaminated
are
not
eligible
for
the
conditional
exclusion.
On
the
other
hand,
because
the
industrial
wipes
are
already
likely
to
be
ignitable
because
of
the
nature
of
the
solvents
on
them,
and
because
this
risk
is
managed
by
the
conditions
of
the
exclusion,
wipes
co­
contaminated
with
ignitable
waste
would
remain
eligible
for
the
exclusion
if
they
meet
the
other
conditions
of
the
exclusion.

Discussion
The
proposed
rule
is
not
intended
to
override
EPA's
mixture
rule
regarding
contaminants
on
industrial
wipes
other
than
the
solvents
specified
in
this
proposal.
In
addition
to
these
solvents,
spent
wipes
from
industrial
applications
may
be
contaminated
with
material
removed
during
the
industrial
process
S
anything
from
dirt
and
grease
to
listed
hazardous
wastes.
The
presence
of
these
co­
contaminants
may
make
the
industrial
wipes
subject
to
the
hazardous
waste
mixture
rule
(
40
CFR
part
261.3(
a)(
2)(
iv)),
which
states
that
a
mixture
made
up
of
any
amount
of
a
nonhazardous
solid
waste
and
any
amount
of
a
listed
hazardous
waste
is
a
listed
hazardous
waste.
Therefore,
if
the
wipe
contains
a
listed
waste
other
than
the
identified
solvents,
it
will
be
considered
a
listed
hazardous
waste
and
will
no
longer
be
eligible
for
the
exclusion
from
the
definition
of
hazardous
waste
being
proposed.

Spent
wipes
from
industrial
applications
are
not
only
contaminated
with
solvents
(
some
listed
and/
or
characteristically
hazardous),
but
they
are
also
often
contaminated
with
material
removed
during
the
industrial
process.
This
material
may
be
specific
to
the
industry
or
process
(
e.
g.,
inks
and
printing
sludges;
lacquers
and
other
coatings
from
auto
body
repair;
stains,
shellacs
and
other
coatings
from
the
furniture
production
and
refinishing
industry),
or
they
may
be
generic
in
nature
(
e.
g.,
dirt,
metal
shavings,
waxes
and
spent
lubricating
oils).
In
either
case,
these
cocontaminants
may
pose
a
hazard
to
human
health
or
the
environment
if
they
are
disposed
with
spent
wipes
in
a
non­
hazardous
waste
landfill
or
incinerator.

Previous
investigations
have
identified
the
following
industries
as
likely
to
produce
significant
quantities
of
spent
wipes
contaminated
with
listed
or
characteristically
hazardous
solvents:


printing

auto
body
repair

furniture
refinishing
The
materials
used
in
each
of
these
industries
and
the
tasks
for
which
solvents
and
wipes
are
used
suggest
contaminants
that
are
likely
to
be
found
on
spent
wipes.
These
contaminants
are
discussed
below,
in
categories
by
industry.
The
information
presented
here
is
based
on
information
gathered
during
site
visits,
literature
research,
and
Internet
searches.
74
Printing
The
printing
industry
encompasses
diverse
processes
for
transferring
images
to
a
wide
range
of
substrates,
including
coated
and
uncoated
paper,
polymer
films,
and
fabrics.
These
diverse
processes
include
lithographic,
flexographic,
offset,
rotogravure
and
screen
printing.
All
of
these
industrial
printing
processes
generate
waste
ink
and
ink
sludges
that
are
frequently
codisposed
with
spent
wipes.
While
actual
ink
formulations
differ
from
process
to
process,
they
are
generally
composed
of
 
°
A
colorant
(
either
pigment
[
insoluble
colorant]
or
dye
[
soluble
colorant]);
°
A
vehicle
(
which
disperses
the
colorant);
and
°
A
modifier
(
added
to
control
ink
or
coating
viscosity,
slickness
of
the
surface,
drying
time,
stability
to
exposure
to
light
and
humidity,
and
rub
resistance).

Colorants
represent
the
most
chemical
diversity
in
the
ink
system,
and
pose
the
greatest
potential
for
hazard.
Colorants
may
be
generally
classified
as
 
°
Organic
pigments
­
based
primarily
on
carbon
but
may
contain
metallic
elements
necessary
to
make
the
compound
insoluble.
They
include
azo
compounds,
triphenylmethane
salts,
rhodamines,
and
phthalocyanines.
°
Inorganic
pigments
­
including
salts
and
oxides
of
lead,
chromium,
cadmium,
barium,
titanium,
and
iron;
calcium
carbonate,
aluminum
silicates,
magnesium
carbonate,
and
alumina
hydrate;
aluminum
powders
for
silver
inks
and
bronze
powders
for
gold
inks.
°
Carbon
black
pigments
­
very
small
particle
size
and
structural
complexity
in
relation
to
all
of
the
other
pigment
types.
°
Acidic
dyes
­
these
have
limited
applications
and
are
rarely
used.
°
Basic
dyes
­
primarily
aniline
compounds.
°
Azo
metal
complexes
(
dyes)
­
azo
dyes
complexed
with
inorganic
constituents,
most
commonly
chromium.
°
Disperse
dyes
­
low
molecular
weight
organic
compounds
that
sublimate
at
relatively
low
temperatures.

Little
specific
information
could
be
found
on
the
vehicles
(
dispersants)
used
in
ink
formulations.
Ink
MSDSs
obtained
on
the
Internet
usually
claimed
the
information
to
be
proprietary
or
did
not
include
any
information
at
all.
Anecdotal
information
indicates
that
the
vehicles
are
usually
solvents
(
at
least
for
liquid
inks),
and
that
these
solvents
primarily
consist
of
toluene,
acetone,
varnish
maker's
and
painter's
naphtha,
xylenes,
and
various
aliphatic
hydrocarbons.
Inadequate
data
is
available
to
assess
the
relative
proportion
of
solvent
burden
on
the
contaminated
wipe
at
the
time
of
disposal
that
can
be
attributed
to
solvent
in
the
waste
ink
or
sludge
versus
the
amount
of
solvent
applied
directly
to
the
wipe.

Modifiers
are
added
to
ink
systems
to
control
process
and
wear
characteristics.
The
majority
of
these
additives
fall
into
one
of
the
following
categories:

°
Phenolic
resins
75
°
Acrylic
resins
°
Hydrocarbon
(
petroleum­
based)
resins
°
Cellulose
and
modified
cellulose
resins.

MSDSs
indicate
that
glycol
ethers
and
vinyl
chloride
monomer
are
also
added
as
modifiers
(
vinyl
chloride
is
a
known
human
carcinogen).

No
data
could
be
found
on
the
volumes
of
inks
or
specific
colorants
sold
or
used
in
any
given
time
period
that
would
allow
one
to
draw
even
preliminary
conclusions
about
the
amounts
of
any
of
these
components
that
are
disposed
of
during
a
given
time
period,
nor
to
estimate
possible
risks
to
human
health
and
the
environment
posed
by
specific
disposal
scenarios.
However,
observations
made
during
site
visits
conducted
earlier
indicate
that
the
total
amounts
of
waste
inks
and
ink
sludges
disposed
on
contaminated
wipes
may
be
significant.
As
demonstrated
by
MSDSs,
many
of
the
colorants
used
include
toxic
compounds
or
elements,
some
of
which
are
toxicity
characteristic
constituents.
Insufficient
data
is
available
to
estimate
the
fate
of
contaminated
wipes
in
the
TCLP.

Auto
Body
Repair
Site
visits
indicate
that
industrial
wipes
are
one
of
auto
body
repair
shops'
multiple
waste
streams.
Outside
of
general
housekeeping
activities,
wipes
appear
to
be
used
with
listed
or
characteristically
hazardous
solvents
for
surface
preparation.
Some
applications
are
 
°
Wax
and
grease
removal;
°
Dust
and
particulate
removal,
including
metal
shavings
and
epoxy,
acrylic
and
urethane
resins;
and
°
Removal
of
lacquers
and
coatings.
The
colorants
present
in
automotive
paints
appear
to
be
the
same
as
many
of
those
used
in
ink
formulations.
No
data
could
be
found
on
the
volumes
of
automotive
body
fillers,
paints
and
finishes,
or
specific
colorants
that
would
lead
to
conclusions
about
the
amounts
of
these
materials
co­
disposed
with
spent
wipes
or
to
estimate
possible
risks
to
human
health
and
the
environment
posed
by
specific
disposal
scenarios.
However,
observations
made
during
site
visits
indicate
that
the
total
volume
of
co­
contaminants
on
spent
wipes
generated
in
body
shops
is
not
significant.
As
demonstrated
by
MSDSs,
many
of
the
colorants
used
include
toxic
compounds
or
elements,
some
of
which
are
toxicity
characteristic
constituents.
Insufficient
data
is
available
to
estimate
the
fate
of
contaminated
wipes
using
the
TCLP.
Additionally,
reactants
used
in
epoxy
and
urethane
resin
formation
and
curing
are
known
to
be
toxic.
Whether
any
significant
amount
of
unreacted
material
is
present
on
spent
wipes
is
not
known.

Furniture
Refinishing
Furniture
finishing
and
refinishing
processes
involve
the
application
of
solvents,
stains,
and
finishes
(
lacquers,
shellacs,
urethane
coatings),
which
generate
spent
wipes
that
are
cocontaminated
with
all
of
these
materials.
Through
anecdote,
EPA
found
that
production
of
spent
wipes
in
these
processes
is
significant.
Insufficient
data
was
available
to
make
conclusive
judgements
about
these
materials,
as
most
of
the
formulations
are
considered
proprietary.
MSDSs
17
As
used
here,
destruction
compares
the
composition
of
the
exiting
ash
to
the
composition
of
the
incoming
municipal
solid
waste.
For
comparison,
hazardous
waste
combustors
require
99.99
percent
destruction,
when
comparing
the
composition
of
the
exiting
air
to
the
composition
of
the
incoming
waste.
Because
the
constituents
of
concern
are
largely
volatile,
larger
quantities
of
the
unreacted
constituent
are
expected
to
be
present
in
exhaust
gas
rather
than
in
ash
residue.

76
do
indicate
that
the
formulations
are
solvent­
based
(
primarily
acetone,
methyl
ethyl
ketone,
isopropyl
alcohol,
aliphatic
hydrocarbons
and
aromatic
hydrocarbons),
and
that
some
finishes
also
may
contain
nitrocellulose.
No
information
was
located
on
the
types
of
colorants
used
in
wood
stains.
Insufficient
information
is
available
to
estimate
either
the
volume
or
composition
of
the
waste
stream,
or
to
evaluate
any
potential
hazard
posed
by
co­
disposal
with
spent
wipes.

IV.
D.
11.
Proposed
Conditions
for
Burning
Solvent­
Contaminated
Industrial
Wipes
in
Combustors
Proposal
EPA
is
proposing
that
municipal
and
other
waste
combustors
be
allowed
to
burn
solventcontaminated
industrial
wipes
that
meet
the
proposed
conditions
for
the
exclusion.
Facilities
managing
these
wipes
would
have
to
ensure
that
the
wipes
remain
in
containers
that
meet
either
the
proposed
generator
or
transportation
condition
until
they
enter
the
combustion
process.
Also,
if
a
combustion
facility
finds
industrial
wipes
with
free
liquid
solvents
when
it
initiates
processing
of
the
wipes,
for
industrial
wipes
to
retain
the
exclusion,
the
facility
would
have
the
choice
of
removing
the
free
liquids
and
managing
them
as
a
hazardous
waste
or
closing
the
container
and
sending
the
wipes
back
to
the
originating
generator.
When
returning
the
wipes
and
liquid
to
the
generator,
the
combustor
would
have
to
transport
them
in
containers
that
meet
the
original
shipment
conditions,
but
would
not
need
to
use
a
hazardous
waste
manifest.

Discussion
The
proposed
rule
would
allow
solvent­
contaminated
wipes
to
be
managed
at
MWCs
regulated
under
subtitle
D
and
applicable
state­
specific
controls,
provided
neither
the
wipes
themselves,
nor
the
containers
they
are
in,
contain
free
liquids
and
that
they
are
shipped
to
the
MWC
in
closed
containers
that
are
appropriately
labeled.
Destruction
rates
for
solvents
are
expected
to
be
at
least
99.99
percent
in
MWCs,
when
comparing
the
incoming
waste
concentration
to
the
ash
concentration.
17
These
rates
are
expected
because
constituents
would
be
destroyed
and/
or
would
volatilize
to
the
exhaust
air.
Based
on
the
Agency's
analysis
of
the
potential
risks
associated
with
this
proposal,
the
Agency
found
that
given
the
rate
of
destruction
expected
to
occur
in
MWCs,
ash
from
burning
solvent­
containing
wipes
is
not
likely
to
exceed
these
limits.

The
advantages
of
this
approach
include
 

Greater
regulatory
relief
for
generators;


Decreased
costs
for
treatment
and
disposal;


Emissions
controls
stringent
enough
to
ensure
protection
against
potential
releases
77
of
solvent
constituents;
and

Greater
potential
for
residues
to
remain
under
subtitle
D
controls.

The
disadvantages
of
this
approach
include
 

Potential
confusion
due
to
variation
in
state­
specific
requirements
for
the
management
of
wastes
at
MWCs;
and

Some
MWCs
may
refuse
to
ever
accept
exempted
hazardous
waste.

Municipal
Waste
Combustors
MWCs
do
not
obtain
RCRA
permits,
do
not
operate
under
subtitle
C
management
requirements,
and
therefore
are
prohibited
from
managing
hazardous
wastes,
per
40
CFR
270.1(
b).
As
proposed,
however,
solvent­
contaminated
wipes
meeting
the
conditions
of
a
regulatory
exclusion
would
be
excluded
from
the
definition
of
hazardous
waste.
MWCs
burning
such
wipes
would
be
managing
a
"
solid
waste"
rather
than
a
"
hazardous
waste"
and
consequently
would
not
be
required
to
obtain
a
RCRA
hazardous
waste
permit
or
meet
the
operating
requirements
or
performance
standards
applicable
to
hazardous
waste
combustors
(
HWCs).
MWCs
are
already
subject
to
stringent
performance
standards
that
may
be
considered
comparable
to
those
applicable
to
HWCs
regulated
under
40
CFR
part
264,
subpart
O.
Thus,
MWCs
are
capable
of
burning
excluded
wipes
in
a
manner
that
is
protective
of
human
health
and
the
environment.

Although
the
requirements
for
MWCs
are
generally
promulgated
at
the
state
level,
there
are
basic
guidelines
for
thermal
processing
of
solid
wastes
established
at
the
federal
level
under
40
CFR
part
240.
These
requirements
delineate
the
minimum
levels
of
performance
required
of
any
thermal
processing
operation.
However,
the
addition
of
any
further
controls
beyond
the
emissions
standards
established
under
the
Clean
Air
Act
(
CAA)
would
be
done
through
an
individual
state's
municipal
solid
waste
program.
The
guidelines
or
recommendations
provided
in
40
CFR
part
240
also
include
 
°
Designation
of
wastes
acceptable
for
burning
at
facilities;
°
Assurance
that
the
facility
has
been
designed
to
handle
such
wastes;
°
Exclusion
of
wastes
from
being
handled
at
a
combustion
facility
based
on
certain
criteria
(
i.
e.,
facility's
capabilities,
alternative
methods
available,
chemical
and
biological
characteristics
of
the
waste);
°
Recommendations
for
general
design,
site
selection,
water
and
air
quality,
control
of
vectors,
aesthetics,
management
of
residues,
and
safety
measures;
and
°
General
operating
procedures
which
specify
that
the
facility
should
be
operated
and
maintained
in
a
manner
that
assures
the
facility
will
meet
the
design
requirements.
Recommended
procedures
include
providing
adequate
personnel
training,
determining
alternate
disposal
and
operating
procedures
for
emergencies,
and
creating
routine
maintenance
schedules.

EPA
promulgated
revised
air
emission
requirements
for
MWCs
under
the
New
Source
Performance
Standards
(
NSPS)
on
December
19,
1995
(
60
FR
65387).
The
standards
and
18
New
MWCs
are
defined
as
those
for
which
construction
is
commenced
after
September
20,
1994.

78
guidelines
establish
emission
levels
for
 
°
MWC
organics
(
dioxins
and
furans
only);
°
MWC
metals
(
cadmium,
lead,
mercury);
°
MWC
acid
gases
(
hydrogen
chloride,
sulfur
dioxide,
and
nitrogen
oxides);
°
MWC
fugitive
ash
emissions
from
both
new
and
existing
MWCs;
18
and
°
Other
parameters,
such
as
particulate
matter
and
opacity.

In
addition,
operating
conditions
are
specified,
including
carbon
monoxide
levels,
load
restrictions,
and
flue
gas
temperature
at
the
PM
control
device
inlet.
Numerous
other
requirements
concerning
"
good
combustion
practices"
apply
as
well
for
MWCs
(
see
40
CFR
part
60,
subpart
Eb).
These
requirements
include
feed
rate
limits,
continuous
emissions
monitoring,
annual
stack
testing,
and
certification
of
facility
operators.

EPA
has
promulgated
revised
air
emission
requirements
under
the
New
Source
Performance
Standards
for
large
new
MWCs
(
facilities
managing
more
than
250
tons
of
waste
per
day)
under
subparts
Ea
and
Eb
of
40
CFR
Part
60
and
large
existing
MWCs
under
subpart
Cb
of
Part
60.
There
are
167
large
MWCs
in
the
US
and
all
of
these
facilities
now
meet
these
standards.
Similarly,
EPA
has
promulgated
revised
NSPS
air
emission
requirements
for
smaller
MWCs
(
facilities
managing
less
than
250
tons
of
waste
per
day)
under
Subparts
AAAA
and
BBBB
of
40
CFR
part
60.
All
39
existing
smaller
units
should
be
retrofitted
to
meet
these
new
standards
by
2005.
As
described
in
the
TBD,
these
NSPS
standards
provide
a
level
of
protection
comparable
to
hazardous
waste
incinerators
and
should
be
able
to
burn
solvent­
contaminated
wipes
without
any
difficulty.

Hazardous
Waste
Combustors
Hazardous
waste
managed
prior
to
burning
in
a
boiler
or
industrial
furnace
(
BIF)
or
incinerator
is
subject
to
all
applicable
RCRA
regulations,
including
 
°
The
hazardous
waste
manifest
system;
°
The
use
of
hazardous
waste
transporters;
and
°
Storage
in
hazardous
waste
management
units
meeting
the
standards
of
part
264/
265
(
e.
g.,
container
standards
of
subpart
I,
tank
standards
of
subpart
J).

BIFs
and
incinerators
are
regulated
as
hazardous
waste
treatment,
storage,
and
disposal
facilities,
so
they
also
must
comply
with
the
additional
general
management
requirements
of
40
CFR
part
264/
265,
as
follows:

°
Hazardous
waste
general
facility
standards
(
subpart
B);
°
Preparedness,
prevention,
and
emergency
response
standards
(
subparts
C
and
D);
°
Groundwater
monitoring
requirements
(
subpart
F);
°
Closure
and
post­
closure
requirements
(
subpart
G);
and
79
°
Financial
assurance
requirements
(
subpart
H).

HWCs
also
must
obtain
RCRA
hazardous
waste
operating
permits,
a
process
which
involves
public
participation
procedures.

EPA
has
updated
the
air
emission
standards
for
hazardous
waste
combustors,
which
are
co­
promulgated
under
RCRA
and
the
CAA.
This
rule
(
64
FR
52828,
September
30,
1999)
establishes
stringent
air
emission
regulations
for
hazardous
waste
incinerators,
hazardous
wasteburning
cement
kilns,
and
lightweight
aggregate
kilns.
The
standards
include
limits
on
emissions
of
chlorinated
dioxins
and
furans,
mercury,
particulate
matter,
semivolatile
and
low
volatile
metals,
hydrogen
chloride
and
chlorine
gas,
carbon
monoxide,
hydrocarbons,
and
destruction
and
revomal
efficiency,
in
lieu
of
standards
for
nondioxin/
furan
organic
hazardous
air
pollutants.

Comparison
of
Air
Emission
Standards
presents
a
side­
by­
side
comparison
of
the
key
air
emission
standards
for
new
MWCs
and
HWCs.
presents
a
side­
by­
side
comparison
of
the
key
air
emission
standards
for
existing
MWCs
and
HWCs.

Table
11
80
Comparison
of
Key
Air
Emission
Standards
for
New
Combustion
Units
Parameter
New
Municipal
Waste
Combustors
(
MWCs)
New
Hazardous
Waste
Combustors
(
HWCs)

1.
Carbon
monoxide
(
CO)
50­
150
ppmv,
depending
on
unit
type
100
ppmv
2.
Particulates
(
PM)
24
mg/
dscm
(
0.010
gr/
dscf)
34
mg/
dscm
(
0.015
gr/
dscf)

3.
Cadmium
(
Cd)
0.02
mg/
dscm
(
8.7
gr/
mil
dscf)
24
µ
g/
dscm
4.
Lead
(
Pb)
0.20
mg/
dscm
(
87
gr/
mil
dscf)
24
µ
g/
dscm
5.
Mercury
(
Hg)
0.08
mg/
dscm
(
35
gr/
mil
dscf),
or
an
85%
reduction
45
µ
g/
dscm
6.
Dioxins/
Furans
13
ng/
dscm
(
or
7
ng
with
less
frequent
testing)
(
measured
as
total
mass
dioxins/
furans)
0.20
ng/
dscm
(
TEQ)

7.
Sulfur
Dioxide
(
SO
2)
The
higher
of
80%
reduction
or
30
ppmv
N.
A.

8.
Hydrochloric
Acid
(
HCl)
The
higher
of
95%
reduction
or
25
ppmv
21
ppmv
(
HCl/
Cl
2)

9.
Hydrocarbons
(
HC)
N.
A.
10
ppmv
10.
Low
Volatile
Metals
(
As,
Be,
Cr,
Sb)
N.
A.
97
µ
g/
dscm
11.
Nitrous
Oxide
(
NOx)
150
ppmv
(
large
plants
(>
225
Mg/
day)
only)
N.
A.

12.
Fugitive
Dust
Emissions
(
fly
ash/
bottom
ash)
Visible
emissions
<
5%
of
time
N.
A.

13.
Opacity
<
10%
(
6­
minute
average)
N.
A.

Table
12
81
Comparison
of
Key
Air
Emission
Standards
for
Existing
Combustion
Units
Parameter
Existing
MWCs
Existing
HWCs
1.
Carbon
monoxide
(
CO)
50­
250
ppmv,
depending
on
unit
type
100
ppmv
2.
Particulates
(
PM)
27
mg/
dscm
(
0.012
gr/
dscf)
for
large
plants;
70
mg/
dscm
(
0.03
gr/
dscf)
for
small
plants
34
mg/
dscm
(
0.015
gr/
dscf)

3.
Cadmium
(
Cd)
0.04
mg/
dscm
(
18
gr/
mil
dscf)
for
large
plants;
0.10
mg/
dscm
(
44
gr/
mil
dscf)
for
small
plants
240
µ
g/
dscm
4.
Lead
(
Pb)
0.49
mg/
dscm
(
200
gr/
mil
dscf)
for
large
plants;
1.6
mg/
dscm
(
700
gr/
mil
dscf)
for
small
plants
240
µ
g/
dscm
5.
Mercury
(
Hg)
0.08
mg/
dscm
(
35
gr/
mil
dscf),
or
an
85%
reduction
130
µ
g/
dscm
6.
Dioxins/
Furans
60
ng/
dscm
(
if
ESP­
based
controls)
(
30
ng/
dscm
otherwise)
for
large
plants;
125
ng/
dscm
for
small
plants
0.20
ng/
dscm
(
TEQ)

7.
Sulfur
Dioxide
(
SO
2)
The
higher
of
75%
reduction
or
31
ppmv
for
large
plants;
50%
reduction
or
80
ppmv
for
small
plants
N.
A.

8.
Hydrochloric
Acid
(
HCl)
The
higher
of
95%
reduction
or
31
ppmv
for
large
plants;
50%
reduction
or
250
ppmv
for
small
plants
77
ppmv
(
HCl/
Cl
2)

9.
Hydrocarbons
(
HC)
N.
A.
10
ppmv
10.
Low
Volatile
Metals
(
As,
Be,
Cr,
Sb)
N.
A.
97
µ
g/
dscm
11.
Nitrous
Oxide
(
NOx)
200­
250
ppmv
(
large
units
(>
225
Mg/
day)
only)
N.
A.

12.
Fugitive
Dust
Emissions
(
fly
ash/
bottom
ash)
Visible
emissions
<
5%
of
time
N.
A.

13.
Opacity
<
10%
(
6­
minute
average)
N.
A.
19In
fact,
the
Agency
identified
incineration
as
the
basis
for
the
LDR
treatment
standard
for
all
organic
constituents
regulated
in
nonwastewaters
with
the
exception
of
seven
constituents:
disulfoton,
famphur,
methyl
parathion,
parathion,
phorate,
diphenylamine,
and
diphenylnitrosamine
(
EPA
1994,
4­
10).

82
A
comparison
of
the
applicable
air
emissions
standards
for
municipal
waste
combustors
and
hazardous
waste
combustors
shows
that
the
standards
applicable
to
municipal
waste
combustors
are
similar
or
somewhat
more
stringent
than
the
standards
that
apply
to
hazardous
waste
combustors,
with
the
exception
of
hydrocarbons.
Therefore,
an
evaluation
of
the
potential
effectiveness
of
municipal
waste
combustors
in
treating
solvent­
contaminated
wipes,
based
solely
on
the
basis
of
the
technology
and
the
emissions
standards
(
and
without
a
thorough
evaluation
of
handling
practices)
leads
to
a
conclusion
that
these
units
are
as
effective
in
treating
or
destroying
the
wastes.

It
should
be
noted
that,
regardless
of
whether
a
municipal
combustion
facility
manages
solvent­
contaminated
wipes,
the
ash
generated
by
these
facilities
is
a
newly
generated
waste
and
is
subject
to
the
waste
identification
requirements
of
40
CFR
parts
261
and
262.
Owners
and
operators
of
MWCs
must
determine
whether
or
not
the
ash
generated
at
their
facilities
exhibits
one
or
more
of
the
characteristics
of
hazardous
waste.
If
the
ash
generated
at
a
MWC
exhibits
the
toxicity
characteristic,
the
ash
must
be
managed
as
a
hazardous
waste
in
compliance
with
all
applicable
subtitle
C
management
requirements,
including
the
land
disposal
restrictions
requirements.

Land
Disposal
Restriction
Issues
Related
to
Incineration
of
Wipes
or
Burning
Wipes
for
Energy
Recovery
EPA
considered
various
options
for
modifying
current
RCRA
rules
to
exclude
industrial
wipes
contaminated
with
hazardous
waste
solvents
from
hazardous
waste
management
regulations.
This
section
discusses
issues
associated
with
the
current
applicability
of
the
Land
Disposal
Restrictions
(
LDRs)
at
40
CFR
part
268
to
these
materials
and
with
the
combustion
of
solvent­
contaminated
wipes
in
MWCs.

Under
the
current
RCRA
regulations,
hazardous
wastes
destined
for
land
disposal
must
meet
the
LDR
treatment
standards.
It
can
be
reasonably
assumed
that
thermal
treatment
technologies
would
be
selected
only
for
the
treatment
of
nonwastewater
forms
of
F001­
F005.
The
nonwastewater
LDR
treatment
standards
for
all
organic
solvent
wastes
are
based
on
incineration.
19
However,
any
technology
can
be
used
so
long
as
it
meets
the
treatment
standard.
For
organic
wastes,
the
technologies
selected
typically
involve
combustion,
such
as
incineration
in
a
hazardous
waste
combustor
or
fuel
substitution
for
energy
recovery.
For
the
purposes
of
the
LDRs,
combustion
is
defined
at
40
CFR
268.42
as
High
temperature
organic
destruction
technologies,
such
as
combustion
in
incinerators,
boilers,
or
industrial
furnaces
operated
in
accordance
with
the
applicable
requirements
of
40
CFR
part
264,
subpart
O,
or
40
CFR
part
265,
subpart
O,
or
40
CFR
part
266,
subpart
H,
and
in
other
units
operated
in
accordance
with
applicable
operating
requirements;
and
certain
non­
combustive
83
technologies,
such
as
the
Catalytic
Extraction
Process.

Thus,
combustion
units
receiving
hazardous
wastes
must
be
permitted
or
have
interim
status
under
RCRA
subtitle
C
to
handle
hazardous
wastes.
Municipal
waste
combustors,
therefore,
do
not
meet
the
LDR
requirements
for
combustion.

IV.
D.
12
Disposal
of
Treatment
Residues
from
Municipal
Waste
and
Other
Combustion
Facilities
Proposal
and
Discussion
Under
the
proposed
rule,
when
solvent­
contaminated
industrial
wipes
meet
the
conditions
of
the
exclusion
before
being
combusted,
they
would
not
be
considered
hazardous
wastes.
Therefore,
the
derived­
from
rule
does
not
apply
to
the
ash
derived
from
the
burning
of
these
materials.
In
other
words,
as
stated
above,
the
ash
generated
by
a
MWC
or
other
combustion
facility
is
a
newly­
generated
waste
and
is
subject
to
the
waste
identification
requirements
of
40
CFR
parts
261
and
262.
Owners
and
operators
of
MWCs
and
other
combustion
facilities
must
determine
whether
or
not
the
ash
generated
at
their
facilities
exhibits
one
or
more
of
the
characteristics
of
hazardous
waste.
They
may
do
so
by
using
knowledge
of
the
wastes
they
receive
and/
or
generate,
coupled
with
a
knowledge
of
the
capability
of
their
combustor
facility,
or
by
testing
the
ash.
If
they
determine
that
MWC
ash
exhibits
a
hazardous
characteristic,
the
ash
must
be
managed
as
a
hazardous
waste
in
compliance
with
all
applicable
subtitle
C
management
requirements,
including
the
LDRs.

IV.
E.
Proposed
Conditions
for
Exclusion
from
the
Definition
of
Solid
Waste
for
Reusable
Solvent­
Contaminated
Industrial
Wipes
This
section
details
a
number
of
proposed
conditions
designed
to
ensure
that
reusable
solvent­
contaminated
industrial
wipes
are
handled
as
valuable
commodities.

IV.
E.
1.
Proposed
Conditions
for
Initial
Storage
and
Accumulation
Proposal
The
proposed
conditional
exclusion
from
the
definition
of
solid
waste
would
apply
to
solvent­
contaminated
industrial
wipes
at
the
point
where
the
generator
ceases
using
them.
If
the
wipes
are
managed
according
to
the
proposed
conditions,
they
are
not
considered
solid
waste.

For
the
exclusion
from
the
definition
of
solid
waste,
EPA
is
proposing
the
same
performance­
based
on­
site
management
condition
as
for
the
exclusion
of
disposable
industrial
wipes
from
the
definition
of
hazardous
waste.
For
reusable
industrial
wipes,
when
wipes
are
discarded,
the
user
must
place
them
in
a
non­
leaking,
covered
container.
This
condition
is
described
more
fully
in
Section
IV.
F.
1.
above.

Discussion
84
Management
standards
for
accumulation
of
reusable
industrial
wipes
differ
from
state
to
state
due
to
varying
state
policies.
However,
some
trade
associations
and
industrial
laundries
already
encourage
their
members
and
customers
to
use
closed
or
sealed
containers
during
storage
and
transportation
of
solvent­
contaminated
wipes.

EPA
believes
that
the
proposed
condition
ensures
responsible
management
of
the
wipes
in
a
manner
that
is
commodity­
like
by
preventing
the
loss
of
wipes,
preventing
the
loss
of
solvent
which
could
be
recovered
and
reused,
and
protecting
against
risks
from
fires.
The
primary
type
of
damage
incident
identified
by
EPA
as
a
result
of
the
mismanagement
of
solvent­
contaminated
wipes
is
fire­
related
damage
due
to
the
ignitability
or
flammability
of
these
materials.
The
proposed
condition
also
allows
for
a
wide
variety
of
containers
to
be
acceptable
for
accumulation
of
reusable
wipes.

Site
visits
conducted
by
EPA
in
1997
provided
evidence
that
both
open
and
closed
containers
are
used
for
the
accumulation
of
solvent­
contaminated
wipes.
The
most
common
management
practices
involved
the
use
of
a
wide
variety
of
containers,
ranging
from
approximately
five
gallons
in
size
(
e.
g.,
safety
cans)
to
55­
gallon
drums.
Some
sites
also
used
safety
cans
as
satellite
accumulation
units
from
which
the
wipes
were
later
transferred
to
a
centralized
accumulation
unit.
As
with
the
exclusion,
the
performance­
based
requirement
proposed
by
EPA
provides
flexibility
by
allowing
generators
to
accumulate
solvent­
contaminated
wipes
in
any
of
these
containers,
including
spring­
bottomed
drums,
which
prevent
air
releases
when
not
being
used,
but
accommodate
the
needs
of
workers
constantly
needing
to
open
the
drum.
Under
the
proposed
rule,
generators
may
take
innovative
approaches
to
meet
the
performance
standard
rather
than
being
required
to
use
a
specific
design.
A
performance
standard
also
provides
a
degree
of
flexibility
in
terms
of
allowing
different
approaches
that
minimize
the
length
of
time
required
for
workers
to
place
a
used
wipe
in
a
storage
container.
This
requirement
also
is
in
keeping
with
the
spirit
and
intentions
of
OSHA
regulations.
Generators
who
already
meet
OSHA
container
standards
should
meet
the
proposed
requirement
for
the
safe
on­
site
storage
of
solvent­
contaminated
wipes.

IV.
E.
2.
Proposed
Conditions
for
Containers
Used
for
Transportation
Proposal
For
transportation
of
reusable
industrial
wipes,
EPA
is
proposing
that
facilities
which
transport
reusable
solvent­
contaminated
industrial
wipes
off
site
to
an
industrial
laundry,
a
dry
cleaner,
or
a
facility
that
removes
solvents
from
industrial
wipes
prior
to
cleaning,
must
do
so
in
containers
that
are
designed,
constructed
and
managed
to
minimize
loss
to
the
environment;
this
is
the
same
condition
we
are
proposing
for
disposable
industrial
wipes
that
are
conditionally
excluded
from
the
definition
of
hazardous
waste.
We
believe
this
condition
reflects
the
manner
in
which
a
commodity
would
be
transported
because
it
minimizes
the
possibility
that
valuable
material
would
be
spilled,
lost
or
damaged
during
transportation.

Discussion
85
This
condition
is
more
fully
described
above
in
Section
IV.
F.
2.
In
addition,
implementation
questions,
as
well
as
other
options
being
considered,
are
discussed
in
the
preamble
to
this
proposal.

IV.
E.
3.
Proposed
Conditions
for
Transportation
to
Laundry,
Dry
Cleaner,
or
Handler
Proposal
EPA
is
proposing
that
generators
be
required
to
remove
all
free
liquids
prior
to
sending
solvent­
contaminated
reusable
industrial
wipes
off
site
to
be
cleaned
for
reuse.
This
condition
is
the
same
as
the
condition
for
disposable
industrial
wipes
being
transported
for
disposal
at
a
nonland
disposal
facility,
such
as
a
municipal
solid
waste
combustor,
which
is
discussed
in
IV.
F.
5
above.
Note,
however,
that
there
is
no
labeling
condition
for
reusable
industrial
wipes.

Discussion
This
condition
and
background
information
on
this
condition
are
discussed
in
the
preamble
of
this
proposal.

IV.
E.
4.
"
Exotic
Solvents"

Proposal
In
the
proposed
rule,
EPA
requests
information
and
comments
on
"
exotic"
solvents,
such
as
terpenes
and
citric
acids,
and
how
they
are
presently
managed.
EPA
asks
for
information
and
comments
to
help
the
Agency
develop
a
final
rule.

Discussion
For
a
more
detailed
discussion
of
exotic
solvents,
see
Section
IV.
F.
6
of
this
technical
background
document.

IV.
E.
5.
Proposed
Conditions
for
Generators
who
Remove
Solvent
from
Industrial
Wipes
Proposal
Any
solvent
removed
from
an
industrial
wipe
by
a
generator
when
using
solvents
in
conjunction
with
industrial
wipes
may
be
subject
to
regulation
as
a
hazardous
waste.
Therefore,
the
generating
facility
must
determine
whether
the
solvent
removed
from
the
industrial
wipe
is
listed
as
a
hazardous
waste
or
exhibits
a
characteristic
of
a
hazardous
waste
as
defined
in
40
CFR
part
261
and,
if
so,
manage
it
according
to
prescribed
RCRA
regulations
under
40
CFR
parts
260­
268
and
270.

Discussion
86
Under
the
proposed
exclusion
from
the
definition
of
solid
waste,
the
solvent­
contaminated
wipes
would
not
be
a
solid
or
a
hazardous
waste
at
the
time
they
undergo
solvent­
removal.
Therefore,
solvent
removal
technologies
would
not
be
considered
treatment
under
RCRA
and
such
operations,
whether
they
were
conducted
at
generating
or
handling
facilities,
would
not
require
a
RCRA
permit.
Further
discussion
of
this
issue
can
be
found
above
in
Section
IV.
F.
7.

IV.
E.
6.
Proposed
Conditions
for
Intra­
Company
Transfers
Proposal
EPA
is
proposing
that
generators
can
qualify
for
the
exclusion
from
the
definition
of
solid
waste
when
transferring
solvent­
contaminated
reusable
industrial
wipes
containing
"
free
liquids,"
provided
the
transfer
is
between
facilities
within
the
same
company,
and
the
receiving
facility
has
a
solvent
extraction
and/
or
recovery
process
that
removes
enough
solvent
from
industrial
wipes
for
them
to
meet
the
"
no
free
liquid"
condition.
Generators
must
transport
the
industrial
wipes
in
containers
that
are
designed,
constructed,
and
managed
to
minimize
loss
to
the
environment.

Discussion
A
more
detailed
discussion
of
this
provision,
as
well
as
other
options
EPA
is
considering,
can
be
found
above
in
Section
IV.
F.
8.
However,
reusable
industrial
wipes
being
managed
under
the
exclusion
from
the
definition
of
solid
waste
would
not
have
to
meet
the
labeling
condition
that
disposable
industrial
wipes
must
meet.

IV.
E.
7.
Proposed
Conditions
for
Management
at
Handling
Facilities
Proposal
As
described
for
disposable
industrial
wipes,
generators
would
have
the
primary
responsibility
for
assuring
that
their
industrial
wipes
meet
the
conditions
for
the
proposed
exclusion.
However,
handling
facilities
which
receive
and
process
reusable
industrial
wipes,
such
as
industrial
laundries,
would
also
need
to
meet
certain
minimum
conditions
for
the
wipes
to
remain
excluded
from
the
definition
of
solid
waste.

The
first
condition
EPA
is
proposing
states
that
to
maintain
the
exclusion
from
the
definition
of
solid
waste
for
reusable
industrial
wipes,
between
arriving
on
site
and
entering
a
facility's
process
the
wipes
would
have
to
be
stored
either
 
(
a)
In
containers
that
are
designed,
constructed
and
managed
to
minimize
loss
to
the
environment
that
meet
the
proposed
transportation
condition,
or
(
b)
In
non­
leaking
covered
containers
that
meet
the
proposed
generator
accumulation
condition.

The
process
begins
when
the
laundry
begins
to
handle
the
wipes.
For
example,
at
many
laundries,
the
wipes
are
sent
through
a
counting
machine
first,
before
they
are
cleaned,
to
record
how
many
87
wipes
the
generator
has
sent
to
be
cleaned.
In
this
example,
wipes
would
enter
the
handling
process
when
they
are
counted.

From
site
visits,
we
expect
that
at
the
laundries,
the
solvent­
contaminated
industrial
wipes
will
generally
remain
in
the
containers
in
which
they
were
transported.
In
the
case
where
a
facility
chooses
to
transfer
the
industrial
wipes
into
another
container
before
the
wipes
enter
the
handling
process,
we
are
proposing
that
the
generator
condition,
placement
in
a
non­
leaking
covered
container,
would
be
sufficient
to
maintain
the
exclusion
from
the
definition
of
solid
waste.

Handling
facilities
would
also
not
be
allowed
to
mismanage
free
liquids.
For
example,
an
industrial
laundry
may
not
introduce
free
liquids
into
their
laundering
process.
Facilities
that
happen
to
receive
solvent­
contaminated
industrial
wipes
in
containers
with
free
liquids
(
unless
they
are
being
transported
intra­
company)
would
be
required
to
either
 
(
a)
Return
the
container
(
with
the
wipes
and
liquid)
to
the
user
(
generator)
as
soon
as
practicable,
or
(
b)
Recover
and
properly
manage
any
liquid
solvent
that
arrives
at
the
facility
under
applicable
federal
or
state
hazardous
waste
regulations.

When
returning
the
wipes
and
liquids
to
the
user,
the
laundry
would
have
to
transport
them
in
the
containers
that
meet
the
original
shipment
conditions,
but
would
not
be
required
to
use
a
hazardous
waste
manifest.

Discussion
The
discussion
of
this
provision
of
the
proposed
rule
is
discussed
in
the
preamble
of
the
proposal.

V.
Summary
of
Risk
Screening
Analysis
88
V.
A.
Introduction
This
section
describes
the
approach
EPA
took
to
evaluate
the
risks
from
disposing
of
solvent­
contaminated
industrial
wipes
and
their
residues
in
landfills.
EPA's
risk
screening
and
assessment
approach
used
a
series
of
mathematical
models
to
evaluate
the
potential
risks
from
landfilling
industrial
wipes
containing
hazardous
solvents
as
well
as
the
ash
and
sludge
residues
from
combustion
and
waste
water
treatment
processes,
respectively.
this
section
is
meant
as
an
overview
of
the
risk
screening
did
in
developing
this
proposal.
The
actual
report
from
the
risk
analysis
is
available
in
the
docket
to
the
proposed
rule.

V.
B.
Assessing
the
Risks
from
the
Landfilling
Industrial
Wipes
Containing
Hazardous
Solvents
EPA
conducted
an
analysis
to
determine
the
constituent­
specific
risks
from
landfilling
F­
listed
spent
solvents
that
are
contained
on
industrial
wipes
used
for
cleaning
and
degreasing
operations.
This
analysis
addressed
the
following
questions:
(
1)
which
F­
listed
constituents
present
the
most
risk;
and
(
2)
using
reasonable
assumptions,
do
circumstances
exist
where
industrial
wipes
containing
F­
listed
solvents
can
be
managed
in
landfills
without
posing
unacceptable
risk
to
human
health
and
the
environment?
For
this
analysis
EPA
evaluated
disposal
in
a
municipal
solid
waste
landfill.

The
overall
approach
to
answering
these
questions
consisted
of
three
separate
analyses.
First,
EPA
calculated
a
risk
loading
threshold
for
each
constituent,
which
is
the
daily
solvent
loading
to
a
municipal
landfill
that
poses
unacceptable
risks
to
human
health.
Second,
using
the
results
from
this
effort,
EPA
then
compared
the
risk
loading
threshold
for
each
F­
listed
solvent
to
the
total
solvent
loadings
disposed
of
in
a
landfill
on
a
daily
basis
to
determine
whether
the
quantity
of
F­
listed
solvent
disposed
would
pose
unacceptable
health
risks.
For
this
analysis,
the
human
health
benchmarks
were
a
hazard
quotient
(
HQ)
of
1
for
a
noncarginogen
and
a
carcinogenic
risk
of
10­
5.
Values
above
these
numbers
were
deemed
to
pose
an
unacceptable
risk
to
human
health.
In
conducting
these
analyses,
EPA
generally
used
a
deterministic
approach
(
i.
e.,
discreet
values
of
input
parameters
were
selected).

This
section
provides
some
of
the
background
on
how
solvent
from
solvent­
contaminated
industrial
wipes
could
pose
a
risk
to
human
health
and
the
environment.
In
broad
terms,
generators
use
industrial
wipes
in
conjunction
with
hazardous
solvents
and
become
a
hazardous
waste
once
the
wipes
no
longer
can
be
used.
Once
the
hazardous
waste
is
disposed
in
a
landfill,
the
solvent
contaminants
contained
on
the
wipe
may
leach,
enter
the
groundwater,
and
impact
an
offsite
receptor
drinking
water
well.
A
resident
could
be
exposed
to
these
solvent
contaminants
through
drinking
water
and
non­
ingestion
routes,
such
as
dermal
and
inhalation
exposure.
This
analysis
calculates
a
unit
risk
coefficient
per
day
for
each
solvent,
as
well
as
the
maximum
quantity
of
contaminant
that
can
be
present
in
the
landfill.

V.
B.
1.
Constituents
Evaluated
89
As
stated
elsewhere
in
this
document,
there
are
an
almost
infinite
number
of
combinations
of
solvent
blends
used
by
generating
facilities
for
cleaning
and
degreasing
operations.
Some
generators
use
blends
consisting
of
three
or
four
constituents;
others
use
pure
solvents.
Also,
many
generators
use
very
few
wipes
a
day
while
many
others
use
thousands.
In
effect,
no
two
generators
are
the
same
in
terms
of
their
solvent
use
practices.
Because
of
this
situation,
EPA
adopted
a
simplified
approach
to
estimate
unit
risks
from
disposing
of
F­
listed
solvents
in
a
municipal
landfill.

For
this
analysis
(
as
well
as
for
the
analyses
associated
with
ash
from
combustion
facilities
and
sludges
from
wastewater
treatment
processes),
EPA
evaluated
34
F­
listed
solvents
(
consolidated
to
30
because
of
overlapping
characteristics
associated
with
cresol
and
xylene
solvents)
because
the
RCRA
mixture
rule
(
40
CFR
261.3(
b))
dictates
that
any
solid
waste
mixed
with
RCRA
hazardous
waste
(
e.
g.,
wipes
mixed
with
hazardous
solvents)
is
a
hazardous
waste,
even
if
only
very
small
amounts
of
solvent
are
contained
in
the
wipe.
These
constituents
were
selected
because
they
are
expected
to
be
present
in
mixtures
of
hazardous
waste
spent
solvent
(
e.
g.,
F001
to
F005)
and
wipes.
Even
though
RCRA
regulates
other
hazardous
solvents
(
such
as
P­
and
U­
listed
commercial
chemical
products),
EPA
did
not
consider
them
for
this
analysis
because
it
had
no
information
on
the
frequency
of
occurrences
for
when
these
solvents
might
be
spilled
during
production
processes,
creating
a
waste
comparable
to
an
F­
listed
solventcontaminated
wipe.
However,
EPA
believes
these
spills
should
occur
very
infrequently
compared
to
F­
listed
solvents
used
in
normal
cleaning
operations.

Toxicity
benchmarks
for
these
30
solvents
are
included
in
Table
13.
Health
benchmarks
include
Reference
Doses
(
RfDs,
for
noncarcinogenic
effects)
and
Cancer
Slope
Factors
(
CSFs,
for
carcinogenic
effects)
for
estimating
risk
from
ingestion
and
dermal
exposures;
risks
from
inhalation
were
determined
using
Reference
Concentrations
(
RfCs,
for
noncarcinogenic
effects)
and
inhalation
unit
risk
factors
(
URFs,
for
carcinogenic
effects).
Benchmarks
were
principally
obtained
from
EPA's
Integrated
Risk
Information
System
(
IRIS),
supplemented
with
other
sources
as
appropriate
(
see
Table
13).
Most
of
the
compounds
had
oral
benchmarks
while
a
significant
number
did
not
have
inhalation
benchmarks.
90
Table
13
Constituents
Present
in
F001
to
F005
Solvents
Constituent
Solvent
Listing
Oral
Benchmark
Inhalation
Benchmark
Noncarcinogens
Nitrobenzene
F004
RfD:
0.0005
RfC:
0.002
f
Pyridine
F005
RfD:
0.001
RfC:
0.007
f
Ethyl
ether
F003
RfD:
0.2
 
Acetone
F003
RfD:
0.1
RfC:
31
f
Methanol
F003
RfD:
0.5
RfC:
13
f
Butanol
F003
RfD:
0.1
 
Carbon
disulfide
F005
RfD:
0.1
RfC:
0.7
Methyl
ethyl
ketone
F005
RfD:
0.6
RfC:
1.0
Methyl
isobutyl
ketone
F003
RfD:
0.08
f
RfC:
0.08
f
Cyclohexanone
F003
RfD:
5.0
 
2­
Ethoxyethanol
F005
RfD:
0.4
RfC:
0.2
Tetrachloroethylene
d
F002
RfD:
0.01
RfC:
0.3
f
Isobutyl
alcohol
F005
RfD:
0.3
 
Cresols
a
F004
RfD:
0.05
(
o­,
m­)
RfD:
0.005
(
p­)
f
 
Chlorobenzene
F002
RfD:
0.02
RfC:
0.02
f
Ethyl
acetate
F003
RfD:
0.9
 
Trichlorofluoromethane
d
F002
RfD:
0.3
RfC:
0.7
f
Dichlorodifluoromethane
b
F001
RfD:
0.2
RfC:
0.2
f
1,2­
Dichlorobenzene
F002
RfD:
0.09
RfC:
0.2
f
Ethyl
benzene
F003
RfD:
0.1
RfC:
1.0
Toluene
F005
RfD:
0.2
RfC:
0.4
1,1,2­
Trichlorotrifluoroethane
d
F002
RfD:
3.0
RfC:
30
f
1,1,1­
Trichloroethane
d
F002
RfD:
0.2
f
RfC:
1.0
f
Table
13
Constituents
Present
in
F001
to
F005
Solvents
Constituent
Solvent
Listing
Oral
Benchmark
Inhalation
Benchmark
91
Xylenes
(
total)
c
F003
RfD:
2.0
(
o­,
m­,
and
total)
f
 
(
o­,
m­)
RfC:
0.43
(
total)
F
Carcinogens
Methylene
chloride
d
F002
RfD:
0.06
CSF:
0.0075
RfC:
3.0
f
URF:
4.7
x
10­
7
1,1,2­
Trichloroethane
F002
RfD:
0.004
CSF:
0.057
URF:
1.6
x
10­
5
Carbon
tetrachloride
F001
RfD:
0.0007
CSF:
0.13
URF:
1.5
x
10­
5
f
2­
Nitropropane
F005
 
RfC:
0.02
URF:
2.7
x
10­
3
F
Benzene
e
F005
CSF:
0.029
e
URF:
8.3
x
10­
6
e,
f
Trichloroethylene
d
F002
CSF:
0.011
f,
g
URF:
1.7
x
10­
6
f
Sources
of
toxicity
data
are
the
Integrated
Risk
Information
System
(
IRIS),
except
otherwise
noted.
RfD
(
oral)
is
in
units
of
mg/
kg/
d.
RfC
(
inhalation)
is
in
units
of
mg/
m3.
Lower
values
correspond
to
more
severely
acute
toxicity
properties.
CSF
(
oral)
is
in
units
of
(
mg/
kg/
d)­
1.
URF
(
inhalation)
is
in
units
of
(
µ
g/
m3)­
1.
Higher
values
correspond
to
more
severe
carcinogenic
properties.
a.
The
isomers
o­,
m­,
and
p­
cresols
were
evaluated;
risks
from
`
total
cresols'
were
not
evaluated.
The
highest
risks
were
from
p­
cresol
which
were
used
to
represent
all
`
cresols.'
b.
The
F001
listing
identifies
`
chlorinated
fluorocarbons.'
Dichlorodifluoromethane
was
selected
as
one
such
compound.
Other
chlorofluorocarbons
are
explicitly
identified
in
the
F002
listing.
c.
The
isomers
o­
and
m­
xylene
were
evaluated
along
with
total
xylenes.
d.
These
compounds
are
listed
in
both
F001
and
F002
descriptions.
e.
Toxicity
data
for
benzene
was
updated
in
IRIS
subsequent
to
the
risk
analysis.
The
new
assessment
shows
slightly
lower
carcinogenic
properties
from
inhalation
(
i.
e.,
the
new
inhalation
URF
is
2.2
to
7.8
x
10­
6
(
µ
g/
m3)­
1
compared
to
the
value
of
8.3
x
10­
6
used
in
the
risk
assessment).
Carcinogenic
properties
from
oral
properties
are
approximately
unchanged
(
i.
e.,
the
new
oral
CSF
is
0.015
to
0.055
(
mg/
kg/
d)­
1
compared
to
the
value
of
0.029
used
in
the
risk
assessment).
f.
Indicates
IRIS
was
not
used
as
a
source
for
toxicity
data.
See
EPA
(
1999)
for
complete
referencing
of
all
benchmarks.
g.
EPA
has
recently
published
a
draft
health
risk
assessment
for
trichloroethylene
(
EPA,
Trichloroethylene
Health
Risk
Assessment:
Synthesis
and
Characterization
(
External
Review
Draft,
August
2001,
EPA/
600/
P­
01/
002A).
This
source
presents
a
range
of
CSFs,
of
0.02
to
0.4
(
mg/
kg/
d)­
1.
It
also
presents
an
RfD
of
0.0003
mg/
kg­
day.
The
range
of
CSFs
in
the
draft
health
risk
assessment
is
higher
than
that
used
in
the
risk
screening
assessment
for
industrial
wipes.
Additionally
the
draft
health
risk
assessment
presents
an
RfD;
EPA
did
not
assess
noncarcinogenic
effects
of
trichloroethylene
in
its
risk
screening
assessment
for
industrial
wipes.
These
new
toxicity
data
in
the
August
2001
draft
health
risk
assessment
would
result
in
higher
risks
from
this
constituent.
However,
the
August
2001
report
is
not
final
and
is
undergoing
external
review.
92
V.
B.
2.
Transport,
Fate
and
Receptor
Assumptions
Used
to
Estimate
Risk
Loading
Thresholds
The
risk
loading
threshold
was
derived
using
the
following
approach:

°
Generators
use
industrial
wipes
in
conjunction
with
a
certain
amount
(
1.3
kg/
day)
of
hazardous
solvents
on
each
wipe
to
derive
a
waste
once
the
wipes
no
longer
can
be
used.
This
quantity
(
1.3
kg/
day)
represents
the
estimated
amount
that
would
be
necessary
for
a
generator
to
become
a
large
quantity
generator
(
LQG).
However,
this
quantity
is
used
only
as
a
base
to
derive
unit
coefficients
and
does
not
reflect
the
more
complex
loading
assumptions
detailed
later
in
this
report
and
used
in
identifying
constituents
posing
unacceptable
risks.
°
The
waste
is
disposed
in
a
landfill.
°
The
solvent
contaminants
contained
on
the
wipe
leach,
enter
the
groundwater,
and
impact
an
offsite
receptor
drinking
water
well.
°
A
resident
is
exposed
to
these
solvent
contaminants
through
drinking
water
and
non­
ingestion
routes.
°
The
risk
for
each
solvent
is
calculated.
°
The
maximum
quantity
of
contaminant
that
can
be
present
in
the
landfill
is
calculated
using
a
noncarcingenic
Hazard
Quotient
(
HQ)
of
1
or
a
carcinogenic
risk
of
10­
5.
This
is
the
risk
loading
threshold.

V.
B.
2.
a.
What
Type
of
Landfill
Is
Used
for
Disposal
of
the
Waste?

The
landfill
was
assumed
to
be
an
municipal
solid
waste
landfill
(
MSWLF),
with
no
liner
or
leachate
collection
system.
This
assumption
is
consistent
with
the
approach
used
in
the
proposed
rule
to
list
certain
inorganic
chemical
manufacturing
wastes
as
hazardous
(
65
FR
55684,
September
14,
2000),
as
well
as
other
risk
assessments
for
similar
decisions
regarding
regulatory
decisions
for
hazardous
and
industrial
wastes.
Even
though
regulations
currently
specify
design
criteria
for
MSWLFs
(
40
CFR
258.40),
including
liners
and
leachate
collection,
the
assumption
that
the
landfill
is
unlined
and
has
no
leachate
collection
system
is
made,
in
part,
because
older
unlined
landfills
may
continue
to
be
operating.

Another
important
parameter
for
this
assessment
is
the
type
of
cover
used.
Many
of
the
solvent
components
are
volatile
and
can
pose
potential
risks
from
air
as
well
as
leachate
exposure
pathways.
For
this
analysis,
EPA
assumed
that
a
daily
cover
of
six
inches
is
used,
consistent
with
federal
regulations
(
40
CFR
258.21).
A
final
cover
of
30
inches
was
also
assumed
(
regulations
specify
several
layers
of
final
cover
including
18
inches
of
earthen
material
with
6
inches
of
top
soil).
Finally,
the
waste
was
assumed
to
be
added
in
layers
no
more
than
2.5
feet
deep.
The
landfill
was
assumed
to
be
operational
for
30
years.

The
screening
analysis
considered
four
specific
scenarios,
each
corresponding
to
a
different
landfill
size
and
climatic
condition
assuming
receipt
of
industrial
wipes
from
a
large
quantity
generator:

°
Median
landfill
size,
high­
end
climatic
conditions,
LQG
93
°
Median
landfill
size,
median
climatic
conditions,
LQG
°
Small
landfill
size,
high­
end
climatic
conditions,
LQG
°
Small
landfill
size,
median
climatic
conditions,
LQG
A
high­
end
(`
small')
and
central
tendency
(`
median')
landfill
were
assumed
to
be
8,100
m2
and
60,700
m2,
respectively.
These
correspond
to
the
10th
percentile
and
50th
percentile
sizes
determined
from
EPA's
1988
National
Survey
of
Solid
Waste
(
Municipal)
Landfill
Facilities.
Larger
facilities
were
not
evaluated
because
a
sensitivity
analysis
showed
that
larger
areas
were
associated
with
less
risk
for
both
leachate
and
air
releases.
As
discussed
later
in
this
section,
the
scenario
resulting
in
the
highest
receptor
risks
was
a
small
landfill
in
high­
end
climatic
conditions;
these
results
were
used
in
calculating
the
risk
loading
thresholds.
The
quantity
of
solvent
placed
in
the
landfill
was
also
varied,
however
this
variation
was
not
relevant
for
development
of
the
risk
loading
thresholds.

Contaminant
release
corresponding
to
two
climatic
conditions
were
evaluated:
those
corresponding
to
Lincoln,
Nebraska
(
central
tendency)
and
Houston,
Texas
(
high­
end).
The
central
tendency
site
was
the
same
one
identified
in
the
proposed
1995
Hazardous
Waste
Identification
Rule.
The
high­
end
site
was
selected
to
attempt
to
represent
a
case
where
releases
to
both
the
groundwater
and
air
pathways
would
be
increased.
These
were
selected
from
a
total
of
29
meteorological
regions
identified
during
the
EPA
Superfund
Soil
Screening
Level
program.

The
most
important
climatic
parameters
affecting
releases
to
the
air
are
windspeed
and
temperature,
while
the
most
important
climatic
parameter
affecting
releases
to
groundwater
is
infiltration
rate.
The
infiltration
rates
associated
with
these
conditions
correspond
to
25
cm/
yr
for
the
central
tendency
case
and
40
cm/
yr
for
the
high­
end
case.

V.
B.
2.
b.
How
Are
The
Contaminants
Assumed
to
Be
Released
from
the
Waste?

The
contaminants
in
the
waste
were
assumed
to
be
available
for
release
and
not
irreversibly
bound
to
the
matrix.
A
uniform
quantity
of
waste
was
assumed
to
be
disposed
every
day
for
350
days
per
year
for
the
entire
30­
year
operational
life
of
the
landfill.

Once
in
the
landfill,
the
contaminants
were
assumed
to
be
released
from
the
waste
to
both
the
air
and
the
leachate.
EPA
used
a
series
of
partitioning
equations
to
determine
how
much
contaminant
mass
would
be
retained
in
the
waste
management
unit
and
how
much
would
be
released
into
the
environment.
These
equations
are
based
upon
a
series
of
articles
by
Jury
and
others
(
see
EPA
1999).
EPA
used
the
partitioning
equations
to
estimate
the
mass
of
a
contaminant
that
would
be
lost
from
the
landfill
due
to
volatilization
into
the
air,
contaminant
leaching
into
the
subsurface,
and
degradation.
These
losses
were
assumed
to
occur
during
the
entire
30­
year
active
life
of
the
landfill
and
for
a
40­
year
post­
closure
period.

EPA
assumed
that
volatilization
losses
could
occur
prior
to
the
landfill
being
covered
with
daily
cover
or
daily
waste
addition,
through
the
daily
cover,
and
through
the
cap
that
is
placed
on
the
landfill
(
or
individual
cells)
after
closure.
The
landfill
model
sums
each
of
these
contributions
in
a
dynamic
fashion.
Note,
however,
that
advective
transport
was
not
considered,
which
is
the
release
of
contaminant
as
landfill
gas
(
e.
g.,
methane),
and
in
general
the
post­
closure
losses
were
94
assumed
to
be
negligible
following
the
capping
of
the
landfill.

EPA
assumed
that
leachate
losses
could
occur
during
the
pre­
and
post­
closure
periods.
In
addition,
losses
as
a
result
of
biodegredation
and
hydrolysis
were
incorporated
as
an
overall
first
order
degradation
rate
(
e.
g.,
degradation
calculated
from
a
"
half­
life").
Such
loss
rates
were
identified
from
the
literature,
where
most
data
represent
soil.

V.
B.
2.
c.
How
Are
the
Contaminants
Transported
Through
the
Environment?

The
results
of
the
previously
described
partitioning
were
used
as
inputs
to
the
subsequent
groundwater
and
air
transport
models.
The
risk
assessment
evaluated
transport
by
a
groundwater
pathway
and
an
air
pathway.
Specifically,
residents
living
near
landfills
managing
these
wastes
may
be
exposed
to
contaminated
groundwater
or
vapors.
For
all
contaminants,
the
groundwater
pathway
was
found
to
be
dominant.

Groundwater
Pathways
For
groundwater
transport,
the
highest
nine­
year
average
leachate
concentration
was
used
as
input
to
the
groundwater
modeling.
Contaminant­
specific
modeling
was
not
performed.
Instead,
an
overall
Dilution­
Attenuation
Factor
(
DAF)
was
used
to
estimate
the
dilution
between
the
landfill
and
the
receptor
well;
such
DAFs
were
similarly
used
in
EPA's
1995
soil
screening
analysis
(
see
EPA
1999).
The
contaminant
was
assumed
to
reach
an
off­
site
drinking
water
well
which
serves
as
an
exposure
point
to
a
receptor.

In
the
soil
screening
analysis,
EPA's
Composite
Model
for
Leachate
Migration
with
Transformation
Products
(
EPACMTP)
was
used
in
a
Monte
Carlo
framework.
In
this
framework,
values
for
different
parameters
affecting
fate
and
transport
are
randomly
selected
within
the
constraints
of
their
range
in
thousands
of
iterations,
resulting
in
a
corresponding
thousands
of
values
for
the
calculated
DAFs.
The
DAF
corresponding
to
the
95th
percentile
was
selected
for
each
landfill
area
size.
The
Monte
Carlo
analysis
varied
the
receptor
well
location
anywhere
within
the
groundwater
transport
plume
up
to
one
mile
from
the
source.
As
a
result
of
this
analysis,
a
constant
DAF
of
11
was
used
in
the
solvent­
contaminated
industrial
wipes
analyses
with
the
median
size
landfill,
and
a
constant
DAF
of
27
was
used
in
analyses
with
the
small
size
landfill.
Additional
analyses
were
presented
in
EPA
(
1999)
assuming
a
very
close
receptor
well
(
i.
e.,
more
conservative)
and
assuming
a
liner
was
present
(
i.
e.,
less
conservative),
although
results
are
not
presented
here
or
used
for
calculation
of
the
risk
loading
thresholds.

Air
Pathways
For
air
transport,
the
Industrial
Source
Complex
Short
Term
Model
(
ISCST3)
was
used
to
model
the
dispersion
of
volatile
compounds
from
the
landfill
to
a
receptor
located
75
meters
from
the
source.
The
contaminant
was
diluted
by
transport
and
removed
prior
to
reaching
the
receptor
by
deposition.
The
receptor
becomes
exposed
via
inhalation
of
the
contaminant.

Note
that
while
biodegredation
of
the
organic
constituents
was
considered
in
the
landfill,
no
degradation
effects
were
considered
in
the
media
transport
pathways.
95
V.
B.
2.
d.
What
Receptors
Were
Considered?

Risks
associated
with
the
following
exposure
pathways
were
considered
for
each
constituent:

°
inhalation
of
vapors
transported
off
site
as
vapors
°
groundwater
ingestion
°
indirect
exposure
of
groundwater
including
inhalation
in
the
shower,
bathroom,
and
whole
house,
as
well
as
indirect
dermal
exposure
of
groundwater.

All
of
the
pathways
consider
two
receptors:
adult
farmer
and
child.
Appropriate
intake
assumptions
for
each
receptor
were
obtained
from
EPA's
1997
Exposure
Factors
Handbook
(
EPA,
1997a)
and
are
described
in
detail
in
EPA
(
1999).
In
general,
average
values
were
used
for
most
of
the
exposure
parameters.

Inhalation
risk
factors
are
estimated
for
a
child
in
Houston
exposed
for
12
hours
to
constituents
disposed
of
by
a
LQG
in
a
small
landfill
75
meters
from
the
child's
home.
Groundwater
ingestion
risk
factors
are
estimated
for
a
child
in
Houston
ingesting
groundwater
from
a
well
located
downgradient
of
a
small
landfill
containing
constituents
disposed
of
by
a
LQG
(
well
distance
is
determined
by
national
distribution).
Indirect
exposure
factors
are
determined
by
adding
the
HQs
for
inhalation
of
the
constituent
in
the
shower,
bathroom,
and
whole
house.
These
HQs
are
calculated
using
a
unit
concentration
for
the
constituent's
concentration
in
groundwater.
The
HQ
calculations
for
dermal
exposure
were
also
based
on
the
constituent's
concentration
in
groundwater.

Separate
risks
were
calculated
for
each
of
the
four
landfill
management
scenarios
discussed
above.
For
each
scenario,
risks
were
determined
for
the
direct
inhalation
of
the
landfill
vapors,
ingestion
of
contaminated
drinking
water,
and
indirect
exposure
from
household
use
of
water.
Both
adult
and
child
receptors
were
considered
in
the
risk
screening.

EPA
evaluated
carcinogens
at
a
risk
loading
threshold
of
10­
5,
the
same
level
used
in
the
proposed
rule
to
list
chlorinated
aliphatics
wastes
as
hazardous
wastes.
In
that
proposal,
EPA
considered
a
decision
to
list
wastes
if
the
carcinogenic
risks
are
10­
5
or
higher
(
64
FR
46489,
August
25
1999).

For
each
constituent,
the
exposure
resulting
from
all
sources
of
groundwater
(
i.
e.,
ingestion,
inhalation,
and
dermal
exposures)
were
summed.
Additionally,
risks
resulting
from
carcinogen
exposure
were
summed
(
i.
e.,
this
affected
each
of
the
six
contaminants
with
carcinogenic
effects
identified
in
Table
13).

Carcinogens
are
assumed
to
have
cumulative
effects,
such
that
exposure
to
multiple
carcinogens
would
present
a
greater
risk
than
risks
to
a
single
constituent.
In
this
analysis,
such
effects
were
accounted
for
by
first
calculating
the
risks
posed
by
individual
constituents.
The
cumulative
risks
were
calculated
by
also
adding
the
risks
from
all
other
lower
toxicity
carcinogens.
The
risk
loading
thresholds
were
subsequently
calculated
from
these
cumulative
risks.
This
impact
is
shown
in
Table
14
for
the
six
carcinogens.
The
additional
toxicity
is
96
calculated
by
dividing
the
sum
of
carcinogenic
risks
from
all
other
carcinogenic
contaminants
by
the
risk
from
the
individual
contaminant.

For
noncarcinogens,
the
contaminants
are
assumed
to
have
independent
effects
(
i.
e.,
if
a
receptor
is
exposed
to
both
methanol
and
acetone,
the
compounds
are
assumed
to
affect
different
parts
of
the
body).
Therefore,
risks
from
different
noncarcinogens
are
not
`
summed.'

Table
14
Carcinogenic
Effects
of
Solvent
Constituents
For
the
following
contaminant
with
carcinogenic
effects...
The
additional
toxicity
due
to
additive
effects
is...

2­
Nitropropane
1x
(
Additional
toxicity
is
negligible
due
to
high
toxicity
of
this
contaminant.)

Methylene
chloride
1.9
x
Benzene
2.6
x
1,1,2­
Trichloroethane
1.5
x
Carbon
tetrachloride
1.1
x
Trichloroethylene
1x
(
No
additional
effect
because
this
contaminant
is
the
least
toxic)

V.
B.
2.
e.
What
Are
the
Results?

The
calculated
risk
loading
thresholds
are
presented
in
Table
15.
This
table
presents,
for
each
F­
listed
constituent,
the
risks
from
various
pathways
assuming
a
loading
of
1.3
kg/
day
per
landfill.
The
sum
of
risks
from
these
pathways
are
determined
in
the
next
to
last
column.
The
last
column
presents
the
calculated
risk
loading
threshold,
in
kg/
day.
This
amount
is
intended
to
signify
the
quantity
of
contaminant
that
can
be
placed
in
a
landfill
to
result
in
an
HQ
of
1
or
a
carcinogenic
risk
of
10­
5.
It
is
calculated
by
proportion.
For
example,
in
the
case
of
acetone,
a
risk
of
HQ=
0.75
results
from
a
landfill
loading
of
1.3
kg/
day.
Therefore,
by
simple
proportion,
an
HQ=
1
is
expected
to
result
from
a
landfill
loading
of
1.7
kg/
day.
This
assumes
linear
performance
of
all
models;
the
uncertainty
and
limitation
of
this
assumption
are
discussed
in
section
V.
B.
6.

Groundwater
receptor
well
concentrations
were
calculated
for
each
of
the
four
different
combinations
of
climatic
conditions
and
landfill
size.
The
highest
concentrations
were
selected
for
use
in
subsequent
calculations;
the
highest
concentrations
resulted
from
the
small
landfill
in
a
high­
end
climate
(
Houston,
TX),
although
there
was
very
little
difference
in
the
results
from
the
two
locations.

Risks
from
groundwater
exposure
were
determined
by
adding
risks
from
ingesting
the
water,
from
various
inhalation
pathways,
and
from
dermal
exposure.
Each
of
these
routes
of
97
exposure
was
summed
to
identify
the
total
risk
from
a
particular
contaminant
resulting
from
all
pathways.

The
results
of
the
last
two
columns
illustrate
which
F­
listed
solvents
could
pose
a
problem
if
disposed
in
a
landfill.
For
example,
the
risk
loading
threshold
derived
for
nitrobenzene
using
the
above
assumptions
is
only
0.043
kg/
day.
Therefore,
even
very
little
nitrobenzene
disposed
in
a
landfill
on
a
daily
basis
may
pose
a
risk.
Conversely,
the
risk
loading
threshold
for
ethy
ether
is
4.30
kg/
day.
Therefore,
larger
amounts
of
this
solvent
could
be
disposed
without
posing
an
unacceptable
risk
to
human
health.

The
magnitude
of
these
risk
loading
thresholds
differ
substantially,
from
0.003
kg/
day
(
for
2­
nitropropane)
to
403
kg/
day
(
for
1,1,2­
trichlorotrifluoroethane).
Additionally,
the
dominant
exposure
pathway
is
different
depending
on
the
constituents,
split
between
groundwater
ingestion
and
indirect
inhalation
from
groundwater
use.
This
difference
in
risk
loading
thresholds
is
due
to
several
factors,
including
the
following:

°
Differing
toxicity
between
chemicals:
as
shown
in
Table
13,
the
carcinogenic
URF
for
2­
nitropropane
is
very
high,
suggesting
high
toxicity.
Both
the
noncarcinogenic
RfD
and
RfC
for
1,1,2­
trichlorofluoroethane
are
very
high,
suggesting
low
toxicity.

°
Chemical
properties:
chemical
properties
such
as
degradation
rates,
Henry's
Law
constant,
and
solubility
affect
partitioning
between
leachate,
air,
and
solid
in
the
landfill
waste
and/
or
between
air
and
water
in
the
receptor's
house.

°
Differing
toxicity
between
routes
of
exposure:
as
shown
in
Table
13,
many
compounds
do
not
have
inhalation
exposure
benchmarks,
and
therefore
risks
from
inhalation
pathways
were
not
estimated
for
these
constituents.
98
Table
15
Risk
Loading
Threshold
Results
Constituent
Relative
Risk
(
as
HQ
or
carcinogenic
risk),
based
on
disposal
of
1.3
kg
contaminant/
day
in
a
landfill
Resulting
Risk
Loading
Threshold
(
kg/
d,
per
landfill)
From
Direct
Inhalation
From
Ground­
Water
Ingestio
n
From
Indirect
Ground­
Water
Exposure
(
Inhalation)
From
Indirect
Ground­
Water
Exposure
(
Dermal)
Sum
of
Risk
from
Pathways
Noncarcinogens
(
Risk
expressed
as
hazard
quotient)

Nitrobenzene
(
F004)
(
U169)
0.00013
5
25
0.195
30
0.043
Pyridine
(
F005)
(
D038)
(
U196)
0.0003
90
120
0.78
211
0.006
Ethyl
ether
(
F003)
(
U117)
 
0.3
 
0.002
0.30
4.30
Acetone
(
F003)
(
U002)
0.000002
0.7
0.05
0.001
0.75
1.73
Methanol
(
F003)
(
U154)
0.000002
0.2
0.02
0.0002
0.22
5.90
Butanol
(
F003)
(
U031)
 
0.8
 
0.005
0.81
1.61
Carbon
disulfide
(
F005)
(
P022)
0.00007
0.08
2
0.0035
2.1
0.62
Methyl
ethyl
ketone
(
F005)
(
D035)
(
U159)
0.00003
0.1
4
0.00072
4.1
0.32
Methyl
isobutyl
ketone
(
F003)
(
U161)
0.0002
0.6
42
0.007
43
0.03
Cyclohexanone
(
F003)
(
U057)
 
0.02
 
0.0001
0.020
64.55
2­
Ethoxyethanol
(
F005)
(
U359)
0.000008
0.3
0.04
0.0005
0.34
3.82
Tetrachloroethylene
(
F002)
(
D039)
(
U210)
0.0001
0.02
0.2
0.003
0.22
5.83
Isobutyl
alcohol
(
F005)
(
U140)
 
0.3
 
0.0015
0.30
4.31
Cresols
a
(
F004)
(
D023
to
D026)
(
U052)
 
3
 
0.16
3.2
0.41
Chlorobenzene
(
F002)
(
D021)
(
U037)
0.0004
0.02
3.6
0.003
3.6
0.36
Ethyl
acetate
(
F003)
(
U112)
 
0.08
 
0.00042
0.080
16.17
Trichlorofluoromethane
(
F002)
(
U121)
0.00007
0.0009
0.08
0.00009
0.081
16.05
Dichlorodifluoromethane
(
F001)
(
U075)
0.0002
0.003
0.6
0.0002
0.60
2.16
Table
15
Risk
Loading
Threshold
Results
Constituent
Relative
Risk
(
as
HQ
or
carcinogenic
risk),
based
on
disposal
of
1.3
kg
contaminant/
day
in
a
landfill
Resulting
Risk
Loading
Threshold
(
kg/
d,
per
landfill)
From
Direct
Inhalation
From
Ground­
Water
Ingestio
n
From
Indirect
Ground­
Water
Exposure
(
Inhalation)
From
Indirect
Ground­
Water
Exposure
(
Dermal)
Sum
of
Risk
from
Pathways
99
1,2­
Dichlorobenzene
(
F002)
(
U070)
0.000002
0.0008
0.1
0.0005
0.10
12.84
Ethyl
benzene
(
F003)
0.000009
0.007
0.1
0.002
0.11
11.95
Toluene
(
F005)
(
U220)
0.00005
0.006
0.6
0.001
0.61
2.14
1,1,2­
Trichlorotrifluoroethane
(
F002)
0.000002
0.00002
0.0032
0.000003
0.0032
403.37
1,1,1­
Trichloroethane
(
F002)
0.00004
0.002
0.08
0.0002
0.082
15.81
Xylenes
(
total)
b
(
F003)
(
U239)
0.00001
0.0002
0.21
0.00007
0.21
6.18
Carcinogens
(
Risk
expressed
as
carcinogenic
risk)

Methylene
chloride
(
F002)
(
U080)
4x10­
9
1.5x10­
5
2.1x10­
6
2.7x10­
7
I=
1.7x10­
5
C=
3.3x10­
5
0.39
1,1,2­
Trichloroethane
(
F002)
(
U227)
3x10­
8
7x10­
6
4x10­
6
4x10­
7
I=
1.1x10­
5
C=
1.6x10­
5
0.83
Carbon
tetrachloride
(
F001)
(
D019)
(
U211)
9x10­
8
2.6x10­
6
8x10­
7
4x10­
7
I=
3.8x10­
6
C=
4.3x10­
6
3.0
2­
Nitropropane
(
F005)
(
U171)
9x10­
6
 
4x10­
3
 
I=
4x10­
3
C=
4x10­
3
0.003
Benzene
c
(
F005)
(
D018)
(
U019)
5x10­
8
1.3x10­
5
7x10­
6
1.1x10­
6
I=
2.1x10­
5
C=
5.4x10­
5
0.24
Trichloroethylene
(
F002)
(
D040)
(
U228)
7x10­
9
2.7x10­
7
1.5x10­
7
5x10­
8
I=
4.7x10­
7
C=
4.7x10­
7
27.66
For
`
Sum
of
Risk
Pathways'
for
carcinogens,
`
I'
refers
to
risks
from
the
individual
compound,
while
`
C'
refers
to
the
sum
of
risks
from
all
other
carcinogenic
compounds
of
less
toxicity.
The
risk
loading
threshold
is
based
on
the
higher,
`
C'
results.
Source
of
relative
risk
results:
U.
S.
Environmental
Protection
Agency.
Estimating
the
Risk
from
the
Disposal
of
Solvent­
Contaminated
Shop
Towels
and
Wipes
in
Municipal
Landfills."
March
1999.
The
risk
loading
thresholds
were
calculated
from
these
results.
Relative
risk
shows
HQ
or
carcinogenic
risks
resulting
from
disposal
of
1.3
kg/
day
in
a
landfill,
which
was
necessary
to
conduct
a
`
forward'
calculation.
Risk
loading
thresholds
show
disposal
rate
that
results
in
an
HQ=
1
or
carcinogenic
risk
=
10­
5.
This
was
calculated
by
dividing
1.3
kg/
day
by
the
sum
of
risk
from
all
pathways
(
which
based
on
a
1.3
kg/
day
disposal
rate),
and
multiplying
by
HQ=
1
or
carcinogenic
risk
=
10­
5.
Shading
indicates
the
dominant
exposure
pathway.
a.
The
isomers
o­,
m­,
and
p­
cresols
were
evaluated
individually;
risks
from
p­
cresol
were
greatest
and
presented
here.
b.
The
isomers
o­
and
m­
xylene,
and
total
xylenes,
were
evaluated
individually;
risks
from
total
xylenes
were
greatest
and
presented
here.
100
c.
Updated
toxicity
data
for
benzene
on
IRIS
shows
slightly
lower
carcinogenic
properties
from
inhalation
compared
to
those
used
here.
Because
indirect
inhalation
exposure
is
not
a
`
driver'
in
this
analysis
when
using
the
older
toxicity
information,
the
toxicity
reassessment
should
not
have
a
significant
effect
on
this
analysis.

V.
B.
3.
Estimating
Total
Risks
from
All
Sources
Disposing
Solvent­
Contaminated
Industrial
Wipes
in
a
Landfill
V.
B.
3.
a.
What
Data
was
Used
to
Estimate
Risk?

The
above
analysis
calculated
the
maximum
quantity
of
F­
listed
solvent
constituents
that
can
be
disposed
each
day
in
a
landfill
such
that
resulting
risks
to
human
health
would
equal
an
HQ
of
1
or
a
carcinogenic
risk
of
10­
5.
Using
these
risk
loading
thresholds,
EPA
compared
the
thresholds
to
the
estimated
quantity
of
each
solvent
expected
to
result
from
disposing
industrial
wipes.
To
conduct
the
analysis,
EPA
looked
at
the
following
seven
categories
of
data.

Number
of
Disposable
Industrial
Wipes
Used
Annually
by
Small
and
Large
Quantity
Generators
The
number
of
disposable
industrial
wipes
used
nationwide
was
estimated
in
2001
to
be
1.009
billion,
consisting
of
49.8
million
printer
wipes
and
959.2
million
non­
printer
wipes.
These
estimates
were
made
using
data
supplied
by
a
trade
association
(
Association
of
the
Nonwoven
Fabrics
Industry)
for
1997.
These
were
updated
to
2001
based
on
the
average
annual
economic
growth
using
the
`
Industrial
Production
Index'
for
each
of
13
industries
which
use
wipes.

Number
of
Days
Landfill
Operates;
Number
of
Landfills
Nationally;
Concentration
of
Facilities
Sending
their
Wipes
to
a
Single
Landfill
For
this
analysis,
EPA
also
distinguished
between
printer
wipes
and
non­
printer
wipes
since
the
printing
industry
appears
to
use
much
larger
amounts
of
wipes
and
larger
amounts
of
solvent
on
each
wipe
compared
to
most
other
industries.
Also,
because
certain
parts
of
the
country
have
more
generators
per
landfill
than
other
parts
of
the
country,
EPA
introduced
the
variable
"
concentration
of
facilities
sending
their
wipes
to
a
single
landfill"
to
account
for
this
situation.

In
the
U.
S.,
there
were
2,514
landfills
in
1997
(`
The
State
of
Garbage
in
America,'
BioCycle,
April
1998).
This
is
an
average
of
about
50
landfills
per
state.
However,
some
areas
of
the
country
are
expected
to
have
fewer
landfills.
The
five
states
with
the
fewest
number
of
landfills
(
Connecticut,
Rhode
Island,
Delaware,
Vermont,
and
Maine)
have
a
total
of
24
landfills,
or
an
average
of
about
5
landfills
per
state.
This
is
about
ten
times
less
than
the
national
average.
This
factor
of
ten
is
incorporated
into
the
risk
screening
assessment
as
a
high­
end
parameter.
This
parameter
is
intended
to
identify
regional
effects
where
a
relatively
large
number
of
generators
is
using
a
relatively
small
number
of
landfills,
resulting
in
a
higher
landfill
loading
rate
of
solventcontaminated
industrial
wipes
in
certain
localities.

EPA
assumed
the
landfills
operate
350
days
per
year.

Percentage
of
Disposable
Industrial
Wipes
Containing
F­
Listed
Solvents
The
likelihood
that
a
facility
would
use
an
F­
listed
solvent
was
estimated
to
be
35
percent.
20Based
on
a
survey
of
used
wipe
disposal
practices
for
printers,
18
percent
of
facilities
indicated
that
they
used
methyl
ethyl
ketone,
27
percent
reported
using
acetone,
20
percent
reported
using
xylene,
and
20
percent
reported
using
toluene.
Based
on
this
data
(
all
of
which
represent
F­
listed
solvents),
EPA
assumed
that
25
percent
of
facilities
use
F­
listed
solvents.

21
The
basis
for
this
has
been
information
from
the
printing
industry
identifying
that
10
percent
of
solvents
identified
in
the
industry
were
nonhazardous,
10
percent
were
listed,
and
80
percent
were
characteristic.
Characteristic
wastes
comprise
TC
and
ignitable­
only
wastes;
EPA
assumed
that
a
portion
(
10
percent)
are
TC.

101
This
assumes
that
facilities
use
F­
listed
solvents
25
percent
of
the
time
and
toxicity
characteristic
(
TC)
solvents
10
of
the
time.
The
basis
for
the
25
percent
value
is
data
from
the
Screenprinting
and
Graphic
Imaging
Association
International
(
SGIA
1998a).
20
The
10
percent
value
is
an
assumption
also
based
on
information
from
the
printing
industry.
21
Percentage
of
Wipes
that
Could
Contain
a
Given
F­
listed
Solvent
The
likelihood
that
the
F­
listed
solvent
would
contain
the
subject
contaminant
is
highly
uncertain
because
representative
data
are
not
available.
Each
constituent
was
assigned
a
value
of
10
percent
or
50
percent.
This
signifies
that
if
a
facility
actually
uses
an
F­
listed
solvent
(
which,
as
described
above,
is
assumed
to
only
occur
at
35
percent
of
facilities
anyway),
then
this
is
the
probability
that
the
subject
contaminant
would
be
present.
These
numbers
were
arbitrarily
selected.
The
following
approach
was
used
in
assigning
a
value
of
10
percent
or
50
percent
to
each
constituent:

°
Data
characterizing
solvent
composition
in
three
sectors
(
printing,
furniture,
autobody
repair)
were
prepared
as
an
addendum
to
SAIC,
"
Use
and
Management
Practices
of
Solvent
Contaminated
Industrial
Shop
Towels,"
Final
Report,
1997.
A
total
of
15
different
F­
listed
constituents
were
found
in
the
solvents
identified.
Each
of
these
constituents
were
assigned
a
value
of
50
percent
since
their
use
in
solvents
is
documented.
These
15
constituents
are
acetone,
butanol,
o­
cresol,
isobutanol,
methanol,
methyl
ethyl
ketone,
ethyl
acetate,
tetrachloroethylene,
cyclohexanone,
ethyl
benzene,
toluene,
1,1,1­
trichloroethane,
trichlorofluoromethane,
xylenes,
and
methylene
chloride.

°
Three
compounds
considered
to
be
less
toxic
were
assigned
a
probability
of
50
percent.
It
was
assumed
that
facilities
would
use
these
less
toxic
components
preferentially
over
more
toxic
components.
These
three
compounds
are
1,1,2­
trichlorotrifluoroethane,
m­
xylene,
and
o­
xylene.
(
Note
that
data
for
the
xylene
isomers
are
not
presented
in
Table
15.)

°
The
remaining
constituents
were
assigned
a
value
of
10
percent.

Concentration
of
Each
F­
Listed
Solvent
The
percentage
of
contaminant
likely
to
be
present
in
a
solvent
also
has
high
uncertainty
and
variability.
A
solvent
can
contain
contaminant
concentrations
ranging
from
less
than
1
percent
102
to
100
percent.
Data
characterizing
solvent
composition
in
three
sectors
(
printing,
furniture,
and
autobody
repair)
were
prepared
as
an
addendum
to
SAIC,
"
Use
and
Management
Practices
of
Solvent
Contaminated
Industrial
Shop
Towels,"
Final
Report,
1997.
A
total
of
15
different
F­
listed
constituents
were
found
in
the
solvents
identified
(
these
15
constituents
are
identical
to
those
identified
above).
For
each
constituent
in
each
industry,
a
range
was
developed
using
the
data
in
the
SAIC
(
1997)
report.
For
constituents
with
no
data,
an
arbitrary
range
of
5
to
50
percent
was
used
which
corresponded,
approximately,
to
the
range
for
most
constituents
with
composition
data.
The
arbitrary
percentage
range
is
uncertain
because
the
data
are
not
representative
of
the
evaluated
industries.
For
this
analysis
an
average
(
rather
than
a
maximum)
concentration
was
used.
The
average
concentration
was
calculated
as
the
arithmetic
mean
between
the
two
extremes
of
the
range.
A
`
floor'
of
ten
percent
was
established
for
each
constituent
to
be
consistent
with
the
F001
to
F005
definition.
For
each
of
the
30
constituents,
the
concentrations
ranged
from
10
to
51
percent;
the
exact
concentration
used
was
constituent­
dependent.

Amount
of
Solvent
Contained
on
Each
Wipe
This
analysis
assumed
that
dry
wipe
weight
was
25
grams.
However,
the
amount
of
solvent
contained
on
each
wipe
is
dependent
on
industry
type.
It
was
assumed
that
wipes
from
printer
facilities
contain
25
grams
of
solvent
whereas
wipes
from
non­
printer
facilities
contain
only
12.5
grams
of
solvent.
Therefore,
a
solvent
to
wipe
ratio
of
1
for
printers
and
0.5
for
non­
printers
was
used.

This
estimate
was
derived
from
data
collected
from
EPA
site
visits.
These
amounts
were
calculated
by
first
weighing
and
measuring
the
dry
wipe,
giving
it
to
the
worker
to
add
solvent
to
it,
and
measuring
the
weight
a
second
time.
The
data
were
used
to
calculate
a
ratio
of
solvent
added
to
dry
wipe
weight;
a
high
ratio
indicates
that
a
large
amount
of
solvent
is
used
as
compared
to
the
size
and
weight
of
the
wipe.
As
expected,
there
is
wide
variability
in
the
amount
of
solvent
placed
on
all
types
of
wipe.
Some
of
the
facilities
visited
apply
relatively
small
amounts
of
solvent
to
each
wipe
(
i.
e.,
the
solvent/
wipe
ratio
ranges
from
0.1
to
1).
Other
facilities
used
solvent
in
a
ratio
between
2
and
3,
while
one
facility
had
a
ratio
of
7,
representing
a
saturated
wipe.
Conclusions
from
this
investigation
were
that
(
1)
within
a
facility
or
industry,
different
tasks
require
different
quantities
of
solvent;
and
(
2)
the
ratios
for
facilities
within
the
printing
industry
were
generally
higher
than
the
ratios
from
other
facilities,
such
as
those
in
the
auto
body
industry.
The
selected
solvent
quantities
represent
the
middle
of
the
distribution,
as
determined
from
the
site
visits.

Percentage
of
Wipes
that
will
be
Landfilled
(
Rather
than
Combusted)

The
percentage
of
disposable
industrial
wipes
that
are
actually
managed
in
a
landfill
was
assumed
to
be
78
percent.
This
is
equal
to
the
quantity
of
municipal
solid
waste
landfilled
(
118
million
tons
in
1995)
divided
by
the
quantity
of
municipal
solid
waste
discarded
(
152
million
tons
in
1995).
The
difference
is
the
quantity
combusted
(
EPA
1997b).

Finally,
the
results
of
these
calculations
were
converted
to
a
landfill
basis,
for
use
in
conjunction
with
the
risk
loading
thresholds.
This
conversion
accounts
for
multiple
generators
using
a
single
landfill.
103
V.
B.
3.
b.
Summary
of
Assumptions
Used
to
Estimate
Risk
Table
16
summarizes
the
assumptions
used
for
this
analysis.
Note
that
with
the
exception
of
solvent
concentration
and
percentage
of
wipes
containing
a
specific
solvent,
all
of
the
other
assumptions
discussed
above
are
fixed
regardless
of
the
contaminant.
104
Table
16
Variable
and
Assumptions
Used
in
Estimating
Total
Risks
from
Disposing
of
Solvent­
Contaminated
Industrial
Wipes
in
a
Landfill
Variable
Assumptions
Factors
Affecting
Contaminant
Quantity
Number
of
Disposable
Industrial
Wipes
Used
Annually
Estimated
at
1.009
billion
wipes
using
Census
data
and
trade
association
data
Percentage
of
wipes
containing
F­
listed
solvents
Only
35
percent
of
facilities
are
assumed
to
use
F­
listed
solvent.
Other
solvents
are
not
evaluated
(
as
discussed
in
section
V.
B.
1).

Percentage
of
wipes
that
could
contain
a
given
F­
listed
solvent
Each
constituent
was
assigned
a
probability
of
10
or
50
percent
of
being
present
in
a
solvent,
based
on
usage
information
from
site
visits,
etc.

Concentration
each
F­
listed
solvent
Constituents
were
assumed
to
be
present
as
a
mixture,
with
concentration
ranging
from
10
to
51
percent
based
on
site
visits
and
Material
Safety
Data
Sheets
(
MSDSs)

Amount
of
solvent
contained
on
each
wipe
Disposables
from
printers
were
assumed
to
have
a
solvent
weight
of
25
grams,
whereas
disposables
from
non­
printers
were
assumed
to
have
a
solvent
weight
of
12.5
grams.

Factors
Affecting
the
Landfill
Universe
Percentage
of
wipes
that
will
be
landfilled
(
as
compared
to
combustion)
Only
facilities
using
MSWLFs,
rather
than
municipal
waste
combustors
(
MWCs),
were
considered
here.
Seventy­
eight
(
78)
percent
of
municipal
solid
waste
(
MSW)
is
landfilled,
22
percent
combusted.

Number
of
days
landfill
operates
350
days,
assumed
Number
of
landfills
nationally
2,514
based
on
1997
BioCycle
survey
data
Concentration
of
facilities
sending
their
wipes
to
a
single
landfill
A
factor
of
10
was
used,
as
a
high­
end
parameter,
to
account
for
localized
effects
of
a
relatively
large
number
of
generators
clustered
near
a
relatively
small
number
of
landfills.
105
The
overall
calculation
is
summarized
below:

1,009
million
number
of
disposables
used
by
LQGs
and
SQGs
×
0.35
fraction
with
F­
listed
constituents
×
0.78
fraction
landfilling
(
rather
than
combusting)
disposable
industrial
wipes
×
0.1
or
0.5
fraction
using
given
constituent
×
0.1
to
0.51
fraction
of
constituent
in
solvent
(
based
on
arithmetic
average
concentration)
×
[(
0.049
×
fraction
of
disposables
used
by
printers
25)
+
grams
of
solvent
per
wipe
for
a
printer
(
0.951
×
fraction
of
disposables
used
by
non­
printers
12.5)]
grams
of
solvent
per
wipe
for
a
non­
printer
×
10
concentration
of
facilities
to
a
single
landfill,
above
the
national
average
(
high­
end
parameter)
/
350
days
per
year
that
landfill
operates
/
2,514
number
of
landfills
nationwide
1.13
to
10.4
kg/
day
loading
to
landfill,
depending
on
the
contaminant
Based
on
the
calculations,
it
is
assumed
that
from
1.13
to
10.4
kg/
day
of
a
constituent
is
disposed
at
a
single
landfill
(
depending
on
the
constituent).

What
if
Solvent
Loading
is
Reduced
by
Centrifuging?

As
part
of
this
analysis,
EPA
also
examined
the
potential
risks
assuming
less
solvent
was
present
on
the
disposable
wipe.
This
analysis
assumes
generators
use
an
advanced
solvent
extraction
technology,
such
as
centrifuging,
where
greater
than
90
percent
of
solvent
is
removed.

V.
B.
4
Risks
from
Landfilling
Disposables
Results
of
the
risks
from
landfilling
disposables
in
landfills
are
presented
in
Table
17.
This
table
presents
the
following
information
for
each
constituent:

°
The
risk
loading
threshold,
derived
in
section
V.
B.
2.
As
previously
described,
reasons
for
different
limits
include
differences
in
toxicity
and
physical/
chemical
properties.

°
The
landfill
loading,
derived
in
section
V.
B.
3.
This
quantity
is
dependent
on
the
contaminant
and
varies
from
a
low
of
1.13
kg/
day/
landfill
for
a
number
of
contaminants,
to
a
high
of
10.4
kg/
day/
landfill
for
methylene
chloride.
As
previously
described,
reasons
for
different
loading
between
constituents
include
differences
in
the
frequency
of
use
and
its
concentration.

°
Landfill
loading,
assuming
a
centrifuge
is
present.
For
this
analysis,
the
landfill
loadings
were
multiplied
by
10
percent,
as
described
in
section
V.
B.
3.
106
°
One
of
three
conclusions
based
on
a
comparison
between
the
risk
loading
threshold
and
the
landfill
loading:

°
If
the
risk
loading
threshold
is
greater
than
the
landfill
loading,
then
EPA
concludes
that
the
contaminant
is
unlikely
to
present
a
risk
given
the
assumptions
used
in
the
risk
assessment.
The
contaminant
is
identified
as
`
Acceptable.'

°
If
the
risk
loading
threshold
is
less
than
the
landfill
loading
(
even
assuming
a
centrifuge
is
present),
then
EPA
concludes
that
the
contaminant
is
likely
to
present
a
risk
given
the
assumptions
used
in
the
risk
assessment.
The
contaminant
is
identified
as
`
Ineligible.'

°
If
the
risk
loading
threshold
is
between
the
landfill
loadings
for
centrifuged
and
not
centrifuged
wipes,
then
EPA
concludes
that
the
contaminant
is
unlikely
to
present
a
risk
as
long
as
centrifuging
is
conducted
prior
to
disposal.
The
contaminant
is
identified
as
`
Centrifuge
Required.'

In
summary,
Table
17
shows
that
of
the
30
constituents
evaluated,
16
constituents
are
acceptable,
8
are
acceptable
only
if
centrifuged
beforehand,
and
the
remaining
6
are
ineligible
because
the
projected
loading
is
higher
than
the
risk
loading
threshold.
More
specifically,
the
following
constituents
were
found
for
the
above
three
categories:

°
Acceptable
(
16
constituents):
carbon
tetrachloride,
cyclohexanone,
1,2­
dichlorobenzene,
dichlorodifluoromethane,
2­
ethoxyethanol,
ethyl
acetate,
ethyl
benzene,
ethyl
ether,
isobutyl
alcohol,
methanol,
tetrachloroethylene,
1,1,1­
trichloroethane,
trichloroethylene,
trichlorofluoromethane,
1,1,2­
trichlorotrifluoroethane,
xylenes.

°
Centrifuge
required
(
8
constituents):
acetone,
benzene,
butanol,
carbon
disulfide,
chlorobenzene,
cresols,
toluene,
1,1,2­
trichloroethane.

°
Ineligible
(
6
constituents):
nitrobenzene,
pyridine,
methylene
chloride,
methyl
ethyl
ketone,
methyl
isobutyl
ketone,
2­
nitropropane.
107
Table
17
Evaluation
of
Disposable
Solvent­
Contaminated
Industrial
Wipes
for
Landfilling
CAS
No.
Constituent
(
RCRA
Waste
Codes)
Risk
Loading
Thresholda
(
kg/
d,
per
landfill)
Loading
(
kg/
day,
per
landfill)
Loading
Assuming
Centrifuging
(
kg/
day,
per
landfill)
Conclusion
Noncarcinogens
67­
64­
1
Acetone
(
F003)
1.73
4.72
0.47
Centrifuge
required
71­
36­
3
Butanol
(
F003)
1.61
2.05
0.21
Centrifuge
required
75­
15­
0
Carbon
disulfide
(
F005)
0.62
1.13
0.11
Centrifuge
required
108­
90­
7
Chlorobenzene
(
F002)
(
D021)
0.36
1.13
0.11
Centrifuge
required
108­
94­
1
Cyclohexanone
(
F003)
64.55
2.05
0.21
Acceptable
1319­
77­
3
Cresols
(
F004)
(
D023)
(
D024)
(
D025)
(
D026)
0.41
1.13
0.11
Centrifuge
required
75­
71­
8
Dichlorodifluoromethane
(
F001)
2.16
1.13
0.11
Acceptable
95­
50­
1
1,2­
Dichlorobenzene
(
F002)
12.84
1.13
0.11
Acceptable
141­
78­
6
Ethyl
acetate
(
F003)
16.17
2.46
0.25
Acceptable
100­
41­
4
Ethyl
benzene
(
F003)
11.95
2.05
0.21
Acceptable
60­
29­
7
Ethyl
ether
(
F003)
4.30
1.13
0.11
Acceptable
110­
80­
5
2­
Ethoxyethanol
(
F005)
3.82
1.13
0.11
Acceptable
78­
83­
1
Isobutyl
alcohol
(
F005)
4.31
2.05
0.21
Acceptable
67­
56­
1
Methanol
(
F003)
5.90
3.49
0.35
Acceptable
78­
93­
3
Methyl
ethyl
ketone
(
F005)
(
D035)
0.32
4.00
0.40
Ineligible
108­
10­
1
Methyl
isobutyl
ketone
(
F003)
0.03
1.13
0.11
Ineligibleb
98­
95­
3
Nitrobenzene
(
F004)
0.043
1.13
0.11
Ineligible
110­
86­
1
Pyridine
(
F005)
(
D038)
0.006
1.13
0.11
Ineligible
127­
18­
4
Tetrachloroethylene
(
F002)
(
D039)
5.83
4.82
0.48
Acceptable
108­
88­
3
Toluene
(
F005)
2.14
5.54
0.55
Centrifuge
required
Table
17
Evaluation
of
Disposable
Solvent­
Contaminated
Industrial
Wipes
for
Landfilling
CAS
No.
Constituent
(
RCRA
Waste
Codes)
Risk
Loading
Thresholda
(
kg/
d,
per
landfill)
Loading
(
kg/
day,
per
landfill)
Loading
Assuming
Centrifuging
(
kg/
day,
per
landfill)
Conclusion
108
71­
55­
6
1,1,1­
Trichloroethane
(
F002)
15.81
9.86
0.99
Acceptable
76­
13­
1
1,1,2­
Trichlorotrifluoroethane
(
F002)
403.37
5.65
0.56
Acceptable
75­
69­
4
Trichlorofluoromethane
(
F002)
16.05
3.80
0.38
Acceptable
1330­
20­
7
Xylenes
(
total)
(
F003)
6.18
2.05
0.21
Acceptable
Carcinogens
71­
43­
2
Benzene
(
F005)
(
D018)
0.24
1.13
0.11
Centrifuge
required
56­
23­
5
Carbon
tetrachloride
(
F001)
(
D019)
3.02
1.13
0.11
Acceptable
75­
09­
2
Methylene
chloride
(
F002)
0.39
10.42
1.04
Ineligible
79­
46­
9
2­
Nitropropane
(
F005)
0.0033
1.13
0.11
Ineligible
79­
01­
6
Trichloroethylene
(
F002)
(
D040)
27.66
1.13
0.11
Acceptable
79­
00­
5
1,1,2­
Trichloroethane
(
F002)
0.83
1.13
0.11
Centrifuge
Required
a
Loading
threshold
shows
disposal
rate
that
results
in
an
HQ=
1
or
carcinogenic
risk
=
10­
5.
b
Methyl
isobutyl
ketone
is
listed
for
its
characteristic
of
ignitability
and
therefore,
when
it
is
mixed
with
solid
waste,
is
no
longer
considered
hazardous
waste
unless
it
continues
to
display
its
characteristic.
Therefore,
although
this
assessment
lists
MIK
as
Ineligible,
a
wipe
containing
it
can
be
disposed
of
in
a
landfill
if
it
meets
the
other
requirements.

V.
B.
5.
What
High­
End
Assumptions
Are
Related
With
this
Analysis?

Separate
sets
of
assumptions
associated
are
with
the
two
parts
of
this
analysis:
the
assumptions
regarding
the
loading
of
contaminants
to
the
landfill
and
the
assumptions
regarding
the
subsequent
transport
and
exposure.
High­
end
assumptions
are
summarized
here.
The
next
section,
section
V.
B.
6,
identifies
areas
where
the
analysis
is
uncertain
or
may
potentially
underestimate
risk.

The
high­
end
assumptions
identified
in
the
analysis,
as
they
relate
to
the
loading
of
the
contaminant
to
the
landfill,
include
the
following:
22
As
part
of
their
petition,
Kimberly­
Clark
submitted
data
showing
the
evaporation
rates
of
certain
solvents
from
disposable
industrial
wipes.
SAIC
(
1997)
also
presents
data
regarding
evaporation
rates
under
a
variety
of
conditions.

109
°
Other
than
centrifuging,
no
other
removal
processes
are
assumed
to
occur
prior
to
landfilling.
This
includes
evaporation.
22
Removal
efficiencies
of
such
processes
are
variable.

°
The
number
of
generators
using
a
single
MSW
landfill
is
assumed
to
be
ten
times
greater
than
the
national
average.
Such
an
approach
assumes
a
`
localized
concentration'
of
generators.

Additionally,
once
the
contaminant
enters
the
landfill
a
number
of
additional
high­
end
assumptions
are
associated
with
fate
and
transport.
These
include
the
following:

°
The
contaminants
in
the
waste
are
assumed
to
be
available
for
release,
not
irreversibly
bound
to
the
matrix.

°
Assumption
of
use
of
one
of
four
scenarios
which
results
in
the
greatest
receptor
well
concentrations
(
i.
e.,
in
this
case,
a
small
landfill).

°
The
DAF
for
groundwater
transport
was
evaluated
at
the
95th
percentile
level
in
a
Monte
Carlo
analysis.

V.
B.
6.
What
Uncertainties
and
Limitations
Are
Related
With
this
Analysis?

Uncertainty
and
limitations
can
be
categorized
according
to
(
1)
exposure
and
toxicological
benchmarks,
(
2)
the
loading
of
the
constituent
to
the
landfill,
and
(
3)
the
partitioning,
transport,
and
exposure
of
the
constituent
once
it
enters
the
landfill.
Many
uncertainties,
limitations,
and
comments
regarding
the
predictive
nature
of
the
assessment
were
identified
when
the
EPA
(
1999)
report
was
distributed
to
three
outside
experts
as
a
peer
review.

V.
B.
6.
a.
Overall
Uncertainty
EPA
did
not
attempt
to
quantify
total
uncertainty
of
the
analysis
and
thus
does
not
know
the
direction
or
magnitude
of
each
of
the
identified
uncertainties.
EPA
did
not
conduct
a
field
validation
effort
to
identify
the
direction
of
the
uncertainties.
Thus,
the
cumulative
impact
of
these
uncertainties
is
unknown.

EPA
did
not
conduct
a
sensitivity
analysis
that
would
identify
the
most
sensitive
parameters
in
the
assessment.
This
adds
some
uncertainty
into
the
modeling
application
because
the
databases
and
modeling
methodology
associated
with
these
parameters
could
be
reviewed
for
completeness
and
acceptability
if
the
most
sensitive
parameters
were
identified.
EPA
recognizes
that
the
"
source
term"
assumptions
associated
with
the
landfill
are
likely
to
be
uncertain
because
the
data
associated
with
developing
these
assumptions
was
generally
limited.
110
V.
B.
6.
b.
Uncertainty
in
Benchmarks
and
Exposure
Assumptions
Sources
of
uncertainty
in
toxicological
benchmarks
include
one
or
more
of
the
following:
extrapolation
from
laboratory
animal
data
to
humans,
variability
of
response
within
the
human
population,
extrapolation
of
responses
at
high
experimental
doses
under
controlled
conditions
to
low
doses
under
highly
variable
environmental
conditions,
and
adequacy
of
the
database
(
number
of
studies
available,
toxic
endpoints
evaluated,
exposure
routes
evaluated,
sample
sizes,
length
of
study,
etc.).
Toxicological
benchmarks
are
designed
to
be
conservative
(
i.
e.,
to
overestimate
risk)
because
of
the
uncertainties
and
challenges
associated
with
condensing
toxicity
data
into
a
single
quantitative
expression.

Another
important
area
of
uncertainty
involves
estimates
of
risks
to
children
from
carcinogenic
compounds.
EPA
estimated
the
risk
of
developing
cancer
from
the
estimated
lifetime
average
daily
dose
and
the
slope
of
the
dose­
response
curve.
A
cancer
slope
factor
is
derived
from
either
human
or
animal
data
and
is
taken
as
the
upper
bound
on
the
slope
of
the
dose­
response
curve
in
the
low­
dose
region,
expressed
as
a
lifetime
additional
cancer
risk
per
unit
exposure.
However,
individuals
exposed
to
carcinogens
in
the
first
few
years
of
life
may
be
at
increased
risk
of
developing
cancer.
EPA
did
not
adjust
the
cancer
slope
factors
to
account
for
age­
specific
differences
in
exposure
assumptions
(
e.
g.,
body
weight).
However,
EPA
recognizes
that
significant
uncertainties
and
unknowns
exist
regarding
the
estimation
of
lifetime
cancer
risks
in
children.
Methodologies
for
estimating
environmental
threats
to
children's
health
are
relatively
new.
They
are
currently
being
debated
within
the
scientific
community
and
will
continue
to
evolve.

Non­
cancer
effects
in
children
is
also
an
area
of
uncertainty.
Non­
cancer
reference
doses
and
reference
concentrations
for
children
are
based
on
comparing
childhood
exposure,
for
which
EPA
has
age­
specific
data,
with
adult
toxicity
measures,
where
adequate
age­
specific
doseresponse
data
is
lacking.
This
mismatch
results
in
a
large
amount
of
uncertainty
in
the
estimation
of
hazard
quotients
for
children
and
would
sometimes
result
in
an
overestimation
of
children's
risk
and
sometimes
in
an
underestimation.
This
issue
is
still
under
investigation
in
the
scientific
community,
and
no
consensus
has
been
reached.

Another
uncertainty
is
the
impact
of
inter­
individual
variability
in
exposure.
In
this
analysis,
exposure
variables
(
for
example,
media
intake
rates,
residence
duration)
are
fixed
for
all
receptors
of
a
given
type
and
age.
Preliminary
simulations
suggest
that
variability
may
not
be
too
large
given
the
large
variability
of
media
concentrations
nationally.
However,
with
further
regionalization
and
refinement
of
environmental
fate
and
source
characterization
model
inputs,
inter­
individual
variability
in
exposure
could
become
a
significant
factor
in
model
output
in
the
future.

In
addition,
the
analysis
only
considered
exposure
to
groundwater
through
household
uses
of
the
water.
Other
potential
exposures
to
groundwater
could
occur
through
the
use
of
groundwater
for
crop
irrigation
and
through
use
of
surface
waters
fed
by
contaminated
groundwater.
EPA
expects
that
these
exposures
would
be
significantly
lower
than
the
exposure
through
household
use.
111
V.
B.
6.
c.
Uncertainty
in
Chemical
Fate
and
Transport
Another
important
area
of
uncertainty
is
the
transformation
of
chemicals
that
can
occur
either
in
the
waste
management
unit
or
in
environmental
media.
Once
chemicals
are
placed
in
a
waste
management
unit,
this
analysis
assumed
that
various
processes
such
as
biodegradation
and
hydrolysis
act
to
change
the
chemical.
These
changes
result
in
transformation
products.
Often
the
transformation
from
one
chemical
to
another
results
in
a
less
toxic
chemical;
however,
for
a
few
chemicals,
the
resultant
transformation
products
can
be
more
toxic.
The
risk
assessment
did
not
model
transformation
products.

The
risk
screening
assessment
accounts
for
degradation
within
the
landfill,
although
this
is
expected
to
differ
on
a
case­
by­
case
basis
due
to
the
following
factors:

°
Some
landfills
may
be
constructed
to
encourage
or
discourage
degradation;

°
The
presence
of
a
liner
may
slow
the
migration
of
a
contaminant,
in
effect
giving
it
more
time
to
degrade
within
the
landfill;

°
While
degradation
in
the
groundwater
flow
path
was
not
considered
in
the
assessment,
their
varying
rates
of
decomposition
(
i.
e.,
`
half
lives')
indicate
that
some
contaminants
could
be
expected
to
degrade
more
quickly
than
others
in
the
environment.

As
a
result
of
these
effects,
contaminants
with
relatively
short
half­
lives
are
expected
to
be
impacted
by
this
uncertainty
to
a
greater
extent
than
contaminants
that
are
not
expected
to
degrade
quickly.
For
contaminants
that
were
not
assumed
to
degrade
or
for
which
degradation
was
not
assumed
to
occur
due
to
lack
of
data
(
e.
g.,
ethyl
ether),
this
uncertainty
cannot
be
assessed.

In
modeling
the
fate
and
transport
of
chemicals
in
groundwater,
EPA
did
not
assess
complex
hydrogeology
such
as
karst
or
highly
fractured
aquifers.
Some
fraction
of
the
groundwater
settings
in
this
analysis
have
fractured
flow.
In
general,
fractured
flow
in
groundwater
can
channel
the
contaminant
plume,
thus
allowing
it
to
move
faster
and
more
concentrated
than
in
nonfractured
flow
environment.
This
would
result
in
higher
concentrations
in
the
groundwater.

In
addition,
the
modeling
methodology
itself
is
another
source
of
uncertainty,
because
models
and
their
mathematical
expressions
are
simplifications
of
reality
that
are
used
to
approximate
real­
world
conditions
and
processes
and
their
relationships.
The
sources
of
model
uncertainty
include
relationship
errors
and
modeling
errors.
Models
do
not
include
all
parameters
or
equations
necessary
to
express
reality
because
of
the
inherent
complexity
of
the
natural
environment
and
the
lack
of
sufficient
data
to
describe
the
natural
environment.
Consequently,
models
are
based
on
numerous
assumptions
and
simplifications
and
reflect
an
incomplete
understanding
of
natural
processes.

EPA
selected
the
models
used
in
this
risk
assessment
based
on
science,
policy,
and
professional
judgment.
These
models
were
selected
because
they
provide
the
information
needed
for
this
analysis
and
because
EPA
generally
considers
them
to
be
state­
of­
the­
art
science.
Even
112
though
the
models
used
in
the
risk
analyses
are
used
widely
and
have
been
accepted
for
numerous
applications,
they
each
retain
significant
sources
of
uncertainty.
Evaluated
as
a
whole,
the
sources
of
model
uncertainty
in
our
analysis
could
result
in
either
an
overestimation
or
underestimation
of
risk.

V.
B.
6.
d.
Uncertainty
in
Site
Characteristics
EPA
was
not
able
to
directly
measure
many
of
the
site
characteristics
(
for
example,
depth
to
groundwater;
aquifer
thickness;
hydraulic
conductivity;
location
of
wells;
behavioral
characteristics
of
receptors)
near
each
landfill
to
estimate
risk.
These
model
inputs
were
characterized
through
regional
and
national
databases.
As
a
result,
the
data
used
has
several
limitations.
Overall,
the
use
of
regional
and
national
input
data
rather
than
site­
based
facility
and
environmental
data
could
cause
estimated
concentrations
to
be
low
or
high
at
a
given
location,
with
no
known
general
bias.

In
addition,
the
risk
assessment
tracks
individual
chemicals
from
waste
disposed
in
landfills
into
the
surrounding
multimedia
environment
at
a
series
of
locations
around
the
country.
A
variety
of
transport
processes,
including
volatilization,
leaching,
runoff,
erosion,
advection,
dispersion,
and
deposition,
move
chemicals
from
the
landfills
through
the
multimedia
environment
to
locations
where
human
receptors
are
likely
to
be
exposed.
A
set
of
chemical­
specific
data
are
required
for
the
environmental
simulation
models
that
are
used
to
calculate
chemical
fate
and
characterize
the
resulting
exposures
and
risks.

Some
of
the
chemical
properties,
such
as
solubility
and
effective
hydrolysis
rate
constants,
will
vary
with
temperature
and
pH
across
different
sites.
The
uncertainty
resulting
from
the
assumptions
concerning
environmental
conditions
results
from
a
paucity
of
data
describing
conditions
at
waste
management
sites
and
from
the
requirement
to
conduct
the
assessment
on
a
national
basis.

V.
B.
6.
e.
Some
Uncertainties
and
Limitations
of
the
Landfill
Loading
Term
The
most
significant
uncertainty
in
estimating
landfill
loading
results
from
cumulative
calculations.
As
shown
in
section
V.
B.
3,
the
landfill
loading
is
calculated
from
a
series
of
assumptions,
each
of
which
is
highly
variable
(
e.
g.,
the
concentration
of
contaminants
in
the
solvents).
Other
significant
limitations
include
the
following:

°
Only
compounds
identified
as
the
basis
for
listing
F001
to
F005
were
considered
in
each
analysis
(
e.
g.,
co­
contaminants
such
as
metals
and
other
compounds
that
could
be
present
in
solvents
were
not
considered).
Also,
EPA
did
not
consider
other
hazardous
solvents
due
to
the
lack
of
data
on
their
occurrence.

°
The
analysis
only
accounted
for
wipes
generated
by
LQGs
and
small
quantity
generators
(
SQGs),
but
negligible
amounts
of
the
constituent
are
present
in
the
rest
of
the
solid
waste
sent
to
the
landfill.
Therefore,
it
does
not
account
for
the
potential
introduction
of
the
constituent
by
conditionally
exempt
small
quantity
generators
(
CESQGs)
and
from
household
hazardous
waste.
113
V.
B.
6.
f.
Linearity
of
Models
Most
of
the
transport
calculations
are
linear.
For
example,
if
landfill
loading
is
doubled,
then
the
groundwater
concentration
is
also
doubled.
The
risk
loading
thresholds
presented
in
Table
15
assume
such
a
linearity
of
the
results.
The
indirect
exposures,
however,
are
not
necessarily
linear.
This
is
because
the
indirect
inhalation
model
is
comprised
of
a
series
of
modules
and
equations,
with
terms
that
rely
on
the
differences
in
concentrations
between
different
media.
Risks
for
such
indirect
exposures
were
calculated
assuming
a
uniform
groundwater
concentration
of
1
mg/
L
for
each
constituent
(
EPA
1999).
For
simplicity,
this
risk
screening
assessment
assumed
that
such
results
are
linear
(
e.
g.,
a
groundwater
concentration
of
2
mg/
L
was
assumed
to
result
in
twice
the
indirect
exposure
risk
than
a
groundwater
concentration
of
1
mg/
L).

This
assumption
is
expected
to
be
appropriate
for
calculated
groundwater
concentrations
near
1
mg/
L.
However,
as
the
receptor
groundwater
concentration
becomes
much
less
(
or
much
greater)
than
1
mg/
L,
there
is
expected
to
be
greater
uncertainty
in
the
results.
EPA
did
not
evaluate
the
effect
of
this
uncertainty
on
the
results.

V.
B.
7.
What
Are
the
Results
of
the
Peer
Review?

In
September
1998,
the
risk
analysis
was
sent
to
three
experts
outside
of
EPA.
The
peer
review
was
limited
to
the
fate
of
the
constituents
once
the
waste
enters
the
landfill.
The
comments
are
detailed
separately
(
EPA,
Summary
and
Assessment
of
Peer
Review
Comments
Solvent­
Contaminated
Towels,
Rags,
and
Wipes,
November
18,
1998)
and
summarized
below.
The
reviewers
identified
ways
in
which
the
analysis
is
conservative,
ways
in
which
the
analysis
underpredicts
risk,
and
uncertainties
in
the
approach.

Ways
in
which
the
analysis
was
found
to
potentially
over­
estimate
risks
include
the
following:
(
1)
the
model
accounts
for
too
little
degradation
of
the
solvent
components
in
the
landfill;
(
2)
the
assumption
that
none
of
the
solvent
is
permanently
bound
to
the
wipe
is
conservative,
as
is
the
assumption
that
no
degradation
occurs
after
the
compound
leaves
the
landfill
(
unfortunately,
insufficient
data
is
available
in
the
literature
to
adequately
quantify
these
effects);
and
(
3)
trichloroethylene's
carcinogenic
health
effects
may
be
overestimated.

Ways
in
which
the
analysis
may
underestimate
risks
include
the
following:
(
1)
additional
parameters
other
than
climatic/
geographic
conditions
and
landfill
size
could
be
relevant
and
should
be
considered
in
the
sensitivity
analysis
(
a
finding
that
other
parameters
are
more
sensitive
than
those
parameters
set
at
a
high­
end
would
increase
the
modeled
risk);
(
2)
groundwater
transport
could
result
in
larger
risks
than
specified;
(
3)
effects
from
co­
solubilization
and
co­
contaminants
could
increase
risk;
(
4)
the
potential
carcinogenic
effects
from
one
constituent,
tetrachloroethylene,
should
have
been
considered;
and
(
5)
additional
transport
pathways
exist
and
may
result
in
higher
risks
than
the
pathways
and
risks
evaluated.
The
latter
includes
evaluating
a
potentially
more
sensitive
receptor
(
worker
at
a
landfill)
and
advective
transport
from
the
landfill
resulting
from
the
generation
of
methane.
In
addition,
in
considering
degradation,
the
report
ignores
any
effects
from
toxic
daughter
products,
which
would
increase
the
risk
to
a
receptor.
114
Other
factors
include
those
which
have
unknown
effects
on
the
risk
assessment
results.
These
include
(
1)
misapplication
of
the
landfill
partitioning
equations;
(
2)
a
need
for
greater
and
better
presentation
of
uncertainty;
(
3)
the
lack
of
comparisons
to
actual
or
observed
conditions
which
could
support
the
conclusions
of
the
report.

EPA
did
not
modify
the
risk
analysis
to
address
peer
reviewers'
concerns
but
plans,
instead,
to
address
the
peer
review
comments
in
conjunction
with
addressing
public
comments
from
the
proposed
rule.
This
approach
was
pursued
in
order
to
address
all
comments
at
one
time
before
finalizing
the
proposal.

V.
B.
8.
Recommendations
EPA
today
is
proposing
the
following
based
on
the
findings
of
its
risk
screening
analyses
coupled
with
several
policy
decisions
that
address
the
uncertainties
of
these
analyses:

°
With
respect
to
industrial
wipes
containing
F­
listed
solvents
disposed
directly
in
municipal
landfills,
EPA
is
proposing
not
to
allow
the
following
11
F­
listed
solvents
in
municipal
landfills
either
because
they
pose
unacceptable
risks
and/
or
because
those
solvents
are
found
in
the
Toxicity
Characteristic
(
TC)
List
(
See
40
CFR
261.24).
These
F­
listed
solvents
are
pyridine
(
TC),
nitrobenzene
(
TC),
cresols
(
TC),
methyl
ethyl
ketone
(
TC),
tetrachoroethylene
(
TC),
chlorobenzene
(
TC),
2­
nitropropane,
methylene
chloride,
benzene
(
TC),
carbon
tetrachloride
(
TC),
and
trichloroethylene
(
TC).
Of
these
11
constituents
ineligible
for
landfilling,
9
are
toxicity
characteristic
(
TC)
solvents.
Of
these
9
TC
solvents,
six
(
6)
were
not
found
to
pose
an
adverse
risk
in
the
analysis.
However,
EPA
is
proposing
that
they
be
ineligible
for
landfilling
because
of
their
status
as
TC
wastes.

°
With
respect
to
the
remaining
19
F­
listed
solvents,
EPA
is
proposing
to
allow
these
solvents
to
be
disposed
of
in
municipal
landfills
provided
they
are
"
dry";
i.
e.,
the
wipes
do
not
contain
more
than
5
grams
per
wipe
solvent.
This
is
in
some
cases
more
stringent
than
the
results
of
our
risk
screening
analysis.
Because
of
the
uncertainties
and
lack
of
detailed
demographic
data
in
the
risk
screening
analysis,
EPA
has
chosen
to
propose
a
more
stringent
condition
in
order
to
compensate
for
possible
inaccuracies
and
to
provide
a
simpler
regulatory
structure.
However,
the
five
gram
standard
for
all
contaminated
wipes
going
to
landfill
should
be
achievable
by
many
generators
with
little
or
no
effort
since
they
use
very
little
solvent
on
each
wipe
as
part
of
their
production
process.
This
proposed
approach
continues
to
provide
regulatory
relief
and
flexibility
to
generators,
and
has
the
benefit
of
providing
a
simple
regulatory
structure.
In
addition,
the
risk
analysis
shows
the
five
gram
standard
to
fall
within
the
range
of
what
is
shown
to
be
safe.

V.
C.
Ecological
Risks
Because
constituents
in
these
industrial
wipes
may
impact
ecological
receptors
differently
115
than
human
health
receptors,
a
screening
level
analysis
was
conducted
to
assess
potential
ecological
risks.

First,
EPA
identified
appropriate
ecological
benchmarks.
EPA
developed
freshwater
benchmarks
in
preparation
of
the
proposed
1999
Hazardous
Waste
Identification
Rule
(
64
FR
63381,
November
19,
1999).
EPA
also
identified
freshwater
benchmarks
in
support
of
developing
a
protocol
for
permitting
RCRA
hazardous
waste
combustion
facilities
(
Screening
Level
Ecological
Risk
Assessment
Protocol
for
Hazardous
Waste
Combustion
Facilities,
Peer
Review
Draft
November,
1999).
As
a
result,
aquatic
benchmarks
were
identified
in
this
manner
for
10
of
the
30
constituents
which
form
the
basis
for
listing
F001
to
F005
wastes.
These
aquatic
toxicity
benchmarks
are
identified
in
Table
18.
For
convenience,
Table
18
also
identifies
the
underlying
sources
of
the
data
identified
in
these
two
reports.

EPA
conducted
additional
analyses
to
account
for
dilution
of
groundwater
infiltration
to
a
surface
water
body,
using
a
conservative
approach.
First
EPA
identified
a
typical
flow
rate
and
dimensions
of
a
small
stream
(
i.
e.,
because
higher
contaminant
concentrations
would
result
from
a
small
stream).
Next,
it
identified
the
quantity
of
leachate
generated
from
the
modeled
landfill
and
assumed
that
100
percent
of
the
contaminant
leaving
the
landfill
as
leachate
would
enter
the
surface
water.

Table
18
Aquatic
Benchmarks
for
Constituents
in
Solvent­
Contaminated
Industrial
Wipes
Constituent
Name
Concentration,
mg/
L
Source
Acetone
1.5
(
1);
Suter
and
Tsao
(
1996)

Benzene
0.13
(
2);
Stephan
et
al.
(
1985);
Suter
and
Tsao
(
1996)
Table
18
Aquatic
Benchmarks
for
Constituents
in
Solvent­
Contaminated
Industrial
Wipes
Constituent
Name
Concentration,
mg/
L
Source
116
Carbon
disulfide
0.00092
(
2);
Stephan
et
al.
(
1985);
Suter
and
Tsao
(
1996)

Chlorobenzene
0.064
(
2);
Stephan
et
al.
(
1985);
Suter
and
Tsao
(
1996)

Methylene
chloride
2.2
(
2);
Stephan
et
al.
(
1985);
Suter
and
Tsao
(
1996)

Nitrobenzene
0.27
(
1);
U.
S.
EPA
(
1987)

Tetrachloroethylene
0.098
(
2);
Stephan
et
al.
(
1985);
Suter
and
Tsao
(
1996)

Toluene
0.0098
(
2);
Stephan
et
al.
(
1985);
Suter
and
Tsao
(
1996)

1,1,1­
Trichloroethane
0.011
(
2);
Stephan
et
al.
(
1985);
Suter
and
Tsao
(
1996)

Trichloroethylene
0.047
(
2);
Stephan
et
al.
(
1985);
Suter
and
Tsao
(
1996)

All
other
constituents
No
data
 
(
1)
U.
S.
Environmental
Protection
Agency.
Screening
Level
Ecological
Risk
Assessment
Protocol
for
Hazardous
Waste
Combustion
Facilities,
Peer
Review
Draft,
November,
1999.
Appendix
E,
Toxicity
Reference
Values,
Screening
Level
Ecological
Risk
Assessment
Protocol,
August
1999.
http://
www.
epa.
gov/
epaoswer/
hazwaste/
combust/
eco­
risk/
volume3/
appx­
e.
pdf
(
2)
U.
S.
Environmental
Protection
Agency.
Data
Collection
for
the
Hazardous
Waste
Identification
Rule.
Section
14.0
Ecological
Benchmarks.
October
1999.
http://
www.
epa.
gov/
epaoswer/
hazwaste/
id/
hwirwste/
pdf/
risk/
data/
s0044.
pdf
References
cited
in
these
two
reports
are
as
follows:
Stephan,
C.
E.,
D.
I.
Mount,
D.
J.
Hansen,
J.
H.
Gentile,
G.
A.
Chapman,
and
W.
A.
Brungs.
1985.
Guidelines
for
Deriving
Numerical
National
Water
Quality
Criteria
for
the
Protection
of
Aquatic
Organisms
and
Their
Uses.
PB85­
227049.
National
Technical
Information
Service,
Springfield,
VA.
Suter,
II,
G.
W.,
and
C.
Tsao.
1996.
Toxicological
Benchmarks
for
Screening
Potential
Contaminants
of
Concern
for
Effects
on
Aquatic
Biota:
1996
Revision.
U.
S.
Environmental
Protection
Agency.
Quality
Criteria
for
Water
 
Update
#
2.
EPA
440/
5­
86­
001.
Office
of
Water
Regulations
and
Standards.
May
1987.

Assumptions
regarding
the
typical
size
and
flow
rate
of
a
small
stream
used
in
this
analysis
were
taken
directly
from
EPA's
analysis
for
the
paint
production
wastes
proposed
rule
(
EPA,
Risk
Assessment
Technical
Background
Document
for
the
Paint
and
Coatings
Hazardous
Waste
Listing
Determination,
January
2001)
For
modeling
purposes,
the
stream
is
shaped
as
a
rectangle
5.5
m
wide,
a
width
typical
of
a
third­
order
fishable
stream
(
van
der
Leeden
et
al.,
1990).
A
third­
order
stream
refers
to
a
type
of
stream
segment
classification.
In
this
classification
scheme,
a
first­
order
stream
segment
is
one
with
no
tributaries.
That
is,
a
first­
order
stream
segment
receives
all
of
its
flow
from
runoff
from
the
surrounding
watershed
soils.
A
second­
order
stream
segment
is
produced
when
two
first­
order
stream
segments
come
together.
A
third­
order
stream
segment
occurs
when
two
second­
order
segments
come
together.
The
third­
order
steam
segment,
therefore,
has
the
combined
flow
of
at
least
two
second­
order
stream
segments.
The
third­
order
stream
was
selected
because
it
reasonably
represents
the
smallest
body
of
water
that
would
routinely
support
recreational
fishing
of
consumable
fish.
The
stream
segment
modeled
in
this
assessment
is
assumed
to
be
homogeneously
mixed
with
a
depth
of
0.21
m
(
including
water
column
and
benthic
sediment)
117
and
a
flow
rate/
velocity
of
0.5
m/
s
(
van
der
Leeden
et
al.,
1990).
A
stream
with
these
dimensions,
therefore,
has
a
flow
rate
of
49,896
m3/
day.

The
quantity
of
leachate
generated
from
the
modeled
landfill
is
calculated
from
the
landfill
area
and
the
infiltration
rate.
As
discussed
previously
in
this
report,
highest
human
health
risks
were
found
when
using
a
landfill
with
an
area
of
8,094
m2
and
an
infiltration
rate
of
0.397
m/
year
(
i.
e.,
a
small
landfill
in
Houston
Texas)
(
EPA
1999).
This
is
a
total
leachate
generation
rate
of
9.2
m3/
day.
The
ratio
of
the
stream
flow
to
the
landfill
leachate
flow
is
5,400,
assuming
that
the
entire
landfill
leachate
quantity
enters
the
stream.
This
is
much
larger
than
the
dilution­
attenuation
factor
of
27
used
in
the
analysis
for
human
health
risks
from
drinking
water
wells
and
shows
that
much
greater
dilution
results
from
a
stream.

The
benchmarks
of
Table
18
were
compared
to
the
simulated
surface
water
concentration,
calculated
from
the
landfill
loading
rates
identified
for
each
constituent
in
Table
17
(
assuming
no
centrifuging).
Results
are
presented
in
Table
19.
Table
19
lists
each
constituent,
its
ecological
benchmark
(
from
Table
18),
and
the
simulated
surface
water
concentration
calculated
assuming
no
pre­
centrifuging
of
solvent­
contaminated
industrial
wipes
(
note
that
assuming
centrifuging
of
the
solvent­
contaminated
industrial
wipes
prior
to
landfilling
would
result
in
even
lower
surface
water
concentrations).
For
each
constituent,
the
simulated
surface
water
concentrations
are
less
than
the
corresponding
ecological
benchmark.
Based
on
this
analysis,
EPA
believes
that
none
of
these
evaluated
constituents
would
pose
adverse
ecological
risks
from
the
disposal
of
solventcontaminated
industrial
wipes
in
municipal
solid
waste
landfills.

Table
19
Ecological
Screening
Results
for
Solvent­
Contaminated
Industrial
Wipes
Constituent
Name
Concentration,
mg/
L
Conclusion
Aquatic
Benchmarka
Surface
Water,
without
pre­
Centrifugingb
Acetone
1.5
0.02
No
eco
risk
Table
19
Ecological
Screening
Results
for
Solvent­
Contaminated
Industrial
Wipes
Constituent
Name
Concentration,
mg/
L
Conclusion
Aquatic
Benchmarka
Surface
Water,
without
pre­
Centrifugingb
118
Benzene
0.13
0.003
No
eco
risk
Carbon
disulfide
0.00092
0.0004
No
eco
risk
Chlorobenzene
0.064
0.00003
No
eco
risk
Methylene
chloride
2.2
0.02
No
eco
risk
Nitrobenzene
0.27
0.002
No
eco
risk
Tetrachloroethylene
0.098
0.0001
No
eco
risk
Toluene
0.0098
0.0004
No
eco
risk
1,1,1­
Trichloroethane
0.011
0.0003
No
eco
risk
Trichloroethylene
0.047
0.00002
No
eco
risk
All
other
constituents
No
data
 
No
data
a
Aquatic
benchmarks
are
presented
in
Table
18.
b
Surface
water
concentrations
calculated
by
combining
EPA
(
1999)
results
with
solvent
loading
and
centrifuging
assumptions
described
elsewhere
for
the
human
health
risk
assessment.

V.
D.
Assessing
Risks
from
the
Combustion
of
Disposables
EPA's
analysis
of
possible
risks
from
the
combustion
of
disposables
in
a
municipal
waste
combustor
addressed
the
following
questions:

°
Of
the
quantity
of
solvent
entering
the
MWC,
how
much
of
it
remains
unburned
in
the
residual
ash?

°
Would
this
residual
quantity
in
the
ash
present
a
potential
risk
when
disposed
in
a
landfill?
Would
it
meet
numerical
land
disposal
restrictions
(
LDRs)
and
TC
limits?

At
the
same
time,
the
scope
of
the
analysis
was
limited
to
potential
risks
from
the
ash
only
and
did
not
address
questions
such
as
the
following:

°
Would
there
be
any
incremental
risks
from
unburned
constituents
in
stack
emissions?

°
Would
the
loadings
contribute
to
dioxin/
furan
formation
or
other
undesirable
effects?
119
The
general
approach
to
answering
the
above
questions
is
as
follows:

1.
Estimate
how
much
(
e.
g.,
kg/
day)
contaminant
is
sent
to
a
MWC.

2.
Estimate
how
much
of
each
contaminant
is
destroyed
(
or
at
least
volatilized
from
the
waste
so
it
is
not
present
in
the
ash).
Also,
estimate
the
size
of
a
MWC
and
make
assumptions
regarding
how
many
MWCs
would
send
their
ash
to
a
single
landfill.

3.
Calculate
how
much
contaminant
remains
in
the
ash.
Compare
these
estimates
to
the
risk
loading
thresholds
calculated
in
section
V.
B.
1
to
conclude
if
the
quantity
of
residual
solvent
in
the
ash
would
be
greater
than
or
less
than
the
quantity
that
may
pose
a
risk.
Also
evaluate
these
levels
against
TC
and
LDR
standards.

4.
Identify
what
high­
end
assumptions
were
used,
as
well
as
the
uncertainties
and
limitations
of
the
analysis.

5.
Based
on
this
information,
make
conclusions
regarding
the
potential
risks
from
combusting
disposable
industrial
wipes.

As
described
below,
the
analysis
uses
several
conservative
assumptions.
Therefore,
the
analysis
can
be
characterized
as
a
screening
level
analysis.

V.
D.
1.
What
Quantities
of
Solvent
Are
Expected
to
be
Sent
to
a
MWC?

The
first
step
of
the
analysis
is
to
estimate
the
quantity
of
each
constituent
that
is
present
in
wipes
sent
to
a
MWC.
Many
of
the
same
assumptions
made
in
section
V.
B.
for
disposables
in
landfills
are
relevant
to
the
MWC
analysis
as
well.
Discussed
below
are
additional
assumptions
used
to
specifically
apply
to
the
MWC
analysis.

There
are
132
MWCs
operating
in
the
United
States
(
EPA
1997b).
EPA
used
this
number
to
obtain
a
nationwide
average.

Due
to
the
relatively
small
numbers
of
MWCs
(
132)
and
the
relatively
large
number
of
landfills
(
over
2,000),
each
of
the
MWC
facilities
would
be
expected
to
dispose
of
its
ash
in
a
different
landfill.
However,
to
apply
an
additional
conservative
factor,
EPA
assumed
that
there
could
be
localized
effects
such
that
a
large
number
of
MWC
units
(
5
times
such
a
national
average)
use
a
single
landfill.

EPA
also
assumed
that
a
constituent
would
be
destroyed
to
0.01
percent
of
its
initial
loading.
The
basis
for
this
assumption
is
presented
in
section
V.
D.
2.
120
Using
these
data
and
assumptions,
EPA
calculated
the
quantity
of
contaminant
being
sent
to
a
individual
MWC
to
be
as
follows:

1,009
million
number
of
disposables
used
by
LQGs
and
SQGs
×
0.35
fraction
with
F­
listed
constituents
×
[
1­
0.78]
fraction
combusting
(
rather
than
landfilling)
disposable
industrial
wipes
×
0.1
or
0.5
fraction
using
given
constituent
×
0.1
to
0.51
fraction
of
constituent
in
solvent
(
based
on
arithmetic
average
concentration)
×
[(
0.049
×
fraction
of
disposables
used
by
printers
25)
+
grams
of
solvent
per
wipe
for
a
printer
(
0.951
×
fraction
of
disposables
used
by
non­
printers
12.5)]
grams
of
solvent
per
wipe
for
a
non­
printer
×
5
localized
concentration
of
generators
above
national
average
/
350
days
per
year
that
landfill
operates
/
132
number
of
MWCs
nationwide
x
0.0001
99.99%
destruction
0.0003
to
0.003
kg/
day
loading
to
landfill,
depending
on
the
containment
V.
D.
2.
What
Are
the
Properties
of
a
Municipal
Waste
Combustion
Unit?

Two
properties
of
a
MWC
are
important
for
these
calculations:
its
size
and
its
destruction
efficiency.
Size
is
used
in
estimating
the
quantity
of
ash
generated.
Destruction
efficiency
is
used
for
identifying
how
much
of
the
incoming
solvent
would
be
destroyed
by
the
combustion
process,
and
for
estimating
whether
the
resulting
calculated
concentrations
of
contaminants
in
the
ash
would
exceed
TC
or
LDR
levels.

Estimating
the
Size
of
a
MWC
The
data
from
EPA's
Municipal
Solid
Waste
Factbook
(
1997b)
helped
estimate
the
number
and
size
of
MWCs
in
the
United
States.
It
indicates
that
there
are
132
MWCs
with
a
total
capacity
of
111,149
tons
per
day,
for
an
average
capacity
of
842
tons
per
day.
To
be
conservative,
this
analysis
assumes
a
small
combustor
(
the
10th
percentile
from
the
population
of
MWCs
reported
in
the
data)
with
a
capacity
of
72.3
tons
per
day
(
65,600
kg/
day).
It
assumes
this
combustor
operates
at
90
percent
of
capacity
(
based
on
capacity
utilization
for
MWCs
as
a
whole).
Thus,
the
total
quantity
of
waste
combusted
by
this
small
MWC
is
59,000
kg
trash
per
day
(
65,600
×
0.9).

The
assumption
of
a
small
MWC
unit
is
conservative
because
it
generates
a
smaller
quantity
of
ash
in
which
any
residual
solvent
is
contained.
In
effect,
a
smaller
quantity
of
ash
will
concentrate
the
solvent.
For
this
analysis,
a
75
percent
weight
reduction
of
the
waste
is
assumed
(
i.
e.,
the
quantity
of
ash
generated
is
25
percent
of
the
feed,
so
59,000
kg/
day
x
0.25
=
15,000
kg/
day).
Note
that
the
size
of
the
MWC
unit,
in
this
case,
has
no
effect
on
the
quantity
of
solvent
present
in
wipes
entering
the
unit.
Even
by
assuming
a
smaller
than
average
MWC,
solventcontaminated
industrial
wipes
would
comprise
a
very
small
percentage
of
a
unit's
total
feed.
23
As
used
here,
destruction
compares
the
composition
of
the
exiting
ash
to
the
composition
of
the
incoming
municipal
solid
waste.
For
comparison,
hazardous
waste
combustors
require
99.99
percent
destruction,
when
comparing
the
composition
of
the
exiting
air
to
the
composition
of
the
incoming
waste.
Because
the
constituents
of
concern
are
largely
volatile,
larger
quantities
of
the
unreacted
constituent
are
expected
to
be
present
in
exhaust
gas
rather
than
in
ash
residue.

121
Fate
of
Organics
in
a
MWC
A
brief
literature
search
was
conducted
to
identify
the
fate
of
volatile
constituents
in
MWCs.
Most
of
the
literature
regarding
organics
focuses
on
dioxin,
polychlorinated
biphenyls
(
PCBs),
and
similar
compounds,
which
are
of
limited
use
in
this
analysis.
However,
three
references
were
found
to
be
relevant
for
estimating
destruction
of
solvent
constituents.
These
analyses
indicate
that
the
quantity
of
contaminant
in
stack
air
compared
to
the
feed
is
at
least
99.99
percent
less,
that
there
is
even
less
contaminant
in
the
ash,
and
organic
contaminants
that
are
present
might
be
the
result
of
formation
from
other
non­
solvent
materials
rather
than
as
unreacted
raw
MSW
feed.
Based
on
this
information,
EPA
makes
a
conservative
estimate
that
99.99
percent
of
the
incoming
contaminant
is
destroyed
with
the
remainder
staying
on
the
ash.
23
This
is
conservative
for
the
following
reasons:

°
Destruction
of
trichlorofluoromethane
is
at
least
99.998
percent
in
a
MWC.
The
average
destruction
of
trichlorofluoromethane
(
CFC­
11)
was
found
to
be
99.998
percent
in
a
full­
scale
municipal
solid
waste
incinerator
in
Germany.
This
is
based
on
the
incineration
of
known
amounts
of
solid
polyurethane
foam,
which
contain
CFC­
11.
In
this
case,
destruction
is
based
on
comparisons
of
exhaust
gas
composition
to
the
feed.
Similar
(
slightly
higher)
destruction
results
were
found
at
a
test
facility
intended
to
simulate
MWC
conditions
(
Rittemeyer
et
al.,
1994).
Ash
concentrations
were
not
measured.
Similar
investigations
of
other
F001
through
F005
solvent
compounds
were
not
located,
but
similar
destruction
equal
to
or
greater
than
99.99
percent
were
assumed
for
the
remaining
constituents
based
on
the
results
for
CFC­
11.

°
Any
organics
that
are
not
destroyed
will
favorably
partition
to
exhaust
air
rather
than
to
ash.
One
source
measured
PCBs,
chlorobenzenes,
and
chlorophenols
(
as
total
levels
of
all
of
these
components)
at
two
full­
scale
MWCs.
At
one
facility,
the
quantities
emitted
in
exhaust
air
ranged
from
43
to
92
grams/
day,
the
quantity
discharged
in
ash
residue
was
2
grams/
day,
and
the
quantities
in
the
feed
ranged
from
149
to
940
grams/
day.
Similar
trends
were
evident
from
the
second
facility
(
Ozvacic
et
al.,
1985).
Similar
partitioning
(
at
least
20:
1
gas
to
ash)
is
expected
for
the
solvent
compounds,
since
some
are
represented
by
these
compound
classes
but
most
are
even
more
volatile,
which
would
decrease
the
quantity
present
in
the
ash
compared
to
the
exhaust
air.

°
Any
organic
compounds
present
in
the
ash
or
exhaust
gas
(
e.
g.,
a
limited
subset
of
solvent
compounds
such
as
chlorobenzenes)
may
be
the
result
of
products
of
incomplete
combustion,
rather
than
uncombusted
feed.
In
one
test
using
a
benchscale
unit,
MSW
incinerator
feed
was
spiked
with
a
known
amount
of
a
122
tetrachlorinated
phenol
isomer.
Other
chlorinated
phenol
isomers
were
present
in
the
exhaust
gas,
but
this
particular
isomer
was
present
at
much
lower
levels
(
Kanters
and
Louw,
1994).
Therefore,
the
presence
of
solvent
components
in
ash
or
exhaust
gas
may
be
the
result
of
their
formation
in
the
MWC,
rather
than
as
wholly
unreacted
MSW
feed.

V.
D.
3.
What
Are
the
Resulting
Risk
Estimates
and
LDR/
TC
Results?

EPA
used
the
results
of
sections
V.
D.
1
and
V.
D.
2
to
estimate
contaminant
loadings
to
a
MWC
for
the
30
F­
listed
solvents.
The
findings
are
shown
in
Table
20
and
are
summarized
as
follows:

°
TC
limits.
Nine
of
the
30
contaminants
are
TC
constituents.
These
limits
are
expressed
as
milligram
contaminant
per
liter
of
waste
extract.
The
TC
limits
range
from
0.5
mg/
L
(
benzene)
to
200
mg/
L
(
methyl
ethyl
ketone).
Based
on
the
data
in
Table
20,
the
quantity
of
uncombusted
solvent
ranges
from
about
0.0003
to
0.003
kg/
day.
With
an
ash
generation
rate
of
15,000
kg/
day
(
identified
above),
the
concentration
range
of
the
solvent
contaminants
in
the
ash
range
from
about
0.02
to
0.2
mg/
kg.
The
ash
would
not
be
expected
to
exhibit
the
TC
for
these
constituents
because
even
assuming
that
the
entire
quantity
of
solvent
leaches
from
the
ash
would
result
in
leachate
concentrations
well
below
their
respective
TC
limits.
(
As
part
of
the
calculations,
20
liters
of
extract
are
generated
per
kilogram
of
waste,
based
on
the
Toxicity
Characteristic
Leaching
Procedure
(
TCLP)
protocol).

°
LDR
treatment
standards.
Of
the
30
contaminants,
all
but
three
have
numerical
treatment
standards.
Most
of
these
have
limits
based
on
total
levels;
LDR
limits
range
from
2.6
to
170
mg/
kg.
A
few
have
limits
based
on
TCLP
levels;
in
these
cases
LDR
limits
range
from
0.75
to
4.8
mg/
L.
In
each
case
the
calculated
concentrations
in
the
ash
(
0.0003
to
0.003
mg/
kg)
are
well
below
these
LDR
levels.

°
Risk
loading
thresholds.
Risk
loading
thresholds,
which
identify
the
maximum
quantity
of
solvent
that
can
be
disposed
in
a
landfill
and
not
present
a
risk,
were
identified
in
Table
15
for
all
30
contaminants,
based
on
a
hazard
quotient
of
1
or
cancer
risk
of
10­
5
for
a
child
receptor
from
multimedia
exposure.
The
loading
rate
of
contaminant
in
ash
is
less
than
the
risk
loading
threshold
for
each
constituent,
indicating
that
none
of
the
contaminants
present
a
risk.

Table
20
Evaluation
of
Disposable
Solvent­
Contaminated
Industrial
Wipes
for
MWC
CAS
No.
Constituent
(
RCRA
Waste
Codes)
TC
Limit,
mg/
L
LDR
Limit
Risk
Loading
Threshold
(
kg/
d,
per
landfill)
a
Loading
(
kg/
day,
per
landfill)
Conclusion
Table
20
Evaluation
of
Disposable
Solvent­
Contaminated
Industrial
Wipes
for
MWC
CAS
No.
Constituent
(
RCRA
Waste
Codes)
TC
Limit,
mg/
L
LDR
Limit
Risk
Loading
Threshold
(
kg/
d,
per
landfill)
a
Loading
(
kg/
day,
per
landfill)
Conclusion
123
67­
64­
1
Acetone
(
F003)
NAb
160
mg/
kg
1.73
0.0013
Acceptable
71­
36­
3
Butanol
(
F003)
NA
2.6
mg/
kg
1.61
0.0006
Acceptable
75­
15­
0
Carbon
disulfide
(
F005)
NA
4.8
mg/
L
TCLP
0.62
0.0003
Acceptable
108­
90­
7
Chlorobenzene
(
F002)
(
D021)
100
6
mg/
kg
0.36
0.0003
Acceptable
108­
94­
1
Cyclohexanone
(
F003)
NA
CMBSTc
64.55
0.0006
Acceptable
1319­
77­
3
Cresols
(
F004)
(
D023)
(
D024)
(
D025)
(
D026)
200
5.6
mg/
kg
0.41
0.0003
Acceptable
75­
71­
8
Dichlorodifluoromethane
(
F001)
NA
NA
2.16
0.0003
Acceptable
95­
50­
1
1,2­
Dichlorobenzene
(
F002)
NA
6
mg/
kg
12.84
0.0003
Acceptable
141­
78­
6
Ethyl
acetate
(
F003)
NA
33
mg/
kg
16.17
0.0007
Acceptable
100­
41­
4
Ethyl
benzene
(
F003)
NA
10
mg/
kg
11.95
0.0006
Acceptable
60­
29­
7
Ethyl
ether
(
F003)
NA
160
mg/
kg
4.30
0.0003
Acceptable
110­
80­
5
2­
Ethoxyethanol
(
F005)
NA
NA
3.82
0.0003
Acceptable
78­
83­
1
Isobutyl
alcohol
(
F005)
NA
170
mg/
kg
4.31
0.0006
Acceptable
67­
56­
1
Methanol
(
F003)
NA
0.75
mg/
L
TCLP
5.90
0.0009
Acceptable
78­
93­
3
Methyl
ethyl
ketone
(
F005)
(
D035)
200
36
mg/
kg
0.32
0.0011
Acceptable
108­
10­
1
Methyl
isobutyl
ketone
(
F003)
NA
33
mg/
kg
0.03
0.0003
Acceptable
98­
95­
3
Nitrobenzene
(
F004)
2
14
mg/
kg
0.043
0.0003
Acceptable
110­
86­
1
Pyridine
(
F005)
(
D038)
5
16
mg/
kg
0.006
0.0003
Acceptable
127­
18­
4
Tetrachloroethylene
(
F002)
(
D039)
0.7
6
mg/
kg
5.83
0.0013
Acceptable
108­
88­
3
Toluene
(
F005)
NA
10
mg/
kg
2.14
0.0015
Acceptable
71­
55­
6
1,1,1­
Trichloroethane
(
F002)
NA
6
mg/
kg
15.81
0.0026
Acceptable
Table
20
Evaluation
of
Disposable
Solvent­
Contaminated
Industrial
Wipes
for
MWC
CAS
No.
Constituent
(
RCRA
Waste
Codes)
TC
Limit,
mg/
L
LDR
Limit
Risk
Loading
Threshold
(
kg/
d,
per
landfill)
a
Loading
(
kg/
day,
per
landfill)
Conclusion
24
MWC
ash
is
not
required
to
meet
LDR
treatment
standards.
This
evaluation
was
conducted
for
comparative
purposes
only.

124
76­
13­
1
1,1,2­
Trichlorotrifluoroethane
(
F002)
NA
30
mg/
kg
403.37
0.0015
Acceptable
75­
69­
4
Trichlorofluoromethane
(
F002)
NA
30
mg/
kg
16.05
0.0010
Acceptable
1330­
20­
7
Xylenes
(
total)
(
F003)
NA
30
mg/
kg
6.18
0.0006
Acceptable
Carcinogens
71­
43­
2
Benzene
(
F005)
(
D018)
0.5
10
mg/
kg
0.24
0.0003
Acceptable
56­
23­
5
Carbon
tetrachloride
(
F001)
(
D019)
0.5
6
mg/
kg
3.02
0.0003
Acceptable
75­
09­
2
Methylene
chloride
(
F002)
NA
30
mg/
kg
0.39
0.0028
Acceptable
79­
46­
9
2­
Nitropropane
(
F005)
NA
30
mg/
kg
0.0033
0.0003
Acceptable
79­
01­
6
Trichloroethylene
(
F002)
(
D040)
0.5
6
mg/
kg
27.66
0.0003
Acceptable
79­
00­
5
1,1,2­
Trichloroethane
(
F002)
NA
6
mg/
kg
0.83
0.0003
Acceptable
a
Risk
loading
threshold
shows
disposal
rate
that
results
in
an
HQ=
1
or
carcinogenic
risk
=
10­
5.
b
NA
=
No
applicable
limit.
c
LDR
limit
of
CMBST
is
technology­
based,
requiring
combustion
as
the
treatment
standard
without
a
specific
numeric
limit.
This
requirement,
in
part,
assumes
a
minimum
99.99%
destruction
for
hazardous
waste.

V.
D.
4.
Analysis
of
Results
The
results
indicate
that
F­
listed
constituents
in
MWC
ash
are
expected
to
be
destroyed
in
a
MWC
unit
sufficient
to
meet
existing
LDR
treatment
standards
and
TC
limits.
24
All
of
the
30
Flisted
constituents
would
clearly
be
sufficiently
destroyed
such
that
any
residual
contaminant
remaining
in
the
ash
would
present
negligible
risk.

These
conclusions
are
limited
to
the
effects
of
the
contaminants
on
the
ash.
Effects
on
stack
air
and
subsequent
risks,
including
risks
from
uncombusted
solvents,
as
well
as
any
products
of
incomplete
combustion,
were
not
evaluated.
25
As
part
of
their
petition,
Kimberly­
Clark
submitted
data
showing
the
evaporation
rates
of
certain
solvents
from
disposable
industrial
wipes.
SAIC
(
1997)
also
presents
data
regarding
evaporation
rates
under
a
variety
of
conditions.

125
V.
D.
5.
What
High­
End
Assumptions
Are
Related
With
this
Risk
Assessment?

This
analysis
uses
many
of
the
same
high­
end
assumptions
used
for
the
analysis
for
disposables
in
landfills
presented
in
section
V.
B.
The
high­
end
assumptions
used
in
the
MWC
analysis,
as
they
relate
to
the
loading
of
the
contaminant
to
the
landfill,
include
the
following:

°
No
removal
processes
are
assumed
to
occur
prior
to
combustion.
This
includes
evaporation.
25
Removal
efficiencies
of
such
processes
are
variable.

°
It
is
assumed
that
five
MWCs
use
the
same
landfill.
A
similar
`
localized
concentration'
effect
was
used
for
the
landfill
analysis
(
equal
to
ten
times
the
national
average
of
landfills).
While
different
multipliers
were
used
for
each
analysis
(
i.
e.,
five
for
MWCs
and
ten
for
disposables
in
landfills),
they
have
a
slightly
different
meaning.
Based
on
the
data
used
for
this
analysis,
there
are
132
MWCs
and
over
2,000
landfills,
or
a
national
average
of
less
than
one
MWC
per
landfill.
By
assuming
as
many
as
five
MWCs
use
the
same
landfill,
this
is
actually
much
greater
than
five
times
the
national
average.

Additionally,
once
the
contaminant
enters
the
landfill,
a
number
of
additional
high­
end
assumptions
are
associated
with
fate
and
transport.
These
include
the
following:

°
The
contaminants
in
the
waste
are
assumed
to
be
available
for
release
and
not
irreversibly
bound
to
the
matrix.

°
Use
of
one
of
four
scenarios
which
results
in
the
greatest
receptor
well
concentrations
(
i.
e.,
a
small
landfill).

°
The
DAF
for
groundwater
transport
was
evaluated
at
the
95th
percentile
level
in
a
Monte
Carlo
analysis.

The
contaminant
loadings
to
a
MWC
were
estimated
as
0.0003
to
0.003
kg/
day,
depending
on
the
contaminant
(
from
Table
20).
For
comparison,
the
loadings
to
a
landfill
were
estimated
as
1.13
to
10.4
kg/
day,
depending
on
the
contaminant
(
from
Table
17).

V.
D.
6.
What
Uncertainties
and
Limitations
Are
Related
With
this
Risk
Assessment?

This
analysis
assumes
that
a
MWC
would
achieve
99.99
percent
destruction
of
the
organic
constituents
of
concern.
This
assumption
is
based
on
the
measured
destruction
of
CFC­
11
(
trichlorofluoromethane),
one
of
the
30
F­
listed
constituents,
in
a
MWC.
No
data
is
available
for
the
other
constituents.
The
analysis
also
conservatively
assumes
that
the
unreacted
solvent
feed
would
partition
to
the
ash
when
information
from
the
literature
indicates
otherwise.
Again,
126
however,
the
literature
does
not
provide
partitioning
information
for
all
of
the
F­
listed
solvents.

EPA
also
did
not
assess
whether
certain
compounds
are
actually
formed
during
the
combustion
process
as
products
of
incomplete
combustion.
For
example,
dioxins
and
furans,
as
well
as
their
precursors,
are
formed
during
the
combustion
process
rather
than
present
as
incoming
feed.
However,
there
is
no
information
to
indicate
what
role,
if
any,
these
solvent
constituents
have
on
dioxin/
furan
formation.

Additional
uncertainties
and
limitations
are
similar
or
identical
to
those
discussed
for
the
landfill
analysis
in
section
V.
B.
These
include
the
following:

°
Only
compounds
identified
as
the
basis
for
listing
F001
to
F005
were
considered
in
each
analysis
(
e.
g.,
co­
contaminants
such
as
metals,
and
other
compounds
that
could
be
present
in
solvents
were
not
considered).

°
Negligible
amounts
of
the
constituent
are
present
in
the
rest
of
the
solid
waste
sent
to
a
MWC.
Therefore,
it
does
not
account
for
the
potential
introduction
of
the
constituent
by
CESQGs
and
from
household
hazardous
waste.

V.
D.
7.
Was
the
Approach
for
MWCs
Externally
Reviewed?

The
derivation
of
the
risk
loading
thresholds
for
this
analysis
are
identical
to
that
used
for
the
landfill
analysis
described
in
section
V.
B.
The
peer
review
evaluation
results
for
this
portion
of
the
risk
screening
are
applicable
here.
EPA
also
presented
a
draft
of
this
analysis
to
the
Integrated
Waste
Services
Association
(
IWSA).

IWSA
stated
that
the
analysis
was
extremely
conservative
and
supported
conclusions
that
generated
ash
would
not
pose
risks
for
the
majority
of
contaminants.
However,
they
also
stated
that
ash
testing
has
not
detected
volatile
organic
compounds
and
that
semivolatile
organic
compounds,
when
found,
do
not
leach.
Additionally,
they
supported
an
even
greater
destruction
limit
than
99.99
percent.
The
Association
contends
that
the
inclusion
of
these
observations
would
support
a
conclusion
that
all
solvent­
contaminated
industrial
wipes
can
be
safely
managed
in
a
MWC.

EPA
notes
that
this
risk
screening
analysis
did
not
identify
any
potential
risks
from
solvents
in
residual
ash.
Even
if
the
analysis
was
made
less
conservative,
based
on
IWSA's
concerns,
the
results
of
the
analysis
would
not
change.

V.
D.
8
Recommendations
For
municipal
waste
combustion
units
that
accept
solvent­
contaminated
industrial
wipes,
EPA
is
proposing
to
allow
the
generated
municipal
waste
combustion
ash
to
be
disposed
of
in
municipal
waste
landfills.

V.
E.
Assessing
Risks
from
the
Laundering
of
Reusable
Industrial
Wipes
127
SHOP
AND
PRINTER
TOWEL
GENERATORS
Laundry
Landfill
Sludge
Air
Effluent
wastewater
(
sampled)

leaching/
ground
water
transport
Figure
1:
Fate
of
Solvent
Components
in
Reusable
Solvent­
Contaminated
Wipes
When
Washed
V.
E.
1.
How
Can
Solvents
Enter
the
Environment
from
Reusable
Industrial
Wipes?

EPA
proposed
effluent
guidelines
for
the
industrial
laundry
industry
(
62
FR
66182,
December
17,
1997).
EPA
subsequently
finalized
a
decision
not
to
promulgate
effluent
guidelines
for
this
industry
(
64
FR
45071;
August
18,
1999).
For
the
proposed
rule,
EPA
collected
extensive
information
regarding
the
industrial
laundry
industry,
types
of
items
accepted,
wastewater
treatment
technologies,
and
wastewater
discharge
characteristics.
The
data
presented
in
this
section
highlights
the
findings
of
this
work
as
it
relates
to
risks
from
the
laundering
of
wipes,
as
well
as
further
investigations
concerning
potential
risks
from
sludge.

Potential
risks
from
laundering
solvent­
contaminated
industrial
wipes
result
from
the
following
operations
(
see
Figure
1):

°
Storage.
Oily
materials
are
a
potential
source
of
fuel;
in
conjunction
with
sufficient
air
and
heat
a
fire
may
result.
Additionally,
the
presence
of
free
liquids
creates
additional
fuel
and
risk.
To
discourage
free
liquids
in
reusable
wipes,
the
Uniform
&
Textile
Service
Association
(
UTSA)
has
developed
management
guidelines
encouraging
generators
to
implement
procedures
to
minimize
free
liquids
and
many
states
require
that
wipes
sent
to
laundries
not
contain
free
liquids.
Additionally,
based
on
data
collected
in
1994
for
the
Agency's
effluent
guidelines
rulemaking
effort,
most
laundries
at
that
time
rejected
articles
with
free
liquids.

°
Effluent.
All
industrial
laundries
discharge
to
a
municipal
treatment
facility
(
i.
e.,
a
publicly
owned
treatment
works
(
POTW)),
which
collects
and
further
treats
waste
waters
from
industrial,
commercial,
and
residential
sources
prior
to
discharge.
Contaminants
from
industrial
wipes,
therefore,
impact
the
environment
following
a
complex
path
of
pretreatment
at
the
facility
followed
by
centralized
treatment
at
the
POTW.

°
Solid
wastes.
Industrial
wipes,
including
solvent­
contaminated
industrial
wipes,
128
contribute
a
significant
amount
of
contaminants
to
a
laundry's
pretreatment
system.
To
control
these
pollutants
prior
to
POTW
discharge,
laundries
conduct
treatment
practices
such
as
oil
separation,
dissolved
air
flotation,
or
conduct
no
treatment
at
all.
The
generated
solids
are
managed
as
solid
wastes
using
management
methods
such
as
landfilling
or
energy
recovery.

°
Air
risks.
Although
the
potential
for
air
emissions
is
always
present
for
volatile
compounds,
very
little
data
regarding
this
pathway
are
available.
The
potential
risks
and
loadings
are
greatest
where
the
concentration
of
hydrocarbons
are
highest
(
i.
e.,
during
wipe
storage,
and
at
oil
removal
points
in
the
laundry's
pretreatment
system).
As
shown
later
in
this
section,
industrial
laundries
should
not
meet
the
25,000
kg
per
year
threshold
of
a
major
source.

For
this
assessment,
EPA
only
considered
potential
risks
resulting
from
the
disposal
of
industrial
laundry
sludge
in
a
municipal
solid
waste
landfill.

V.
E.
2.
What
Quantity
of
Solvent
Is
Expected
to
be
Present
in
Industrial
Laundry
Sludge?

Figure
1
shows
a
generalized
diagram
of
how
solvent
components
present
in
sludge
from
industrial
laundries
can
impact
human
health
and
the
environment.
Multiple
generators
are
assumed
to
generate
industrial
wipes
and
send
these
materials
to
an
industrial
laundry.
Some
of
these
wipes
contain
F001
to
F005
solvents;
the
laundry
cleans
these
(
and
other)
materials.
When
wipes
are
laundered,
the
contaminants
present
in
the
wipes
are
removed
and
transferred
to
air,
water,
or
solid
media.
When
the
sludge
is
disposed,
the
contaminants
in
them
can
enter
the
landfill
leachate
and
be
transported
to
a
receptor.

Risks
from
the
landfilling
of
industrial
laundry
sludge
are
evaluated
here
using
the
following
approach:

°
The
disposal
of
industrial
laundry
sludge
was
considered
alone,
without
consideration
of
disposable
industrial
wipes
in
the
same
landfill
(
i.
e.,
additional
sources
of
contaminants).

°
Two
different
laundry
sizes
were
used
as
calculation
inputs
to
determine
if
sludge
generated
from
such
`
model'
facilities
would
pose
a
risk
when
landfilled:
an
average
and
a
large
laundry.
It
was
estimated
that
an
average
laundry
would
wash
270,000
pounds
of
printer
wipes
and
260,000
pounds
of
shop
wipes
per
year
while
a
few
large
laundries
can
wash
up
to
2,700,000
pounds
of
printer
wipes
and
2,600,000
pounds
of
shop
wipes
per
year.
Each
size
laundry
was
assumed
to
accept
the
same
types
of
materials
such
that
their
washwater
and
sludge
composition
characteristics
were
the
same.

Data
characterizing
laundry
sludges
from
the
washing
of
printer
or
shop
wipes
are
not
available
for
this
analysis.
As
a
result,
the
hazardous
chemical
sludge
content
was
estimated
from
wastewater
characterization.
As
with
other
analyses
conducted
in
this
report,
EPA
considered
only
the
compounds
that
form
the
definition
of
the
F001
through
F005
solvent
listing
(
i.
e.,
other
non­
129
listed
solvents
and
co­
contaminants
are
not
considered).

V.
E.
2.
a.
Office
of
Water
Data
EPA's
Office
of
Water
(
OW)
conducted
sampling
at
numerous
industrial
laundries
as
part
of
effluent
guidelines
development
for
the
1997
proposed
rule.
The
supporting
record
includes
one
sample
of
washwater
generated
from
the
washing
of
printer
wipes
from
each
of
three
different
industrial
laundries.
This
is
washwater
directly
from
the
washer
with
no
pretreatment
or
dilution.
The
highest
detected
concentration
from
the
three
samples
was
used
in
subsequent
calculations.
EPA
does
not
consider
this
a
high­
end
parameter.
EPA
has
noted
the
extreme
variability
of
solvent
use
and
therefore
is
not
confident
that
its
three
data
points
for
characterizing
laundry
washwater
are
representative.
To
account
for
this
uncertainty,
EPA
selected
the
maximum
concentration.
Because
sludge
samples
were
not
collected,
an
air/
water/
solid
partitioning
model
(
WATER8)
was
used
to
estimate
sludge
loadings.

Only
11
of
the
30
F­
list
constituents
were
detected
in
one
or
more
of
these
samples.
The
remaining
constituents
were
either
not
detected
or
not
analyzed,
depending
on
the
constituent.
The
11
chemicals
detected
are
presented
in
Table
21.

Table
21
Constituents
Detected
in
OW
Sampling
The
chemicals
analyzed
in
the
washwater
samples
were...
The
maximum
concentration
found
in
any
one
sample
was
(
mg/
L)...
The
average
concentration
of
the
three
samples
was
(
mg/
L)...
The
results
of
the
1996
Printer
Towel
survey
indicated...

Acetone
96.6
49.7
Used
by
27%
of
printers
Chlorobenzene
0.30
0.467
a
 
Ethylbenzene
29.24
13.2
 
Methylene
chloride
1.54
0.614
 
Methyl
ethyl
ketone
2.24
3.09
a
Used
by
18%
of
printers
Methyl
isobutyl
ketone
0.72
2.07
a
 
Tetrachloroethylene
6.16
3.92
 
Toluene
33.24
20.5
Used
by
20%
of
printers
1,1,1­
Trichloroethane
8.26
4.5
 
Trichloroethylene
0.328
0.476
a
 
Xylenes
102.7
35.9
Used
by
20%
of
printers
Remaining
F­
list
constituents
Either
not
detected
in
any
of
the
three
samples,
or
were
not
analyzed.

a
The
average
concentration
is
sometimes
higher
than
the
maximum
concentration.
This
is
because
the
detection
130
limit
of
non­
detect
concentrations
was
used
in
calculating
the
average
concentrations.
The
detection
limits
are
sometimes
greater
than
the
detected
values.

In
calculations,
EPA
used
the
maximum
concentrations
as
input
to
a
partitioning
model,
WATER8.
Using
this
model,
only
a
portion
of
the
solvent
in
the
wastewater
was
assumed
to
partition
to
the
sludge.
Calculations
were
conducted
with
process
assumptions
that
included
the
following:

°
Volatility
reduces
due
to
surfactant.
The
result
is
that
less
chemical
partitions
to
the
air
and
more
chemical
partitions
to
water
and
sludge.
The
presence
of
a
surfactant
was
suggested
during
the
effluent
guidelines
public
comment
period
as
an
assumption
yielding
a
more
realistic
scenario.

°
Wastewater
treatment
included
commonly
used
oil/
water
separation
and
settling.
The
analysis
assumes
that
a
less
common
technology,
dissolved
air
flotation,
is
not
present.
This
is
a
central
tendency
assumption
because
it
is
the
most
typical
treatment
used,
and
results
in
less
solvent
partitioning
to
the
sludge
than
the
DAF
unit.

°
Each
pound
of
wipes
washed
is
assumed
to
generate
an
average
of
4.61
gallons
of
wastewater,
with
operations
occurring
an
average
of
350
days
per
year,
based
on
analysis
of
the
effluent
guidelines
data.
These
are
central
tendency.

As
a
result
of
using
these
assumptions,
partitioning
was
found
to
range
from
8
to
37
percent
depending
on
the
constituent.
Detailed
calculations
of
this
partitioning
are
presented
in
ERG
(
2000).

The
quantity
of
contaminant
in
the
sludge
is
proportional
(
and
linear)
to
the
quantity
of
wipes
laundered.
EPA
assumed
that
the
sludge
is
landfilled,
such
that
the
solvent
contaminants
could
be
released
to
the
environment
in
the
same
manner
as
described
in
section
V.
B.,
for
disposable
industrial
wipes.
EPA
also
assumed
that
each
laundry
uses
a
different
landfill
for
disposal.
Therefore,
EPA
calculated
the
quantity
of
wipes
that
would
be
associated
with
sludge
contaminant
levels
equal
to
the
risk
loading
thresholds
derived
in
section
V.
B.
1.

The
overall
approach
is
summarized
below
for
an
average­
sized
laundry.
For
a
large
laundry,
only
the
first
two
values
change
(
i.
e.,
pounds
printer
wipes
and
pounds
shop
wipes
washed
per
year):

270,000
pounds
printer
wipes
washed
per
year
by
average
laundry
+
(
260,000
pounds
shop
wipes
washed
per
year
by
average
laundry
×
0.5)
accounts
for
lower
quantity
of
solvent
on
shop
wipes
×
0.3
to
103
concentration
of
contaminant
in
washwater,
mg/
L
×
0.08
to
0.37
sludge
partitioning
without
DAF
(
constituent
specific,
derived
using
WATER8
model)
×
4.61
gallons
of
water
generated
per
pound
of
wipes
washed
131
/
350
days
per
year
that
landfill
operates
0.001
to
0.76
kg/
day
loading
to
landfill,
depending
on
the
contaminant
The
results
of
these
calculations
are
presented
in
section
V.
E.
3.

V.
E.
2.
b.
Approach
for
Constituents
Not
Detected
or
Analyzed
in
OW
Data
The
remaining
19
contaminants
were
either
not
analyzed
by
OW
or
were
not
detected
at
the
sampled
facilities.
A
different
approach
was
necessary
to
estimate
risk
from
sludge
disposal
for
these
solvents.

The
1996
printer
survey
(
referenced
earlier)
indicated
that
acetone,
methyl
ethyl
ketone,
toluene,
and
xylenes
are
the
F­
listed
solvents
most
often
used
by
printers.
Each
of
these
constituents
is
present
in
significant
concentrations
using
the
OW
data,
as
shown
in
Table
21.
It
is
likely
that
the
remaining
solvents
would
be
used
less
often,
and
would
be
present
at
lower
concentrations
in
laundry
washwater.

The
remaining
19
solvents
were
assumed
to
have
a
washwater
concentration
equal
to
2.2
mg/
L.
This
is
the
washwater
concentration
of
methyl
ethyl
ketone
(
MEK),
a
frequently­
used
solvent
by
printers.
Therefore,
solvents
used
less
frequently
that
MEK
are
assumed
to
have
washwater
concentrations
no
higher
than
MEK.

V.
E.
3.
Results
EPA
evaluated
potential
risks
resulting
from
disposal
of
the
laundry
sludge
alone,
calculating
the
quantity
of
contaminant
that
would
be
present
in
the
sludge
from
the
treatment
of
reusable
industrial
wipes
by
`
average'
sized
industrial
laundries.
Results
are
presented
in
Table
22.
As
seen,
only
one
solvent
appears
to
pose
a
problem:
2­
Nitropropane.
132
Table
22
Evaluation
of
Laundry
Wastewater
Treatment
Sludges
for
Landfilling:
Average
Size
Laundry
Constituent
Risk
Loading
Threshold
(
kg/
d)
Solvent
quantity
in
sludge
(
kg/
d)
Conclusion
Pyridine
(
TC)
0.006
0.004
Acceptable
Nitrobenzene
(
TC)
0.04
0.005
Acceptable
p­
Cresol
(
TC)
0.41
0.004
Acceptable
Acetone
(
OW)
1.73
0.26
Acceptable
Butanol
1.61
0.004
Acceptable
Methyl
isobutyl
ketone
(
OW)
0.03
0.002
Acceptable
Isobutyl
alcohol
4.31
0.004
Acceptable
2­
Ethoxyethanol
3.82
0.006
Acceptable
Ethyl
ether
4.30
0.005
Acceptable
Methanol
5.90
0.004
Acceptable
Methyl
ethyl
ketone
(
OW,
TC)
0.32
0.006
Acceptable
Ethyl
acetate
16.17
0.004
Acceptable
Carbon
disulfide
0.62
0.008
Acceptable
Tetrachloroethylene
(
OW,
TC)
5.83
0.03
Acceptable
Chlorobenzene
(
OW,
TC)
0.36
0.0015
Acceptable
Cyclohexanone
64.55
0.012
Acceptable
Ethyl
benzene
(
OW)
11.95
0.21
Acceptable
Toluene
(
OW)
2.14
0.25
Acceptable
Dichlorodifluoromethane
2.16
0.007
Acceptable
1,1,1­
Trichloroethane
(
OW)
15.81
0.03
Acceptable
Trichlorofluoromethane
16.05
0.007
Acceptable
1,2­
Dichlorobenzene
12.84
0.004
Acceptable
Xylenes
(
total)
(
OW)
6.18
0.76
Acceptable
1,1,2­
Trichlorotrifluoroethane
403
0.013
Acceptable
2­
Nitropropane
©
­
air)
0.0033
0.004
Ineligible
Methylene
chloride
(
C,
OW)
0.39
0.005
Acceptable
Benzene
(
C,
TC)
0.24
0.006
Acceptable
1,1,2­
Trichloroethane
(
C)
0.83
0.006
Acceptable
Carbon
tetrachloride
(
C,
TC)
3.02
0.007
Acceptable
Trichloroethylene
(
C,
OW,
TC)
27.66
0.001
Acceptable
EPA
also
evaluated
potential
risks
resulting
from
disposal
of
the
laundry
sludge
when
generated
from
a
large
laundry.
These
laundries
have
the
same
characteristics
as
described
previously,
with
the
exception
that
2.7
million
pounds
of
printer
wipes
and
2.6
million
pounds
of
shop
wipes
are
accepted
annually
by
one
laundry.
Results
are
presented
in
Table
23.
For
this
case,
six
solvents
appear
to
pose
a
problem:
acetone,
nitrobenzene,
2­
nitropropane,
pyridine,
toluene,
and
xylenes.
133
Table
23
Evaluation
of
Laundry
Wastewater
Treatment
Sludges
for
Landfilling:
Large
Laundry
Constituent
Risk
Loading
Threshold
(
kg/
d)
Solvent
quantity
in
sludge
(
kg/
d)
Conclusion
Pyridine
(
TC)
0.006
0.036
Ineligible
Nitrobenzene
(
TC)
0.04
0.049
Ineligible
p­
Cresol
(
TC)
0.41
0.036
Acceptable
Acetone
(
OW)
1.73
2.56
Ineligible
Butanol
1.61
0.036
Acceptable
Methyl
isobutyl
ketone
(
OW)
0.03
0.020
Acceptable
Isobutyl
alcohol
4.31
0.036
Acceptable
2­
Ethoxyethanol
3.82
0.058
Acceptable
Ethyl
ether
4.30
0.049
Acceptable
Methanol
5.90
0.036
Acceptable
Methyl
ethyl
ketone
(
OW,
TC)
0.32
0.063
Acceptable
Ethyl
acetate
16.17
0.040
Acceptable
Carbon
disulfide
0.62
0.080
Acceptable
Tetrachloroethylene
(
OW,
TC)
5.83
0.30
Acceptable
Chlorobenzene
(
OW,
TC)
0.36
0.015
Acceptable
Cyclohexanone
64.55
0.13
Acceptable
Ethyl
benzene
(
OW)
11.95
2.14
Acceptable
Toluene
(
OW)
2.14
2.48
Ineligible
Dichlorodifluoromethane
2.16
0.071
Acceptable
1,1,1­
Trichloroethane
(
OW)
15.81
0.26
Acceptable
Trichlorofluoromethane
16.05
0.071
Acceptable
1,2­
Dichlorobenzene
12.84
0.036
Acceptable
Xylenes
(
total)
(
OW)
6.18
7.57
Ineligible
1,1,2­
Trichlorotrifluoroethane
403
0.13
Acceptable
2­
Nitropropane
©
­
air)
0.0033
0.045
Ineligible
Methylene
chloride
(
C,
OW)
0.39
0.051
Acceptable
Benzene
(
C,
TC)
0.24
0.062
Acceptable
1,1,2­
Trichloroethane
(
C)
0.83
0.058
Acceptable
Carbon
tetrachloride
(
C,
TC)
3.02
0.071
Acceptable
Trichloroethylene
(
C,
OW,
TC)
27.66
0.010
Acceptable
V.
E.
4.
What
High­
End
Assumptions
Are
Related
With
this
Analysis?

This
analysis
uses
many
of
the
same
high­
end
assumptions
as
used
for
the
analysis
for
disposables
in
landfills
presented
in
section
V.
B.
The
high­
end
assumptions
used
in
the
laundry
sludge
analysis,
as
they
relate
to
the
loading
of
the
contaminant
to
the
landfill,
include
the
following:

°
In
one
case,
EPA
evaluated
risks
from
sludge
generated
from
a
large
laundry.
While
such
facilities
exist,
they
represent
a
small
segment
of
the
population.
This
is
a
highend
parameter.
However,
results
were
presented
for
both
a
central
tendency
(
average­
sized)
laundry
and
a
large
laundry.
134
Additionally,
once
the
contaminant
enters
the
landfill,
a
number
of
additional
high­
end
assumptions
are
associated
with
fate
and
transport.
These
include
the
following:

°
The
contaminants
in
the
waste
are
assumed
to
be
available
for
release,
and
not
irreversibly
bound
to
the
matrix.

°
Use
of
one
of
four
scenarios
which
results
in
the
greatest
receptor
well
concentrations
(
i.
e.,
a
small
landfill).

°
The
DAF
for
groundwater
transport
was
evaluated
at
the
95th
percentile
level
in
a
Monte
Carlo
analysis.

V.
E.
5
What
Uncertainties
and
Limitations
Are
Related
With
this
Analysis?

A
primary
area
of
uncertainty
is
sludge
characterization.
All
evaluations
were
based
on
the
projected
levels
of
contaminant
in
the
sludge,
using
OW
data.
There
are
further
limitations
associated
with
this
approach.

°
The
analysis
does
not
account
for
the
range
and
variability
of
operations
and
sludge
disposal
practices
at
individual
laundries.
Such
variability
includes
the
following:

°
Differences
in
pretreatment
practices
of
incoming
wipes
or
variability
in
use
of
the
three
OW
wastewater
samples.

°
Variations
in
wastewater
treatment
system
configurations
and
solvent
removal
efficiency.
A
more
efficient
system
with
a
dissolved
air
flotation
(
DAF)
unit
increases
solvent
loadings
2
to
3
times
depending
on
the
contaminant
(
ERG,
2000).
However,
because
DAF
units
are
uncommon,
results
for
such
an
analysis
are
not
presented.

°
EPA
assumes
that
the
only
source
of
these
constituents
in
the
sludge
results
from
the
wipes
and
that
there
are
no
seasonal
variations
in
wipe
generation
rates
or
in
their
composition.

°
In
this
analysis
EPA
assumed
that
a
single
landfill
is
used
in
managing
waste
from
a
single
facility.
This
is
a
nationwide
average,
but
ignores
regional
variations
where
some
states
have
higher
concentrations
of
laundries.
For
example,
nationwide
there
are
about
2,500
landfills
(`
The
State
of
Garbage
in
America,'
BioCycle,
April
1998)
and
about
1,000
laundries
(
not
all
of
the
laundries
necessarily
manage
shop
and
printer
wipes)
(
EPA,
2000).
These
data
indicate
that
there
are
more
landfills
than
laundries.
However,
the
same
sources
indicate
that
in
five
states
(
Connecticut,
Delaware,
Maine,
Rhode
Island,
and
Vermont),
counted
together,
there
are
equal
numbers
of
laundries
and
landfills
(
24).

°
There
is
limited
sampling
data
available,
and
only
11
constituents
of
interest
were
26
The
HAPs
are
benzene,
carbon
disulfide,
carbon
tetrachloride,
chlorobenzene,
cresols,
ethyl
benzene,
methanol,
methyl
ethyl
ketone,
methylene
chloride,
methyl
isobutyl
ketone,
nitrobenzene,
2­
nitropropane,
tetrachloroethylene,
1,1,2­
trichloroethane,
toluene,
trichloroethylene,
and
xylenes.

135
detected.
The
remaining
constituents
were
not
available
or
not
detected
in
the
OW
data
set,
however,
the
same
series
of
assumption
made
for
the
constituents
with
OW
data
apply.

A
second
area
of
uncertainty
is
with
the
risk
assessment
itself.
These
uncertainties
were
identified
in
section
V.
B.

V.
E.
6.
Effects
from
Air
Emissions
EPA
did
not
evaluate
receptor
risks
from
the
management
of
solvent­
contaminated
industrial
wipes
at
industrial
laundries.
However,
EPA
did
identify
if
industrial
laundries
are
likely
to
be
considered
`
major
sources'
under
the
Clean
Air
Act
(
CAA).
One
of
the
criteria
for
a
major
source
is
whether
a
single
facility
releases
more
than
25,000
kg
(
55,000
pounds)
of
CAA
hazardous
air
pollutants
(
HAPs)
per
year.

Since
solvents
are
comprised
of
volatile
compounds,
the
potential
for
air
emissions
will
always
exist.
For
the
proposed
effluent
guidelines
rule
for
industrial
laundries,
EPA
estimated
that,
as
a
worst­
case
scenario,
HAPs
would
be
emitted
at
a
rate
of
14,000
kg
per
year,
per
facility.
As
part
of
this
present
analysis
regarding
solvent­
contaminated
industrial
wipes,
EPA
has
estimated
quantities
of
solvent
constituent
releases
into
the
air
by
modeling
laundry
facilities
using
the
WATER8
computer
model,
as
described
in
section
V.
E.
2.

Of
the
30
constituents
evaluated,
17
are
HAPs.
26
The
total
quantity
of
the
17
HAPs
released
by
a
laundry
with
the
assumptions
described
in
this
section
is
500
kg
per
year,
for
a
typical
size
laundry.
For
a
large
laundry,
an
estimated
5,000
kg
of
HAPs
are
estimated
to
be
released
annually.
Based
on
this
methodology,
industrial
laundry
facilities
would
not
be
defined
as
a
major
source
of
pollution
under
the
CAA
since
the
total
emissions
of
HAPs
does
not
exceed
the
25,000
kg
(
55,000
lbs.)
per
year
threshold.

V.
E.
7.
Recommendations
For
industrial
laundries
accepting
`
average'
amounts
of
solvent­
contaminated
shop
and
printer
wipes,
EPA
is
proposing
to
allow
the
generated
industrial
laundry
sludge
to
be
disposed
of
in
municipal
waste
landfills.
This
recommendation
would
therefore
allow
2­
nitropropane
contaminated
sludges
generated
by
industrial
laundry
wastewater
treatment
systems
to
be
eligible
for
disposal,
even
though
the
results
of
Table
22
suggest
it
may
present
a
risk.
EPA
is
proposing
this
recommendation
because
it
has
been
unable
to
identify
in
data
searches
even
one
generator
who
uses
this
chemical
for
cleaning
or
degreasing
operations
in
conjunction
with
reusable
(
or
disposable)
wipes.

With
respect
to
the
very
few
industrial
laundries
managing
large
amounts
of
solventcontaminated
industrial
wipes,
EPA
again
is
proposing
to
allow
industrial
laundry
sludge
to
be
136
disposed
of
in
municipal
landfills.
EPA
is
proposing
this
recommendation
because
it
does
not
believe
all
generators
are
using
F­
listed
solvents,
particularly
those
not
found
in
the
Office
of
Water's
washwater
samples.
This
analysis
assumes
that
all
washwaters
contain
the
same
constituents
and
concentrations
as
found
in
OW's
samples,
which
is
not
possible.
In
addition,
EPA
has
found
from
site
visits
that
the
very
large
industrial
laundries
tend
to
utilize
solvent
extraction
technologies
prior
to
entering
the
laundering
process
 
thus
the
amount
of
contaminants
in
the
sludge
should
be
substantially
reduced.

V.
F.
Damage
Cases
Associated
with
Solvent­
Contaminated
Industrial
Wipes
EPA
investigated
whether
there
have
been
damage
cases
involving
solvent­
contaminated
industrial
wipes
(
e.
g.,
where
these
wipes
spontaneously
combusted
or
fires
occurred
involving
these
materials).
In
support
of
this
effort,
EPA
searched
available
databases
and
several
other
sources
to
determine
if
there
are
damage
cases
or
any
formal
documentation
available
on
the
combustibility
of
solvent­
contaminated
industrial
wipes.

Based
on
engineering
analyses
and
results
from
visits
to
generators,
the
most
serious
potential
for
environmental
damage
from
solvent­
contaminated
industrial
wipes
is
the
ignition
of
these
material,
although
other
forms
of
environmental
damage
are
possible,
such
as
uncontrolled
land
disposal
resulting
in
groundwater
contamination.
While
the
migration
of
solvents
in
the
groundwater
has
been
well­
documented
(
see,
for
example,
EPA's
1980
background
document
for
listing
F001
through
F005
wastes
as
hazardous),
EPA
expected
it
would
be
difficult,
if
not
impossible,
to
try
to
investigate
if
contamination
has
resulted
specifically
from
the
landfill
disposal
of
solvent­
contaminated
media.

V.
F.
1.
What
Are
the
Findings?

Although
many
fires
caused
by
solvent­
contaminated
industrial
wipes
are
controlled
and
extinguished
on
site
without
assistance
from
emergency
response
personnel,
other
information
collected
found
that
sometimes
the
fires
escalate
and
result
in
the
entire
facility
being
destroyed.

The
U.
S.
Fire
Administration
(
USFA),
within
the
Federal
Emergency
Management
Agency
(
FEMA),
gathers
and
analyses
information
on
the
magnitude
of
the
nation's
fire
problem,
as
well
as
detailed
characteristics
and
trends.
As
part
of
this,
participating
local
fire
departments
fill
out
Incident
and
Casualty
reports
as
fires
occur.
These
data
are
maintained
on
the
National
Fire
Incident
Reporting
System
(
NFIRS).
Currently,
40
states
and
the
District
of
Columbia
voluntarily
participate
and
report
NFIRS
data.
Nearly
14,000
out
of
30,000
fire
departments
report
NFIRS
data.

In
an
effort
to
understand
the
extent
of
reported
fires
at
industrial
laundries
a
query
was
made
of
NFIRS
for
the
1993­
97
time
period.
Below
is
a
summary
of
the
number
of
the
reported
incidents,
total
number
of
states
where
incidents
were
reported,
and
estimated
dollar
loss.
27Discussion
between
Captain
Rob
Dunham,
Deputy
Fire
Marshal,
City
of
Oceanside,
California
and
Jim
O'Leary
on
August
27,
1999;
discussion
between
Michael
Perry,
Division
of
Fire,
City
of
Franklin,
Ohio
and
Jim
O'Leary
on
September
7,
1999.

137
Year
Total
Incidents
No.
States
w/
Incidents
Est.
Dollar
Loss(
m)
1993
186
28
$
2.1
1994
154
33
$
1.2
1995
158
30
$
1.7
1996
131
29
$
1.1
1997
106
26
$
3.3
The
average
number
of
reported
fires
was
147.
However,
maybe
more
important
has
been
the
steady
decline
from
a
high
in
1993
of
186
reported
fires
to
106
in
1997.
Assuming
only
one
fire
occurred
per
facility,
this
represents
six
percent
of
the
universe
of
industrial
laundries.
Similarly,
the
average
estimated
dollar
loss
of
most
reported
fires
ranges
from
a
low
of
$
7,792
in
1994
to
$
31,132
in
1997.
A
closer
look
at
the
data
reveals
that
most
reported
fires
are
at
the
lower
dollar
loss
range,
but
that
a
few
fires
with
million
dollar
(
and
higher)
estimated
losses
skew
the
results
higher.
Also,
in
discussions
and
correspondence
with
a
few
fire
marshals
where
high
dollar
losses
occurred,
wipes
were
involved
in
the
cause
 
primarily
through
the
self­
combustion
of
these
materials.
27
As
discussed
in
the
preamble
to
this
rule,
officials
from
the
industrial
laundry
trade
associations
are
very
concerned
about
spontaneous
combustion.
EPA
has
asked
for
comments
regarding
whether
generators
should
be
allowed
to
use
exotic
solvents
in
conjunction
with
industrial
wipes
to
send
their
wipes
off
site
with
free
liquids
to
avoid
the
potential
of
self­
ignited
fires.

EPA
also
searched
other
available
databases
and
the
Internet,
and
requested
information
from
several
State
agency
officials
and
representatives
from
trade
associations.
Evidence
of
damage
as
a
result
of
spontaneous
combustion
(
or
self­
ignition)
of
wipes
was
found.
Several
experts
contacted
noted
the
danger
of
ignition
of
solvent­
contaminated
industrial
wipes.
However,
given
the
small
scale
of
most
fires
associated
with
these
materials,
documentation
of
specific
instances
of
fire
damage
due
primarily
to
spontaneous
combustion
of
solvent­
contaminated
industrial
wipes
was
not
available.
Additional
information
on
fires
caused
by
these
materials
may
exist
in
local
fire
departments
not
contacted
by
EPA.

According
to
interviews
with
representatives
from
the
insurance
industry
and
states,
solvent­
contaminated
industrial
wipes
do
present
a
fire
risk.
However,
most
of
the
fires
resulting
from
solvent­
contaminated
industrial
wipes
are
small
in
scale,
are
easily
extinguished
with
a
fire
extinguisher,
and
cause
minimal
damage.
Most
of
the
fires
can
be
easily
avoided
through
better
management.
One
insurance
industry
representative
suggested
that
fires
may
be
more
frequent
in
industrial
laundries
since
they
accept
wipes
from
many
different
companies
and
may
not
be
able
to
control
the
mixing
of
combustibles.
138
V.
F.
2.
Sources
for
Information
on
Environmental
Damage
from
Solvent­
Contaminated
Industrial
Wipes
EPA
reviewed
data
from
numerous
sources
to
identify
evidence
of
environmental
damage
from
solvent­
contaminated
industrial
wipes.
These
sources
included
publicly
available
databases,
conversations
with
officials
in
States
and
EPA
Regions,
fire­
related
trade
associations,
the
Internet,
local
fire
departments,
and
background
materials
in
OW's
docket
supporting
the
pretreatment
standards
rule
for
industrial
laundries.
Each
of
these
sources
is
discussed
below.

Databases
Numerous
databases
catalogue
accident
and
damage
information.
The
Right­
to­
Know
Network
(
http://
www.
rtk.
net)
contains
several
on­
line
databases
which
can
be
searched.
The
following
RTK
Net
databases
were
investigated
for
information
regarding
damage
cases
involving
solvent­
contaminated
industrial
wipes
using
related
search
terms
(
e.
g.,
industrial
laundry,
solvent,
rags,
wipes,
F001­
F005).
The
following
lists
the
specific
databases
that
were
searched,
what
was
looked
for,
and
what
relevant
information
was
found,
if
any.

ARIP
(
Accidental
Release
Information
Program)­­
ARIP
contains
information
on
the
causes
of
accidents,
and
particularly
targets
accidents
that
resulted
in
off­
site
consequence
or
environmental
damage.

CERCLIS
(
CERCLA
"
Superfund"
Information
System)­­
The
database
contains
information
on
hazardous
waste
sites,
site
inspections,
preliminary
assessments,
and
remedial
status.

DOCKET­­
This
database
contains
EPA
Civil
Court
cases
and
Administrative
Actions
filed
by
the
Department
of
Justice
on
behalf
of
EPA.

ERNS
(
Emergency
Response
Notification
System)
 
ERNS
compiles
reports
of
nonroutine
releases
of
certain
substances
when
those
releases
exceed
a
reportable
quantity
(
RQ).
This
database
can
be
searched
by
geographical
area,
discharger,
and
material.

FINDS
(
Facility
Index
System)
 
This
database
provides
basic
information
on
facilities
regulated
under
a
variety
of
EPA
program
areas.

PCS
(
Permit
Control
System
for
water
permits)
 
This
database
tracks
NPDES
surface
water
permits
issued
under
the
Clean
Water
Act.

RCRIS
(
RCRA
Information
System)
 
This
database
contains
information
regarding
violations,
enforcement
actions,
and
inspections
at
RCRA
facilities.

NFIRS
(
National
Fire
Incident
Reporting
System)
 
This
database
compiles
information
about
fires
through
reports
filed
to
the
U.
S.
Fire
Administration
from
local
fire
departments.
139
BLS
(
Bureau
of
Labor
Statistics)
 
The
Bureau
of
Labor
Statistics
Internet
site
contains
a
database
(
http://
www.
osha.
gov/
oshstats/
bls)
containing
information
on
laundry,
cleaning,
and
garment
services.

OSHA
(
Occupational
Safety
and
Health
information)
 
OSHA's
Office
of
Statistics
was
contacted
to
search
their
databases.

States
Few
state
officials
provided
any
information
or
comments
on
damage
cases
caused
by
solvent­
contaminated
industrial
wipes.
Information
regarding
damage
cases
from
both
generators
and
industrial
laundries
was
generally
not
available
as
many
states
and
EPA
RCRA
enforcement
officials
do
not
extensively
regulate
or
collect
information
on
many
of
these
facilities.
140
VI.
References
ERG.
2000.
Mass
Balance
Estimation
for
Solvents
on
Soiled
Printer
Towels
 
Analysis
Based
on
Office
of
Water
Printer
Towel
Sampling
Data.
February
1,
2000.

Jacqueline
Kanters
and
Robert
Louw.
"
Chlorine
Input
and
Output
in
Combustion
of
Municipal
Solid
Waste
in
a
Lab­
Scale
Mini­
Reactor
System."
Chemosphere
29(
9­
11),
pp
1919­
1925
(
1994).

V.
Ozvacic,
G.
Wong,
H.
Tosine,
R.
E.
Clement,
J.
Osburne.
"
Emissions
of
Chlorinated
Organics
from
Two
Municipal
Incinerators
in
Ontario."
Journal
of
the
Air
Pollution
Control
Association
35(
8),
pp
849­
855
(
1985).

C.
Rittemeyer,
P.
Kaese,
J.
Vehlow,
W.
Vilöhr.
"
Decomposition
of
Organohalogen
Compounds
in
Municipal
Solid
Waste
Incineration
Plants.
Part
II:
Co­
Combustion
of
CFC
Containing
Polyurethane
Foams."
Chemosphere
28(
8),
pp
1455­
1465
(
1994).

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