OSW and UTSA/TRSA

Meeting Notes 

November 7, 2006

On Tuesday, November 07, 2006, Tony Wagner, [Uniform and Textile Service
Association (UTSA)] and Robert Schaffer [Textile Rental Services
Association of America (TRSA)] met with the Teena Wooten and Robert
Dellinger of the  Environmental Protection Agency (EPA) Office of Solid
Waste.

UTSA/TRSA is interested in EPA’s progress on the risk assessment for
the solvent-contaminated wipes rule.  They supplied information about
the laundries to Teena in a letter dated September 12, 2006.  They
wanted to know if EPA needed additional information to complete the
assessment.  UTSA/TRSA is concerned about the assumptions EPA is using. 
They wanted to provide us with information that would reduce their
concerns about those assumptions.  

Bob Dellinger explained that EPA could not provide any information on
the risk assessment without a Federal Register notice because it would
be necessary to inform all stakeholders, not just a select few. 
However, EPA plans to publish a notice of data availability (NODA) that
will give the public an opportunity to comment on the assumptions used
in the risk assessment.  EPA is open to discussing the assumptions
subsequent to the NODA.    

UTSA/TRSA explained that a very small percentage of laundries receive
listed solvents.  The laundries that do accept listed solvents collect
the solvent and transport it as a hazardous waste to an incinerator. 
Most of the printing industry, specifically newspaper printers, changed
to soy-based inks several years ago.  The Associations established a
laundry ESP program that requires the laundry customers to remove any
free liquids before sending the wipes to the laundry.  Approximately 6%
of the materials received at laundries are printer towels.   

Based on a survey that covered 1997-2002, the Associations found that
99% of the sludge generated by the laundries is non-hazardous.  The
facilities with hazardous sludge handle it as hazardous waste.  If a
laundry accepts solvent contaminated wipes and it is incapable of
laundering them, the wipes may be sent to an intra-company laundry for
cleaning.  The ESP states that the wipes should not be shipped with free
liquids.  The laundries follow the DOT shipping requirements.  

Laundries only test for constituents required by the landfills. 
Procedure for free liquids: 1) Customer should not ask transporter to
accept.  2) Transporter should not accept.  3) If the laundry receives
shipments with free liquids, they are immediately put back on the truck
and returned to the customer.  Customer is told that the shipment is a
violation and requiring the transporter to transport it is a violation. 


EPA explained that we are reviewing all the comments received on the
risk assessment and other parts of the proposed rule and that we are no
longer requesting additional information.

Teena Wooten

Office of Solid Waste

Hazardous waste Identification Division

Resource Conservation and Recycling Branch

703-308-8751

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