Quickstart Guide to the 2013 EPA Solvent-Laden Wipe Rule Changes

Discussion in 'Infographics and Quickstart Guides' started by Andy, Jan 15, 2014.

  1. Andy

    Andy Administrator Waste Min Publisher 2013 Industrial Waste Survey Participant

    Quickstart Guide to the 2013 EPA Solvent-Laden Wipe Rule Infographic.png
    Last edited: Nov 11, 2014
  2. Andy

    Andy Administrator Waste Min Publisher 2013 Industrial Waste Survey Participant

    Full-text version:

    Quickstart Guide to the 2013 EPA Solvent-Laden Wipe Rule Changes

    It isn't every day that regulations are loosened, but the EPA has done just that with a set of exemptions for the disposal of certain types of solvent saturated wipes, rags and pads. Because this is such an important change, we simplified pages of regs down to a flowchart decision guide to help you quickly understand if your facility might be eligible for the Exclusions, and a 4-Step Blueprint for Compliance to help you understand what you'll need to do to comply.

    The Waste Minimization Forum (wastemin.com) surveyed 461 leading plants in the US and found that few were aware of the rule change and what it meant for their facility. That is why we created this Guide.

    Why this rule change might be important for your facility: The EPA's estimate of annual SAVINGS per facility from this rule change is $30,489 per large quantity generator (LQG) facility and $4,207 per small quantity generator (SQG) facility.

    Find Your Facility's Path to Exclusion (for simplicity, we recommend using the visual decision guide found in the image version ):
    A how-to guide to understand the Solvent-Contaminated Wipes Solid Waste Exclusion or Solvent-Contaminated Wipes Hazardous Waste Exclusion. Adapted from EPA rule materials available at http://www.epa.gov/wastes/hazard/wastetypes/wasteid/solvents/wipes.htm

    1) Is it "a woven or non-woven shop towel, rag, pad or swab made of wood pulp, fabric, cotton, polyester blends or other material" or and absorbent mat pad used for spill cleanup? (40 CFR 260.10)
    • YES: Continue
    • NO: This waste is not eligible for the Exclusion
    2) Do the wipes/pads contain ONE OR MORE of the following solvents? (EPA F001-F005 listed solvents per 261.31 and P- and U- listed solvents per 261.33, both cited per EPA wiper rule)

    n-Butyl Alcohol
    Carbon disulfide
    Carbon Tetrachloride
    Cresylic Acid
    Ethyl Acetate
    Ethyl Benzene
    Ethyl Ether
    Isobutyl Alcohol
    Methyl Ethyl Ketone
    Methyl Isobutyl Ketone
    Methylene Chloride
    Tetrachloroethylene (Perchloroethylene)
    Trichloroethylene (*For reusable wipes ONLY)
    Trichlorotrifluoroethane (Valclene)
    • YES: Continue
    • NO: Do the wipes/pads exhibit ONLY the hazardous characteristic of ignitability when containing one or more NON-LISTED solvents?
      • YES: Continue.
      • NO: This waste is not eligible for the Exclusion
    3) Do the wipes/pads contain listed hazardous other than solvents?
    • YES: This waste is not eligible for the Exclusion
    • NO: Continue.
    4) Do the wipes/pads exhibit the characteristic of toxicity, corrosivity or reactivity due to non-listed solvents or contaminants?
    • YES: This waste is not eligible for the Exclusion
    • NO: Congratulations, this waste is eligible for Exclusion!
    Reusable wipes/pads are eligible for Solid Waste Exclusion - 40 CFR 261.4(a)26
    Disposable wipes/pads are eligible for Hazardous Waste Exclusion - 40 CFR 261.4(b)(18)

    4-Step Blueprint for Compliance if your waste is eligible for Exclusion:

    Step 1) Closed containers. A liquidproof container with a tight fitting lid is needed.
    "Wipes must be accumulated, stored and transported in non-leaking, closed containers that contain free liquids, should they occur."

    Containers must be clearly labelled as "Excluded Solvent-Contaminated Wipes"
    Step 2) No free liquids. Saturated wipers are OK, loose solvent in the container is not.
    "Wipes must contain no free liquids prior to being sent for cleaning or disposal and there may not be free liquid in the container holding the wipes."

    "Free liquids removed from the wipes or from the wipes container must be manager according to applicable hazardous waste regulations in 40 CFR parts 260 through 273."
    Step 3) Time and handling. Dispose within 180 days from when the first wiper hits that drum.
    Wipes/pads may be accumulated up to 180 days on site prior to being sent for cleaning or disposal.

    Eligible laundering: A facility "regulated under sections 301 and 402 or section 307 of the Clean Water Act."

    Eligible disposal: a municipal landfill "regulated under 40 CFR part 258 (incl. 258.40)" or "hazardous waste landfill regulated under 40 CFR parts 264 or 265."

    Eligible incineration: A combustor "regulated under section 129 of the Clean Air Act" or "hazardous waste combustor, boiler or industrial furnace regulated under 40 CFR parts 264, 265 or subpart H."
    Step 4) Recordkeeping. Simple records make sure that you use the Exemption properly.
    Records must be maintained to capture the following:
    1) Name and address of the cleaning or disposal company where the wipes are sent.
    2) Waste collection dates to assure that the wipes are not being accumulated for longer than the 180 day limit.
    3) A description of the process the generator is using to meet the "no free liquids" requirement.
    EPA Press Release
    EPA FAQ on the 2013 Solvent-Contaminated Wipes Rule
    EPA Summary of the new rule
    EPA Paint Filter Liquids Test (an example of how to measure "free liquids")
    Last edited: Jan 21, 2014