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Flexo Sustainable : Year-End 2013
STORAGE LIMITATIONS Facilities that generate solvent contaminated wipes must comply with certain recordkeeping requirements and may not accumulate wipes for longer than 180 days. This ensures that solvent contaminated wipes are not stored indefinitely on site. Generators must maintain certain documentation on site, so that states and the EPA can ensure the generators are maintaining compliance with the conditions of the exclusion. This includes written evidence that they are managing wipes excluded under 40 CFR 261.4(a)(26). This must include the name and address of the laundry or dry cleaner receiving the reusable wipes, documentation that the 180 day accumula- tion time limit is being met and a description of the process the generator is using to meet the ‘‘no free liquids’’ condition. Solvent contaminated wipes that are managed according to the conditions in the final rule are not hazardous wastes and thus generators do not need to meet the more stringent hazardous waste regulations. For example, solvent contam- inated wipes, managed under the final rule exclusions, no longer have to be manifested when being sent off site and may be sent to non hazardous waste handling facilities. REUSABLE & DISPOSABLE There are three main differences between the exclusion for reusable wipes and the exclusion for disposable wipes: • Under the final rule, reusable wipes are not solid and hazardous wastes; however, disposable wipes are solid wastes, but not hazardous wastes • Disposable wipes that are hazardous waste due to the presence of trichloroethylene are not eligible for the ex- clusion because trichloroethylene may pose a significant risk to human health and the environment when disposed in a lined landfill • Reusable wipes may go to laundries or dry cleaners whose discharge, if any, is regulated under the Clean Water Act (CWA). Disposable wipes may go to regulated combustors, municipal solid waste landfills or hazardous waste landfills Laundries and dry cleaners, solid waste combustors and municipal solid waste landfills that receive solvent contam- inated wipes are regulated under their respective CWA, Clean Air Act and RCRA regulations. These statutes serve to address the risk of any potential solvent released to the water, air and land. BENEFITS EPA estimates that the final rule will result in a net savings of between $21.7 million and $27.8 million per year. This includes a net savings of $18 million per year in avoided regu- latory costs and between $3.7 million and $9.9 million per year in other expected benefits, including: • Pollution Prevention • Waste Minimization • Fire Safety IMPACT ON EXISTING RULES Under RCRA Section 3006, the EPA may authorize qualified states to administer the RCRA Subtitle C hazardous waste program within the state. Following authorization, the vetted state program operates in lieu of the federal regulations. The final rule includes requirements and condi- tions that are less strin- gent than those of the base RCRA hazardous waste program. Thus, states with an authorized RCRA program, except as described in this article, are not required to adopt the conditional exclusions. States may, through implementation of waiver authorities or other local laws, allow compliance with the provisions of the federal rule in advance of adoption or authorization. States cannot implement requirements that are less strin- gent than the federal requirements in the final rule. EPA’s pre- vious policy, established in the 1990s, had deferred determi- nation of the regulatory status of solvent contaminated wipes to the states and EPA regions (68 FR 65617). This deferral has resulted in the development of various state programs for solvent contaminated wipes, particularly for reusable wipes. This federal rule for reusable wipes is generally consistent with many of the states’ policies; however, some conditions required by the final rule may be more stringent than some existing state programs. As a result, authorized states whose programs include less stringent requirements than the 2013 final rule are required to modify their programs to maintain consistency with the federal program per the provisions of 40 CFR 271.21(e). In addition, any states that delineate their program for reusable wipes in guidance documents or interpretive letters, will need to promulgate enforceable regulations, as required by 40 CFR 271.7 . The current state requirements remain in place until the state adopts the equivalent to these federal requirements. ADDITIONAL INFORMATION Details on 40 CFR Parts 260 and 261 Conditional Exclusions from Solid Waste and Hazardous Waste for Solvent Contami- nated Wipes, Final Rule, can be accessed at: • www.epa.gov/wastes/laws-regs/state/revision/frs/fr229.pdf • www.epa.gov/epawaste/hazard/wastetypes/wasteid/sol- vents/wipes.htm Details on the Paint Filter Liquids Test can be found at: • www.epa.gov/epawaste/hazard/testmethods/sw846/ pdfs/9095b.pdf n About the Authors: Doreen M. Monteleone, Ph .D. , is the sustainability specialist for the Flexographic Technical Asso- ciation. George Fickau is a member of FTA’s Sustainability Committee. For more information, contact Doreen at dmon- email@example.com. www.flexomag.com YEAR END 2013 Sustainable FLEXO 11
Earth Day 2014