[Sqg-program] Rag & Air filters disposal guidelines QA

Perrigan, Glen Glen.Perrigan at dep.state.fl.us
Thu Dec 18 09:51:30 EST 2008

Hi All


Below are some questions posed by a county and responses by one of our
District DEP offices. As always RCRA interpretations are not always clear
cut. I recommend you contact your District office for their take on these
questions. Districts, feel free to chime in if you have comment or something
to add. Be sure to reply to ALL if you want your response to go to everyone
on the list server. Thanks. Glen

1)      Use of the RCRA "process knowledge" approach (where facility operator
can verify no haz. mat) is extremely rare and neither DEP nor most other
counties allow  for use of this approach for the simple fact that 99% of all
paints at Body Shops contain haz. materials.  It is simpler for facilities to
profile and make a determination than attempt to use process knowledge

For waste paint thinners and related solvent in Paint and Body shops, no
determination is necessary because the waste thinner is, by virtue of listing
(F003 and F005), a hazardous waste and must be managed as such. It is also
characteristically hazardous for ignitability (D001).  Rags used with paint
thinners in a body shop will also be RCRA hazardous for listing, but can be
commercially laundered if the rags are reusable. Spray booth filters have the
potential to be characteristically hazardous for the 8 RCRA Metals. 

Process knowledge may be acceptable, but it depends on the nature of the
waste and the likelihood that contaminants from various sources may
contribute to the hazardous nature of the waste (what if one of the employees
is coming in on the weekends and spraying vehicles with old imported
paints?). For example, it is unlikely we would accept process knowledge for
waste parts washer solvent based on the properties described in the product's
MSDS (high-flashpoint petroleum solvents or alkaline aqueous solutions),
because the facility is cleaning parts in the parts washer or using other
chemicals (like aerosol chlorinated brake cleaners) that may make the
resultant waste hazardous.  For spray booth filters at body shops, it is
typical that they are spraying one type of paint and unlikely that other
contaminants may be introduced to the filters besides those from the paint; a
process knowledge statement with supporting documentation may be acceptable
in this case.  If a facility chooses to make a process knowledge
determination on their waste, it must be comprehensive and include
documentation to substantiate their claims; however, it is at the
Department's discretion to not accept the claim if it is not substantiative.

2)      DEP and most of the other counties have been requiring profiling of
all rags and filters to determine proper disposal methods.  This profiling
should occur ONCE every five years OR if the facility process changes in any
way  (e.g. using new paints, etc.).   Waste determination can be affected by
the amount of paint allowed to accumulate on the filters.

The HW C&E has proposed that facilities perform determinations at a frequency
of every 2 to 3 years; however, that is only guidance.  We offer the guidance
to body shops that the frequency of filter changes could affect the nature of
their waste in that the longer they are in place, the possibility that
greater concentrations of regulated compounds could be present.  If a
facility provides a written process knowledge statement for their filters,
they must include this information in their claim for our evaluation of this

3)      Profiling for filters and rags should include Total Metals and TCLP
(do you typically include flammability?)

We don't usually request total metals because the TCLP value is what is
designated by the regulations. If the total metals concentrations are less
than 20 times the TCLP regulatory concentration, then it is unlikely that
hazardous concentrations would leach out.  However, if a facility does
perform a total metals analysis, then they can proceed with TCLP analysis for
the particular metals, if any, that have concentrations above 20 times to
verify the nature of their waste. We don't typically include ignitability on
a dry solid (if the filters are wet with paint or solvent, there's a

4)      Evaporation of paints is not allowable method since this is
considered treatment.  Only empty paint cans and spray paint cans can be
disposed of.  In general, all containers with paints or solvents must be
maintained closed at all times in the facility.

RCRA-empty containers can go to the trash.  Spray cans are also reactive
wastes (D003) because of the propellant; if the propellant is expended (for
example, using a drum-top can puncturing device), then the cans can go to the
trash or even better recycled as scrap metal. The drum-top can puncturing
devices render the cans nonreactive (acceptable form of treatment), and
collect any residues from the can for hazardous waste disposal (f required
based on the can's contents). Container closure is always a requirement.

5)      Rags don't count against SQG status. 

Rags don't count if they are commercially laundered at a facility with
approval/permitting from the POTW.  If rags are being managed as hazardous
waste, or if they are being thrown in the trash without a HW determination
having been performed, then they count towards a facility's generator status.

The Department of Environmental 

Protection values your feedback as a customer. DEP Secretary Michael W. Sole is committed to continuously assessing and 

improving the level and quality of services provided to you. Please take a few minutes to comment on the quality of 

service you received. Copy the url below to a web browser to complete the DEP 

survey: http://survey.dep.state.fl.us/?refemail=Glen.Perrigan@dep.state.fl.us Thank you in advance for completing the survey.
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