Nebraska Department of Environmental Quality

ENVIRONMENTAL FACT SHEET

01-080 June 5, 2001

Solvent Contaminated Shop Towels, Rags, and Wipers

This Environmental Fact Sheet provides general and specific waste management guidance on hazardous waste issues associated with managing solvent contaminated shop towels, rags, and wipers. This information is based on Title 128 - Nebraska Hazardous Waste Regulations. 1. Wipers that have been contaminated with a listed hazardous waste (Title 128, Chapter 3, 011) are regulated as a listed hazardous waste when disposed (Title 128, Chapter 2, 005 and 005.02). 2. Whether the solvent is applied to an object and cleaned or applied to the wiper prior to use results in the same waste. The department does not make any distinctions on how the spent solvent got onto the wiper. The wiper would be a listed waste either way. 3. Wipers that are a characteristic hazardous waste (Title 128, Chapter 3, 007 through 010) must be managed as a hazardous waste. 4. Wipers contaminated with listed waste listed solely because it exhibits one or more of the characteristics of hazardous waste identified in Title 128, Chapter 3, 007 through 010 present a special circumstance (Title 128, Chapter 2, 004.02C). If these wastes no longer exhibit a characteristic of hazardous waste, they are not considered hazardous waste. However, nonwastewater mixtures are still subject to the land disposal restrictions of Title 128, Chapter 20 even if they do not exhibit a characteristic at the point of land disposal (Title 128, Chapter 2, 004.02C). a) For example, if a wiper is used to clean a part with acetone, the resultant spent wiper is a F003 listed waste. The F003 listing is based solely on the characteristic of ignitability. (See the Hazard Code I associated with F003 at Table 4, Title 128, Chapter 3, 013.) As a result, the waste is not hazardous waste if it loses its characteristic. A dry wiper does not normally exhibit the characteristic of ignitability. b) Using the same example above, if the waste had the characteristic of ignitability at the point of generation but lost it prior to disposal it is a non-hazardous waste that is subject to the Title 128, Chapter 20 land disposal restrictions. Such a wiper would need to meet all the treatment standards for all the constituents of F003 and F001, F002, F004, and F005 listed waste at Table 9 of Title 128, Chapter 20 before the wipers could be sent to a RCRA-D (non-hazardous solid waste) landfill as non-hazardous waste.
Produced by: Nebraska Department of Environmental Quality, P.O. Box 98922, Lincoln, NE 68509-8922; phone (402) 4714217. To view this, and other information related to our agency, visit our web site at www. deq.state.ne.us. This material is intended for guidance purposes only. It is not meant to substitute for the regulations found in Title 128 Nebraska Hazardous Waste Regulations or other applicable Nebraska environmental regulations.

c) Using the same example at paragraph 4a, if the waste did not have the characteristic of ignitability at the point of generation it is a non-hazardous waste and is not subject to the Title 128, Chapter 20 land disposal restrictions. Such a wiper could be sent directly to a RCRA-D landfill as nonhazardous waste. d) Deliberate drying of spent wipers that are hazardous waste for ignitability is considered a form of hazardous waste treatment. 5. Solvent wipers that will be cleaned or laundered and reused are considered to be in continued use. As a result, these wipers have not been discarded and are not a solid waste (Title 128, Chapter 2, 003). This interpretation is contingent upon the following: a) The container used to hold the soiled wipers and the wipers contain no free liquid. If there were free liquids, there is the assumption that hazardous waste could be being disposed incident to the wiper laundering or cleaning. b) The commercial cleaner or laundry receiving the soiled wipers must be in compliance with applicable environmental regulations such as the Clean Water Act for laundries. c) The commercial cleaner or laundry receiving the soiled wipers is not required to obtain a hazardous waste treatment, storage, or disposal permit for the wiper cleaning because the wipers are not considered to be a solid, and hence, a hazardous waste. HELPFUL WEB SITE: NDEQ Home Page: http://www.deq.state.ne.us/ for Title 128 and NDEQ Environmental Fact Sheets and Guidance Documents

CONTACTS: NDEQ Hazardous Waste Compliance Assistance NDEQ Waste Management Section (402) 471-8308 (402) 471-4210