Re: Solvent-laden rag transport

Art Coleman (
Wed Feb 14 07:03:43 1996

For those of you interested in the solvent-laden rag transport issue posed by
Mr. Bill Bilkovich, I would like to take this opportunity to briefly put it into
perspective. The primary regulatory issues are whether or not a laundries
exceed wastewater discharge limits and the transport and management of
hazardous waste. The level of solvent contamination from reusable cloth in a
laundering facility's wastewater may not meet established wastewater
discharge limits. In addition, free liquids (solvent) which settle out from cloth
may be hazardous wastes. In Ohio, shipments containing such free liquids to a
receiving facility must be done in compliance with all of Ohio's applicable
hazardous waste transporter requirements in Chapter 3745-53 of the Ohio
Administrative Code (OAC). Many states, such as Ohio, do not consider
solvent-contaminated cloth sent to a cleaning facility and returned to the
generator for reuse a waste, hence, hazardous waste, provided certain
conditions are met. One condition is that the cloth contain no free liquids. Full
details are disclosed in Ohio's guidance: "Guidance On The Management Of
Solvent-Contaminated Rags And Wipers" (available for distribution upon

Small amounts of liquid collecting on the bottom of a container from
solvent-laden cloth is probably inevitable, but adherence to "good
housekeeping" and other practices should minimize the problem. Generators
typically either hand wring or use mechanical procedures to remove residual
solvent from their contaminated cloth, prior to placing the cloth in a storage
container. Before the cloth is transported to the cleaning facility, the content of
the container should be inspected for free liquids. If free liquids are present,
they are decanted and managed accordingly. Some containers have a "false
bottom" that collects and segregates solvent released from the cloth. The
liquid is removed and disposed of or recycled. Some "high technology" dry
cleaning facilities use a distillation system to recover solvent for reuse from
cloth and absorbents.

As a general rule, we suggest the generator use his/her best judgement in
determining whether or not free liquids are present in cloth. However, free
liquids can be estimated by using a more quantitative approach, such as the
U.S. EPA "Paint Filter Test" or the proposed "Liquid Release Test." The
"Liquid Release Test" takes into consideration bulk weight or pressure as a
factor contributing to the release of free liquids.

Art Coleman



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