We generate a large quantity of solvent-laden towels in our solvent cleaning and maintenance activities. These have been drummed up and disposed as hazardous waste, but our uniform supplier says it can take these towels, clean them and return them to us to reuse. This would lower towel purchase and disposal costs. Is this acceptable to EPA?
This issue has been experienced by many companies. Currently, EPA has not published any specific rulemaking on the cleaning, recycling and reuse of contaminated shop towels, rags and wipes and has left the issue up to each EPA region and RCRA-authorized states to handle.
Based upon our experience, most states have used EPA's definition of a "solid waste" to classify contaminated shop towels, rags and wipes, even if they meet either the definition of a characteristic hazardous waste, such as ignitable, or a listed hazardous waste, such as those containing spent toluene and xylene, NOT as "solid waste" as long as they are sent off-site for laundry, returned for reuse and contain no free liquids. Since the contaminated towels, rags and wipes are not "solid waste," they cannot be "hazardous waste." The rational of "no free liquids" is that if the generator would ship the contaminated towels off-site with free liquids in the bottom of the container, these free liquids could indeed be a hazardous waste, and the laundry would have to "treat" or "dispose" of this hazardous waste. Another caveat is that the states require the laundry to comply with applicable air pollution and wastewater regulation under the Clean Air and Clean Water Acts.
To solve this problem, one of our clients constructed two holding bins for their contaminated rags. The rags are placed into cloth bags which are then deposited upon a screen above the bottom of the bin. This allows the free liquid solvent to drip into the bottom of the bin where it is collected for reuse. After a week or so, the rags and cloth bags are "drip dry" and ready for pickup by the laundry service.
Contact your state or EPA region to inquire if the above arrangement is allowed. If so, I would then contact your uniform supplier and obtain documentation that their laundry facility is in compliance with applicable air pollution and wastewater discharge regulations. If this checks out and you are able to remove the free liquids from the rags, by all means implement this pollution prevention activity.