From the archives of the Enforcement and Compliance Listserv for Hazardous Waste Generators

April 5, 2006

Waste Management Guidance on Still Bottoms from Solvent Distillation Units

Many automobile dealerships, auto body shops, and other businesses operate resource recovery solvent distillation units. These solvent stills help businesses reduce both their solvent purchases and hazardous waste generation rates. Waste still bottoms are generated from the distillation process and must occasionally be removed from the unit and disposed. In recent years, several businesses have been out of compliance because they didn’t know that their still bottoms were hazardous wastes, and they disposed of these still bottoms illegally in a sanitary landfill. This guidance is intended to help you avoid these violations at your business.

Depending on the specific solvent used, the still bottoms from your distillation unit may be hazardous waste. If you use a listed solvent identified in 40 CFR 261.31 as F001, F002, F004 or F005 for cleaning purposes (cleaning surfaces, spray guns, brushes, etc), then the still bottoms will carry the same listing as the solvent. Any of these listed still bottoms are hazardous waste and you will need to apply the waste code that matches the solvent used. For example, if you use methyl ethyl ketone (F005) as a solvent in your distillation unit, then the still bottoms from that unit continue to be a listed hazardous waste and carry the F005 waste code.

If you do not use a listed solvent, then your next step should be to determine if your still bottoms are a characteristic hazardous waste (see determining a hazardous waste for more information.) Unless you suspect that your still bottoms contain some toxic contaminant other than the solvent, it may not be necessary to spend money on having the still bottoms tested using the toxicity characteristic leaching procedure (TCLP) prior to disposal. As noted above, still bottoms are a listed hazardous waste based on the listed solvent source used in the distillation unit. When a F001, F002, F004 or F005 solvent is used for cleaning or dissolving, Federal regulations identify this waste as hazardous regardless of the amount (or lack) of listed solvent in the waste. You will need to do TCLP testing if you suspect that your waste contains a contaminant on the toxicity list in 40 CFR 261.24 (for example lead and benzene are common in still bottoms).

All hazardous waste still bottoms must be managed, transported, and disposed according to the hazardous waste regulations that apply to your generator status. For more information see Does your Business Generate a Hazardous Waste? .

It is important to know that if the solvent is F003 only, and the still bottoms contain no free liquid or any other listed or characteristic hazardous waste, the still bottoms are not hazardous waste. These still bottoms may be legally disposed in a sanitary landfill and should not carry the F003 code.

Please note that the department encourages resource recovery and according to 10 CSR 25-9.020 (2)(A)-(C) most small distillation units used for reclaiming waste from on-site are exempt from the majority of Missouri Hazardous Waste Management Regulations. This regulation does require that you notify the department if you use, reuse, legitimately recycle or reclaim less than 1,000 kilograms (2,200 pounds) of hazardous waste from on-site in a calendar month. You need only notify the Missouri Department of Natural Resources (DNR), Hazardous Waste Program, P.O. Box 176, Jefferson City, MO 65102 of your activities and identify the owner/operator, name and location of the facility, identity of the waste(s) recovered, method(s) of recovery and approximate annual quantity of waste recovered. If you recycle or reclaim 1,000 kilograms (2,200 pounds) of hazardous waste or more you must have a resource recovery certification. Visit Resource Recovery Certification for more details and contact information.

The DERT Fund

Drycleaning Environmental Response Trust (DERT) Fund staff will be holding public seminars throughout Missouri about the DERT program and how it works. Topics include: general information about the DERT Fund; updates on DERT Fund Rules; and the application, claim and reimbursement process. The DERT Fund established monies for investigation, assessment, and remediation of releases of chlorinated solvents from dry-cleaning facilities. For more information on the DERT Fund and an upcoming presentation in your area, please visit DERT Fund and click on seminars.

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If you need further assistance, please email or contact the Department of Natural Resources' Hazardous Waste Program at 573-751-7560 or 800-361-4827.

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