McNabb makes some parts that have to be exceptionally clean. He uses virgin Zep on those, and saves the used stuff.
Then he uses that to clean other parts which just have to be visually clean. He saves the residue from that as well.
He may (I have no knowledge of this one way or the other) use that stuff for general cleaning around the shop.
In other words, he is being environmentally responsible by getting the most use out of the minimum quantity of solvent.
If I understand what I heard correctly, there is no hazardous waste to be disposed of at the end of this process. It has all evaporated.
They will define "treatment" as rendering any waste from a higher level of hazard to a lower level of hazard in order to facilitate disposal.
They will concede that the facility is allowed the use of the material first in one, high performance application, and then, subsequently in several, increasingly lower performance applications. They will tacitly acknowledge that this is a good and proper implementation of a pollution prevention technology.
But, in fact, the EPA only recognizes pollution prevention at all because Congress has forced them to. They really hate pollution prevention because it screws up their Accounting Principles 101 approach to regulation. They love the command and control approach to regulations and pollution prevention starts messing around with that.
The Agency will first claim that, at some point the solvent becomes unusable, even for the least demanding of the cleaning applications. Then they will claim that this otherwise unusable residue, therefore, by definition, has become hazardous waste.
At that point, they will say, the company must treat the material as hazardous waste and begin the paperwork chain to account for it.
Futher, they will claim that, even though the residue may not have manifested a hazardous condition at the time of its disposal, it was hazardous at the point that it became unusable.
Then, they will administer the coup-de-grace, as they demonstrate that evaporation of the solvent was a hazardous waste treatment method employed by the company, and, ipso-facto, they were treating the hazardous waste so they could didpose of it, at a reduced ignitability hazard, as ordinary waste.
The EPA is a criminal enterprise!
So he pays a processor $350 to haul off that drum of waste. The processor distills the solvent out and sells it to a cement kiln as fuel where it is burned at 2000 degrees, just as it would in a hazardous waste incinerator. It has been thermally oxidized.
Now the processor has the sludge left. He will try to find a home for that. He could possibly find a roof coating mfg and give it away to be incorporated into the coating. Whatever he has left has to be sent to the Hazardous Waste Landfill.