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BEFORE THE ILLIN'
IN THE MATTER OF:
PETITION OF RECYCLE
TECHNOLOGIES, INC.
FOR AN ADJUSTED
STANDARD UNDER 35 ILL
ADMIN. CODE 720.131 (c)
PETITION FOR DETERMINING
WHETHER A MATERIAL IS A SOLID WASTE
COMES NOW, Recycle Technologies, Inc., by and through its owner Gary L. Gunderson, for its
petition for determining whether a material is a solid waste, state as follows:
I.
INTRODUCTION
Pursuant to 35 ILL. Admin. Code 720.131 (0,, Recycle Technologies, Inc. ("RT1")
respectfully requests the Illinois Pollution Control Board (the "Board") to issue a new solid
waste determination for filtered used antifreeze from automobile dealership/service centers,
independent service stations and automobile repair shops hauled to a centralized recycling
location for a minor finishing process step. The used anti
free.2
is currently classified as a special
waste based on the Illinois Environmental Protection Agency's (IEPA) determination that the
used antifreeze
(ethylene glycol)
is "partially reclaimed" at the generators site (see attachment I).
The Board should issue a new solid waste determination because the filtered used
antifreeze
is
commodity like after initial reclamation, even though minor finishing reclamation
will occur at
a
centralized location.
APR 3 0 1997
STA I t L,r ILLiNuIS
POLLUTION CONTROL BOARD
H. DISUCSSION
RTI was established in 1994 as anon site antifreeze recycler. RTI trucks currently visit a
generators site, filter (5 micron) the used antifreeze and put the filtered antifreeze into 55 gallon
drums along with additives (scale and corrosion inhibitors, coloring and defoamers) and leave the
recycled antifreeze with the generator for their resale/reuse.
RTI would like to move part of its operations to a centralized facility. The used
antifreeze will still be filtered (5 micron) at the generators site but the accumulated liquids from
several clients will then be brought back to the centralized facility. At the centralized facility the
liquids will be further processed by reverse osmosis to remove the different dyes and colors used
in various types of antifreeze. The antifreeze will then be able to be mixed more thouroughly in
mixing tanks with tile same additives as previously used at the generators site. The antifreeze
will be sold'brack
to the clients for resale/reuse.
The filters generated under both situations are disposed as special wastes as will any dye
residuals from the reverse osmosis process.
III CRITERIA FOR BOARD DECISION
A. Puree qfprocessinv the material has taukuone and decree
of further processing that is.
required.
Once the used antifreeze is filtered at the generators site it is already resaleable/reusable.
Currently all other competing companies are filtering to this level. The additives are to improve
the quality of the end product. Further processing by reverse osmosis is being provided to
remove the various
dyes
(coloring) from the different types of antifreeze to, again, further
improve the cosmetic quality or the end product. Approximetely 99% of the removal process is
completed at
the
generators
site,
A
44-)yriti
B. Value of the material after it has been reclaimed.
The quality of the reclaimed product will approximate virgin product. Thus the value will be
similar. Currently the marketprice for the reclaimed product is $1.75 per gallon in the Chicago
area.
C.
The degree to which the reclaimed material is like an analovus raw material,
The reclaimed material will be equivalent to virgin antifreeze from a chemical and economic
standpoint.
D. The event
to which an end market for the reclaimed material
is
guaranteed
The reclaimed material is sold back to the generators when the next pickup of used antifreeze is
made. RT1's on
site
recycling business has been in operation since 1994 and has an established
client list of over 500
companies.
GM, Ford and most other original equipment manufacturers
app-rove the tfs?of recycled antifreeze (see attachment
g 2). The Chicago area currently has 6
other companies recycling antifreeze and RT1
is
trying to differentiate itself through this further
processing.
• E.
The extent to which the reclaimed otwerial handled to
minimise loss
Only the impurities removed from the used antifreeze are lost during the reclamation.
It is estimated that over 99% of the used antifreeze is reclaimed.
The centralized
process will
F.
consist
Other
of
rel
two
e
identical
?
sets of
three
tanks. The first tank in
each group will be a receiving tank for the filtered used antifreeze. The second tank in each
group will
be a
process tank where the material will be fed to the reverse osmosis machine. The
third tank will hold the finished product until it's pumped back on to trucks for delivery.
All operations will be conducted indoors, on a concrete floor, with no drains. All tanks
and the reverse osmosis machine will be surrounded by containment walls. Only one group of
tanks will be in use at a time. Thus
. , the other group of tanks will be available should a problem
arise.
Attachment 3 is a copy of a letter from the City of Wood Dale. the proposed location of
the centralized facility, in support of the operation.
Wherefore, for the reasons stated above, RTI respectfully requests that the Board
determine that the filtered used antifreeze returned to the centralized facility is not a waste, but
rather is a raw
material to be used in the
manufacture of recycled antifreeze.
Gary L. Gt erson
Recycle Technologies, Inc.
151 Kings Row
Barrington, IL 60010
• 847-304-7868
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Staterif Illitiois
NVIRONMENTAL PROTECTION AGENCY
Mary A. Cade, Director
217/524-3300
2200 Churchill Road, Springfield, IL 62794-9276
March 17, 1997
Recycle Technologies, Inc.
Attn: Gary L.Gunderson
151 Kings Row
Barrington, Illinois 60010
Re: 0970000000 -- Lake County
Recycle Technologies, Inc.
Log No, PS97-027
General Correspondence
Dear Mr. Gunderson;
This letter is in response to your February 22, 1997 letter concerning the recycling of used
antifreeze.
Spent antifreeze is currently considered a special waste in the State of Illinois as defined at 35 111.
Adm. Code 808.110, and may be characteristically hazardous waste as defined in 35 III. Adm.
Code
721,
Subpart C (the generator must make a determination pursuant to 35 111. Adm. Code
722.111).
llowever, in accordance with 35 111. Adm. Code 721.102(e)(1)(A), materials which are "used or
reused as ingredients in an industrial process to make a product, provided the
materials arc not
being reclaimed" are not solid waste when recycled. In this case, the "material" in question
would be the (on-site) pre-filtered ethylene glycol. Since this material,has already been
processed or "partially reclaimed" at the generator's site, the antifreeze would remain a solid
waste unless you received a determination from the Pollution Control Board in accordance with
35
111. Adm. Code 720.131(c). Therefote, until such time the Board determines the antifreeze is
not a solid waste, the facility, if operated
as proposed, would be accepting esolid waste" as
defined by the regulations,
Pursuant
to Section 21 of the Illinois Environmental Protection Act (the Act), no person is
allowed'to accept waste for storage, treatment, or disposal without a permit granted by the
Agency. lithe waste in question is a hazardous waste as defined in 35 111, Adm. Code Part
72
I..
you cannot accept the waste until your facility has obtained a RCRA permit as specified in 35 111.
Mm. Code 703.121(a). lithe waste is found to be non-hazardotts, you cannot accept the wvste
until you have obtained a State Permit as required
by 35
Ill. Adm. Code 807, Subpart B. Also,
before the
Agency can review a permit application: you must obtain local siting approval in
accordance
with Section
39,2 of
the Act.
79,
If you
have any questions concerning this response, please contact Scott liacke at 217/524-3267.
Sincerely,
Edwin
C. Bakowski, P.E.
Manager, Permit Section
Bureau of Land
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94P,9,r,pAilfry,7;4(.1:4_.!W:op.; rot
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.0.t..04,9y,
toup:Ra 'CW2 ra n1Y
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Ad rnini St raitcn%
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Bulle
t
in No.: 310304
Date. February, 1994
WARRANTY ADMINISTRATION
SUBJECT:
RECYCLED ENtlINE COOLANT POLICY
MODE LS:
1994 AND PR.OR PASSENGER CARS AND TRUCKS
ATI ENT ION:
WARRANTY C,LAIVS•ADMINISTRATOR AND SERVICE MANAGER
,
Cieneriat
Motor-, SuOr.drt 3 the
use
of
recycled engine coolant
for warranty rep:us/service Ailoviding a GM 2p; nec
system is used. For de721!EJ ;nforr-7.ation on GM approved engire coolant recycli2g equipment guide:.oes 'der :o the
foLowing bulletins: Cadillac 93 -7-13, Gi'
.
.1C Truck 93-0
?
Chevrolet 93-73-5B, PCntiti; 93-6-18, Oldsmobi
l
e 1.9:3•4:1,BuC
93-6B-1 (Corporate Number 235203).
ReCyClE0 coolant will be r eimbur ea at the GMSPO dealer price for new coolant plus the appropr
i
ate mark-up Veen
replacement is
r
equired during a wrr5ntv repair, it is crucial to assure that only the relative amount cf engine coolant
concentrate
?
e :harged, no: the total diluted yolume. In other words, if you are using two gallons ot pre-diiutei.t tif..C.PC1
?
e_
engine coolant -to
?
k,ehicle,
)iou
mat' request reirriburcement for one gallon ol Goodwrench angina
?
.;once
?
a::
the dealer price pin the ar.4..
r
opc.;:le vrarran
!
y pails handling allowance.
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1c4iir
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ahl.Eitirr:?;ttsCCOVe.1
444;-
'Article No.
95-16-6
•
COOLANT—USE
OF RECYCLED ENGINE
COOLANT—SERVICE TIP
•
COOLING SYSTEM—USE OF RECYCLED
ENGINE
COOLANT—SERVICE TIP
FORD: 1980 and after CROWN VICTORIA, ESCORT, MUSTANG, THUNDERBIRD
1982-88 EXP
1984-94 TEMPO
1986 and after_TAURUS
1988-93
FESTIVA
1989 and after PROBE
1994 and after ASPIRE
1995 and after CONTOUR
LINCOLN-MERCURY: 1980 and after CONTINENTAL, COUGAR, GRAND MARQUIS,
TOWN CAR
1981-87 LYNX
1984-92 MARK VII
1984-94 TOPAZ
1986 and after SABLE
1987-89 TRACER
1991-94 CAPRI
and after TRACER
1993 and after MARK VIII
1995 and after MYSTIQUE
MERKUR:
1985-89 XR4TI
1988-89 SCORPIO
LIGHT TRUCK: 1980 and after F-150-350 SERIES
1981 and after ECONOLINE
1982 and after BRONCO
1983 and after RANGER
1984-90 BRONCO II
1986 and after AEROSTAR
1988 and after F SUPER DUTY
1991 and after EXPLORER
1993 and after VILLAGER
1995 and after WINDSTAR
ISSUE:
rFord
Motor Company authorizes the use
t
of recycled engine coolant that, when
properly processed and re.inhibiteds
Ford specifiallon ESE-M97844-A. At this
time, the Rotunda Coolant Recycler
(181-00003) process is"the only approved
coolant recycling method available
through Ford that is capable of .producing
recycled engine coolant that meets Ford
specification ESE-M97644-A.
ACTION:
Refer to the following Service
Procedure for coolant processing and
reinhibiting using Rotunda Coolant
Recycler (181-00003).
PAGE 10
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ATTACHMENT III
;11V42:AI3144...1
CITY
OF WOOD DALE
m Forrest
uilding Inspector
,V1Vd:pe:P.1/4•4 • ...
404
Nolan
WOOD DALE ROA I)
%MOD DM.
•
.11.1.INOIS 60191-1596
March 19, 1997
Mr. Ed Gunderson
151 Kings Row
Barrington, IL 60010
Re: Recycle Technologies
Dear Mr. Gunderson:
It was our pleasure to meet with you on two occasions in order to discuss the planned move of
your business into the City of Wood Dale.
It-is our understanding that you arc involved with the bulk recycling of anti-freeze products.
A review of ybut- rOposed process, and the products you use has been done by this department
and the Wood Dale Fire Protection District.
It appears that as tong as all City of Wood Dale Buildine. Code issues are complied with, this -
department does not anticipate any problems with your proposed business being located in our'
industrial park.
Thank you for choosing the City of Wood Dale as the new home for Recycle Technologies.
Yours truly,
JF:hhr
PC: Mayor
City Manager
Assistant City Manager
Blinding Administrator
Wood Dale Fire Protection District
CERTIFICATE OF SERVICES
The undersigned certifies that a copy of the foregoing document was mailed first class
certified mail, postage prepaid. this .)-b
?
day of April. 1997 to:
Clerk of the Maid -
Illinois Pollution Control Board
State of Illinois Center
100 West Randolph Street
Suite 11-500
Chicago, IL 60601
Ms. Mary Gade
Director
Illinois Environmental Protection Agency
- 2200 Churchill Road
Sprin–gfield.112.44279-1-9276
Date
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