Why didn EPA include the operation of a countercurrent drum rinsing station that uses solvent in the list of P2 practices?
Drum rinsing stations allow for the recycle (as opposed to reuse) of drum rinsates (note: discharge from drum rinsing stations must be treated prior to discharge). EPA did not specifically list the use of countercurrent drum rinsing stations for solvent-containing drums because it is not common in the industry; however, a facility could seek an unlisted modification for this practice.