Burning Coolant mixed with Saw Dust

Is it okay to mix Grinding Coolant with Saw dust to burn?  This was an issue that was brought to Tom by one of our customers.  Wanting to be absolutely certain that we gave this customer the right answer, we checked with the experts. 

The information below comes from Kerry- a hazordous waste and toxic reduction engineer:

Here is some information about combining machine coolant as a fuel with sawdust. It seems to apply mostly to oil-based coolants. 

Kerry Graber has several different scenarios based on the chemical make-up of the coolant.  

An oil-based coolant used for grinding or cutting can be managed as used oil if it does not contain any chlorinated hydrocarbons. It is okay under our rules to send it to a used oil processor for blending into fuel in the same manner as other used oil.

 If it is oil based, does not contain chlorinated hydrocarbons, but they want to blend it in with sawdust for burning, it is actually okay to do that because it is being used as a fuel just like any other used oil in this state. However, if they are burning it in an on-site burner, it has to be either an industrial boiler or furnace, or a space heater that is designed to have a max capacity of not more than 0.5 million Btu per hour and the combustion gases from the heater are vented to the ambient air. Used oil burner regulations might apply.
If the above is true but they are sending it offsite to be burned, there’s all kinds of used oil requirements for off-site burners, and the generating facility would also be a used oil marketer.

If it contains any chlorinated hydrocarbons, it would have to go through designation to see if it is a dw (Designated Waste). It may not be managed as used oil because -515 has a prohibition against it. If it is not a designated waste after designation, it would be a solid waste and I believe mixing it into sawdust for burning on-site is probably okay. I would defer to the solid waste program and the local health department on that call. Of course if it turns out to be a dw, they can’t manage it with sawdust it must go to a TSDF or legitimate dw recycler.

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