Tables one and two below demonstrate that solvent that has undergone the SystemOne
recycling process remains pure and virtually identical to virgin mineral spirits.

Chemical analysis of samples and reports that relate only to the
solvent in the recycling parts washers.

An advisory control limit of 20% for RPD is appropriate for original and duplicate sample values
Table 1
 Relative Percent Differences (RPDs) for Recycled Product Flash Point Measurements vs. New Product
Sample Location ID
Flash Point
Relative Percent Difference (RPD) to new product
V-1
145
new product
M-1
160
9.8%
M-2
150
3.4%
M-3
155
6.7%
M-4
150
3.4%
M-5
155
6.7%
M-6
153
5.4%
Average RPD
6%
Table 2
 Relative Percent Differences (RPDs) for Recycled Product EPA 8015M Measurements vs. New Product
Sample Location ID
mg pure produce per
kilogram of sample
Relative Percent Difference (RPD) vs. 100% pure product
V-1
956,000 or 95.6% pure product
4.4%
M-1
961,000 or 96.1% pure product
3.9%
M-2
877,000 or 87.1% pure product
13.1%
M-3
1,009,000 or 109% pure product
8.6%
M-4
860,000 or 96.2% pure product
15%
M-5
962,000 or 96.2% pure product
3.8%
M-6
887,000 or 88.7% pure product
12%
Average Relative Percent Difference (RPD)
8.6%
Tables 1 and 2 above demonstrate that the new Ashland solvent 140-66 and the solvent after it has undergone the Mansur recycling are the same mineral spirit solvent. The average RPD of 6% for the flash point for the samples vs. the new product, and the average RPD of 9% for EPA Method 8015M results vs. the expected 100% recovery, show that the recycled product has not changed during the recycling process. Further, no individual RPDs were above the EPA Fundamental Guidelines of 20% for duplicate analysis