v>EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9443.03(80)
Hazardousness of Paint Residues on Conveyor Hooks
APPROVAL DATE: ^-22-30
EFFECTIVE DATE: 12-22-30
ORIGINATING OFFICE: <*«« of Solid Waste
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REFERENCE (other documents):
OSWER OSWER OSWER
fE DIRECTIVE DIRECTIVE Di
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PART 261 SUBPART C - CHARACTERISTICS
DOC: 9443.03(80)
Key Words:
Regulations
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Paint Residues, Characteristics of Hazardous Waste
RCRA §3010, 40 CFR Parts 262-265
Hazardousness of Paint Residues on Conveyor Hooks
Richard Hill, White Consolidated Industries, Inc.
Gary N. Dietrich, Assistant Administrator for Solid Waste
#9443.03(80)
12-22-80
Because the F017 listing has been deferred, paint residue wastes on con-
veyor hooks resulting from conveyorized spray painting operations are considered
hazardous only if they exhibit one of the characteristics of hazardous waste.
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9443.03 (80)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHIN 3TGN, D.C. 20460
OFFICE OF WATER
AND WASTE MANAGEMENT
Mr. Richard Hill
Whi:e Consolidated Industries, Inc
11770 Berea Road
Cleveland, Ohio 44111
Dear Mr. Hill:
This is in response Co your letter of September 22, 1980,
addressed to Filonena Chau of EPA, in wh'.ch you requested a
clarification of the hazardous waste regulations as to whether
pain", residues on conveyor hooks resulting from conveyorized
spray painting operations are considered hazardous and covered
by the F017 generic hazardous waste listing. The wording of
F017 listing ("paint residues or sludges from industrial
painting ...") and the description in the background document
for this listing convey our determination that such paint
residues are potentially hazardous to human health and the
environment if not properly managed and disposed. The paint
residues which you describe would fall under this category.
We have received many comments on the paint residues
listings promulgated in interim final form on July-16.
Several commenters have raised questions analogous to yours.
and we are currently evaluating them. We expect to meet vich
industry representatives (e.g., NPCA) and would be plaased to
receive your more extended comments on this. matter. la this
respect it would be useful for us to kuow, for instance, vhat
is the quantity of residues which you describe as adhering to
conveyor hooks, what is the quantity of sludges whfch are
•created by the caustic bath treatment, uhat is the fate of
these sludges (how are they disposed), and what is the nature,
amount and disposal of the residuals resulting from the
incineration of* the paint residue.
V
In the event that review and analysis of che comments
show that a change is necessary, the regulations will be
revised. We expect to publish our findings in the Federal
Register in advance of the date (Jaunary 16, 1981) on which
these particular regulations will take effect.
It should be noted^, however, that in an amendment to the
hazardous waste regulations published on October 30, 1980 in
the Federal Register (45 JTR 72024), a copy of which is attached
the Agency excluded from regulation under 4Q CFR Parts 262
through 265 or Pi.rts 122 through 124 or the requirements on
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Section 3010 of RCRA hazardous vasces that are generated In
a product or raw material storage tank*, transport vehicles
or vessels or In a manufacturing process unit. Thus, in
your particular instance, If the hangers containing paint
residue are included within the hazardous waste system, the
conveyor hooks would not be subject to regulation until they
were either discarded or treated (i.e., burned to remove
paint residue from the hangers).
Please feel free to call Dr. Judith Bellin of my staff
if we can be of any further assistance. Her telephone
nunber is (202)755-9187.
Since rely yours ,
Gary N. Dietrich
Associate Deputy Assistant Administrator
for Solid Waste (WH-562)
Enclosure
cc: Filoaena Chau
Dr. Judith Bellin
Kathy Kohl
Matthew Straus
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