SEPA
UniMdStMM
Envtromnemcl Protection
Agency
Off ic« of
Soltd Wast* and
Em*rg*ncy R*spon»*
DIRECTIVE NUMBER: 9444.01(82)
TITLE: Regulation of Paint Filters
APPROVAL DATE: 9-15-82
EFFECTIVE DATE: 9-15-82
ORIGINATING OFFICE: office of solid waste
m FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or DAA
D B — Signed by Office Director
DC — Review & Comment
REFERENCE (other documents):
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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PART 261 SUBPART D - LISTS
DOC: 9444.01(82)
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Paint Waste, Generator
40 CFR Part 261
Regulation of Paint Filters
Chet Mclaughlin, Chief, State Programs Section, Region VII
David Friedman, Manager, Waste Analysis Program
#9444.01(82)
9-15-82
In regulating paint filters which are hazardous wastes when removed from
the spray booth but not after immersion in water, the weight of the spent
filters is to be used in calculating the quantity of hazardous waste generated,
Generators are responsible for evaluating their waste to determine whether it
is hazardous. Testing may be required. If the water fails the EP toxicity
test, it too is a hazardous waste and its weight would be added to that of the
filters.
Waste paint filters are handled the same way as any other hazardous waste
relative to the small generator exemption.
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9444.01 (82)
Regulation of .Paint Filters
David Friedman, Manager
waste Analysis Program (WH-565B)
Chet McLaughlin, Chief
State Prograns Section (Region VII)
Recently you indicated that the States of Iowa and Kansas
have raised questions concerning the regulation of paint
filters removed from spray booths. The questions revolve
around how we regulate those filters which are hazardous
wastes when removed from the spray booth but not after immersion
in water.
I will try to answer the specific questions raised in
your memo (a copy of which is attached).
1. In calculating the quantity of hazardous waste
generated, it is the weight of spent filters (including
occluded, paint) that is used. Generators are responsible
for evaluating their waste to determine whether it is a
ha?ardous waste or not. If necessary they may have to test
their waste to make such an evaluation. However, many times
testing is not required. The necessary evaluation can be
made on the basis of engineering calculations. If the water
fails the EP toxicity test it is also a hazardous waste and
its weight would be added to that of the filters.
2. Waste paint filters are handled the same as any
other hazardous waste relative to the small generator exemption.
3. I am not sure why this particular waste needs special
treatment in the hazardous waste system other than perhaps
for a streamlined system of obtaining treatment perm,its for
the hazard mitigation operation (the 55 gallon drum filled
with water). Except in the case of the EP Toxic waters, the
immersed filters are not hazardous wastes and can be placed
in a sanitary landfill at will, whether the generator is a
large or small generator, N
\
I hope I have answered your questions. If not give me a
call at 8-755-9187 (382-4806 after September 30).
enclosure
cc: Lehman
Lindsey
Corson
Straus
Hotline
WH-565B:DFRIEDMAN:pes:x59187:9-15-82 DISK PS-57-15
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
g 1982
• '• •' >• ^: C:
Regulation of Paint "liters
Chet McLaughlitr, Ch«f
State ?t.o grass Section
Allan Corsoa, (WH-565)
Chief Waste Characterization Branch
The State of Kansas and Iowa have raised a secies of problens with the
regulation of paint: Alters from spray booths especially those generated
infrequently and in small numbers. When these filters are removed, they
can be subject to self ignition and are usually treated by immediately
immersing them in water. Typically these individual filters are then
transported to a nearby sanitary landfill and immediately bur i ad to prevent
auto ignition. This produces :he potential for the container, water,
filter and waste to become hazardous waste subject to handling as such.
The alternative is to allow che filrar to ig-nica and burn releasing small
quantities of potentially hazardous air contaminants and handling of the
ash as appropriate.
The questions raised by the states on this subject are several:
1. Do they consider the weight of the paint or paint and filtar for the
generation quantity? Does the container and water have to be tastad before
it can be disposed? If the wacar fails the Z? toxicity tast aust in be
handled as a hazardous waste? • --- -
2. Do they have to require the handling of filters as a hazardous waste at,
firms where other wastes achieve the 1000
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