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                  TG No. 144                                                          August 1987


                                                       CHAPTER 8
                                                   WASTE MANAGEMENT

                  8-1. BACKGROUND. On 21 October 1976. the President signed Into law the
                  Resource Conservation and Recovery Act (RCRA) which directed the U.S.
                  Environmental Protection Agency (EPA) to develop and implement regulations for
                  the "cradle-to-grave" management of hazardous waste (HW). Since the RCRA's
                  enactment in 1976 and subsequent reauthorization in 1984, the EPA has
                  promulgated an enormous volume of regulations which govern all aspects of HW
                  management including generation, transportation, treatment, storage,
                  recycling, and ultimate disposal. Also, many state environmental regulatory
                  agencies have promulgated HW regulations which are more stringent than the
                  Federal regulations.

                  8-2. WASTE STREAMS.

                      a. Painting operations, regardless of the types of paints used, typically
                  generate one or more waste streams which are subject to regulation as HW under
                  the RCRA.  These waste streams include, but are not limited to the following:

                           (1) Excess or unserviceable paints, paint components, and paint
                  thinners.

                           (2) Spent paint thinners and paint stripping solvents.

                           (3) Paint-contaminated blasting media.

                           (4) Paint-impregnated paper filter elements from paint booth air
                  filtration systems.

                           (5) Paint-contaminated water and sludge from paint booth waterfall
                  air filtration systems.

erior paint booth
                  surfaces.

                           (7) Empty paint, paint component, and solvent containers.

                      b. Whether any of these waste streams would be defined as HW and thus
                  subject to regulation under the RCRA is dependent on the following two factors:

                           (1) The waste may be among those specifically listed as an HW by the
                  EPA. For example, unserviceable 1,1,1-trichloroethane (one of the thinners
                  used in the application of CARC) is a listed HW (EPA HW number U226); oe





                                                           8-1
Box ID = BX000000
Unit = VII CORPS       
Parent Organization = ARCENT          
Folder Title = PORT OPERATIONS CARC PAINTING POLICY                                                            
Subject = ARMY REGULATION 11-34 (RESPIRATORY PROTECTION PROGRAM
Document Number =        103
Image file name = 00000132.tif

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