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          TG No. 144                                                        August 1987


                  (2) The waste may exhibit one or more of the four characteristics of
          NW as defined in the RCRA regulations (i.e., lgnitability, corrosivity,
          reactivity, and Extraction Procedure (EP) toxicity (heavy metals)). For
          example, paint-impregnated paper filter elements may exhibit the character-
          istic of EP toxicity (lead and/or chromium) if the paints they are impregnated
          with contained lead and/or chromium in their pigment formulations. Knowledge
          of the paint formulation and/or actual analytical testing of filter elements
          would be required before this type of determination could be made.

              c. There are other factors which must be considered when determining if a
          particular painting waste stream is subject to regulation as an HW. For
          instance, many wastes are specifically excluded from regulation under the
          RCRA. For example, containers which held certain HWs are exempt from
          regulation if they meet the regulatory definition of "empty." Also. certain
          HWs are exempt from regulation if they are recycled ina specific manner. For
          example, off-specification 1.1.1-trichloroethane is not subject to regulation
          as an NW if it is returned to the manufacturer for regeneration.

          B-3. MANAGING THE WASTE. The characterization and management of wastes under
          the RCRA is a complex Issue. On DA installations, the installation environ-
          mental coordinator is normally assigned the responsibility for ensuring that
          RCRA issues are adequately addressed. The environmental coordinator acts on
          behalf of the installation commander who, under provision of AR 420-47, is
          ultimately responsible for the management of NW on the Installation.
          Therefore, before taking steps to manage any painting waste stream, the
stallation environmental coordinator must be notified. The environmental
          coordinator will be able to evaluate each waste stream to determine if it is
          an HW and will know which regulations, if any, apply.
          8-4. TECHNICAL ASSISTANCE. Additional technical assistance and guidance on
          the proper management of painting wastes may be obtained from the Commander,
          U.S. Army Environmental Hygiene Agency, Waste Disposal Engineering Division,
          Aberdeen Proving Ground, MD 21010-5422, AUTOVON 584-3651.















                                                 8-2
                                                                                        87
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 = 00000133.tif

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