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Hazardous Waste News

Volume 8, Issue 34

August 28, 2007

Question of the Week

Are My Discarded Paint Rollers Hazardous Waste?

Q. If you have used paint rollers that you clean with some organic solvent, would they (1) be considered hazardous waste that you have to count toward your status and (2) is cleaning them considered treatment?

A. The rollers would be considered a spent material, which is defined at 40 CFR 261.1(c)(1) as a material that has been contaminated and can no longer achieve its intended purpose without processing. Cleaning them would be a form of reclamation as defined at 40 CFR 261.1(c)(4) as processing to recover a usable product. According to Table 1, the recycling table, at 40 CFR 261.2, a spent material being reclaimed is considered a solid waste.

However, the rollers would not be hazardous waste or count toward your generator status unless they exhibit the toxicity characteristic described at 40 CFR 261.24 by failing a TCLP for any of the toxicity constituents contained in either the dried paint or the roller itself, such as lead or chromium.

The process of cleaning the rollers would be considered treatment as defined at 40 CFR 260.10, because it changes the physical characteristic or composition of the waste. However, if the rollers do not exhibit the toxicity characteristic and are not hazardous waste, they will only be solid waste and can be treated or cleaned freely.

If the rollers do exhibit the toxicity characteristic and are hazardous waste, they must be managed as hazardous waste and counted toward your generator status. Note that they may be reclaimed or cleaned without a permit per 261.6(c)(1), which exempts the recycling process from regulation. If the same rollers are used and cleaned again, the roller would not have to be counted toward your status a second time.

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RCRA News, Rules, and Interpretations

08/17/2007—Texas Man Sentenced to Five Months in Prison for Hazardous Waste Transport Crimes
Dennis Rodriguez of El Paso, Texas, was sentenced yesterday to five months in prison for violating hazardous waste transport law while operating his company, North American Waste Assistance, located in the same city. Rodriguez was also sentenced to five months home confinement, two years of supervised release and ordered to pay a $10,000 fine. Read more...

08/17/2007—Notice of Twenty-second Update of the Federal Agency Hazardous Waste Compliance Docket
Section 120(c) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) requires EPA to establish a Federal Agency Hazardous Waste Compliance Docket (Docket) which contains information reported to EPA by federal facilities that manage hazardous waste or from which hazardous substances, pollutants or contaminants have been or may be released. Read more...

07/01/2007—2007 Citizen Excellence in Community Involvement Award
The Office of Superfund Remediation and Technology Innovation is pleased to announce the Savannah River Site Citizens Advisory Board (SRS CAB) as this year’s winner of the Citizen Excellence in Community Involvement Award. This award recognizes an individual or a community group working with EPA to address hazardous waste issues. The Citizens Advisory Board is recognized for their dedication and commitment to the residents around the Savannah River Site in Aiken and Barnwell counties, South Carolina. Read more...

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State Hazardous Waste News

California

08/10/2007—Clean Harbors to Operate Former Rail Facility in Redwood City
The California Department of Toxic Substances Control (DTSC) has issued a Consent Order to Clean Harbors Environmental Services, Inc. allowing the company to conditionally operate the rail transfer facility in Redwood City formerly owned by Romic Environmental Technologies Corporation. Read more...

More California Resources

New York

08/14/2007—NY DEC and KeySpan Sign Agreement to Investigate and Clean up 12 Sites in Brooklyn and Nassau County
New York State Department of Environmental Conservation (DEC) Commissioner Pete Grannis today announced the signing of an expanded consent order between the state and KeySpan Energy Delivery that will require the cleanup of contamination at five Manufactured Gas Plant (MGP) sites and seven gas storage sites in Brooklyn and Nassau County. The agreement broadens a February 2007 consent order signed between DEC and KeySpan and brings the total number of sites covered under this agreement to 26. Read more...

More New York Resources

Texas

08/22/2007—TCEQ Approves Fines Totaling $646,339
The Texas Commission on Environmental Quality (TCEQ) today approved penalties totaling $646,339 against 71 regulated entities for violations of state environmental regulations. Read more...

More Texas Resources

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