Chapter 9.

2
Waste Handling and Disposal
Bernard R. Appleman

Sources of Waste in Painting Activities Table 1. Examples of Waste Streams from Painting
Waste is generally defined as any material that Operations.
is discarded and not intended for some other
productive use. EPA defines solid waste as any
garbage, refuse, sludge, or semisolid. The definition
also includes liquid wastes, which are not otherwise
regulated under the Federal Water Pollution Control
Act.1
Surface preparation and coating operations
typically generate a variety of wastes. Some of these
waste streams may be large (e.g., spent abrasives).
These materials are listed in Table 1.2,3
Waste materials must be handled properly to
protect workers from health or safety hazards. Some
wastes are considered hazardous because they can
pose a substantial risk to human health or the
environment. EPA and local regulatory agencies have
established very stringent procedures for handling
hazardous wastes and for discharging water
containing potentially hazardous materials:
• Special protection of areas where hazardous waste
is generated and stored
• Warning signs about the presence of hazardous
waste
• Limits on the amount of hazardous waste and the
duration that it can be stored on site
• Special containers and labels for the waste
• Methods for sampling and testing the waste
• Training for workers who will handle the waste
• Preparing and retaining records of the type, amount,
and properties of the waste
• Restriction on treating or using the waste for other 1984 by the Hazardous and Solid Waste Amendments
purposes (HSWA).5 RCRA and HSWA are designed to track and
regulate hazardous waste from manufacture to final
Regulating Hazardous Waste disposal (“cradle to grave”).
The Federal EPA has jurisdiction over Another federal regulation, Comprehensive
handling and disposing of hazardous and solid waste. Environmental Response Compensation and Liability
The major federal regulation dealing with this is the Act (CERCLA), also known as “Superfund,” was
Resource Conservation and Recovery Act (RCRA).4 enacted in 1980.6 CERCLA is intended to control
Enacted by Congress in 1976, RCRA was amended in cleanup and designate liability for abandoned,
uncontrolled, or inactive waste sites, and to deal with from solvent-borne paint, degreasing compounds, and
hazardous waste releases in an emergency. CERCLA other solvents not considered listed wastes.
is discussed in Chapter 9.3.
Congress’ main goal under RCRA is to reduce Corrosivity. This category includes materials that have
or eliminate the generation of hazardous waste and to a low or high pH (less than 2 or greater than 12.5) or
ensure that wastes are treated, stored, and disposed are excessively corrosive to steel, including rust
of so as to minimize present and future threats to removers and acid or alkaline cleaning fluids (e.g.,
human health and the environment. certain chemical strippers).
RCRA regulations include subtitles A through J
as published in the Code of Federal Regulations, Title Reactivity. This characteristic applies to materials that
40, Parts 261-281. Sections most relevant to the are unstable or undergo rapid or violent chemical
protective coatings industry are: reactions with water or other materials. Examples are
• Part 261 Identification and Listing of Hazardous cyanide, plating waste, waste bleaches, and other
Waste oxidizers.
• Part 262 Standards Applicable to Generators of
Hazardous Waste Toxicity. These are wastes that, when subjected to an
• Part 268 Land Disposal Restrictions extraction procedure using an acid, are found to
contain high concentrations of heavy metals or
Classifying Waste pesticides that could be released into ground water.
There are two means by which a waste can be This is the characteristic by which lead or other toxic
classified as hazardous: it may be specifically included paint residues may be classified as hazardous waste.
on any one of four lists of hazardous wastes, or it may It is the RCRA provision with the greatest impact on
have one of the characteristics that define hazardous the protective coatings industry. Other metals that may
wastes. cause waste to be classified as toxic include arsenic,
chromium, barium, cadmium, and mercury.
Listed Wastes Using EPA Method 1311: Toxicity
EPA has identified over 400 substances that Characteristic Leaching Procedure (TCLP), the
are considered hazardous, based on their known abrasive, paint, or other waste is broken up into small
properties. These include spent paint solvents, such pieces (less than 3/8 inch sieve size) and agitated in
as xylene, acetone, ethyl acetate, and methyl isobutyl an acid for 16-24 hours.7 If the amount of lead or other
ketone (MIBK), spent halogenated solvents (e.g., metal that leaches (dissolves) into the acid is greater
methylene chloride, 1,1,1-trichloroethane, and carbon than or equal to the threshold value, the debris is
tetrachloride), cyanide and compounds, toxic organics, considered hazardous.
and sludges from various manufacturing and A waste from which 5 mg/L of lead or more
treatment processes. Each of these has been leaches is a “characteristic” hazardous waste.8 Table 2
assigned a specific EPA hazardous waste number lists the threshold limits for the eight metals, each of
(e.g., F003 for xylene). which is assigned a specific waste code. The “D”
series is designated for characteristic toxic wastes
Characteristic Wastes (e.g., lead is D008). This test method is discussed
These substances are defined as hazardous further in the sections on sampling and testing and
based on one or more of the following four treatment and disposal of waste.
characteristics:
• ignitability Other Considerations for Waste Classification
• corrosivity
• reactivity Acutely Hazardous Waste. EPA has established
• toxicity special requirements for small quantities of waste
considered extremely hazardous, including certain
Ignitability. An ignitable waste is a liquid having a flash pesticides and materials containing dioxin. These are
point of less than 140°F (60°C). This includes waste not commonly generated in the protective coatings

456
industry, but do require special treatment and Disposal of Scrap Metal . Scrap metal, even if coated
reporting. with lead paint, is considered a recyclable material not
subject to the requirements of Subtitle C. For this
Table 2: Characteristic Levels for Toxic Metals. exemption to apply, a steel mill or ferrous foundry
must reuse the scrap metal as raw materials in the
process. If the scrap metal were simply to be
discarded, then it would need to be treated as
potentially hazardous and tested by the TCLP method.
In any case, workers handling the scrap metal must be
protected in accordance with OSHA’s Lead in
Construction Standard.

Responsibilities for Hazardous Waste

Major Parties
Under RCRA, EPA has assigned
responsibilities to three key groups: the generator of
Recycled or Reused Hazardous Waste. A waste that the waste; the shipper (transporter) of the waste; and
is classified as hazardous but is to be reused or the treatment, storage, and disposal (TSDF) facility.
recycled in some beneficial fashion is not subject to The protective coatings industry is generally not
the requirements of Subtitle C. (See 40 CFR Part 260, directly involved in transporting, treating, or disposing
Appendix 1, Figure 3 for special provisions for certain of hazardous waste, although these activities may be
hazardous wastes intended to be legitimately and an incidental part of the work done by a painting
beneficially used, re-used, recycled, or reclaimed.) In contractor or a facility owner. The major role of owners
a May 1998 rule, EPA confirmed that lead- and contractors is that of generator.
contaminated steel grit intended to be recycled is not
considered a waste.9,10

Residues of Hazardous Waste in an Empty Container.

Under 40 CFR 261.7 definitions of an “empty”
container are:
• All wastes have been removed using commonly
employed procedures for emptying the container
• No more than 1 inch (25 mm) of residue remains on
the bottom of the container
• No more than 3% by weight of the capacity of the
container remains in containers with a capacity of 110
gal. (418 L) or less
• No more than 0.3% of the weight of the total capacity
Figure 1. Clean up of polluted waste site.
remains in containers with a capacity greater than 110
gal. (418 L)
Waste generator. A “generator” is defined by EPA as
any person whose act or process creates a hazardous
An “empty” container as defined above would
waste or makes it subject to RCRA. A facility owner is
not be subject to RCRA rules. If the container held
the primary generator of the hazardous waste
more than this amount of solvent-thinned paints or
produced by removing coatings from structures. This
paint residue, there is a potential that the waste would
is true even though a contractor may be the party that
require treatment as hazardous. Some disposal
physically removes the paint (e.g., by abrasive blast
facilities may have more stringent criteria for a
cleaning). In the preamble to the EPA Rule on
container to be considered empty.

457
Certification and Training for Residential Deleading site at any one time.
(published August 29, 1996), EPA confirmed that the • Small quantity generator—Generates between
owner and the contractor may be regulated as co- 220-2,200 lbs (100 kg and 1,000 kg) per month and
generators of waste from lead-based paint activities accumulates less than 13,200 lbs. (6,000 kg).
(such as removal or abatement). 11 Under co-generator • Conditionally exempt small quantity generator—
status “both parties remain legally responsible for Generates less than 220 lbs. (100 kg) per month.
proper disposal of the waste and for RCRA
compliance.” A large quantity generator must comply with all
This designation however, does not relieve the the requirements listed in this section. There are some
facility owner from full responsibility for ensuring that minor differences in the requirements for a small
all operations (i.e., generation [by removal], quantity generator.35 A conditionally exempt small
transportation, and disposal) and the other activities quantity generator does not need to follow the
described here are performed in accordance with reporting requirements, but still must assure that the
RCRA rules. waste is properly tested and disposed. These activities
The disposal of waste paints or thinners are the responsibility of the generator:
determined to be hazardous may sometimes be the
responsibility of the contractor who purchased them. If Identification of Waste. Under 40 CFR 262.11, EPA
the coatings have been used in shop application (e.g., requires that the generator determine if the waste is
rail car or steel fabricating shop), the shop facility is hazardous. This is accomplished by applying
the waste generator. knowledge of the hazardous characteristics of the
material in light of the process used, or through
Waste Transporter. A transporter is defined as the laboratory testing of waste samples. If a project is
person engaged in the transportation of hazardous consistently producing material with a similar
waste off the site of generation. Only licensed composition and consistency, the generator can utilize
transporters may be involved in shipping hazardous the documented process and test data as evidence of
waste off site. Transporting the waste within a site the material characteristics. For paint removal
(i.e., relocating to a special storage area from the projects, the variability of the waste is such that using
generation area) does not fall within 40 CFR Part 263, “applied knowledge” is not appropriate, and
and may be performed by the generator without any representative samples must be taken from different
additional permit. waste streams and tested in a laboratory.
Laboratory testing is intended to simulate the
Treatment Storage and Disposal Facilities (TSDF). type of long-term leaching that could occur in sanitary
Treatment, storage, and disposal of hazardous waste landfills. In the case of lead paint debris, if the
are most commonly performed by specially licensed leaching meets or exceeds the allowable levels, the
facilities located off the premises of the waste debris is considered to be hazardous due to the
generation site. Under some circumstances the waste characteristic toxicity.
generator may deliberately or inadvertently “treat” the
hazardous waste. It is important to understand what EPA Identification Number. Under 40 CFR 262.12, the
types of treatments or processes are regulated and generator must obtain a number to treat, store,
what the permitting or reporting requirements are. transport, or dispose of the hazardous waste. This
number is obtained from the state or local EPA office.
Responsibility of Generators Different types of EPA identification numbers are
available. The owner should determine the type
Classification of Generators. Generators are classified needed. The different types are:
based on the amounts of hazardous waste generated.
These are: • Regular—Permanent ID numbers are intended for
• Large quantity generator—Generates greater than or facilities that will generate a hazardous waste on a
equal to 2,200 lbs. (1,000 kg) per month, or long-term, constant basis. Owners may obtain a permit
accumulates more than 13,200 lbs. (6,000 kg) at the under one ID number for all of their facilities where

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lead-containing debris will be generated. collection to final disposal. The manifest must be
• Site Specific—These ID numbers are intended for obtained from the state where the waste is being
facilities that will generate a hazardous waste once. disposed, if that state requires its use. If the disposal
Owners may obtain a unique ID number for each water state does not supply the manifest, the form from the
tower, bridge, or tank farm. state where the waste is generated should be used. If
• Provisional—These ID numbers are intended for neither state requires a specific manifest, the federal
unforeseen circumstances where a large amount form can be used.
(greater than 2,200 lbs. [1,000 kg]) of hazardous waste
is generated: for example, soil clean up after an Packaging and Labeling Requirements. The waste
accidental diesel fuel spill. must be packaged in accordance with the
requirements of 40 CFR 262.30 through 262.33, as
The owner may delegate obtaining site well as U.S. Federal Department of Transportation
specific and provisional EPA ID numbers to the regulations presented in 49 CFR 173, 178, and 179.
contractor. Labeling should be in accordance with 49 CFR 172.12
Essentially, these sections require that the packaging
Notification and Certification. The generator must be leak-proof during normal transportation conditions
provide notification and certification for each shipment as well as upset conditions (e.g., the container falls
of debris in accordance with 40 CFR 268.7 and 40 out of the truck). The rules also require the use of
CFR 268.9. The specific wording is found in the labels, marking, or placards to identify the
regulations, and it varies according to whether the characteristics or dangers associated with transporting
waste tests hazardous or non-hazardous, or has been the waste.
treated to render it non-hazardous. Notification (from
the generator to a licensed TSDF) indicates the desire Container Enclosure Requirements. The requirements
to ship a hazardous waste to a facility. In practice, for the large- and small-quantity generators (40 CFR
most disposal facilities confirm the required 265) vary, but both essentially order the use of
information back to the generator. These notifications leak-proof drums or bins with secure lids or covers for
include the TSDF permit number, their authorization to containing the material and locked storage site located
treat the specific waste being shipped, and their ability on well-drained ground. The containers must be
to handle the volume of waste being shipped. The inspected weekly for corrosion and leaking.
contractor is generally responsible for providing this
information (i.e., the “notification”) to the owner prior to Contingency Plan and Training. Sections 40 CFR 265
the generation of hazardous waste. and 40 CFR 262.34 require that the personnel
Certification (from the TSDF to the generator) involved with handling hazardous waste, including
after disposal of a waste, attests that the waste has paint removal crews, be trained to respond effectively
been received, properly treated, and disposed. The to emergencies. Basic safety information must be
certification that the waste has been disposed is available, including hazard labels on containers, the
returned to the generator. date that the accumulation of hazardous waste began,
the name and telephone number of the site employee
Manifesting the Waste. 40 CFR Parts 262.20 through serving as emergency coordinator, telephone number
262.23 require that the generator complete a of fire department, location of fire extinguishers, etc.
hazardous waste manifest to accompany each
shipment. The manifest includes a description of the Waste Analysis Plans for On-Site Treatment. If the
waste, the amount, and the handling requirements. generator decides to treat the waste on-site to render
The generator signs the manifest as does each it non-hazardous, a written waste analysis plan must
transporter and the TSDF. The completed manifest be filed according to 40 CFR 268.7 with the EPA
must be returned to the generator within a designated regional administrator a minimum of 30 days prior to
number of days (45 days for large-quantity generators the treatment activity.
and 60 days for small-quantity generators). It assures
that the waste is properly handled from debris Waste Accumulation Time. There are restrictions on

459
the length of time that the waste may accumulate that such solid waste or hazardous waste or any
on-site (40 CFR 262.34). A large-quantity generator constituent thereof may enter the environment or be
may accumulate hazardous waste on-site for 90 days emitted into the air, or discharged into any waters,
or less without a treatment permit from the EPA. An including ground waters.
extension of up to 30 days may be granted due to
unforseen, temporary, or uncontrollable Following treatment, the TDSF must also
circumstances. A small quantity generator may provide the generator with certification of disposal. The
accumulate waste on-site for 180 days with a possible extensive requirements for these facilities are
exemption for up to 270 days. If these time limits are described in 40 CFR Parts 264 and 265.42. Details of
exceeded, the generator may be considered an generator, transporter, and TSDF responsibilities and
operator of a storage facility and subject to very specific application to hazardous lead paint are
extensive requirements. provided in the Industrial Lead Paint Removal
Handbook.13
Recordkeeping and Reporting. The signed manifests
and associated documentation must be maintained for Sampling and Testing
at least three years (40 CFR 262.40 through 262.44). As noted previously, it is the generator’s
For generators treating the waste on-site, the responsibility to determine if waste is hazardous. For
recordkeeping requirements can be more elaborate. listed wastes, such as xylene and other solvents, there
is no need for testing. The waste is hazardous by
Responsibilities of Transporters and Treatment, definition. For waste paints, the determining factor for
Storage and Disposal Facilities (TSDF) ignitability is the flash point. This may be obtained
from the manufacturer; alternatively, an outside testing
Transportation. The generator can transport waste laboratory or an in-house testing facility could easily
containers to temporary holding areas on-site without determine it using EPA Method 1010.14 For
special hauling permits. However, for off-site solvent-borne paints, it may be prudent to assume that
transportation, the requirements of 40 CFR 263, the waste is hazardous and handle and treat it
Standards Applicable to Transporters of Hazardous accordingly.
Waste, apply. Determining the pH of acid or alkali cleaners
or chemical strippers can be readily accomplished in
Treatment, Storage and Disposal. Treatment, storage, the field using standard pH paper. The manufacturer’s
and disposal are defined as follows under 40 CFR material safety data sheets (MSDS) will identify the
260.10, Definitions. characteristics of the material, including the pH and
• Treatment—Any method, technique, or process, any toxic components at 1% or greater. Unless the
including neutralization, designed to change the material has been diluted, mixed, or otherwise altered,
physical, chemical, or biological character or it is important to assume that the most hazardous
composition of any hazardous waste so as to properties of the material are also true of the waste.
neutralize such waste, or so as to recover energy or
material resources from the waste, or so as to render Analysis of Solid Waste
such waste nonhazardous, or less hazardous; safer to For solid paint waste or abrasive residue
transport, store, or dispose of; or amenable for suspected of containing lead or other heavy metals,
recovery, amenable for storage, or reduced in volume. the TCLP test is normally required to determine the
leachate concentration of the metals. The collection
• Storage—The holding of hazardous waste for a and sampling of the waste to be tested must be
temporary period, at the end of which the waste is performed according to EPA procedures. For example,
treated, disposed of, or stored elsewhere. the sampling must be taken from a homogeneous mix,
using random sampling techniques.15 Typically, a
• Disposal—The discharge, deposit, injection, minimum of four samples are required to demonstrate
dumping, spilling, leaking, or placing of any solid waste that a sample is non-hazardous (e.g., less than 5 mg/L
or hazardous waste into or on any land or water so for lead). If the generator is willing to handle and

460
dispose of the material as a hazardous waste, it is not Less Than 0.5% Solids. If a multi-phase sample
necessary to test for the presence of lead or other contains less than 0.5% solids, the liquid sample itself
heavy metals. However, at least one sample is is analyzed for its metal content (which is therefore
recommended for historical records, to guide the “total” metals rather than “leachable” metals). An
disposal facility in the appropriate treatment example of a multi-phase sample containing less than
procedures, and to provide a summary of the 0.5% solids is the waste generated during hygiene
expected waste characteristic. Samples required for activities (e.g., water from the shower). As above, the
the TCLP test normally must be about 1 lb. (300– results of this analysis will dictate whether or not the
400 g) and placed in labeled containers. Additional liquid will require additional filtering or treatment prior
information on sampling procedures is contained in to transportation to a publicly owned treatment facility
refs. 16–17. for disposal. If liquid waste is treated the final
concentration of lead must be 0.69 mg/L or less,
Analysis of Liquid Waste according to the Universal Treatment Standard. 19
Liquid waste (water) is often generated when
waterjetting and wet abrasive blasting are the paint Treatment and Disposal of Hazardous
removal methods. The procedures to analyze liquid Waste
waste differ from those used for solid waste.
Water generated during coating removal Lead Treatment Standards
operations may need to be contained and captured If lead waste is treated and has a leachable
along with the paint chips and other larger debris. lead level of 0.75 mg/L it can be classified as non-
These materials are filtered from the water using hazardous.19 Thus a treated waste initially tested at 3
coarse screens. The filtered water is then often mg/L can be classified non-hazardous. However, if a
pumped to a holding tank for reuse or disposal. Once waste is initially tested at 20 mg/L and has a leachable
the project is completed, the solid debris is sampled lead level of 3 mg/L after treatment, it is still classified
and tested using the standard TCLP method. The as hazardous. This regulation has the greatest impact
testing procedure for the liquid depends upon the on facilities that treat lead prior to disposing of it. The
percentage of solid material in the liquid waste.18 requirements are summarized in Table 3.

Greater Than 0.5% Solids. Samples containing Table 3. Criteria for Treated and Untreated Lead-
greater than 0.5% solids must be analyzed according Containing Wastes.
to a multi-phase protocol. An example of such a waste
would be that generated during wet abrasive blast
cleaning operations.
First, the free liquids are removed from the
original sample and retained. A minimum of 100 g of
the remaining solid material is extracted according to
standard TCLP. The extract that is derived from the
solid portion is then combined proportionally with an If a waste that has been collected and tested
aliquot of the liquid that was removed from the original is determined to be hazardous, the generator must
sample. It is this combined sample that is analyzed for arrange for treatment to render it non-hazardous. This
toxic metals. requirement is based on the 1990 Land Disposal
The result of this analysis will dictate whether Restrictions, or “Land Ban,” Rule (40 CFR 268).20
the liquid will require additional filtering or treatment “Land Ban” prohibits the land disposal of any
prior to transportation to a publicly owned treatment hazardous waste. Treatment is not required if the
facility for disposal. These facilities often have different material is to be recycled or reused for beneficial
requirements or thresholds for the level of toxic metals purposes.
as well as the maximum amount of solids permitted in Hazardous waste treatment can be performed
the liquid waste. Most landfills do not accept liquid on- or off-site. EPA permits on-site treatment under
waste. very special circumstances. Off-site treatment services
are offered by a number of firms that specialize in this.

461
Off-Site Treatment of Hazardous Wastes levels of total lead. This effect is caused by a chemical
reaction in which the lead “plates out” and remains
Treatment Methods. Common treatment methods for insoluble. However, numerous studies have shown
lead-containing wastes involve the use of lime or that this reaction is often only temporary and after the
Portland cement.21 Once treated and found to be iron oxidizes the lead can become resolubilized.
below the regulatory limit, EPA regulations permit the Accordingly, in 1998 EPA banned the use of iron filings
material to be disposed of in a Subtitle C (hazardous) for this purpose.8 Although EPA did not include steel
or Subtitle D (nonhazardous) landfill. However, states abrasives in this ban, adding any steel to lead-
may have additional requirements for testing and containing paint waste with leachable lead of 5 mg/L
manifesting the waste. or greater is considered an on-site treatment requiring
Waste thinners and paints are typically special permits. When steel grit is used in abrasive
incinerated, because once the solvent is burned the blasting, it is typical to declare the waste hazardous,
explosion or fire hazard has been eliminated. Acids regardless of the results of any TCLP testing.
and bases can be readily treated by neutralizing with
other bases or acids, respectively. Adding Steel Grit to Expendable Abrasives. A Federal
Highway Administration (FHWA) study has shown that
Disposal Procedure. State or regional EPA offices can adding 3–6% by weight of G-80 steel grit to
provide assistance in identifying an appropriate TSDF. conventional expendable abrasives has reduced the
The generator must inform the TSDF of the quantity leachable level of lead from over 50 mg/L to less than
and the hazardous nature of the waste, so the facility 2 mg/L.21 The same study and other field histories
can treat it prior to disposal. It is the generator’s have indicated that the “stabilization” of lead may not
responsibility to assure that the TSDF is permitted be permanent, because over time the lead solubility
and reputable. could increase as the steel grit oxidizes. Thus, this
It is also necessary to select a hazardous treatment, while satisfying the letter of the RCRA law,
waste transporter. Hauling waste from the temporary could cause lead to leach into the environment, after
storage site to the TSDF must be performed by a the waste has been disposed. In the 1998 rule on iron
transporter with an EPA identification number. A list of filings, EPA cautioned against this practice, noting that
licensed hazardous waste haulers can be obtained the generator is not shielded from future liability, as
from the appropriate state agency. the lead eventually leaches into the soil. A potential
solution to this problem is to further treat the
On-Site Treatment of Hazardous Waste grit-stabilized lead waste with a cementitious material.
Generators can treat waste on-site in 90-day In this case, however, the recordkeeping would be
holding containers or tanks, if approved by the state or simplified because the waste is not hazardous and the
regional EPA office. A waste analysis plan must be requirements for holding containers and the waste
submitted prior to treatment. analysis plan are not in effect.

Pretreatment of Blast Abrasives Proprietary Additives. These are typically incorporated

There are several types of materials that, at 15-18% of the weight of the conventional abrasive
when added to abrasives prior to blasting lead- (e.g., coal slag, copper slag, silica sand). One such
containing paint, will result in non-hazardous waste. additive has been found to effectively reduce the
Examples are steel grit and a proprietary leachable lead content to approximately 0.1 mg/L—
cementitious-type material. These additives chemically well below the threshold level.21 This stabilization
react with the lead during the TCLP digestion method, as identified by the manufacturer, involves pH
procedure and reduce the solubility of the lead control and encapsulation. Unlike waste containing
compound below the threshold limit of 5 mg/L. steel grit additives, waste containing this proprietary
material shows no increase in leachable content after
Adding Iron Filings to Paint Waste. Adding steel shot, running multiple leaching procedures. Because this
grit, or iron filings to lead paint waste can cause the material is blasted onto the surface along with the
waste to test as non-hazardous even at relatively high abrasive, it should be manufactured or treated to

462
reduce dusting and to avoid leaving a soluble deposit generated, and personnel requirements. A variety of
on the steel to be subsequently painted. Another solvent recovery and recycling systems are
proprietary material is first applied to the structure by commercially available.
spraying. When the surface is subsequently abrasive
blast cleaned, the proprietary surface treatment results Reducing Paint Waste. Paint waste may include left
in non-hazardous waste. over sludge in paint containers, overspray, paint that is
“out of spec” or beyond its shelf life, still bottoms from
Minimizing Paint, Solvent and Thinner Waste recycled cleaning solvents, and rags and other
materials contaminated with paint. In many cases, the
Eliminating or Reducing the Use of Solvents. Coating amount of paint waste generated can be reduced
application shops use solvents in a variety of cleaning through the use of improved equipment with high
and degreasing operations including parts and transfer efficiencies, alternative coatings, and good
process equipment cleaning and surface preparation operating practices, such as purchasing paint in either
for coating applications. Some of the major solvents in bulk containers or the smallest quantities required.
used are petroleum distillates and oxygenated (esters,
ethers, ketones, and alcohols) and halogenated
solvents.2 State Regulation of Hazardous and
Eliminating solvent use eliminates the waste Non-Hazardous Waste
associated with it.22,23 Non-solvent cleaning agents Almost every state has enacted regulations
may be used instead or the need for cleaning regarding production, storage, transport, treatment, or
eliminated altogether. Alternatives to solvent stripping disposal of hazardous substances or waste. RCRA
agents include aqueous stripping agents, plastic encourages states to assume some of the federal
media, or cryogenic or thermal stripping. responsibilities for operating their own waste
Solvent usage may be reduced by controlling programs. In general, state laws and standards are
air emissions at the source, using solvents and required to be equivalent to or more stringent than
equipment efficiently, and maintaining solvent quality. federal requirements. There are some variations from
Source control addresses ways in which solvent can state to state, and certain states have enacted more
be contained, reducing the chances for evaporation stringent hazardous waste requirements than others.
loss. Efficient use of solvent and equipment through For example, California has established a
better operating procedures can reduce the amount Soluble Threshold Limit Concentration (STLC) for
required for cleaning. Maintaining the quality of solvent leachable content of heavy metals and Total Threshold
will extend its life-cycle effectiveness. Limit Concentration (TTLC) for total heavy metal
concentration.24 Under Title 22, this state has also
Solvent Recycling. The final cost of solvent used for added several metals that are not on the EPA
various cleanup operations is estimated at nearly hazardous waste list, most notably zinc and zinc
twice the original purchase price primarily because of compounds. Thus, if zinc exceeds 250 mg/L in the
the expense associated with disposal, transportation, STLC test or 5,000 mg/kg under TTLC, it is classified
and manifesting. Increasing the recyclability of as a hazardous waste. Prior to 1997, Michigan also
solvents can be achieved by maintaining the quality of classified zinc as hazardous waste, but the state has
the solvent, standardizing the solvents used, and subsequently removed it from the list.25
consolidating the use of solvent within the facility. States are also responsible for disposing of
Maintaining solvent quality can be viewed as a nonhazardous waste, which is not included in RCRA.
measure that will reduce the amount of solvent used, Non-hazardous wastes are often classified as
as quality is much more critical when solvents are municipal and special, industrial, or residual wastes.
recycled. Municipal wastes can be disposed of in a municipal
There are several options available for landfill, along with household garbage. Non-municipal
recycling solvent waste. Solvents can be recovered wastes often require special handling and paperwork.
on- or off-site, where usually depends upon the capital For example, Illinois EPA requires that any waste from
outlay and operating cost, volume of solvent waste abrasive blasting or other lead removal projects be

463
tested and manifested, even if it is below the 5 mg/L 11. Requirements for Lead-Based Paint Activities in
threshold level for hazardous waste.26 For this Target Housing and Child-Occupied Facilities; Final
“industrial” waste, licensed haulers are required. Rule. Code of Federal Regulations, Section 745, Title
Pennsylvania also has special regulations for 40; Fed. Regist. 1996, 45778-45830.
“residual” wastes, which again require special 12. U.S. Department of Transportation Regulations on
handling and recordkeeping.27 Transporting Waste. Code of Federal Regulations,
In these instances, the cost of disposing of Section 172-179, Title 40; Fed. Regist.
non-hazardous waste may approach that of hazardous 13. Trimber, K.A. Industrial Lead Paint Removal
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being applied. In states where there are no special 14. EPA Method 1010: Pensky-Martens Closed-Cup
requirements for non-hazardous waste, costs for Method for Determining Ignitability. In Test Methods for
disposal are significantly lower (e.g., on the order of Evaluating Solid Waste (Manual SW-846), 3rd Edition;
$100 rather than $400 per ton). Often, landfill U.S. EPA: Washington, D.C., 1995.
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present a risk because it contains lead or other Sampling and Quality control for Hazardous Waste
hazardous constituents, even though it is Testing. Journal of Protective Coatings and Linings,
characterized as non-hazardous by TCLP. April 1990, pp 36-44.
16. SSPC Guide 7—Guide for the Disposal of Lead-
References Contaminated Surface Preparation Debris; SSPC:
1. Federal Water Pollution Control Act. Public Law 92- Pittsburgh, 1995.
500, 1971; Clean Water Act. Public Law 95-217, 1977. 17. Tinklenberg, G. Sampling for Lead Analysis. In
2. NSRP 0378. Solvent Recycling for Shipyards; 1993; SSPC Lead Paint Bulletin; Summer 1993.
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Shipyards; 1994; National Shipbuilding Research Wastes Generated During Coating Removal. In SSPC
Program and National Steel and Shipbuilding Co. Lead Paint Bulletin; First Quarter 1997.
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Hazardous Waste. In Procedure Handbook: Surface regnews/EPAWASTERULE.html EPA’s Regulation on
Preparation and Painting of Tanks and Closed Areas; Lead Waste Treatment and Handling (accessed April
SSPC: Pittsburgh, 2000. 2002).
4. Resource Conservation Act. Public Law 94-580, 20. Land Disposal Restrictions—Phase IV. Code of
1976. Federal Regulations, Sections 148, 268, and 271, Title
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Law 98-616, 1984. 21. Smith, L.M.; Tinklenberg, G. L. Lead Containing
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1980. Washington, D.C., 1995.
7. U.S. EPA. Toxicity Characteristic Leaching 22. Kaelin, A. Handling and Disposing of Paint and
Procedure. In Test Methods for Evaluating Solid Waste Solvent Waste. Journal of Protective Coatings and
(Manual SW-846), 3 rd Edition; U.S. EPA: Washington, Linings, May 1999, pp 42-47.
D.C., 1995. 23. Solvent Waste Reduction Alternatives; EPA/625/4-
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for the Toxicity Characteristics. Code of Federal 24. California Administrative Code. Title 22, Section
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27. Guidelines for Disposal of Residual and Household
Waste; Harrisburg: Pennsylvania Dept. of
Environmental Resources, 1992.

Acknowledgements
The author and SSPC gratefully acknowledge Gary
Tinklenberg’s peer review of this document.

About the Author

Bernard R. Appleman
Dr. Bernard R. Appleman has been active in the
protective coatings industry since 1974. He served as
executive director of SSPC from 1984-1999, prior to
his current position as vice president and technical
director of KTA-Tator, Inc. He has also worked at
Federal Highway Administration on research and
testing of bridge coatings, at Exxon Corporation on
coatings and corrosion for the petrochemical industry,
and for the U.S. Navy on corrosion and fouling-
resistant ship coatings. He is an SSPC protective
coatings specialist (PCS) and has published over 100
technical publications.

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