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Re: HVLP painting equipment and robots

At 04:47 PM 6/27/97 -0700, you wrote:
>I was aware of the "speckled" finish resulting from curing mixed powder
>coatings and it apparently isn't widely used except possibly for
>surfaces that require protection from oxidation but are not readily
>visible such as the inside of metal housings.  To my knowledge, TCLP was
>not routinely done since the operators claimed awareness from the MSDS
>and past experience regarding the powder being "OK" to toss.  Obviously,
>this argument is very easily applied to any and all situations where
>there is no desire to spend the money to run TCLP. What can I say?
>Paul Saunders
Your attitude about the TCLP is inappropriate.  First, there is no
regulatory requirement that one run the TCLP if one has knowledge of the
concentrations of the relevant constituents.  The TCLP is merely a tool for
acquiring knowledge if it is missing, and is not superior to other sources
of the same information.

Process knowledge is the alternative, and it is ALWAYS used.  It is used
because it is necessary to know that the sample is representative, that the
process has not changed, that the TCLP is appropriate, etc., etc.  Thus
Process Knowledge is superior to the TCLP and is always used, while the TCLP
is used to supplement Process Knowledge.

Spending money on unnecessary testing is wasteful and not appropriate to
pollution prevention, where all resources need to be used with respect,
including financial resources.


Ralph E. Cooper, Ph.D.
3475 Norwood, Suite N
Shaker Heights, OH 44122-4975
e-mail:	rec3@po.cwru.edu
Voice:	216-991-6837 (w/voice mail)
Fax:	216-991-6849