Hazardous Waste Management

Wastes with Land Disposal Restrictions

See this Advisor article to determine if a waste meets the definition of a hazardous waste. If the LDR apply to a waste at the point of generation (i.e., the waste is at concentrations at or above the LDR treatment standards), they continue to apply even if the waste is later decharacterized or excluded from the definition of a hazardous waste.

The company, which repairs and paints vessels, will pay a $31,000 penalty and obtain a Clean Air Act permit from the State of Rhode Island that caps the facility’s emissions of VOCs and requires use of paints and other coatings that meet low-VOC standards. The company will also comply with applicable recordkeeping and certification requirements.

The company provides marine services including painting and other repair operations. According to EPA, the paint used emitted excess levels of VOCs. These pollutants can cause human health problems and also contribute to the formation of ground-level ozone, a primary constituent of smog.

Newport is in an area that has failed to meet federal air quality standards for ozone. Under its permit, the company will use low-VOC solvents and paints that comply with regulatory limits for VOCs. In addition, the company will use paint spray guns with high transfer efficiencies, implement best work practices to minimize VOC emissions from painting and cleanup, and implement required recordkeeping and reporting requirements.

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What Exactly Is a VOC?

A VOC is any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate, that participates in atmospheric photochemical reactions. In simple terms, an atmospheric photochemical reaction is the reaction of a VOC with sunlight in the atmosphere to form ground-level ozone. The following organic compounds have been determined to have negligible photochemical reactivity and are therefore excluded from the definition of VOC:

  • Methane
  • Ethane
  • Methylene chloride (dichloromethane)
  • 1,1,1-trichloroethane (methyl chloroform)
  • Parachlorobenzotrifluoride (PCBTF)
  • Cyclic, branched, or linear completely methylated siloxanes
  • Acetone
  • Perchloroethylene (tetrachloroethylene)
  • The following CFC, HFC, and HCFC compounds: CFC-11, CFC-12, CFC-113, CFC-114, CFC-115, HFC-23, HFC-32, HFC 43-10mee, HFC-125, HFC-134, HFC-134a, HFC-143a, HFC-152a, HFC-161, HFC 227ea, HFC-236ea, HFC-236fa, HFC-245ca, HFC-245ea, HFC-245eb, HFC-245fa, HFC-365mfc, HCFC-22, HCFC-31, HCFC-123, HCFC-123a, HCFC-124, HCFC-141b, HCFC-142b, HCFC-151a, HCFC-225ca, and HCFC-225cb

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  • 1,1,1,2,2,3,3-heptafluoro-3-methoxy-propane (n-C3F7OCH3, HFE-7000)
  • 1,1,1,2,2,3,3,4,4-nonafluoro-4-methoxy-butane (C4F9OCH3 or HFE-7100)
  • 1-ethoxy-1,1,2,2,3,3,4,4,4-nonafluorobutane (C4F9OC2H5 or HFE-7200)
  • 1,1,1,2,2,3,4,5,5,5-decafluoro-3-methoxy-4-trifluoromethyl-pentane (HFE-7300)
  • 3-ethoxy-1,1,1,2,3,4,4,5,5,6,6,6-dodecafluoro-2-(trifluoromethyl) hexane (HFE-7500)
  • 2-(difluoromethoxymethyl)-1,1,1,2,3,3,3-heptafluoropropane ((CF3)2CFCF2OCH3)
  • 2-(ethoxydifluoromethyl)-1,1,1,2,3,3,3-heptafluoropropane ((CF3)2CFCF2OC2H5)
  • Methyl acetate
  • Methyl formate
  • Propylene carbonate
  • Dimethyl carbonate
  • trans-1,3,3,3-tetrafluoropropene
  • HCF2OCF2H (HFE-134) – effective March 14, 2013
  • HCF2OCF2OCF2H (HFE-236cal2) ) – effective March 14, 2013
  • HCF2OCF2CF2OCF2H (HFE-338pcc13) ) – effective March 14, 2013
  • HCF2OCF2OCF2CF2OCF2H (H-Galden 1040x or H-Galden ZT 130 (or 150 or 180)) ) – effective March 14, 2013
  • trans 1-chloro-3,3,3-trifluoroprop-1-ene (SolsticeTM 1233zd(E)) – effective May 16, 2013
  • Perfluorocarbon compounds that fall into these classes:
    • Cyclic, branched, or linear, completely fluorinated alkanes
    • Cyclic, branched, or linear, completely fluorinated ethers with no unsaturations
    • Cyclic, branched, or linear, completely fluorinated tertiary amines with no unsaturations
    • Sulfur containing perfluorocarbons with no unsaturations and with sulfur bonds only to carbon and fluorine

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