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EPA Regulations

 
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Old 03-17-2010, 06:46 PM   #1
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EPA Regulations


Just found this forum, great information. My question that I have been looking all over for is in regards to the proper disposal of boat bottom paint and media. I'm located in Massachusetts. Regulations through Waste Management are ridiculous. They want to test each boat individually before blasting. Waiting to hear from Clean Harbors with their answer.

Everything I hear so far is counterproductive. I'm not looking to get in trouble (fined) or trying to wake a sleeping giant.

I haven't found a lot of specifics on this topic. Any input is helpful.
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Old 03-17-2010, 07:49 PM   #2
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Re: EPA Regulations


You pretty much answered your own question. You test the abrasive used for each boat and dispose of accordingly. Follow all Local, State and Federal laws reguarding proper didposal of waste. Most would be taken to a Sub Title D Landfill.

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Old 03-17-2010, 10:02 PM   #3
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Re: EPA Regulations


You could never test a boat before a job, that's insane. No customer is going to pay you up front for the cost of a test. They will just call another blaster. The local authority is different for each boat depending where you are going to blast and if you went to a township building to ask you will never get an answer. They won't have any knolege of boat bottoms but they will now be aware of you and concerned and may tell you you can't even do it. I doubt anyone on this site has any idea if there is a federal law concening any sort of blasting or would have any idea what federal web site or department to call. I called the EPA for Pa and did get a call back from them. The guy said a tarp on the ground as a best effort to collect as much as possible would be acceptable. He did not say anything about tenting. Then he said you would bag it and find a local lab to have it tested and then I think take it to a clean land fill I think what ever that is. I have no idea what all this would cost and the time is rediculous. It's hard to even get a couple hundred bucks to begin with. Why even test it? Can't you skip that and just go straight to a clean land fill with it and just assume it's toxic? And where are these speacial land fills? What if they are a hundred miles from you ? How do you really comply with this crap?
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Old 03-17-2010, 10:49 PM   #4
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Re: EPA Regulations


By law you are suppose to have your spent abrasive tested before dumping into any landfill. Even here in Alabama, the landfill will require to have the test results in hand before they will even let the truck drive onto the scales. The test is a TCLIP Test. It test for the Eight Heavy Metals.

Arsenic
Barium
Cadminum
Chromium
Lead
Mercury
Selenium
Silver

The test takes a couple to three days to complete. I would always as soon as the blasting begins, I would go ahead and collect a sample. About half of a quart zip lock bag worth and go ahead and take it to the lab for testing. After the job is completed then the spent material is put into a lined roll off dumpster and it sits until the testing is completed and the results is in. Afterward, the material can be delivered to the landfill leagal. Oh by the way, It is the owners responsability to handle the disposal. It is there waste anyway. Even though you removed the coating they are the owner/generator. Contractor and owner is both liable, but the waste does belong to the owner. Check your state and local laws for what applies for you.
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Old 03-19-2010, 08:10 AM   #5
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Re: EPA Regulations


So if it does show these metals then what happens? If it still goes to the same land fill why do they require a test ?
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Old 03-19-2010, 09:54 AM   #6
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Re: EPA Regulations


If the metals show up in the testing then it will determine if the material has to be classes as a Haz-Waste or not. If it is classed as a Haz-Waste and it is going to go to the same landfill then they will of course charge way more per ton of the material. They require the test to determine how the waste stream is to be handled. Remember, it's all about the MONEY!!
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Old 03-19-2010, 06:24 PM   #7
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Re: EPA Regulations


Painter213,
What is a ball park price for the testing?

I know in Maine when its haz. material... no matter what size truck that is transporting, you have to have a class B drivers lience and a Haz mat indorsment.
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Old 03-19-2010, 09:08 PM   #8
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Re: EPA Regulations


Ballpark pricing for a TCLIP is somewhere around $75-$100. Depends on where you go. Here in B'ham, Lab I use when I would have a client to send the material in is $75.
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Old 03-19-2010, 10:05 PM   #9
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Re: EPA Regulations


So $75. for the test... then you have to somhow get this load of crud to a landfill that might be 80 miles away and pay how much to them for disposal. So all I have to do is get boat bottom customers to pay and extra five or six hundred bucks for testing travel and waste disposel. No problem.
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Old 03-20-2010, 09:54 AM   #10
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Re: EPA Regulations


The waste belongs to the customer. Get them to sign a waiver and leave it up to them to dispose of. It's all a part of doing business. You either do it legal or one day pay the hard way with fines, leagal troubles and maybe even jail time. Your call on this one. It's called playing by the rules. Take it or leave it. Hazards are not dealt with like they used to be. I don't make the rules.
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Old 03-20-2010, 07:09 PM   #11
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Re: EPA Regulations


Glen, on many of my Boat jobs, I have them sign a waiver saying that they are assuming responsibility for the material (hazardous or not) and that they should follow any rules or regulations that the state has. Most just take it to the local dump.

Residential House owners are allowed to dispose of a cretin amount of waste.

Boat yards, most of the time, have a dumpster for hazmat stuff.

Only once have I had to remove the material, and I passed on the cost to the customer. They didnít want to deal with it, so it was worth the cost for them.

Plus, I just talked to a guy that removes Fiberglass resin (considered Haz) and he says that youíre allowed up to 1000lbs to transport without a class B license.
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Old 03-20-2010, 09:15 PM   #12
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Re: EPA Regulations


Another waiver guys? I guess I better start writing again.

Dear blasting customer. This is to inform you that to the best of my knolege I was never here and have never met you or any of your relatives either living or deceased.

Nothing I do would be leagle for you so I will be good enough to do nothing for you.
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Old 03-21-2010, 06:42 AM   #13
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Re: EPA Regulations


Glen, what this does is, if the guy takes the soda with bottom paint and dumps it out back of the house, the nabor Bitches and turns them in to the state, they cant come back on you.

or take it home and through it in the dumpster? just don't let anyone know....

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