PWGC Aviation Newsletter — Fall 2014 Edition
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Fall Newsletter

Aviation Edition

Helping you make your airport the best for
your community and the environment!

More States Adopting the Solvent-Contaminated Wipes Final Rule

As published in our Spring 2014 newsletter, the EPA issued the Solvent-Contaminated Wipes Final Rule to modify the hazardous waste management regulations for solvent-contaminated wipes under the Resource Conservation and Recovery Act (RCRA) which became effective January 31, 2014. The rule revises the definition of solid waste to conditionally exclude solvent-contaminated wipes that are cleaned and reused and revises the definition of hazardous waste to conditionally exclude disposable solvent-contaminated wipes. The Secondary Materials and Recycled Textiles Association (SMART) is assisting with promoting the adoption of the Environmental Protection Agency (EPA) rule on industrial wiping. Currently, the following states: Alaska, Florida, Iowa, Illinois, Louisiana, North Carolina, New Jersey, Pennsylvania, and Virginia have all implemented the rule in its entirety. The state of Montana is expected to become the next state to adopt the rule.

Contact PWGC to find out if your state has adopted the new rule. For more information see:


Contact PWGC for additional information

Changes to Underground Storage Tank Used Regulations on the Horizon

The EPA's proposed changes to the 1988 underground storage tank (UST) regulations in 2012 and they are anticipated to be finalized by the end of 2014. The changes may affect many facilities. A significant change that could impact facilities is the removal of the current regulatory exclusion of USTs that store fuel solely for emergency power generator to 40 CFR 480 subpart D (release detection). This means that these USTs would now be subject to all UST requirements.
PWGC will keep you informed once the rule has been finalized and what requirements will be necessary to come into compliance.

For more information, contact PWGC.

Contact PWGC for additional information

EPA Proposed Changes to Refrigerant Venting Rules

In November of 1995, Section 608 of Clean Air Act (CAA) made it illegal to knowingly vent substitutes for CFC and HCFC refrigerants during the maintenance, service, repair and disposal of air-conditioning and refrigeration equipment. The EPA is currently applying the venting prohibition to the different substitute refrigerants and to the various types of air-conditioning and refrigeration equipment.

In summary the proposed regulated as stated on the EPA website ( would:
  • Exempt certain substitute refrigerants from the venting prohibition;
  • Extend to hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs) refrigerants the requirements currently in place for CFC and HCFC refrigerants, including required practices, certification programs for recovery/recycling equipment, reclaimers, and technicians, a prohibition on the sale of refrigerant to anyone but certified technicians, leak repair requirements, and safe disposal requirements;
  • Make minor changes to the required practices, recovery equipment standards, and refrigerant purity standards for CFCs and HCFCs to accommodate the addition of the HFC and PFC refrigerants; and
  • Lower the maximum allowable leak rates for comfort cooling chillers, commercial refrigeration, and industrial process refrigeration. The new maximum allowable leak rates would apply to equipment containing CFCs, HCFCs, HFCs, and PFCs.
The EPA is proposing to exempt the following refrigerants from the venting prohibition:
  • ammonia that is used in absorption systems or in commercial or industrial process refrigeration systems
  • hydrocarbons that are used in industrial process refrigeration systems for processing hydrocarbons
  • chlorine that is used in industrial process refrigeration systems for processing chlorine or chlorine compounds
  • CO2, nitrogen, and water
It is important to maintain proper records of facility refrigerant use, repair, leak, and maintenance. For more information contact PWGC.

Contact PWGC for additional information

EPA Addressing Greenhouse Gas Emissions from Aviation

The EPA has initiated steps towards addressing greenhouse gas emissions from aviation. A timeline to determine if emissions from aviation are harmful to the public health or welfare indicates that the EPA’s findings will be presented in spring of 2015, with final determinations expected in 2016. The EPA will regulate greenhouse gases from aircraft if it determines the emissions endanger public health or the environment.


It is important to have regular internal or third party inspections of solid and hazardous waste generated at your facilities to ensure compliance with regulations. Violations such as improper record-keeping and labeling, open containers, missing paperwork, and improper hazardous waste determination can lead to large fines (over $100,000). Such violations can be avoided with regular auditing. Contact PWGC today for assistance!

Contact PWGC for additional information
PWGC has provided this newsletter solely for informational purposes; we make no warranties or certifications for a specific matter. If you require further information on a subject of this newsletter, would like to discuss your particular circumstances or would like to provide comments, please feel free to contact us.
Copyright © 2014 P.W. Grosser Consulting, All rights reserved.

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