of automotive refinishing. of david p. labrode environmental analyst bureau of waste prevention...

of

AUTOMOTIVE REFINISHING

of

David P. LaBrodeDavid P. LaBrodeEnvironmental Analyst Environmental Analyst

Bureau of Waste PreventionBureau of Waste PreventionNortheast Regional OfficeNortheast Regional Office

Department of Environmental ProtectionDepartment of Environmental Protection205B Lowell Street, Wilmington, MA 01887 205B Lowell Street, Wilmington, MA 01887

phone: (978) 694 3270phone: (978) 694 3270fax: (978) 694-3499fax: (978) 694-3499

email: [email protected]: [email protected]

of

Information Sources

http://www.mass.gov/dephttp://www.mass.gov/ota

of

Department of Environmental Department of Environmental Protection/RegionsProtection/Regions

of

Organization of DEPOrganization of DEP

• Bureau of Resource Protection– Wetlands, Water Pollution, Water Supply

• Bureau of Waste Site Clean Up– Brownfields & Emergency Response

• Strike Force– Investigate environmental crime

of

Bureau of Waste PreventionBureau of Waste Prevention

• Multi-Media Inspections– Solid Waste– Toxics Use Reduction– Industrial Wastewater– Air Quality; includes Asbestos– Hazardous Waste

• Compliance & Enforcement• Permitting

of

DEP vs EPADEP vs EPA

• Department of Environmental Protection– Commonwealth of Massachusetts

• Environmental Protection Agency– United States of America

WE ARE NOT THE EPA!!!!

of

INSPECTED?INSPECTED?

• Has anyone ever been inspected?

• Pleasure or Pain?

of

What to expect when DEP What to expect when DEP comes a knockin’comes a knockin’

Hi, I’m from the government, and I’m here to help

of

Solid WasteSolid Waste

of

Solid WasteSolid Waste

• 310 CMR 19.00• Does your company recycle?• Do you know “waste bans”?

-Recyclable Paper-Glass Containers-Metal Containers-Single Resin Narrow-Necked Plastics (soda)-White Goods, CRT’s,metal, wood.

of

Industrial WastewaterIndustrial Wastewater

of


• 314 CMR 3.00 – 7.00314 CMR 3.00 – 7.00• DEP regulates the discharge, treatment, DEP regulates the discharge, treatment,

and storage of IWW.and storage of IWW.• Any effluent other than sanitary is IWWAny effluent other than sanitary is IWW• Three areas:Three areas:

– Sewer ConnectionsSewer Connections– Surface Water (NPDES)Surface Water (NPDES)– Ground WaterGround Water

of


• Auto Shops generally have floor Auto Shops generally have floor drainsdrains

of


of


• Typical oil/water separator

• Also called MDC trap

Oil/water SeparatorsOil/water Separators

-Required by most -Required by most POTW’s as well as POTW’s as well as DEP/MWRADEP/MWRA

of


of


• Common IWW from Automotive Common IWW from Automotive RefinishingRefinishing-Vehicle wash water-Vehicle wash water

-MUST discharge to sewer or tight tank!!!!!-MUST discharge to sewer or tight tank!!!!!

There are limited exceptions…There are limited exceptions…

of


• Surface Water Discharges (NPDES)Surface Water Discharges (NPDES)– Individual Main PermitIndividual Main Permit– Non-Contact Cooling WaterNon-Contact Cooling Water– General Storm Water PermitGeneral Storm Water Permit– NEW – Reverse Osmosis PermitNEW – Reverse Osmosis Permit

of


• Groundwater DischargeGroundwater Discharge– Difficult to get. Anyone have one?Difficult to get. Anyone have one?

• Holding TanksHolding Tanks– Must be certified DEP01Must be certified DEP01

of

Air QualityAir Quality

of

AirAir QualityQuality

• 310 CMR 6.00- 8.00310 CMR 6.00- 8.00

• Applicable regs.Applicable regs.

– 7.02 Plan Approval7.02 Plan Approval

– 7.03 Plan Approval Exemption7.03 Plan Approval Exemption• 7.03(16) Paint Spray Booth7.03(16) Paint Spray Booth

• 7.18(28) Automotive Refinishing7.18(28) Automotive Refinishing

of

Air QualityAir Quality Spray BoothsSpray Booths

of


of


• 7.03 exemption “Permit by Rule”

-Performance standards• Usage restrictionsUsage restrictions• Compliant coatingsCompliant coatings• HVLP spray gunsHVLP spray guns• Dry fabric filters – 2” or greaterDry fabric filters – 2” or greater

of


• Proper face velocity 200 ‘ per second• Compliant surface prep. 1.67 for lbs per

gallon for metal. 6.5 lbs. Per gallon for plastic

• Gun cleaner• Proper exhaust stack******** BIG ISSUE!!• Record keeping

of


Dry Fiber Mat Filter

of


•

of

Air QualityAir Quality• Stack design BAD!!

of


of


• Proper Stack Design– Discharge vertically UPWARDS.

– NO rain protection that restricts vertical exhaust flow.

– Exit velocity > 40’ per second

– Height 35’ above ground or 10 ‘ above roof level.

of


of


Stack Design

GOOD!!!!

of


of


• #1 complaint we receive regarding Auto Body Shops…

of

Air QualityAir QualitySpray GunsSpray Guns

HVLP or equivalent!HVLP or equivalent!•

of


of


•

of


• Enclosed Gun Washer

of


of


• INSPECTION:– Will check and verify equipment is compliant

• Booth, guns, stack, washer– Verify compliance with Record Keeping and Verify compliance with Record Keeping and

ReportingReporting• 7.02 Plan Approvals, LPA, CPA, RES, and 7.02 Plan Approvals, LPA, CPA, RES, and

ECPECP• 7.03 Plan Approval Exemption 7.03 Plan Approval Exemption

RequirementsRequirements• 7.12 Source Registration7.12 Source Registration• 7.18 VOC & HOC RACT

of


• 7.12 Source Registration• MORE Record Keeping & Reporting

– Who reports?

– Chances are your school reports

– Must include Paint Spray Booth as well

of


• SR/ES Forms now to be filed on-line

• Please visit DEP web site for full info.

• PLEASE report information ACCURATELY!!!!

of


• The key is staying on top of your recordkeeping.

of

Hazardous WasteHazardous Waste

•

of


• 310 CMR 30.000 Responsibilities regarding the management and storage of hazardous waste/waste oil

• Generator ID Numbers – Generation Status. Hazardous Waste/Waste Oil

of


• Are you a generator?• What status?

– LQG >270 gallons per month

– SQG 27-270 gallons per month

– VSQG < 27 gallons per month

• What about waste oil?

of


• Do you know your generator ID number?

• There are a variety of ‘em

• MAV, MV, MAD, MAR, MA5, and MAC• MP is not permanent!!!!!

of


• Manifests– As of 09-2006 no more 2,4, or 8 Part

manifests– National 6 part manifest– No need to mail a copy to state anymore

unless shipment is going out of state.– Copy 6 retained by Generator, Copy 3

mailed by Facility to Generator*– Must be kept on site for 3 years

of


• Lines, Lids, and Labels

of


•

of


• Typical Label for HW in Automotive Refinishing Shops

HAZARDOUS WASTE

WASTE PAINT RELATED MATERIAL

(TOLUENE, XYLENE)

IGNITABLE

of


• HW Storage/Accumulation Standards– Delineation

– Signage

– Emergency Plan (Emer. Info)

– Closed containers

– Time limits

– Secondary containment

of


•

of


of


• Satellite Accumulation– Point of generation

– Up to one 55g container per waste stream

– Unlimited time

– Must be managed by a responsible person

– Labeled and moved within 3 days when full

of


• Cradle to Grave

of automotive refinishing. of david p. labrode environmental analyst bureau of waste prevention...

Documents

industrial wastewater

depmwra slide

air quality slide

solid waste slide

automotive refinishing

certified dep01 slide

water pollution

waste bans