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of AUTOMOTIVE REFINISHING
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of David P. LaBrode Environmental Analyst Bureau of Waste Prevention Northeast Regional Office Department of Environmental Protection 205B Lowell Street, Wilmington, MA 01887 phone: (978) 694 3270 fax: (978) 694-3499 email: david.labrode@state.ma.us
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of Information Sources http://www.mass.gov/dep http://www.mass.gov/ota
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of
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Department of Environmental Protection/Regions
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of Organization 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
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of Bureau of Waste Prevention Multi-Media Inspections –Solid Waste –Toxics Use Reduction –Industrial Wastewater –Air Quality; includes Asbestos –Hazardous Waste Compliance & Enforcement Permitting
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of DEP vs EPA Department of Environmental Protection –Commonwealth of Massachusetts Environmental Protection Agency –United States of America WE ARE NOT THE EPA!!!!
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of INSPECTED? Has anyone ever been inspected? Pleasure or Pain?
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of What to expect when DEP comes a knockin’ Hi, I’m from the government, and I’m here to help
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of Solid Waste
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of Solid 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.
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of Industrial Wastewater
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of Industrial Wastewater 314 CMR 3.00 – 7.00314 CMR 3.00 – 7.00 DEP regulates the discharge, treatment, and storage of IWW.DEP regulates the discharge, treatment, and storage of IWW. Any effluent other than sanitary is IWWAny effluent other than sanitary is IWW Three areas:Three areas: –Sewer Connections –Surface Water (NPDES) –Ground Water
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of Industrial Wastewater Auto Shops generally have floor drainsAuto Shops generally have floor drains
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of Industrial Wastewater
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of Industrial Wastewater
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of Industrial Wastewater Typical oil/water separator Also called MDC trap Oil/water Separators -Required by most POTW’s as well as DEP/MWRA
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of Industrial Wastewater
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of Industrial Wastewater
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of Industrial Wastewater
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of Industrial Wastewater Common IWW from Automotive RefinishingCommon IWW from Automotive Refinishing -Vehicle wash water -MUST discharge to sewer or tight tank!!!!! There are limited exceptions…
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of Industrial Wastewater Surface Water Discharges (NPDES)Surface Water Discharges (NPDES) –Individual Main Permit –Non-Contact Cooling Water –General Storm Water Permit –NEW – Reverse Osmosis Permit
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of Industrial Wastewater Groundwater DischargeGroundwater Discharge –Difficult to get. Anyone have one? Holding TanksHolding Tanks –Must be certified DEP01
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of Air Quality
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of AirQuality 310 CMR 6.00- 8.00310 CMR 6.00- 8.00 Applicable regs.Applicable regs. –7.02 Plan Approval –7.03 Plan Approval Exemption 7.03(16) Paint Spray Booth7.03(16) Paint Spray Booth 7.18(28) Automotive Refinishing7.18(28) Automotive Refinishing
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of Air Quality Spray Booths Spray Booths
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of Air Quality
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of Air Quality
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of Air Quality
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of Air Quality 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
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of Air Quality 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
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of Air Quality Dry Fiber Mat Filter
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of Air Quality
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of Air Quality Stack design BAD!!
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of Air Quality
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of Air Quality
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of Air Quality 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.
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of Air Quality
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of Air Quality Stack Design GOOD!!!!
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of Air Quality
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of Air Quality
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of Air Quality
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of Air Quality #1 complaint we receive regarding Auto Body Shops…
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of Air Quality Spray Guns HVLP or equivalent!
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of Air Quality
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of Air Quality
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of Air Quality Enclosed Gun Washer
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of Air Quality
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of Air Quality INSPECTION: –Will check and verify equipment is compliant Booth, guns, stack, washer –Verify compliance with Record Keeping and Reporting 7.02 Plan Approvals, LPA, CPA, RES, and ECP7.02 Plan Approvals, LPA, CPA, RES, and ECP 7.03 Plan Approval Exemption Requirements7.03 Plan Approval Exemption Requirements 7.12 Source Registration7.12 Source Registration 7.18 VOC & HOC RACT
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of Air Quality 7.12 Source Registration MORE Record Keeping & Reporting –Who reports? –Chances are your school reports –Must include Paint Spray Booth as well
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of Air Quality SR/ES Forms now to be filed on-line Please visit DEP web site for full info. PLEASE report information ACCURATELY!!!!
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of Air Quality The key is staying on top of your recordkeeping.
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of Hazardous Waste
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of Hazardous Waste 310 CMR 30.000 Responsibilities regarding the management and storage of hazardous waste/waste oil Generator ID Numbers – Generation Status. Hazardous Waste/Waste Oil
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of Hazardous Waste 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?
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of Hazardous Waste Do you know your generator ID number? There are a variety of ‘em MAV, MV, MAD, MAR, MA5, and MAC MP is not permanent!!!!!
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of Hazardous Waste 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
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of Hazardous Waste Lines, Lids, and Labels
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of Hazardous Waste
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of Hazardous Waste Typical Label for HW in Automotive Refinishing Shops HAZARDOUS WASTE WASTE PAINT RELATED MATERIAL (TOLUENE, XYLENE) IGNITABLE
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of Hazardous Waste HW Storage/Accumulation Standards –Delineation –Signage –Emergency Plan (Emer. Info) –Closed containers –Time limits –Secondary containment
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of Hazardous Waste
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of Hazardous Waste
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of Hazardous Waste 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
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of Hazardous Waste Cradle to Grave
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