HAPs 6H

446 views

Published on

HAPs 6H

Published in: Business, Technology
0 Comments
0 Likes
Statistics
Notes
  • Be the first to comment

  • Be the first to like this

No Downloads
Views
Total views
446
On SlideShare
0
From Embeds
0
Number of Embeds
2
Actions
Shares
0
Downloads
3
Comments
0
Likes
0
Embeds 0
No embeds

No notes for slide

HAPs 6H

  1. 1. AIR TOXICS. . . . . POLLUTION PREVENTION
  2. 2. AIR TOXICS. . . . . POLLUTION PREVENTION
  3. 3. AIR TOXICS. . . . . POLLUTION PREVENTION Presenters Steven Schillinger President - GRC-PIRK Management 775.690.9098 - sespirk@earthlink.net Len Lazarus Office of Enforcement and Compliance Assurance - EPA Lazarus.Leonard@epamail.epa.gov Sapna Budev Director of Industry Programs – ISA Sapna.Budev@signs.org
  4. 4. AIR TOXICS. . . . . POLLUTION PREVENTION Questions • If you have questions during the presentation, please submit them using the “Questions” feature • Questions will be answered at the end of the webinar
  5. 5. AIR TOXICS. . . . . POLLUTION PREVENTION CONTENT This webinar is designed to help shop owners and managers be familiar with the requirements of the new HAPs 6H Rule. This webinar does not contain a review of the entire Rule, but provides an overview for sign industry requirements, compliance dates, information about related OSHA standards, and simplify some black rumor & gossip.
  6. 6. AIR TOXICS. . . . . POLLUTION PREVENTION National Emissions Standard for Hazardous Air Pollutants “NESHAP” (Federal Clean Air Act) EPA 40 CFR Part 63 Subpart HHHHHH a.k.a. (6H) • Overview • EPA Requirements • OSHA Requirements • Enforcement • Local Codes • Where to Go for Help a.k.a. NESHAP Rule 40a.k.a. Refinishing Rulea.k.a. Area Source Rulea.k.a. Heavy Metals Rule The HAPs 6H Rule was publicized in the Federal Register in 2007 as a result of a lawsuit won by the Sierra Club in 2006. The final Rule became law in January 2008. a.k.a. Air Toxics Rule EPA 40 CFR Part 63
  7. 7. AIR TOXICS. . . . . POLLUTION PREVENTION AIR QUALITY PERMITS SIGN SHOPS CAN EMIT 3-TYPES OF REGULATED POLLUTANTS: 1. Particulate matter (PM) from sanding, blasting, welding, and spray coating activities; 2. Volatile organic compounds (VOCs) from solvents used in surface prep and equipment cleaning activities, as well as in the coating formulations; and 3. Other Hazardous air pollutants (HAPs) besides those regulated by the new HAPs 6H Rule. – Even though a shop may not require a permit, all shops must comply with EPAs Air Regulations. In addition to the Rule 6H requirements, air quality regulations prohibit the release of pollutants that cause harm to the environment or human health. – The need for an Air Quality Permit depends on the types and amounts of pollutants emitted from shop activities.
  8. 8. AIR TOXICS. . . . . POLLUTION PREVENTION AIR POLLUTION
  9. 9. AIR TOXICS. . . . . POLLUTION PREVENTION HAZARDOUS AIR TOXICS http://www.epa.gov/ttn/atw
  10. 10. AIR TOXICS. . . . . POLLUTION PREVENTION There are many definitions of heavy metals. • One description says they are the chemical elements that have a specific gravity 5-times greater than that of water (Life Extension Foundation). • Another defines heavy metals as particulate matter that are toxic in nature. Most common examples are: Chromium, Copper, Nickel, Mercury, Lead, and Zinc. HEAVY METALS - AIR TOXICS
  11. 11. AIR TOXICS. . . . . POLLUTION PREVENTION What HAPs are Covered The EPA has identified 30 HAPs that pose the greatest threat to public health. The EPA has identified categories that account for 90 percent of the releases of the 30 HAPs. Sign shops are subject to the HAPs 6H Rule if they spray or containing compounds of: chromium, lead, manganese, nickel, or cadmium. (the target HAPs)
  12. 12. AIR TOXICS. . . . . POLLUTION PREVENTION AEROSPACE OPERATIONS 10,000+ shops AEROSPACE TRADE ASSOCIATION PLASTIC COATING OPERATIONS 15,000+ shops PLASTIC & RUBBER TRADE ASSOCIATION METAL COATING OPERATIONS 20,000+ shops FABRICATED METAL ASSOCIATION SIGNS SHOPS 30,000+ shops INTERNATIONAL SIGN ASSOCIATION AUTOMOTIVE COLLISION REPAIR 60,000+ shops AUTOMOTIVE SERVICE ASSOCIATION SPRAY COATING OPERATIONS
  13. 13. AIR TOXICS. . . . . POLLUTION PREVENTION www.epa.gov/collisionrepair
  14. 14. AIR TOXICS. . . . . POLLUTION PREVENTION THE HAPS 6H RULE REGULATES THREE ACTIVITIES: 1) Paint stripping 2) Spray coating of motor vehicles 3) Spray coating of metals and plastics THE HAPS 6H RULE CAN BE DEVIDED INTO 4-SECTIONS: 1) Booth Enclosures 2) Equipment (Type & Maintenance) 3) Employee Training 4) and, Recordkeeping HAPs 6H REGULATIONS
  15. 15. AIR TOXICS. . . . . POLLUTION PREVENTION DEFINITIONS • Spray application means that coatings are applied using a hand-held device that atomizes the coating. • Coating means a material spray-applied for decorative, protective or functional purposes. • Parts and products include: – Architectural Apparatus – Construction Components – Support Structures & Assemblies – Sign or advertising products made of plastic or metal
  16. 16. AIR TOXICS. . . . . POLLUTION PREVENTION MeCl (Paint Stripping) The HAPs 6H Rule requires the development of a written MeCl Minimization Plan for shops that use more than 1 ton of MeCl. 1 ton of MeCl is approximately 180 gallons in one year. However, most sign shops use much less than 1 ton/yr and don’t need a plan.
  17. 17. AIR TOXICS. . . . . POLLUTION PREVENTION MeCl (Paint Stripper) • If you use any MeCl, the HAPs 6H Rule requires management practices be implemented: – Evaluate each application to insure there is a need to strip the old paint from the surface; – Reduce exposure of all MeCl-containing paint strippers; – Optimize application and storage conditions of paint strippers to reduce the MeCl evaporation. • The HAPs 6H Rule requires recordkeeping for ANY amount of MeCL: – A list of all the MeCl-containing paint stripper products used; – The MeCl content of each product used; and – Purchase receipts, MSDS, usage records, or calculations.
  18. 18. AIR TOXICS. . . . . POLLUTION PREVENTION Equipment Type & Cleaning • All spray-applied coatings must be applied with a high-volume low-pressure (HVLP), or equivalent technology. • Paint spray guns must be cleaned so that an atomized mist is not created outside of the container. – Use an enclosed spray gun cleaner. – Do not spray into the sink, filters or a bucket.
  19. 19. AIR TOXICS. . . . . POLLUTION PREVENTION When using Target HAPs, spray coating to be preformed in a prep station or spray booth. (some open air spraying exclusion) – The prep stations and spray booths must have a full roof and at least three complete walls or side curtains. – Prep stations and spray booths must use filters with 98 percent filter efficiency. • Establish and document filter change-out schedule and procedure • Maintain filter purchase records Spray Booth & Filters
  20. 20. AIR TOXICS. . . . . POLLUTION PREVENTION Owners must keep copies of records for the status of HAPs 6H compliance for a minimum of 5-years. – Booth filter purchase records. – Spray gun manufacturers’ data sheets. – Spray gun transfer efficiency evidence. – Regional and state compliance notifications. – Paint stripper and spray coating MSDS sheets. – Assessments, deviations or corrective actions. – Employee classroom training records . – Employee hands-on training records. Record Keeping
  21. 21. AIR TOXICS. . . . . POLLUTION PREVENTION Train and certify all spray equipment operators (helpers & painters) within 180 days. – A employee list by name, job description (title) and date(s) of training. – Hands-on (physical) training: setup, operation and usage of equipment, including spray gun transfer efficiency test. – Classroom (tutorial) instruction: Address the HAPs 6H regulations, procedures and maintenance of equipment, including related environmental health and safety requirements. Training and Certification
  22. 22. AIR TOXICS. . . . . POLLUTION PREVENTION
  23. 23. AIR TOXICS. . . . . POLLUTION PREVENTION Hands-On Requirements  ____________  ________________
  24. 24. AIR TOXICS. . . . . POLLUTION PREVENTION RELATED RULES Health, Safety and Fire Marshal laws that may apply to the HAPs 6H Rule are as follows:  NFPA – Spray Coating Using Flammable & Combustible Liquids  EPCRA – HazCom/HazMat (Right-to-Know)  OSHA – Respiratory Protection  OSHA – Flammable and Combustible Liquids  OSHA – Air Contaminants  OSHA – Cadmium  EPA/OSHA – Lead (EPA Renovation, Repair & Painting)  OSHA – Chromium        
  25. 25. AIR TOXICS. . . . . POLLUTION PREVENTION OSHA has revised the employee notification requirements under the Hexavalent Chromium [Cr(VI)] regulation requiring employers to notify employees of the results of all exposure determinations. The action comes in the form of a Direct Final Rule, which became effective June 15, 2010. OSHA CR(vi) Regulation:  Each region is required to conduct at least five inspections each year.  Employers participating in cooperative Green programs may be exempt from programmed inspections.  Area Offices are required to conduct follow-up inspections on other toxic substances targeted by the Regulation. NEW OSHA Cr REQUIREMENTS
  26. 26. AIR TOXICS. . . . . POLLUTION PREVENTION RENOVATION, REPAIR & PAINTING RULE • The EPA RRP Rule represents the most significant and far-reaching Federal lead regulation since the HUD Lead- Safe Housing Rule a decade ago. • Anyone working on some pre-1978 buildings now need to be certified in the new lead based paint regulations. • The EPA will not take enforcement action for violations of the RRP rule until October 1, 2010. • EPA won’t enforce against shops and workers if they signed up for training by September 30, 2010 and complete the training by December 31, 2010.
  27. 27. AIR TOXICS. . . . . POLLUTION PREVENTION Multi- Agency ENFORCEMENT The HAPs 6H Rule can be implemented and enforced by U.S. EPA, or a delegated authority such as your State, local, or tribal agency.  Air District  Water District  Regulated Waste  OSHA, Fire Dept or city inspector
  28. 28. AIR TOXICS. . . . . POLLUTION PREVENTION EPA ENFORCEMENT EPA, State and local governments are responsible for enforcement of the Clean Air Act. • Citizens can also sue violating sources. • Before the 1990 CAA, enforcement was through the courts. • The 1990 Clean Air Act gave EPA authority to bypass court in order to speed up the process. The federal EPA fines can be up to $37,500 per day. Plus, another $25,000/day (California)
  29. 29. AIR TOXICS. . . . . POLLUTION PREVENTION COMPLIANCE DATES REQUIREMENTS SOURCE TYPE NEW EXISTING General – Enclosures Upon startup January 10, 2011 General – Type and Cleaning of Spray Guns Upon startup January 10, 2011 Employee Training Hands-On: 180 days after hire Classroom: 180 days after hire No later than 180 days after hire of by Jan 10, 2011, whichever is later EPA Initial Notification July 7, 2008, or 180 days after initial startup January 11, 2010 Compliance Notification July 7, 2008, or 180 days after initial startup March 11, 2011 Recordkeeping July 7, 2008, or 180 days after initial startup January 10, 2011 Reporting Each March 1st of the following calendar year Each March 1st of the following calendar year
  30. 30. AIR TOXICS. . . . . POLLUTION PREVENTION Benefits and Burdens Associated NESHAP Paint Stripping and Miscellaneous Spray Coating Rule C O M P L I A N C E E X E M P T I O N B e n e f i t s Green Recognition Pollution Prevention Employee Protection Positive Public Image Spray Coating Efficiency Regulatory Peace-of-Mind B e n e f i t s No New Filters Delay Upgrades Postpone Training Open Air Spraying Use Old Spray Guns No Waste Management B u r d e n s Equipment Upgrades Extra Employee Training Paint Stripping Restrictions Additional Waste Management B u r d e n s Unexpected Violations Uninformed Employees Vibrant Paint Restriction Buy Segregated Products PROS and CONS
  31. 31. AIR TOXICS. . . . . POLLUTION PREVENTION EPA, OSHA & NFPA TYPE OF WASTE WASTE MANAGEMENT REGULATIONS SANDING DUST DISPOSE OF WASTE DUST COLLECTED IN VACUUM SANDERS PROPERLY. USED SPRAY BOOTH FILTERS DO NOT DISPOSE OF USED FILTERS CONTAINING HEAVY METALS: • CHROMIUM, COPPER, NICKEL, MERCURY, LEAD, AND ZINC, ETC • (6H TARGET) CHROMIUM, LEAD, MANGANESE, NICKEL, CADMIUM USED PAINT CUP LINERS IF THE PAINT DOES NOT CONTAIN METALS, USED PAINT CUP LINERS CONTAINING DRIED PAINT MAY BE DISPOSED OF A NON HAZARDOUS WASTE. • ONLY IF ALLOWED BY LOCAL LAND FILL LAWS. EMPTY PAINT CANS CANS CONTAINING DRIED PAINT MUST BE DISPOSED OF AS HAZARDOUS WASTE UNLESS TESTED TO DEMONSTRATE LEVELS BELOW LIMITS. USED/RECYCLED SOLVENT & PAINT WASTE LABEL ALL CONTAINERS “HAZARDOUS WASTE” FOR USED SOLVENT PAINT WASTE AND WATERBORNE PAINT WASTE (WASTE WATER & FLOCCULANTS), AND CONSULT A LOCAL HAZARDOUS WASTE DISPOSAL CONTRACTOR FOR PROPER DISPOSAL. SHOP TOWELS DISPOSABLE TOWELS THAT HAVE BEEN CONTAMINATED WITH HAZARDOUS MATERIALS (SOLVENTS) MUST BE DISPOSED OF AS HAZARDOUS WASTE. Waste generated in the shop is considered hazardous under RCRA standards. • RCRA – Resource Conservation and Recovery Act regulates solid waste management (cradle-to-grave)
  32. 32. AIR TOXICS. . . . . POLLUTION PREVENTION SUMMARY  Mandatory Compliance Jan 10, 2011  Employee Training Documentation  Purchase Records Documentation  Spray Gun Equipment Conformity  98% Efficient Booth Filter Usage  Paint Stripper Recordkeeping  Open Area Spray Limitation
  33. 33. AIR TOXICS. . . . . POLLUTION PREVENTION Truly “GREEN” According to the FTC standards and EPA, HAPs 6H compliance is a good start!
  34. 34. www.haps6h.comwww.sign.org

×