Collision repair shops nationwide have five days to comply with new Environmental Protection Agency standards that became effective three years ago.
By Jan. 11, 2010, all U.S. body shops must file an initial notification with the EPA and/or their state identifying the shops compliance status with the National Emission Standards for Hazardous Air Pollutants NESHAP, subpart HHHHHH, which became effective in January 2008.
Notification may certify that the shop is currently in compliance with all aspects of the rule. If a shop is not currently in compliance with the rule, the notification may be filed stating the shop will be in compliance by the final compliance deadline of Jan. 10, 2011. An additional notification must then be submitted by March 11, 2011 to certify this compliance.
This new rule is intended to control emissions from paint stripping and miscellaneous service coating operations. To comply with this rule, all shops must do the following:
Paint Stripping Operations
Implement management practices that minimize emissions of methylene chloride (MeCl).
• Evaluate the need for paint stripping (e.g., is it possible to re-coat without stripping?)
• Evaluate each application to identify potential alternative stripping methods.
• Reduce exposure of strippers to air.
• Optimize application conditions.
• Practice proper storage and disposal.
For each paint stripping operation with more than one ton MeCl annual usage, develop and implement a written MeCl minimization plan. No implementation plan is needed if usage is less than one ton MeCl; however, sources must still utilize work practices to minimize emissions of MeCl. Consult the MSDS sheet to identify the amount of MeCl contained in the paint stripper, but note that annual usage should not exceed 181 gallons of MeCl.
Maintain records of annual usage of paint strippers containing MeCl.
Motor Vehicle/Mobile Equipment/Miscellaneous Surface Coating Operations.
• Train/certify all painters on spray gun equipment selection, spray techniques, maintenance, and environmental compliance (consult 73 FR 1738, pg. 1762, section 63.11173(f)(2)(i)-(iv)).
• Install/operate filter technology on all spray booths/stations/enclosures to achieve at least 98 percent capture efficiency.
• Spray booths/stations used to refinish complete motor vehicles or mobile equipment must be fully enclosed and ventilated at negative pressure or up to 0.05 inches water gauge positive pressure for booths that have seals on all doors and other openings and an automatic pressure balancing system.
• Spray booths/stations used to coat miscellaneous parts or products or vehicle subassemblies must have a full roof, at least three complete walls or side curtains, and ventilated so that air is drawn into the booth.
• Spray-applied coatings must be applied with a high-volume, low pressure (HVLP) spray gun, electrostatic application, airless or air-assisted airless spray gun, or an equivalent technology.
• Paint spray gun cleaning must be done so that an atomized mist or spray of the cleaning solvent is not created outside a container that collects used gun cleaning solvent.
• Train and certify all personnel who spray apply surface coatings no later than 180 days after hiring or by July 7, 2008 (new sources) or by January 10, 2011 (existing sources).
Once compliant, each shop must maintain a compliance file accessible for inspection. The file should include the following documents:
• Copies of Notifications submitted to EPA.
• Painter training certifications.
• Spray booth filter efficiency documentation.
• Spray gun transfer efficiency.
• MeCl content information such as MSDS.
• Annual usage of MeCl for paint stripping, and written MeCl minimization plan if annual usage is more than one ton per year.
• Deviation and corrective action documentation.
An annual notification of changes report needs to be filed each calendar year in the event any reportable changes occur.
To obtain further information and assistance in complying with this rule, contact the following sources:
EPA:
www.epa.gov/ttn/atw/area/arearules.html
State:
www.epa.gov/ttn/atw/area/table_state_contacts.doc
www.4cleanair.org/contactUsaLevel.asp
State Air Quality Division
State Small Business Environmental Assistance Program
