Back in January 2010, collision repair shops were required to
file an Initial Notification with the U.S. Environmental
Protection Agency (EPA) and/or their state regulator and be in
compliance with the National Emission Standards for Hazardous
Air Pollutants (NESHAP), Paint Stripping and Miscellaneous
Surface Coating Operations Rule. For an existing affected
source, the compliance deadline is Monday, Jan. 10, 2011, and
full compliance status is due by March 11, 2011. This rule was
finalized in January 2008.
In September 2007, the Environmental Protection Agency
(EPA) issued proposed air toxic standards for smaller emitting
sources. These emitting sources were referred to as area
sources, and were involved in three industry sectors, including
paint stripping and surface coating operations.
Area sources are defined as those having the potential
to emit less than 10 tons per year of a single toxic air
pollutant or less than 25 tons per year of any combination of
toxic air pollutants.
Sources affected by the rule need to implement
equipment and management practices in compliance with the new
standards. The practices both reduce toxic material consumption
and produce a savings to the facility. The restrictions include
the following rules:
- For paint stripping operations, the proposed rules
would also require new and existing area sources to implement
management practices that minimize evaporative loss of MeCl.
Existing area sources consuming more than 150 gallons per year
of paint stripping formulation must also develop and implement
a minimization plan designed to reduce their consumption of
MeCl by identifying alternatives, when possible.
- For surface coating operations, the proposed
rule would also require new and existing area sources to
implement equipment and management practices that minimize the
amount of coating required and to capture toxic metal
particulates from the process. The toxic metal compounds are
those containing cadmium, chromium, lead, manganese and nickel.
The equipment practices include confining spray operations to
within a properly filtered spray booth or preparation station,
using high-volume/low-pressure (HVLP) or equivalent spray
equipment, and either cleaning spray guns manually or by using
an enclosed spray gun washer. The management practices include
proper training and certification of HVLP equipment operators.
The Automotive Service Association (ASA) partnered with
the EPA to promote the Paint Stripping and Miscellaneous
Surface Coating Operations Rule and hosted EPA representatives
at the International Autobody Congress and Exposition (NACE) in
Las Vegas.
The final regulation and a fact sheet provided by the EPA are
available on the ASA legislative website, TakingtheHill.com.
For additional information visit www.ASAshop.org.
