Autobody Refinishing Requirements

National Emission Standards for Hazardous Air Pollutants (NESHAP) for Paint Stripping and Miscellaneous Surface Coating Operations at

Area Sources

Kim Teal, Rule WriterU.S. EPA, Office of Air & Radiation

Office of Air Quality Planning and StandardsSector Policies and Programs Division

Natural Resources and Commerce Group(919) 541-5580

teal.kim@epa.gov

BACKGROUND• Clean Air Act (CAA)

– EPA sets limits on the emissions of a pollutant– States may implement stronger pollution controls– States historically implement the requirements

• Air toxics– EPA refers to chemicals that cause serious

health and environmental hazards as hazardous air pollutants (HAP) or air toxics

– The CAA deals more strictly with large sources (major ) than small ones, but EPA must regulate small sources (area) of HAP as well

– Major sources are to use Maximum Available Control Technology (MACT) to reduce pollutant releases; this is a very high level of control.

• Regulatory History– HAP standards for major sources in 2004– National volatile organic compound (VOC)

standards for refinish coatings in 1998 • Why we need an area source rule

– CAA requires EPA to identify >30 HAP that pose the greatest potential health threat in urban areas,

– Refinishing was a source of some of these HAP– EPA must consider MACT when developing

standards but must issue Generally Available Control Technology (GACT), at a minimum.

• Pollutants of Concern for RefinishingChromium, Cadmium, Lead, and Manganese

BACKGROUND (cont’d)

Goals

• Address remaining urban air pollution following regulation of major sources

• Mitigate human health complications due to inherently urban industrial activities

• Although individually small, aggregate emissions may contribute significantly to adverse health effects of exposed populations.

RULE DEVELOPMENT PROCESS

• Industry research• Emission reduction options

• Environmental & economic impacts

• Proposal• Comment• Promulgation of a final rule

COMMUNICATION

• Refinishing, restoration, and fleet maintenance shops

• Small Business Environmental Assistance Programs (SBEAP) Representatives

• Automobile Services Association (ASA)• Automotive Aftermarket Industry

Association (AAIA)• National Paint & Coatings Association

(NPCA)• Trade schools and community colleges• State & local representatives

Communication Forum

• Shop visits• Public meetings• Conferences• Trade magazines• Websites• Electronic mail• Phone calls

OUR UNDERSTANDING OF THE INDUSTRY PERSPECTIVE

• Most shops use booths• Different levels of throughput

– Hobbyist– Restoration (1-2 cars/yr, high $/job, private pay)– Small collision repair shops (3-10 cars/wk,

primarily insurance)– Mobile repair operations (spot repairs @

dealerships)– Large collision repair (>20 cars/wk, wide range of

services, insurance & private pay)– Fleet maintenance & repair (private business,

State or local government, in house work, etc.)

Industry-expressed Goals• Level the playing field• Point of Sale restrictions• Spray booths• Clean operations• Consider potential economic impact

on shops supported by insurance work

• Eliminate dirty shops to improve image

Applicability

• Spray application of coating…as part of repair, maintenance, and restoration… automobiles, …except – refinishing performed by individuals on

their personal vehicles, property or possessions, either as a hobby or for maintenance of their personal vehicles, possessions, or property provided they coat no more than two vehicles per year.

Definition of Spray Application

• Spray application of coatings requires the use of a hand-held device that creates an atomized mist of coating and deposits the coating on a substrate except:

spray gun or air brush with a paint cup capacity that is less than 3.0 fluid ounces

powder coating or non-atomizing technology

-handheld, non-refillable aerosol containers

- thermal spray operations in which solid metallic or non-metallic material is heated to a molten or semi-molten state and propelled to the work piece or substrate by compressed air or other gas, where a bond is produced upon impact

Definition of Spray Application

Generally Available Control Technology (GACT) Requirements

• Autobody Refinishing Operations–High volume low pressure (HVLP)

spray gun–Proper training–Spray booth

–Emissions from atomized spray gun washing must be controlled

TRUE OR FALSE???

By the year 2011, the EPA is looking into

restricting the sale of auto body paints to only those who are certified

to use the product.

U.S. EPA did not propose or finalize any prohibition on the sale of refinish paints nor does EPA have plans to prohibit the sale of refinish paints in the future!

FALSE…

TRUE OR FALSE???Unless you are certified,

and have a $100,000 filtered paint booth, you won't be able to buy the necessary paints to restore old cars, trucks or motorcycles."

The only booth requirement is that it must have a roof + 3 sides for full vehicles or a roof + 2 sides for parts! It does not specify that it must be permanent nor commercially purchased and installed.

FALSE…

Additional Information

• Seek guidance from:

– State or Local staff as they may have additional requirements

– EPA Regional staff

– “Where You Live” link at www.epa.gov

Additional Information

• http://www.epa.gov/ttn/atw/area/paint_stripb.pdf

• Mr. Leonard Lazaruslazarus.leonard@epa.gov(202) 564-6369

• Ms. Kim Teal teal.kim@epa.gov(919) 541-5580

2020

Reducing emissionsReducing emissionsProtecting neighborsProtecting neighborsProtecting workersProtecting workersSaving moneySaving money

Collision Repair Collision Repair CampaignCampaign

Holly Wilson, Team LeaderCommunity Air Program OAQPSJuly 2008

Collision Repair Collision Repair CampaignCampaign

The CRC began as a voluntary community air toxics initiative.EPA regional air toxics were receiving calls from communities identifying emissions & odors from auto body shops as a possible health andenvironmental concern.

These shops are widespread in nature and tend to be clustered in low-income, minority, and mix use neighborhoods.

Many shops are small businesses and do not use standard methods for auto body repair & painting.

Some of the smaller shops do not or can not comply with acceptedindustry practices or current control technology.

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What is theWhat is the Collision Repair Collision Repair CampaignCampaign ??

A joint initiative of the EPA and communities to address A joint initiative of the EPA and communities to address health threats and to drastically reduce auto body health threats and to drastically reduce auto body emissions across the nation. emissions across the nation.

In addition, participating shop owners and operators In addition, participating shop owners and operators can achieve early and beyond compliance with the can achieve early and beyond compliance with the Paint Stripping & Miscellaneous Surface Coating Rule Paint Stripping & Miscellaneous Surface Coating Rule by implementing these voluntary measures.by implementing these voluntary measures.

Great framework for coordination, information Great framework for coordination, information dissemination, tool development, collaboration, dissemination, tool development, collaboration, technical support, and stakeholder, and partnership technical support, and stakeholder, and partnership building.building.

2323

Voluntary Campaign Program to Voluntary Campaign Program to Complement Rule Complement Rule -- GoalsGoals

�� Work with Work with 400+ shops400+ shops to institute BMPs and/or work to institute BMPs and/or work toward early and beyond compliance requirements.toward early and beyond compliance requirements.

�� Create Create 10 regional partnerships10 regional partnerships with trade associations, with trade associations, state programs and technical providers. state programs and technical providers.

�� Initiate Initiate 10 community based projects10 community based projects in neighborhoods.in neighborhoods.

�� Create a Create a sustainable Campaign that can be transferredsustainable Campaign that can be transferredto Tribes, States, locals, and NGOs partners to Tribes, States, locals, and NGOs partners

Achieve up to Achieve up to 90% emission reductions90% emission reductions for participating for participating shops.shops.

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Potential Benefits Potential Benefits from the Campaignfrom the Campaign

Environmental Benefits Environmental Benefits �� Decrease solvent use by more than Decrease solvent use by more than 50%50%�� Decrease air pollution by Decrease air pollution by 70%70% to to 90%90%

Economic Benefits to OperatorsEconomic Benefits to Operators�� 95%95% reduction in operating cost by using waterreduction in operating cost by using water--

based cleaning systembased cleaning system�� Saving up to Saving up to $13000/year$13000/year at a shop spraying 15 at a shop spraying 15

cars/weekcars/week�� Reduced clean up cost if installing vacuum Reduced clean up cost if installing vacuum

sanding system sanding system -- investment of investment of $9000$9000 results in results in annual saving of annual saving of $7000$7000

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Best PracticesBest Practices

HVLP spray guns HVLP spray guns **�� Increase transfer efficiency to Increase transfer efficiency to 65%65%

Spray booths Spray booths **�� Spray booth filters are >Spray booth filters are >90%90% efficient for particulatesefficient for particulates

Vacuum or wet sandingVacuum or wet sandingLow VOC or water based paintLow VOC or water based paintLow VOC solventsLow VOC solventsClosed containersClosed containersComputerized paint mixing systems Computerized paint mixing systems

* Rule requirement

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Reduction in Auto Body Shop Emissions with Best Practices

020406080

100

Conventionalspray gun

HVLP spraygun

Booth +Conventional

spray gun

Booth + HVLPspray gun

Best Practice

% R

educ

tion

in E

mis

sion

s

Diisocyanates Lead, Chromium Organic Solvents

2727

How Do WeHow Do WePromote Best Practices?Promote Best Practices?

EPAEPA’’s Design for the Environment (s Design for the Environment ( DfEDfE))�� TrainTrain--thethe--Trainer courseTrainer course�� Best Practices Tool KitBest Practices Tool Kit

Partnering with:Partnering with:�� Collision Repair AssociationsCollision Repair Associations�� Trade Schools (secondary and post secondary)Trade Schools (secondary and post secondary)�� Pollution Prevention ProgramsPollution Prevention Programs�� Small Business ProgramsSmall Business Programs�� Air ProgramsAir Programs

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RegionalRegional CampaignsCampaignsEach Region identified a Campaign strategy Each Region identified a Campaign strategy from a range of possibilitiesfrom a range of possibilities

�� Partnered with states and small business Partnered with states and small business programsprograms

�� Conducted training workshops locallyConducted training workshops locally

�� Rolled out an expansive outreach campaignRolled out an expansive outreach campaign

�� Worked with regional trade associations and Worked with regional trade associations and VoVo--tech schoolstech schools

Visit CRC website for project detailsVisit CRC website for project details

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Some Campaign ResultsSome Campaign Results

Partners and Participants:Partners and Participants:1010 EPA RegionsEPA Regions

5 5 EPA Program OfficesEPA Program Offices

2525 State and Local agenciesState and Local agencies

2020 Community Colleges & VoCommunity Colleges & Vo--tech schoolstech schools

1010 Industry & Trade Associations Industry & Trade Associations

55 Community for a Renewed Environment (CARE) Community for a Renewed Environment (CARE) granteesgrantees

44 Paint SuppliersPaint Suppliers

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Some Campaign ResultsSome Campaign Results contcont’’d.d.

Design for Environment training workshop Design for Environment training workshop results:results:

Auto body Owners/workers/stakeholders: Auto body Owners/workers/stakeholders: 498498Students: Students: 167167Teachers: Teachers: 5454Outreach packets distributed for students in other Outreach packets distributed for students in other

classes: classes: 130130SelfSelf--evaluation sheets distributed & returned: evaluation sheets distributed & returned: 518518Shop Site Visits: Shop Site Visits: 66School Site Visits: School Site Visits: 77

Over 81% of participantsOver 81% of participants made changes that will reduce shop made changes that will reduce shop emissions and provide better health in the workplace emissions and provide better health in the workplace and environment. and environment.

VOC & PM Emission after Best Management Practices

511,368

335,323

158,247

371,904

4,609 3,873 2,696

399,035

-

100,000

200,000

300,000

400,000

500,000

600,000

No Training and No Know ledgeof BMPs

Commitments from w /sattendees to implement BMPs

and w ork tow ards earlycompliance of the NESHAP Rule

over the next 6 months

Compliance w ith the Final Rule2011

100% Early Compliance w ith AllBMPs Beyond NESHAP Final Rule

lbs.

/yr Total VOC Emission after

BMPs (lbs/yr)

Total PM Emission afterBMPs (lbs/yr)

81%

*Statistics are based on 489 attendees at 22 workshops with an average of 1,490 gallons of paint used per week.

Material Savings and Cost Avoidance

$0.00

$1,869,705.74

$2,308,278.69 $2,308,278.69

545,915 lbs.

240,010 lbs. 194,408 lbs

0-

500,000

1,000,000

1,500,000

2,000,000

2,500,000

No Training and No Know ledge ofBMPs

Commitments from w /s attendees toimplement BMPs and w ork tow ards

early compliance of the NESHAP Ruleover the next 6 months

Compliance w ith the Final Rule 2011 100% Early Compliance w ith AllBMPs Beyond NESHAP Final Rule

Material Savings(lbs/yr)

Cost Savings(Annually)

.

*Statistics are based on 489 attendees at 22 workshops with an average of 1,490 gallons of paint used per week.

81%

Material Usage Reduction (lbs/yr)

-

545,915

240,010

194,408

-

100,000

200,000

300,000

400,000

500,000

600,000

No Training and No Know ledge ofBMPs

Commitments from w /s attendeesto implement BMPs and w ork

tow ards early compliance of theNESHAP Rule over the next 6

months

Compliance w ith the Final Rule2011

100% Early Compliance w ith AllBMPs Beyond NESHAP Final Rule

lbs.

/yr

Material Savings(lbs/yr)

*Statistics are based on 489 attendees at 22 workshops with an average of 1,490 gallons of paint used per week.

81%

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Some of our External PartnersSome of our External Partners3M3MAkzo NobelAkzo NobelDuPont Performance CoatingsDuPont Performance CoatingsMattosMattosBASFBASFAlabama Collision Repairers Industry Assoc.Alabama Collision Repairers Industry Assoc.InterInter--Industry Conference Auto Collision Repair (IIndustry Conference Auto Collision Repair (I--CAR)CAR)Coordinating Committee for Automotive Repair (CCAR)Coordinating Committee for Automotive Repair (CCAR)Iowa Waste Reduction CenterIowa Waste Reduction Center’’s STAR programs STAR programNational Automotive Technicians Educational Foundation (NATEF)National Automotive Technicians Educational Foundation (NATEF)National Automotive DealerNational Automotive Dealer’’s Assoc. (NADA)s Assoc. (NADA)Clean Air PartnersClean Air PartnersPPG Industries PPG Industries –– SeattleSeattlePacific Northwest Pollution Prevention Resource CenterPacific Northwest Pollution Prevention Resource CenterClean Air Minnesota Clean Air Minnesota Rochester Green Business NetworkRochester Green Business Network

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Next Steps Over 12 MonthsNext Steps Over 12 MonthsComplete and distribute CRC DVD & Complete and distribute CRC DVD & poster to shops nationwide poster to shops nationwide -- Jeff Jeff Gordon Gordon (NASCAR).(NASCAR).

Conduct more workshops and trainings Conduct more workshops and trainings with states, trade organizations, with states, trade organizations, vocational schools, community colleges, vocational schools, community colleges, shop owners and staff. (AZ, WA, MA)shop owners and staff. (AZ, WA, MA)

Work with S/L/T to calculate emission Work with S/L/T to calculate emission reductions using reductions using ““DfE Emission DfE Emission Reductions Calculator.Reductions Calculator.””

Air webcast July 28.Air webcast July 28.

http://www.epa.gov/air/toxicair/community/collision .htmlhttp://www.epa.gov/air/toxicair/community/collision .html

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Next Steps Over 12 Months Next Steps Over 12 Months contcont ’’d.d.

Enroll 25 new partners to carry message and conduct Enroll 25 new partners to carry message and conduct training workshops.training workshops.

Continue outreach and consensus building with Regions, Continue outreach and consensus building with Regions, States, and industry, as appropriate.States, and industry, as appropriate.

Create a fact sheet summarizing the requirementsCreate a fact sheet summarizing the requirements

Create training checklist for shopsCreate training checklist for shops

Explore SEP opportunitiesExplore SEP opportunities

Track resultsTrack results

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Tools & Actions NeededTools & Actions NeededCommon Evaluation Methods: Common Evaluation Methods: ICR, common ICR, common measures, data gathering and reporting techniques, etc.measures, data gathering and reporting techniques, etc.

Fact Sheets:Fact Sheets:�� How to examine MSDSs to determine if your coatings How to examine MSDSs to determine if your coatings

have targeted HAPhave targeted HAP

�� How to Petition for Exemption (if no HAP in coatings)How to Petition for Exemption (if no HAP in coatings)

Info from Major Paint Manufacturers:Info from Major Paint Manufacturers:�� their coatings containing HAPtheir coatings containing HAP

�� their alternative coatingstheir alternative coatings

Procedures for processing compliance Procedures for processing compliance notifications, exemption petitions, etc.notifications, exemption petitions, etc.

Develop desktop training course for shopsDevelop desktop training course for shops

Model training certificatesModel training certificates

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For more informationFor more informationhttp://www.epa.gov/dfe/pubs/projects/auto/index.htm -DfE Website

www.ccar-greenlink.org - OECA’s Coordinated Committee for Auto Repair – an Automotive Sector Compliance Assistance Center

http://www.epa.gov/ttn/atw/area/arearules.html - EPA’s Air Toxics Website for Area Source Standards

http://www.paintcenter.org/paintstripping.cfm -OECA’s Paints & Coatings Resource Center

http://www.epa.gov/erp - Environmental Results Program

Holly Wilson, Coordinator(919) 541-5624wilson.holly@epa.gov

National Collision Repair Campaign

http://www.epa.gov/air/toxicair/community/collision .html