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.

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