Autobody Refinishing Requirements

Transcription

1 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 Writer U.S. EPA, Office of Air & Radiation Office of Air Quality Planning and Standards Sector Policies and Programs Division Natural Resources and Commerce Group (919)

2 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.

3 BACKGROUND (cont d) 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 Refinishing Chromium, Cadmium, Lead, and Manganese

4 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.

5 RULE DEVELOPMENT PROCESS Industry research Emission reduction options Environmental & economic impacts Proposal Comment Promulgation of a final rule

6 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

7 Communication Forum Shop visits Public meetings Conferences Trade magazines Websites Electronic mail Phone calls

8 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 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.)

9 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

10 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.

11 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

12 Definition of Spray Application -handheld, non-refillable aerosol containers - thermal spray operations in which solid metallic or non-metallic material is heated to a molten or semimolten state and propelled to the work piece or substrate by compressed air or other gas, where a bond is produced upon impact

13 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

14 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.

15 FALSE 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!

16 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."

17 FALSE 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.

18 Additional Information Seek guidance from: State or Local staff as they may have additional requirements EPA Regional staff Where You Live link at

19 Additional Information Mr. Leonard Lazarus (202) Ms. Kim Teal (919)

20 Collision Repair Campaign Reducing emissions Protecting neighbors Protecting workers Saving money Holly Wilson, Team Leader Community Air Program OAQPS July

21 Collision Repair Campaign 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 and environmental concern. These shops are widespread in nature and tend to be clustered in lowincome, 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 accepted industry practices or current control technology.

22 What is the Collision Repair Campaign? A joint initiative of the EPA and communities to address health threats and to drastically reduce auto body emissions across the nation. In addition, participating shop owners and operators can achieve early and beyond compliance with the Paint Stripping & Miscellaneous Surface Coating Rule by implementing these voluntary measures. Great framework for coordination, information dissemination, tool development, collaboration, technical support, and stakeholder, and partnership building. 22

23 Voluntary Campaign Program to Complement Rule - Goals Work with 400+ shops to institute BMPs and/or work toward early and beyond compliance requirements. Create 10 regional partnerships with trade associations, state programs and technical providers. Initiate 10 community based projects in neighborhoods. Create a sustainable Campaign that can be transferred to Tribes, States, locals, and NGOs partners Achieve up to 90% emission reductions for participating shops. 23

24 Potential Benefits from the Campaign Environmental Benefits Decrease solvent use by more than 50% Decrease air pollution by 70% to 90% Economic Benefits to Operators 95% reduction in operating cost by using water- based cleaning system Saving up to $13000/year at a shop spraying 15 cars/week Reduced clean up cost if installing vacuum sanding system - investment of $9000 results in annual saving of $

25 Best Practices HVLP spray guns * Increase transfer efficiency to 65% Spray booths * Spray booth filters are >90% > efficient for particulates Vacuum or wet sanding Low VOC or water based paint Low VOC solvents Closed containers Computerized paint mixing systems * Rule requirement 25

26 Reduction in Auto Body Shop Emissions with Best Practices % Reduction in Emissions Conventional spray gun HVLP spray gun Booth + Conventional spray gun Booth + HVLP spray gun Best Practice Diisocyanates Lead, Chromium Organic Solvents 26

27 How Do We Promote Best Practices? EPA s s Design for the Environment (DfE( DfE) Train-the the-trainer course Best Practices Tool Kit Partnering with: Collision Repair Associations Trade Schools (secondary and post secondary) Pollution Prevention Programs Small Business Programs Air Programs 27

28 Regional Campaigns Each Region identified a Campaign strategy from a range of possibilities Partnered with states and small business programs Conducted training workshops locally Rolled out an expansive outreach campaign Worked with regional trade associations and Vo-tech schools Visit CRC website for project details 28

29 Some Campaign Results Partners and Participants: 10 EPA Regions 5 EPA Program Offices 25 State and Local agencies 20 Community Colleges & Vo-tech schools 10 Industry & Trade Associations 5 Community for a Renewed Environment (CARE) grantees 4 Paint Suppliers 29

30 Some Campaign Results cont d. Design for Environment training workshop results: Auto body Owners/workers/stakeholders: 498 Students: 167 Teachers: 54 Outreach packets distributed for students in other classes: 130 Self-evaluation evaluation sheets distributed & returned: 518 Shop Site Visits: 6 School Site Visits: 7 Over 81% of participants made changes that will reduce shop emissions and provide better health in the workplace and environment. 30

31 600, , ,368 VOC & PM Emission after Best Management Practices *Statistics are based on 489 attendees at 22 workshops with an average of 1,490 gallons of paint used per week. 400, , ,035 lb s./y r 300, ,323 Total VOC Emission after BMPs (lbs/yr) 200,000 81% 158,247 Total PM Emission after BMPs (lbs/yr) 100,000 - No Training and No Know ledge of BMPs Commitments from w /s attendees to implement BMPs and w ork tow ards early compliance of the NESHAP Rule over the next 6 months 4,609 3,873 2,696 Compliance w ith the Final Rule % Early Compliance w ith All BMPs Beyond NESHAP Final Rule

32 Material Savings and Cost Avoidance 2,500,000 2,000,000 $1,869, $2,308, $2,308, *Statistics are based on 489 attendees at 22 workshops with an average of 1,490 gallons of paint used per week. 1,500,000 1,000,000. Material Savings (lbs/yr) 500,000 81% 545,915 lbs. Cost Savings (Annually) 194,408 lbs 240,010 lbs. - 0 $0.00 No Training and No Know ledge of BMPs Commitments from w /s attendees to implement BMPs and w ork tow ards early compliance of the NESHAP Rule over the next 6 months Compliance w ith the Final Rule % Early Compliance w ith All BMPs Beyond NESHAP Final Rule

33 Material Usage Reduction (lbs/yr) lb s./y r 600, , , , ,915 *Statistics are based on 489 attendees at 22 workshops with an average of 1,490 gallons of paint used per week. 200, , ,010 Material Savings (lbs/yr) 100, No Training and No Know ledge of BMPs 81% Commitments from w /s attendees to implement BMPs and w ork tow ards early compliance of the NESHAP Rule over the next 6 months Compliance w ith the Final Rule % Early Compliance w ith All BMPs Beyond NESHAP Final Rule

34 Some of our External Partners 3M Akzo Nobel DuPont Performance Coatings Mattos BASF Alabama Collision Repairers Industry Assoc. Inter-Industry Industry Conference Auto Collision Repair (I-CAR) Coordinating Committee for Automotive Repair (CCAR) Iowa Waste Reduction Center s s STAR program National Automotive Technicians Educational Foundation (NATEF) National Automotive Dealer s s Assoc. (NADA) Clean Air Partners PPG Industries Seattle Pacific Northwest Pollution Prevention Resource Center Clean Air Minnesota Rochester Green Business Network 34

35 Next Steps Over 12 Months Complete and distribute CRC DVD & poster to shops nationwide - Jeff Gordon (NASCAR). Conduct more workshops and trainings with states, trade organizations, vocational schools, community colleges, shop owners and staff. (AZ, WA, MA) Work with S/L/T to calculate emission reductions using DfE Emission Reductions Calculator. Air webcast July

36 Next Steps Over 12 Months cont d. Enroll 25 new partners to carry message and conduct training workshops. Continue outreach and consensus building with Regions, States, and industry, as appropriate. Create a fact sheet summarizing the requirements Create training checklist for shops Explore SEP opportunities Track results 36

37 Tools & Actions Needed Common Evaluation Methods: ICR, common measures, data gathering and reporting techniques, etc. Fact Sheets: How to examine MSDSs to determine if your coatings have targeted HAP How to Petition for Exemption (if no HAP in coatings) Info from Major Paint Manufacturers: their coatings containing HAP their alternative coatings Procedures for processing compliance notifications, exemption petitions, etc. Develop desktop training course for shops Model training certificates 37

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40 For more information - DfE Website - OECA s Coordinated Committee for Auto Repair an Automotive Sector Compliance Assistance Center - EPA s Air Toxics Website for Area Source Standards - OECA s Paints & Coatings Resource Center - Environmental Results Program 40

41 National Collision Repair Campaign Holly Wilson, Coordinator (919)