be prepared for epa’s new emission standards

BE PREPARED FOR EPA’S NEW EMISSION STANDARDS

www.kpaonline.com

(866) 356-1735

BE PREPARED FOR EPA’S NEW EMISSION STANDARDS

www.kpaonline.com

(866) 356-1735

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QuestionsQuestions

• If you have questions during the presentation, please submit them using the “Questions” feature

• Questions will be answered at the end of the webinar

Presented byPresented by

Chuck ElliottEHS Engineercelliott@kpaonline.com404-626-6310

Guidelines for The New Body Shop Rules

EPA’s New Emission Standards for Collision Centers

October 15, 2009

EPA’s New Emission Standards for Collision Centers

40 CFR Part 63, Subpart HHHHHH

“The 6H Rules”

Paint Stripping and Miscellaneous Surface Coating Operations at Area

Sources

Why the Need for this Rule?Why the Need for this Rule?

CLEAN AIR ACT

EPA’s New 6H

Emission Regulations

Misc. Surface Coating

Paint Stripping

Operations

Auto Body Refinishing

What are the New Requirements?

Notification

Painter Training

Spray Gun Selection

Spray Gun Cleaning

Spray Booths

Re-Notification

Recordkeeping

Notification

January 11, 2010

3 Months

Form is Attached

Initial Notification FormInitial Notification Form

Initial Notification FormInitial Notification Form

Initial Notification FormInitial Notification Form

http://www.smallbiz-enviroweb.org

Initial Notification FormInitial Notification Form

Return Receipt Required

January 11, 2010

Deadline for Initial Notification

January 10, 2011

Must Meet Major Requirements

March 11, 2011

Deadline to Re-Notify

Painter Training Requirements

All Painters must complete by January 10, 2011

Renewed Every 5 Years

Available from Multiple Sources

Painter Training Must Include:

Spray gun equipment selection, set up, and operation.

Spray techniques for different types of coatings to improve transfer efficiency and minimize coating

usage and overspray.

Routine spray booth and filter maintenance.

Environmental Compliance Requirements of these

New 6H Regulations.

Spray Gun Selection

HVLP or Equivalent Technology

Electrostatic Application, Airless Spray Gun or an Air-Assisted Airless Spray Gun

Written Approval Required from the EPA for Non-HVLP Sprayers

Spray Gun Cleaning

If you are spraying solvent through your gun to clean it, you must collect the spray.The EPA suggests using a fully enclosed spray gun washer, but they do not require it.

KPA

Spray Booth Requirements

Is the EPA requiring all painters to have a booth now?

OSHA Regulations Already Requires a Paint Booth

Can be a Prep Station or Mobile Enclosure

29 CFR 1910.107

Spray Booth Requirements

Ventilation is Required

Filter Efficiency of 98%

Spray Booth for Refinishing Whole Vehicles

Full Roof

4 Complete Walls or Curtains

Ventilated at Negative Pressure

Spray Booth for Refinishing Parts

Full Roof

3 Complete Walls or Curtains

Ventilation that Draws Air In

Mobile Spray Booths

For Spot RepairsEnclosed Enough to Retain All Paint OversprayOverspray Must Be Directed to the Ventilation System Filters

Re-Notification

March 11, 2011 Deadline

Check off that you are now in compliance.

Must sign the form this time.

Annual Notification of Changes Report

Only required if your information or status changes.

March 1 Deadline

Recordkeeping

Most Important Step

Must be able to provide required documents.

What records must you keep?

Copies of all signed notifications you send to the EPA.

All signed receipts from the postal service that proves you sent your notifications.

Certification that each painter has completed the training.

Documentation of your filter efficiency.

Documentation for non-HVLP spray guns.

Records of any deviation from the requirements.

Recordkeeping

Must Retain Records for 5 Years

Designate a specific location to maintain these records.

Good News – We are almost done!

Bad News – We still need to cover 2 complicated issues.

New Facility?

If you installed new equipment after September 17, 2007.

Equipment includes: Mixing Room, Mixing Room Equipment, Prep Station, Spray Booth, Spray Guns and Associated Equipment, Spray Gun Cleaning Equipment, Solvent Recyclers

So you are a New Facility – What’s the big Deal?

Your Compliance Date was the Day You Opened!

New Facilities Should Already have done:

Notification

Painter Training

Spray Gun Selection

Spray Gun Cleaning

Spray Booths

Re-Notification

Recordkeeping

Exemption?

Must ensure that all of your sprayed materials do not contain:

Cadmium - CdChromium - Cr

Lead - PbNickel - Ni

Manganese - Mn

Exemption?

Exemption?

Exemption?

QUESTIONS?

Free Consulting Time!

Contact InformationContact Information

43– KPA CONFIDENTIAL –

The recorded webinar and presentation slides will be emailed to you today including your local representative’s contact information.

www.kpaonline.com

info@kpaonline.com

866-356-1735

Chuck ElliottEHS Engineer

celliott@kpaonline.com(404) 626-6310

Cameron CurtisAccount Executive

ccurtis@kpaonline.com(303) 228-2389

WWW.KPAONLINE.COM