EPA Releases New Auto Refinishing RegulationPosted 10/8/2007
By Robert L. Redding, Jr.
After a lengthy research and rule development process, the U.S. Environmental Protection Agency (EPA) has released a proposed regulation for National Emissions Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources. As of this writing, the regulation has been made available by the EPA but has not been published in the "Federal Register." Once published, repairers have 30 days to comment on the proposal.
The proposed rule is a result of the Clean Air Act. In 1999, EPA published its Integrated Urban Air Toxics Strategy, which included both the list of urban hazardous air pollutants and the initial list of area source categories. In 2002, the EPA added auto body refinishing paint shops to the list. The Sierra Club sued the EPA, alleging a failure to complete standards for the area source categories listed pursuant to the Clean Air Act within the time frame specified by the statute. Sierra v. Johnson, No. 01-1537, (D.D.C.) The court issued an order requiring the EPA to promulgate standards under the Clean Air Act. This included the EPA completing standards for certain area source categories by Dec. 15, 2007.
EPA professional staff and consultants have attended NACE for the last few years, discussing this issue and evaluating the industry. EPA staffers have also visited many collision shops, around the country, representing various-size operations, and held focus group meetings to discuss industry issues. This proposed regulation is a result of many hours of research and industry input.
The EPA reports that the proposed air toxics standards for smaller-emitting sources are in three industry sectors that involve paint stripping and surface coating operations. The three area sources are:
Although it is anticipated that many shops have implemented the proposed EPA equipment and training items, some shops have not. The proposal allows existing shops two years to comply with the proposed standards. The EPA argues that two years is needed to allow adequate time for existing sources to ensure that all additional equipment, if needed, is purchased and installed and to provide sufficient time for painters employed by the 36,000 sources to receive the training that would be required by the proposed rule.
The EPA noted that emissions from auto body shops came primarily from the spray application of coatings. General available control technologies include:
Proper training is highlighted in the proposed regulation. The EPA concluded, based on the findings of the Spray Technique Analysis and Research (STAR) program, that even when spray operations are confined within a spray booth and appropriate spray technology is used, they are not as effective if the painter is not properly trained. The EPA notes that the training will include measures intended to increase the transfer efficiency and reduce overspray and coating usage. It pointed out that the STAR program demonstrates that spray operator training can increase transfer efficiency for those using high efficiency spray equipment from an average of about 50 percent to 60 percent, or more, representing a 20 percent reduction in coating usage compared to untrained operators. This 20 percent reduction in coating usage would translate into a 20 percent reduction in emissions of organic HAPs that are contained in those coatings. Emissions of heavy metals in the coatings would also be reduced.
The EPA also referenced those programs offered by the Inter-Industry Conference on Auto Collision Repair (I-CAR). The proposal stated that the essential elements of training and certification, for the purposes of achieving compliance with the requirements of the proposed standard, should at a minimum, train, examine and certify each spray operator in the proper techniques in:
What will this equipment requirement cost the industry? Of the 36,000 shops in play, the EPA estimated that there would be no net annual cost to surface coatings operations. Initial compliance costs would be offset by cost savings as a result of more efficient use of labor and materials.
As for training, the EPA estimates that the cost for training is $1,000 per painter, tuition and labor cost for 16 hours of training time. It is estimated that about 18,000 painters would be trained per year at an annual cost of $18 million per year.
The EPA also pointed out the additional benefit of a reduction in worker exposure to harmful chemicals in the workplace; a positive benefit on worker health.
Once published, auto body repairers have an opportunity to submit comments about the regulation. ASA will make the contact information available via the ASA legislative Web site, www.TakingTheHill.com.
ASA has been an advocate for equipment and training requirements for auto body repair facilities. States will have an opportunity to enforce these proposed regulations. If states opt out, regional offices of the EPA will serve in an enforcement capacity.
ASA leaders are reviewing the proposed regulation and will submit comments within the formal comment period. Auto body repairers can find updates on the proposed auto refinishing regulation on ASA's legislative Web site.
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