Collision Repair Campaign - Requirements
Collision Repair Campaign
Compliance Assistance Materials
All personnel, including contractors, who spray apply coatings must be certified as completing training in:
Employees at new sources have 180 days after hire to complete training
Employees at existing sources must complete by the compliance date (January 10, 2011)
Refresher training, at least once every five years following initial training date is required
Spray Booth Requirements
Spray-applied coatings must be applied in spray booth, preparation stations, or mobile enclosure meeting the following requirements:
- Spray gun equipment selection, set up, and operation
- Best spray technique for different types of coatings to improve transfer efficiency and minimize overspray
- Routine booth and filter maintenance, filter selection and installation
- Compliance with requirements of the NESHAP
HLVP Spray Gun Requirements
Spray-applied coatings must be applied with one of the following gun technologies:
- Fitted with filter system demonstrated to have 90% collection efficiency, using vendor provided test data, or using waterwash spray booths operated to manufacture’s specs
- Booths and prep stations requirements:
- For complete motor vehicles or mobile equipment must have full roof and four walls or side curtains, and operate at negative pressure; OR use downdraft booth operated at up to, but no more than, 0.05 inches w.g. positive pressure
- Booths or prep stations for miscellaneous coating or vehicle subassemblies: have full roof, at least 3 complete walls or side curtains, and ventilated so air is drawn into the booth. Roof walls may have openings for conveyors
- Mobile enclosures for spot repairs must enclose and seal against the surface being coated. Must be retained in enclosure and directed to the filter.
Spray Gun Cleaning Requirements
Spray gun cleaning operation should prevent atomized mist or avoid spraying cleaning solvent and paint residue outside container used to collect waste solvent
Acceptable options include:
- High Volume, low pressure (HLVP)
- Air-assisted airless
- With written approval from EPA, other spray technology demonstrated to achieve equivalent transfer efficiency
Records and Reporting
- Hand cleaning of disassembled gun
- Flush gun with solvent, without spraying
- Use fully enclosed gun cleaner
- Combination of non-atomizing methods
Forms available on Area Source Website (under implementation tools)
- New sources – due 180 days after start up
- Existing sources –due by January 9, 2010
Annual Notification of Changes Report
- Existing sources not able to demonstrate compliance in the initial notification must submit this notification by (60 days after January 9, 2011 [March 11, 2011])
- Include same basic information as initial notification
- Indicate date of compliance with all relevant requirements
- Paint stripping sources using more than one ton of MeCl in a year must certify they have written and are implementing their minimization plan
- Sources must submit report annually prior to March 1st if any previously reported information changed during the previous year
- Changes include paint stripping sources that increase usage of MeCl to more than one ton in a calendar year
- Submit changes report by March 1st following year usage went over one ton of MeCl
- Develop and implement a written minimization plan by December 31st
- Submit a notification of compliance status by March 1st the following year
Recordkeeping (keep these records on file)
- Initial Notification (informs EPA that the facility is subject to the standards and when the source will be in compliance).
- Deadline for New Sources: July 7, 2008 or 180 days after startup
- Deadline for Existing Sources: January 11, 2011
- Notification of Compliance (certifies that the source is in compliance with the applicable requirements).
- Deadline for New Sources: As part of the Initial Notification
- Existing Sources: March 11, 2011
- Annual notification of changes report—required each calendar year any reportable changes occur.
Records to be maintained in a form suitable and readily available for expeditious review.
More detailed information
Motor Vehicle/Mobile Equipment/Miscellaneous Surface Coating Operations
- Records to include copies of notifications submitted to EPA.
- Painter training certifications.
- Spray booth filter efficiency documentation.
- Spray gun transfer efficiency.
- MeCl content information such as MSDS.
- Annual usage of MeCl for paint stripping, and written MeCl minimization plan if annual usage > 1 ton per year.
- Deviation and corrective action documentation.
Paint Stripping Operations—implement management practices that minimize emissions of MeCl.
- Train/certify all painters on spray gun equipment selection, spray techniques, maintenance, and environmental compliance (consult 73 FR 1738, pg. 1762, section 63.11173(f)(2)(i)-(iv)).
- Install/operate filter technology on all spray booths/stations/enclosures to achieve at least 98% capture efficiency.
- Spray booths/stations used to refinish complete motor vehicles or mobile equipment must be fully enclosed and ventilated at negative pressure or up to 0.05 inches water gauge positive pressure for booths that have seals on all doors and other openings and an automatic pressure balancing system.
- Spray booths/stations used to coat miscellaneous parts or products or vehicle subassemblies must have a full roof, at least three complete walls or side curtains, and ventilated so that air is drawn into the booth.
- Spray-applied coatings must be applied with a high volume, low pressure (HVLP) spray gun, electrostatic application, airless or air-assisted airless spray gun, or an equivalent technology.
- Paint spray gun cleaning must be done so that an atomized mist or spray of the cleaning solvent is not created outside a container that collects used gun cleaning solvent.
- Train and certify all personnel who spray apply surface coatings no later than 180 days after hiring or by July 7, 2008 (new sources) or by January 10, 2011 (existing sources).
For each paint stripping operation with > 1 ton MeCl annual usage, develop and implement a written MeCl minimization plan. No implementation plan is needed if usage is < 1 ton MeCl; however, sources must still utilize work practices to minimize emissions of MeCl. Consult the MSDS sheet to identify the amount of MeCl contained in the paint stripper, but note that annual usage should not exceed 181 gallons of MeCl.
Maintain records of annual usage of paint strippers containing MeCl.
Need help getting started? Contact the Collision Repair Campaign (R10AutoBodyCampaign@epa.gov)
- Evaluate the need for paint stripping (e.g., is it possible to re-coat without stripping?).
- Evaluate each application to identify potential alternative stripping methods.
- Reduce exposure of strippers to air.
- Optimize application conditions.
- Practice proper storage and disposal.