MPCA Compliance as an Auto Body Refinishing Facility
Did you once have an air emissions permit? [Or should you have had a permit, but never got around to getting it?]
Five years ago or so, did you apply to be an exempt source, so you could get rid of your permit? If so, you’ve probably received an email from the MPCA reminding you that being exempt doesn’t mean you can spray paint willy-nilly. You don’t have to send anything to the agency, but you do need to make sure you still qualify for the exemption.
To meet the conditions for not having a permit, you must:
1) Use less than 2,000 gallons per year of paints, reducers, body fillers and other VOC containing products.
Ask your paint supplier or jobber for your VOC report each year. Check the total gallons used, listed at the end of the report. If you’re under 2,000 gallons, file the report.
If you’re over 2,000 gallons, you might still be eligible for the exemption. But you need to do some calculations to determine that. The calculations are a bit tricky to do, so we suggest contacting the MPCA Small Business Program or an experienced consultant for help with that.
2) Use only HVLP guns or equivalent.
3) Have exhaust filters in your spray booths and prep stations that are at least 98 percent efficient.
4) Do all painting and priming in a ventilated paint booth or prep station. The one exception: tiny touch-up jobs.
5) When your painters clean their guns, don’t let them spray the gun cleaner into a paint filter. They can take them apart to clean, use an enclosed gun washer, or flush gun cleaner through them. But they must not spray out the gun cleaning solvent.
6) Maintain your booths. You should have a manometer or pressure gauge to help you determine when the exhaust filters need to be changed. Keep a log of those filter changes.
7) Make sure all of your painters have received training in correct and efficient use of the spray equipment and the booth. This might be called NESHAPs 6H training (or just 6H), because it was initially required by the EPA NESHAPs 6H standard.
Painters (and those priming) need to have the training within 180 days of hire, and then get a refresher every five years. The University of Northern Iowa offers the training online (iwrc.uni.edu/online-painter-training), as does 3M. Your paint supplier probably offers it. I-CAR might also offer it. Many painters received the training a dozen years ago, when the 6H standard came out. You just need to make sure they keep up with it.
When you applied for exemption, you attested that you were doing these things. This is your five-year reminder, sent to all shops that are exempt. You don’t need to submit paperwork to the MPCA. But you do want to keep records of your VOC reports, training, and booth maintenance, so you can show that you continue to be in compliance.
For more information, contact Carol Keyes at 651-481-9787 or carkey@chess-safety.com
Want more? Check out the June 2024 issue of AASP-MN News!