1.7         Paint Booths and Abrasive Blasting Operations Permitting Process

Coating and painting operations, including the use of paint booths, require the consultant to apply for an Air Quality Permit to Construct prior to installation of a paint booth.

Paint booths and their associated spray coating activities are regulated under 40 CFR Part 63 (National Emissions Standards for Hazardous Air Pollutants [NESHAPs]), Subpart HHHHHH – Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources. Categories and entities potentially affected by NESHAP Subpart HHHHHH are paint stripping operations using methylene chloride (MeCl)-containing paint strippers, motor vehicle and mobile equipment surface coating operations, and miscellaneous surface coating operations located at area sources. An area source is defined in the Clean Air Act (CAA) section 112(a) as any stationary source of Hazardous Air Pollutants (HAPs) that is not a major source. A major source is defined as any stationary source or group of stationary sources located within a contiguous area and under common control that emits, or has the potential to emit, considering controls, in the aggregate, 10 tons per year (tpy) or more of any single HAP or 25 tpy or more of any combination of HAPs. For the purposes of this rule, paint stripping operations are those that perform paint stripping using MeCl for the removal of dried paint (including, but not limited to, paint, enamel, varnish, shellac, and lacquer) from wood, metal, plastic, and other substrates at area sources as either: (1) an independent activity where paint stripping is the principal activity at the source, or (2) an activity incidental to the principal activity (e.g., surface coating, inspection, maintenance, etc.) at the source.

For co-located operations, the EPA considers paint stripping activities that use one ton or less to be incidental to the principal activity and those using more than one ton to be performing paint stripping as a principal activity. Motor vehicle and mobile equipment surface coating operations involve the spray application of coatings at area sources to automobiles, light trucks, heavy duty trucks, buses, construction equipment, self-propelled vehicles, and equipment that may be drawn and/or driven on a roadway. Miscellaneous surface coating operations are those that involve the spray application of coatings that contain compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd), herein after referred to as target HAPs, to miscellaneous parts and/or products made of metal or plastic, or combinations of metal and plastic.

1.7.1            Permitting Requirements for Vehicle Surface Coating Operations

1.       MDE/ARMA requires an Air Quality General Permit to Construct for Vehicle Refinishing. This general permit applies to auto body repair facilities that are at a fixed stationary location; use no more than 400 gallons of vehicle refinishing materials per year; have two or less paint spray booths; and do not use materials containing lead, formaldehyde, or pot life extenders. The Air Quality General Permit to Construct for Vehicle Refinishing can be found on the MDE Air Quality General Permits to Construct Application Forms web page.

In order to obtain an Air Quality General Permit to Construct for Vehicle Refinishing, the Consultant can either request a General Permit to Construct package from MDE/ARMA by calling (410) 537-3230, or the Consultant may simply download the package from the MDE website listed above. The package will include the Air Quality General Permit for Vehicle Refinishing, an Initial Notification Form, a Compliance Notification Form, and information regarding the required permit fee. The General Permit includes any construction and/or operating requirements, air emissions limitations, and other regulatory obligations. The required permitting fee is $500 for the whole facility and must be submitted to MDE/ARMA with the application form. The Initial Notification Form must be sent to the EPA Region III and MDE/ARMA 180 days after initial start-up for new shops and by January 11, 2010 for existing shops. The Compliance Notification Form must be sent to the EPA Region III and MDE/ARMA 180 days after initial startup for new shops and by March 11, 2011 for existing shops. Three (3) copies of the permit application package, each signed and dated individually, must be submitted to MDE/ARMA.

2.       All Permit to Construct Applications, including the Air Quality General Permit to Construct for Vehicle Refinishing, require proof of Worker’s Compensation for the Owner (not the Contractor) under Environmental article 1-202. The Consultant can obtain a copy of this proof from the MDOT MAA Employee Safety & Loss Prevention (410-859-7509).

3.       In addition to complying with all applicable Federal NESHAP Subpart HHHHHH requirements, the VOC content of the materials used shall not exceed the following limitations:

*VOC content limitation is for coatings as applied.

1.7.2            Design Guidelines for Vehicle Surface Coating Operations

1.       Per §63.11173(e), the consultant must ensure that motor vehicle and mobile equipment surface coating operations and miscellaneous surface coating operations meet the following requirements:

a.       All spray-applied coatings must be applied in a spray booth, preparation station, or mobile enclosure that meets the following requirements:

i.         All spray booths, preparation stations, and mobile enclosures must be fitted with a type of filter technology that is demonstrated to achieve at least 98-percent capture of paint overspray. The procedure used to demonstrate filter efficiency must be consistent with the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) Method 52.1, “Gravimetric and Dust-Spot Procedures for Testing Air-Cleaning Devices Used in General Ventilation for Removing Particulate Matter, June 4, 1992” (incorporated by reference, see 63.14 of subpart A of this part). The test coating for measuring filter efficiency shall be a high solids bake enamel delivered at a rate of at least 135 grams per minute from a conventional (non-HVLP) air-atomized spray gun operating at 40 pounds per square inch (psi) air pressure; the air flow rate across the filter shall be 150 feet per minute. Owners and operators may use published filter efficiency data provided by filter vendors to demonstrate compliance with this requirement and are not required to perform this measurement. Waterwash spray booths that are operated and maintained according to the manufacturer's specifications are not required to meet these requirements.

ii.       Spray booths and preparation stations used to refinish complete motor vehicles or mobile equipment must be fully enclosed with a full roof, and four complete walls or complete side curtains, and must be ventilated at negative pressure so that air is drawn into any openings in the booth walls or preparation station curtains. However, if a spray booth is fully enclosed and has seals on all doors and other openings and has an automatic pressure balancing system, it may be operated at up to, but not more than, 0.05 inches water gauge positive pressure.

iii.     Spray booths and preparation stations that are used to coat miscellaneous parts and products or vehicle subassemblies must have a full roof, at least three complete walls or complete side curtains, and must be ventilated so that air is drawn into the booth. The walls and roof of a booth may have openings, if needed, to allow for conveyors and parts to pass through the booth during the coating process.

iv.     Mobile ventilated enclosures that are used to perform spot repairs must enclose and, if necessary, seal against the surface around the area being coated such that paint overspray is retained within the enclosure and directed to a filter to capture paint overspray.

b.       The consultant must ensure that all spray-applied coatings must be applied with a high volume, low pressure (HVLP) spray gun, electrostatic application, airless spray gun, air-assisted airless spray gun, or an equivalent technology that is demonstrated by the spray gun manufacturer to achieve transfer efficiency comparable to one of the spray gun technologies listed above for a comparable operation, and for which written approval has been obtained from the Administrator. The procedure used to demonstrate that spray gun transfer efficiency is equivalent to that of an HVLP spray gun must be equivalent to the California South Coast Air Quality Management District's “Spray Equipment Transfer Efficiency Test Procedure for Equipment User, May 24, 1989” and “Guidelines for Demonstrating Equivalency with District Approved Transfer Efficient Spray Guns, September 26, 2002” (incorporated by reference, see 63.14 of subpart A of this part).

c.       There are additional miscellaneous metal coating regulations pertaining to paint booths for coating items other than motor vehicles that could impose other VOC control requirements. Please refer to COMAR 26.11.19.13 for more information depending on the product being coated.