Updated 3/2011
Region 5 Autobody ERP – Survey Instrument for EPA Inspections
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– Spoken question Normal
Font – Site visit record/contacts and response options Italics
– Instruction for inspector (not spoken)
Facility Information |
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Facility Unique project ID |
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Facility Name |
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Facility Address |
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Name of Facility Contact Person |
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Telephone number of Facility Contact |
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Facility in EJ Area? [Y/N and why] |
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Survey Contact Info |
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Date of Visit |
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State/EPA |
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Name of Inspector |
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Phone |
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Baseline
Visit Script
If you wish to call ahead to confirm shop is actively painting:
Hi. My name is ___________________________ and I am from the USEPA Region 5. We are …confirming shops that are affected by a federal rule that is now effective. Are you the person I should talk to, or is there an owner or manager who could better answer my questions?
[Reintroduce if transferred to another person.] Thank you for speaking to me. First, I would like to confirm whether you are the type of shop that may be impacted by the rules.
Do the operations at your shop include spray painting vehicles or parts of vehicles with a spray gun?
___ Yes Ask next question.
___ No No need to schedule a visit. Track as a “DROP” on the sample list. Read paragraph A.
Do you use ONLY spray guns (including those spraying primer) with 3oz cup size or less?
___ Yes Could DROP, or visit to confirm. If dropped, track as a “DROP” on the sample list and explain why.
___ No Read the scheduling script in B:
A. Thank you, but it appears you are not affected by the air toxics rule that we are focusing on at this time. If you would like information on other environmental requirements, I can put you in contact with your state environmental assistance program.
B. As a shop that does spray painting, you may be affected by a number of regulations and in particular the new EPA rule. [Anything else to say since not prearranging for a time?]
On site - Introduction
Hi, my name is [interviewer name]. Is (name of contact) available? [If not available…] Is there another person I should speak to about environmental issues, usually related to use of paints, solvents and disposing of wastes, in your shop? (The ideal respondent is the person from the shop who keeps up with environmental requirements, is familiar with shop set up and operations, and perhaps receives information through training or attending workshops or manages the operations of the shop.)
Hi (name of contact). I am from the USEPA Region 5 office. We are conducting an inspection to check whether you comply with the new rule on autobody refinishing shops. As part of that inspection, I will be going through a survey related to environmental practices at autobody shops.
It will take us about 1 – 2 hrs to talk about these environmental issues and walk through the shop. While we do that, I will be asking a series of questions to complete our survey. Is there an office, or a place where we can sit to go over some of the basic questions first?
It works best to go through all interview questions up front in a quiet office area and then ask to be shown through the shop for observations. Sections A through G = in office. Section I = Walk through questions. If time seems limited (shop owner seems rushed) you may prioritize the questions in order of (1) Basic Info and Air regulatory [A-C & I1 – I8], (2) HW and WW Regs (D-E, I9-I15), (3) BMPs [F-G]. Section A is critical for categorizing the results of the project in the final analysis – DO NOT skip any of those questions unless prompted.
SECTION A: INTRODUCTION |
Instructions and Tips |
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A1. Which of the following categories best describes your role at this shop? (read categories): ___ Owner ___ Manager ___ Technician who applies spray coatings ___ Another role (specify)__________________________________
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A2. What type of services does your shop provide? (mark all that apply)
___ Auto mechanical repair ___ Salvage Yard ___ Autobody shop ___ Car dealership ___ Mobile Paint Service ___ Car wash ___ Other (explain):_________________________________________
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A3. Did your shop start coating vehicles or parts after September 17, 2007?
___Yes ___No
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Defined as a new affected source, and compliance was due Jan 8, 2008.
Mainly, brand new shops only ones affected by this definition. Adding a new booth doesn’t make whole shop “new”, but new booth must meet rule requirements when installed. |
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A4. How many employees and paint technicians (or anyone who may paint) do you have in your shop?
___ # employees (total at shop) ___ # paint technicians
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# employees means total for shop, including owner/manager and office staff MAKE SURE AND INCLUDE “BODY” GUYS SPRAYING PRIMERS ON THE FLOOR AS PAINT TECHS.
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A6. a. Referring to point of sales reports or information from your supplier, how much of each of the following materials have you used or purchased in the last few months? [12 months preferred]
This information may be used to calculate the environmental improvement achieved in the next few years by you and your fellow auto body shops as a group.
c. Were numbers provided in A6a obtained through accurate records? (Answer NO if estimates.) ___ Yes ___ No
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VERY important to get accurate numbers for purposes of making emissions estimates or reduction estimates at the end of the project
Most shops use computerized mixing systems. If, upon inspection, person knows how to use computer, this information can be obtained easily.
Option to just ask for print out from supplier/vendor of 6-12 months of purchase records and calculate at a later time.
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A7a. What are your total paint hours from the past few months? [12 months preferred; enter # months]
___________ hours per ______________# mo
b. Were numbers provided in A7a obtained through accurate records? (Answer NO if estimates.)
___ Yes ___ No
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[More easily tracked by shops than jobs.] Take six months if that’s all they can get, but 12 months will be a better average across the year. |
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A8. Do you do any paint work using a gun with 3ounce cup or less?
___ Yes ___ No
If yes, please describe the types of job and frequency: _________________ ________________________________________________________________
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Useful to capture for future training and providing information on when/where using 3 oz cup is acceptable – if any limitations exist.
That’s about ½ of a Styrofoam coffee cup |
SECTION C: EPA NESHAP
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Instructions and Tips |
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SPRAY BOOTH/PREP STATION QUESTIONS When we walk through the shop, it would be helpful if you could show me your spray booth and exhaust filter system. |
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C1. a. Does your shop have a spray booth?
___ Yes ___ No Skip to C2
b. How many spray booths do you have? ______
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Answer YES for anything they consider a “booth”—I1 will capture description. |
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C2. a. Do you have a prep station/area where coatings are applied on vehicle components?
___ Yes ___ No Skip to C3, or if NO to both C1 and C2 skip to C5
b. How many prep stations/areas do you have?
________
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Answer YES if any area besides booth used for painting. I3 will capture description. |
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Booth
or Prep Station Name/ID
%
coatings/jobs in booth
i.
Booth 1
ii.
Booth 2
iii.
Booth 3
iv.
Booth 4
v.
Prep 1
vi.
Prep 2
vii.
Prep 3
viii.
Prep 4
Other:
(describe)
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Note: these are estimates and will be used for informational purposes |
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C3. b. Did your shop first begin using each enclosure to apply coatings on or before Sept 17, 2007?
c. If any enclosure (paint booth, walled prep area) was installed after September 17, 2007, was the installation due to the new area source NESHAP regulations?
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Any new booth added to existing source, booth must be in compliance with NESHAP – ONLY booth is treated as new source, not whole facility.
b. Mark an X in the box that applies for each enclosure
c. Please note if companies that purchase and install equipment to comply with the area source NESHAP, this would not make an existing source a new source per 63.11171(c)(1). If they just happened to install or start new operations, then needed to comply by Jan 8, 2008 or upon start up.
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C4. a. Is each spray booth/prep station ventilated with an exhaust fan?
___ Yes ___ No
(i) ____ out of _____ booths/prep areas have an exhaust fan
b. Does your exhaust system have a filter system?
___ Yes ___ No Skip to C5
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CA note: Define that general building with multiple prep areas and wall fan may not be enough for compliance. A small room designed to meet same booth specifications could be OK depending on the exact circumstances.
Depending on what EPA says about determination of room as a booth, we may tweak this instruction.
Regardless of issue above, capture what exists without evaluating compliance in a and b. |
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Enter answers in table below.
c. Is the filter capture efficiency rating of your exhaust/filter system at least 98 percent?
d. Is the documentation related to the capture efficiency of your exhaust and filter system present and available for review?
e. When was the filter system first used at your shop?
f. Do ALL of the booths meet the exhaust/filter requirements in C4 at this time?
___ Yes ___ No
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Enter responses for c-e in Table at bottom of question.
If respondent is unsure of answers, note that this information would typically be found on the filter package or provided by the distributor. If not purchased directly, but through a subcontractor they may need to get in touch with them to make sure what they have.
Must show % efficiency.
Acceptable proof of eff% = reference to EPA rule or list basic test criteria, even if Method not written down:
We’ll consider documentation complete if it includes: test parameters OR references the 6H rule OR the ASHRAE method.
Watch out to be sure documents match brand of filters in use, if possible. |
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SPRAY GUN CLEANING When we walk through the shop, it would be helpful if you could show me the gun cleaning area and operations. |
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C5. a. Is all paint spray gun cleaning done with a fully enclosed spray gun washer or in a manner that avoids creating a mist of solvent?
___ Yes ___ No
b. If you answer YES to C5a, identify which method(s) are used: ___ Fully enclosed spray gun washer ___ Fully enclosed spray gun washer and occasionally disassemble and clean by hand ___ Flush with solvent (but don’t spray) ___ Clean disassembled gun by hand or through mechanical methods
c. If you answer YES to C5a, when was this spray gun cleaning approach first used at your shop?
____________ (specific date)
d. If you answered No to C5a, how do you clean your guns? ___ Spray coatings and/or solvent through the gun ___ Other (specify) _________________________________________
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Using air compressor to quick dry guns after cleaning not relevant to rule, but may increase VOCs… |
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PAINT STRIPPING When we walk through the shop, it would be helpful if you could show me the paint stripping operation. |
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C6. a. Do you use chemical products for paint stripping tasks?
___ Yes ___ No Skip to C9
b. Do any of the chemical products you use for paint stripping contain Methylene Chloride?
___ Yes ___ No, based on shop knowledge/review Skip to C9 ___ No, after reviewing materials (MSDS or can) at visit Skip to C9
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Some likely brands: StripRDry, Booth Floor Stripper (both made by CMA Philadelphia); Airplane stripper;
Might be used in restoring old cars to take off layers, otherwise unlikely to need solvents – just sanding.
Also known as di-chloromethane (DCM) or methylene dichloride – CAS # is 75-09-2
What if shop uses MeCl to clean tables? Does rule apply to cleaning? YES, since no exemptions are mentioned in the rule – only whether MeCl is used.
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C7. a. Do you have records related to your shop’s use of paint stripping products containing MeCl?
___ Yes ___ No
b. If there is documentation, how much product containing MeCl is used annually?
______ Gallons per year (as supported by documentation)
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Material usage or purchase records. How many gallons of product do you use? |
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C8. a. Does your shop have a minimization plan for use of MeCl?
___ Yes ___ No
b. If you use more than 2000 pounds (~150 gallons of MeCl) per year, do you have the minimization plan written and posted where paint stripping is conducted?
___ Yes ___ No
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If yes, Field Staff examines documentation.
Plan should include:
If below 150 gallons, considering options for how they are using it and if they can eliminate it. |
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PAINT FORMULATION/DOCUMENTATION
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C9. a. Does your shop have Material Safety Data Sheets (MSDS) and coating formulation data supplied by the manufacturer for ALL the solvents and coatings that you use?
___ Yes ___ No
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Electronic versions will be acceptable if they are easily available to employees. |
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C10. a. Do the coatings used by your shop contain any of the following hazardous air pollutants: chromium, lead, cadmium, nickel, or manganese (includes compounds of these metals)?
___ Yes ___ No ___ Don’t know
b. If you answered No or Don’t Know, have you asked your supplier whether you have the HAPs in the paint?
___ Yes ___ No
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Example of MSDS sheet that shows formulation data.
If they answer No or Don’t know, you could review a few MSDS: red/orange/yellow – lead, chromate blue/green – cadmium primer – chromates for corrosion resistance
Capture whether they’ve attempted to determine if HAPs are present by discussion with supplier, in place of field staff going through to determine. |
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EPA RULE FOLLOW UP
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C11. Before this visit, did you know you are affected by the new EPA rule that affects autobody shops and other small paint shops? This standard applies to businesses that coat parts and vehicles and use coatings that contain chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd) or use paint stripping materials that contain methylene chloride.
_____ Yes _____ No _____ Don’t Know
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This is not meant to make a determination, but to gauge their understanding at this point in time. Some may still be completely in the dark about the rule… |
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C12. a. Are you aware that autobody shops may be able to petition out of new requirements by changing the paints they use?
_____ Yes, I am aware _____ Yes, I have submitted the petition or received my exemption _____ No
_____ I would like more information on how to petition out.
b. To petition out you must certify that you do not spray apply any coatings containing chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd)) or compounds containing these metals. Given this information, do you intend to:
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You can you petition out of coatings requirements but still have to comply with MeCl
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C13. a. Have you submitted an initial notification form (due Jan 10, 2010) to USEPA and the state, where required?
___ Yes ___ No
b. Have you submitted a notification of compliance status form (due Jan 10, 2011) to USEPA and the state, where required?
___ Yes ___ No
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[Illinois, Wisconsin, Ohio required; Indiana is requesting copies]
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[I1 – I8]
SECTION B.i: EPA Rule TRAINING |
Instructions and Tips |
B2. a. Have ALL your paint technicians been trained in proper selection, use, maintenance of spray equipment, and the requirements of the rule, within the proper time frames?
___ Yes ___ No
(i) If no, How many? ___ out of ___ paint techs have been trained
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Add proper time frames tips to answer accurately. MAKE SURE AND INCLUDE “BODY” GUYS SPRAYING PRIMERS ON THE FLOOR.
Baseline timelines:
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b. Has the training addressed and/or included the following regarding spray equipment? (read responses; check all that apply)
(i) Hands on and Classroom: ___ Spray Gun Selection and Set Up (including measuring viscosity, selecting proper fluid nozzle or tip, achieving proper spray pattern, air pressure and volume, and fluid delivery rate) ___ Spray gun use – (spray technique for different types of coatings to improve transfer efficiency and minimize coating usage and overspray, including maintaining the correct spray gun distance and angle to the part, using proper banding and overlap, and reducing lead and lag spraying at the beginning and end of each stroke) ___ Maintenance (booth and filter - including filter selection and installation)
(ii) Classroom:
___ Environmental
requirements in federal NESHAP
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Hands on training resources vary: paint suppliers (Dupont, PPG), jobbers, associations, tech colleges, etc.
BRING A LIST of resources? [But no official approval of training.]
“Hands on” will mean some amount of actual practice with a gun, for selection, setup and use, but we will not judge the time spent on hands on.
OECA is making a determination of extent of “hands on” definition.
Owner or painter can watch DVD online and certify that they watched it/been trained for that piece. May want to have alternate video available. Michigan has video training online. |
c. Do you have records on technicians trained on the use of spray equipment?
___ Yes ___ No
c.(i) Capture who is trained, and whether equivalent work experience is being used, based on records:
___ All technicians have been properly trained. ___ Some (but not all) technicians have been properly trained or trained on all but environmental requirements ___ None of the technicians has been properly trained ___ Some technicians using equivalent work experience #: ___ of ___
d. Are there any specific reasons paint technicians have not been trained on ALL of the topics?
___ Yes ___ No - Skip to Section C.
e. If yes to B2d, what are some of the reasons technicians have not been trained?
___ no locations close by ___ costs ___ timing was bad (describe:_____________________) ___ unaware of training requirements ___ other: ___________________________________________ _______________________________________________________
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Field Staff may examine documentation (certificates, dates, places) to determine whether or not the spray technicians have been properly trained (meaning they have been trained in all areas listed in question B2b. above).
MAKE SURE AND INCLUDE “BODY” GUYS SPRAYING PRIMERS ON THE FLOOR.
30 year expert still has to provide proof of experience. “Owners and operators who can show by documentation or certification that a painter’s work experience and/or training has resulted in training equivalent to the training required in paragraph (f)(2) of this section are not required to provide the initial training required by that paragraph to these painters.”
Document how training has met each of the elements. |
END EPA REGULATIONS…MOVE ON TO STATE REGULATIONS.
SECTION H: COMPLIANCE ASSURANCE
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Instructions and Tips |
H4. a. Have you already received some information on this rule?
____ Yes ____ No Skip to H5 ____ Don’t know Skip to H5
If yes, then how and from whom?
b. How: ___ Mailing/written materials ___ Videos – training or “fact sheets” ___ E-mail messages/documents ___ Web training ___ Web site ___ Facebook/twitter/YouTube ___ On site visit ___ Training sessions/workshops ___ Other (specify:______________________________________________)
c. From whom: ___ Coating manufacturers or suppliers ___ Corporate environmental division ___ Educational institutions (vocational technical school, community college, specialized training center, etc.) ___ Environmental consultant ___ Other auto body shops ___ Local government (town, city, or county) ___ OSHA ___ Small Business Environmental Assistance Program ___ State environmental agencies ___ Suppliers – equipment/other ___ Trade association ___ U.S. EPA ___ Other (Specify)________________________________________ ___ Don’t know
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H5. a. Has your shop been inspected or visited by a government environmental or health and safety official?
____ Yes ____ No Skip to H6 ____ Don’t know Skip to H6
b. What type of government official inspected or visited your shop? (check all that apply)
___ EPA ___ State ___ Local government (environmental, health or fire department) ___ OSHA ___ Other (specify) ________________________________________ ___ Don’t know/Cannot recall
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H6. Is there any other information about your shop's operations that you'd like to share before we walk through the shop together?
Comment:
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Now, I would like to walk through the shop.
(The order of these questions may have to be rearranged based on the set up of the shop.)
SECTION I: WALK THROUGH
[I1 – I8 confirm compliance with NESHAP] |
Instructions and Tips |
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I1. a. May I see your spray booth(s)?
Check all that apply to each booth ID’d:
b. Is there evidence that at least some spray coating occurs outside of a spray booth? ___ Yes ___ No ___ Not sure (Field Staff describe:_______________________ _______________________________________________________)
c. Do the spray booths ALL meet the requirements in I1 at this time? ___ Yes ___ No
Comments:
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Check off booth description and mark whether exhaust present for each booth.
Rule requires booth to have four complete side walls or curtains and a complete roof if large enough to fit a whole vehicle. Only new operations (after 9/17/07, and not done to meet rule) must comply at baseline.
Nothing in rule that says exhaust has to be outdoors, but it does need to be outside the booth (space where painting is taking place, however defined). For now, a space (garage, shed, or other) can be considered a “booth” if doors are kept closed during painting and:
If parts are not removed, then full vehicle has to be painted in full booth (four walls/fully enclosed) OECA is making determination on whether small building is “booth” enclosure. |
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I2. May I see the filter on the spray booth exhaust? Is the filter in good condition? Look for rips or gaps in the filters; check to see if the filters appear to be clogged with paint residue or dust. Answer YES if booth has waterwash system in place of dry filters. May not be able to see filter within waterwash system to answer “condition” question. May be installed on enclosed, positive pressure downdraft booths.
d. Do the spray booth exhaust/filter systems ALL meet the requirements in I2 at this time? ___ Yes ___ No
Comments: |
Field Staff performs visual inspection of booth and filter and determines whether or not there is a particle filter on the exhaust.
Note to Field Staff: you may see a wall fan and small box with filter. Waterwash booths will not have the same type of filters to observe.
If the filters are not in good condition, Field Staff should ask the shop to revisit manufacturer’s recommendation.
Good = not Poor. Poor will be pretty bad, e.g. holes, rips, gaps, no air movement at all.
Power up booth to evaluate pressure.
Positive only allowed for “downdraft” designed booth – fully enclosed, hard walls, and exhaust in floor.
Anything else must have negative, even 4 curtains and roof with air inflow above and exhaust at floor level. Negative should be “felt” standing at openings.
Mobile operation/enclosure should be observed as well. Try to see it, even if not in operation.
When looking at filters, look for evidence of painters clearing guns into the filters. This would look different than any patterns left on the filters by protective grates. |
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I3. a. May I see your prep station(s)/area(s) where painting is done? If no prep station/area(s) present, skip to I5.
Check all that apply to each area ID’d:
Prep
Area ID (separate column for each area/station)
(i)
Prep 1
(ii)
Prep 2
(iii)
Prep 3
(iv)
Prep 4
Fully
enclosed - roof, 3 sides
Not
fully enclosed, but has:
no
roof, 3 sides
roof,
2 sides
no
roof, 2 sides
no
roof or sides (open space)
Prep
area has exhaust fan
Other:
b. Do the prep stations/areas ALL meet the requirements in I3 at this time? ___ Yes ___ No Comments:
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Field Staff performs visual inspection to confirm that prep station/area(s) is enclosed and ventilated.
Rule requires for motor vehicle and mobile equipment subassemblies, any coatings must be spray applied in a booth with a full roof and at least three walls or side curtains. Only new operations (after 9/17/07, and not done to meet rule) must comply at baseline.
Remember that painting part(s) of a car without disassembling from the whole car requires the whole car to be painted inside a 4-walled booth. “Spot” painting with an encircling ring which draws spray into the ring and then directs it through proper filtration is permitted by the rule. |
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I4. May I see the filter on the prep station(s)/area(s) exhaust? Is the filter in good condition? Look for rips or gaps in the filters; check to see if the filters appear to be clogged with paint residue or dust.
d. Do the prep station/area exhaust/filter systems ALL meet the requirements in I4 at this time?
___ Yes ___ No
Comments:
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Field Staff performs visual inspection of pipe and filter and determines whether or not there is a particle filter on the exhaust
Note to Field Staff: you may see a wall fan and small box with filter.
If the filters are not in good condition, Field Staff should ask the shop to revisit manufacturer’s recommendation. Doesn’t have to be exhausted outdoors, but it does need to be outside the booth (space where painting is taking place, however defined). Negative should be “felt” standing at openings – even at 3 wall booth, should feel breeze, papers flap toward back of booth, something. May be good to have hand out for facilities to what to do. |
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I5. Field Staff: Is lighting in the booths/paint areas clean of paint residue, besides what may be present from the most recent job?
___ Yes ___ No
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Based on own observations. Overspray may be indication of poor ventilation. |
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I6. a. May I see the spray guns you have in the shop? (Check all that apply, or if multiple of same gun, fill in separate lines; include guns not in regular use but available)
b. Do they have only compliant spray guns, based on the requirements for 6H, available for use at this time? ___ Yes ___ No Comments:
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Field Staffs: Look for “HVLP” stamped on the body of the spray gun. If no stamp is visible, air flow of 15-26 cubic feet per minute and PSI at orifice of less than 10 lbs, or at inlet of less than 40 lbs is likely to be an HVLP spray gun. You can also look at purchase records or manuals for indicators of whether a gun is HVLP or not. May want to take HVLP list along with us.
DO NOT EVALUATE HVLP GUN STATUS BASED ON USE OR TECHNIQUE. Not in the scope of the project.
Look at all guns, even if not used. RECOMMEND removing any non-approved guns.
Rule preamble does indicate CA approved guns are OK for HVLP-equivalent. We will use those, and anything else would need separate EPA approval to qualify.
Strong recommendation that any non-compliant guns should be removed from shop by next year compliance deadline.
Manufacturer/Model: only enter info if unsure of HVLP/equivalent status – if shop say it is but not on list or stamped. Just check box if HVLP is obvious.
Documentation: answer yes or no if document was presented for an HVLP equivalent gun. (List of guns provided separately.)
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I7. May I see the gun cleaning area, operations? Explain to me what you do here.
Field Staff observes cleaning procedures and categorizes cleaning technique:
___ Uses a fully enclosed spray gun washer ___ Uses a fully enclosed spray gun washer and occasionally disassembles and cleans by hand ___ Flush with solvent (but don’t spray) ___ Spray coatings and/or solvent through the gun ___ Clean disassembled gun by hand or through mechanical methods ___ Other (specify) _____________________________________
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Look for any evidence of painters clearing paint from guns into the ventilation hoods or other areas with or without filters. Not required by rule (possibly by OSHA?), but we can suggest that air flow from above and behind the cleaning station/technician to below and in front of the station/technician (drawing fumes away from the technician’s face). |
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I8. a. Does chemical paint stripping occur in the shop?
___ Yes ___ No Skip to I9
b. If yes, ask: May I see the products you use for paint stripping?
Examine products for ingredients with methylene chloride. Do they contain MeCl?
___ Yes, products with methylene chloride are used ___ No, products with methylene chloride are not used
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Look at MSDS sheets and/or cans. May want to note whether response matches office visit response.
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Thank you for your time. |
Close inspection as appropriate. |
File Type | application/msword |
File Title | Appendix C |
Author | kharmon |
Last Modified By | GFilbin |
File Modified | 2011-07-21 |
File Created | 2011-07-21 |