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Home My WebLink AboutDAQ-2024-0083261 DAQC-527-24 Site ID 10443 (B1) MEMORANDUM TO: FILE – MAACO AUTO PAINTING & BODYWORKS – Sandy Automobile Body Repair and Painting Facility THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Irene Tucker, Environmental Scientist DATE: May 30, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: February 28, 2024 SOURCE LOCATION: 8411 South State Sandy, UT 84070 SOURCE CONTACTS: Russell Wilson, 801-255-7799, maacosandyutah@gmail.com Greg Hill, Owner, 801-255-7799, 385-351-5844, maacosandyutah@gmail.com OPERATING STATUS: Operating normally at time of inspection. PROCESS DESCRIPTION: Maaco operates an auto body repair, priming, and painting business at this location. Some automobiles are cleaned for surface preparation in the pit area, using industrial strength detergents and water to remove dirt and oils. The residue is wiped off with solvents and the metal of some vehicles is rinsed with an acid solution to provide surface etching and paint adhesion on all or part of the vehicle. The automobile is then moved to a preparation booth where repair work is completed. After repairs, a primer coat is applied to the damaged area and all additional preparation work is completed (sanding, additional primers, minor touch ups). After the final preparation, the automobile is placed in a spray booth and paint is applied using High Volume Low Pressure (HVLP) paint spray guns. The paint spray booth is equipped with particulate arrestor filters on all air intake and exhaust ports. There is a solvent cleaning tank for the paint spray guns and also a covered waste can in the spray booth. After the final coatings are applied, the automobile is moved from the spray booth into a dust-controlled drying enclosure. Emissions from the drying booth are controlled by a double HEPA filter system. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN0104430001-10, dated March 25, 2010 / : 2 SOURCE EVALUATION: Name of Permittee: Maaco Auto Painting & Bodyworks Sandy Automobile Body Repair and Painting Facility 8411 South State Sandy, UT 84070 Permitted Location: 8411 South State Sandy, UT 84070 SIC Code: 7532 (Top, Body, & Upholstery Repair Shops & Paint Shops) Section I: GENERAL PROVISIONS I.1 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.2 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.3 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.4 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.5 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.6 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] 3 I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. According to Maaco Sandy, there has been no modification to the equipment or processes approved by this AO. Maaco Sandy did not exceed any limits set forth in this AO. Maaco Sandy maintains records for a minimum of two years, and maintains records of maintenance activities performed on approved equipment. There were no breakdowns that occurred resulting in an emissions event. According to the 2020 Emissions Inventory Report, the emissions indicated compliance with the PTEs of this AO. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Sandy Automobile Body Repair and Painting Facility II.A.2 One (1) Paint Spray Booth Devilbiss Model MDFH9426-34-12 II.A.3 One (1) Drying Enclosure Devilbiss Model MDOC9424 II.A.4 One (1) Double Filtered Paint Arrestor Status: In Compliance. During this inspection, there were no new or unapproved equipment identified onsite. II.B Requirements and Limitations II.B.1 The Sandy Automobile Body Repair and Painting Facility shall be subject to the following: II.B.1.a Visible emissions from any point or fugitive emission source associated with the installation shall not exceed 10% opacity. [R307-401-8] II.B.1.a.1 Opacity observation of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-305-3] Status: In Compliance. There were no visible emissions observed during this inspection. The opacity observation was conducted in accordance with 40 CFR 60, Appendix A, Method 9. See the attachment for additional information. II.B.1.b The paint spray booth shall be equipped with a set of paint arrestor particulate filters to control particulate emissions. All air exiting the booth shall pass through this control system before being vented into the atmosphere. [R307-401-8] In Compliance. The paint spray booth is equipped with a set of paint arrestor particulate filters to control particulate emissions and are replaced weekly. The filters in the drying enclosure are replaced monthly. All air exiting the spray booth passes through particulate filters before being vented into the atmosphere. See the Paint Arrestance Filter Test Report for filter efficiency in the attachment. 4 II.B.1.c A copy of this AO shall be maintained on-site and available to the operators. [R307-401-8] Status: In Compliance. A copy of this AO was maintained onsite and available to the operators. II.B.1.d Particulate emissions to the atmosphere from the paint spray booth shall not exceed the following rates and concentrations: A. PM10 - 1.12 lbs/hr and 0.01 grain/dscf (68ºF, 29.92 in Hg) B. TSP - 1.12 lbs/hr and 0.01 grain/dscf (68ºF, 29.92 in Hg). [R307-401-8] Status: Compliance undetermined. Stack Testing has never been requested by the Executive Secretary. II.B.1.d.1 Stack testing to show compliance with the emission limitations in the above condition shall be performed in accordance with 40 CFR 60, Appendix A; 40 CFR 51 Appendix M and as directed by the Executive Secretary. The following emission points shall be tested for the indicated air contaminants at the indicated schedule: Source Pollutant Paint Booth Exhaust Stack PM10 The following procedures and method(s) of testing shall be used for the indicated pollutant: [R307-401] II.B.1.d.2 Testing Schedule No initial testing is required at this time. However testing shall be conducted upon the direction of the Executive Secretary. [R307-401] II.B.1.d.3 Notification Notification of the test date shall be provided at least 45 days prior to the test. A pretest conference shall be held if directed by the Executive Secretary. It shall be held at least 30 days prior to the test between the owner/operator, the tester, and the Executive Secretary. The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1 and Occupational Safety and Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approvable access shall be provided to the test location. [R307-401] II.B.1.d.4 PM10 For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201 or 201a plus the back half condensibles using the method specified by the Executive Secretary. For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e as appropriate, plus back half condensibles using the method specified by the Executive Secretary. All particulate captured shall be considered PM10. [R307-401] 5 II.B.1.d.5 Sample Location Appendix A, Method 1. [R307-401] II.B.1.d.6 Volume Flow Rate Appendix A, Method 2. [R307-401] II.B.1.d.7 Calculations To determine mass emission rates (lbs/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Executive Secretary to give the results in the specified units of the emission limitation. [R307-401] II.B.1.d.8 Source Operation The production rate during all compliance testing shall normally be no less than 90% of the production rate at which the facility will be operated, or no less than 90% of the maximum production achieved in the previous 3 years. [R307-401] Status: Compliance undetermined. Stack Testing has never been requested by the Executive Secretary. II.B.2 VOC and HAP Limitations II.B.2.a The plant-wide emissions of VOCs from this source shall not exceed 15.48 tons per rolling 12- month period. [R307-401-8] Status: In Compliance. According to a rolling 12-month from January to December 2020, the plant-wide emissions of VOCs indicated 2,736.089 lbs or 1.37 tons. II.B.2.a.1 Compliance with this limitation shall be determined on a rolling monthly total. On the first day of each month a new 12-month total shall be calculated using the previous 12 months. The total VOC emissions shall be determined by maintaining a record of all paints, thinners, and solvents used. The record shall include the following data for each item used: A. Name of paint, thinner, or solvent B. Weight in pounds per gallon C. Percent VOC by weight D. Amount used on a daily basis in gallons E. The amount of VOC emitted monthly by each material used shall be determined by the following equation: VOC = [% VOC by Weight/100] x [Density (lb/gal)] x [Gal Consumed] x (1 ton/2,000 lb) 6 F. The VOC emissions for each individual item or surface coating used shall be calculated, and then the individual emission quantities shall be summed. [R307-401-8] Status: In Compliance. Maaco Sandy determines the plant-wide emissions of VOCs on a monthly rolling total by maintaining records of all paints, thinners, and solvents used. The records also include the name of the paint, thinner, or solvent, the weight in pounds per gallon, and the amount used on a daily basis in gallons. Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. 40 CFR Part 63 Subpart HHHHHH NESHAP: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources Status: In Compliance. There is no mobile operations or equipment at Maaco Sandy. There is one Spray Booth, one full time painter, and two back up painters. The coatings are stored in closed containers on shelves. All stripping is mechanical, by dual action sander or by hand. Stripping is performed on metal and plastic. Only High Volume Low Pressure (HVLP) spray guns are used at Maaco Sandy for increased efficiency. Maaco Sandy no longer uses MeCI for paint stripping. Maaco Sandy manually strips the paints. See the email attachment for additional information. Maaco Sandy ensures that all employees are properly trained and evaluated with the spray equipment, gun set-ups, spray techniques, booth filters, and cleaning techniques. See the 40 CFR Part 63 Subpart HHHHHH Compliance Checklist in the attachment. See the attachment for the documentation of the filter efficiency of any spray booth exhaust filter material. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: R307-304. Solvent Cleaning Status: Exemption; Maaco Sandy is claiming the R307-304-3(1) exemption. At Maaco Sandy, solvent cleaning is all done by hand using the solvent cleaner SX330. The solvent cleaner is sprayed directly onto a disposable cleaning cloth which is then applied to the vehicle. See the email attachment for additional information. According to Maaco Sandy, the spray guns are cleaned in a Hercules cleaning station using a general solvent cleaner, Omni MS251. The spent solvent is collected and continually recycled in 5-gallon increments. R307-325 Ozone Nonattainment and Maintenance Areas Status: In Compliance. Maaco Sandy is located in Salt Lake County, a maintenance area for ozone. Maaco Sandy applies Best Management Practices to limit VOCs, spills, and ensures that all containers are closed when not in use. Rule R307-335. Degreasing. Status: In Compliance. During this inspection the degreaser remained closed during the degreasing process. 7 R307-354: Automotive Refinishing Coatings Status: In Compliance. The coatings, primer/primer surfacer, primer sealer, and adhesion promoter used at Maaco Sandy were in closed containers stored on shelves when not in use. The coating is applied using High Volume Low Pressure (HVLP) paint spray guns for maximum efficiency. The VOC content of the coatings indicated compliance with the VOC limits in R307-354-5. See the Automotive Refinishing Coatings attachment for additional information. EMISSION INVENTORY The emissions listed below are an estimate of the total potential emissions from Maaco Auto Painting & Bodyworks- Sandy Automobile Body Repair and Painting Facility on the Approval Order (AO) DAQE-AN0104430001-10, dated March 25, 2010. The following information was supplied for supplemental purposes only. Estimated Criteria Pollutant Potential Emissions Particulate Matter - PM10 1.16 tons/yr Volatile Organic Compounds 15.48 tons/yr Estimated Hazardous Air Pollutant Potential Emissions EMISSION INVENTORY can be collected from SLEIS Maaco Auto Painting & Bodyworks – Sandy Automobile Body Repair and Painting Facility Emissions Inventory data for the 2020 activity year are recorded as follows: Status: In Compliance. According to the 2020 Emissions Inventory Report, the emissions indicated compliance with the PTEs of this AO. Pollutant Tons/yr Volatile Organic Compounds 0.783 8 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: Maaco Sandy is in compliance with the conditions of AO DAQE-AN0104430001-10 dated March 25, 2010, at the time of inspection. Maaco Sandy maintained good housekeeping practices. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect as usual. Required PPE includes safety glasses. RECOMMENDATION FOR NSR PERMITTING REVIEW: None at this time. ATTACHMENTS: Visible Emissions Observation Form, Paint Arrestance Filter Test Report, Filter Replacement Data, Automotive Refinish Coatings information, 40 CFR Part 63 Subpart HHHHHH Compliance Checklist, Email Communication