Mobile Automotive Refinishing Operations Are You in Violation of the 6H National Emission Standard for Hazardous Air Pollutants (NESHAP)?
The United States Environmental Protection Agency promulgated rules regulating existing and new auto body repair facilities under 40 CFR Part 63 National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations.
The final rule applies to all motor vehicle and mobile equipment surface coating operations.
However, mobile automotive refinishers that perform small touch up or spot repairs at customer locations are subject to the Rule only if they use a spray gun with a cup size greater than 3.0 fluid ounces.
The Small Business Environmental Assistance Program is reminding small businesses that perform mobile automotive refinishing that use of a cup larger than 3.0 fluid ounces immediately makes them subject to all the requirements of the 6H NESHAP and they can be cited for non-compliance with the rule.
Mobile automotive refinishers that need to use a cup with a capacity greater than 3.0 fluid ounces must comply with all of the 6H NESHAP requirements which include notification,reporting, recordkeeping, equipment and enclosure requirements, ongoing training requirements and more.
In the alternative, mobile refinishers may petition the USEPA Administrator for an exemption from the 6H NESHAP requirements by demonstrating, to the satisfaction of the Administrator, that they spray apply no coatings that contain the targeted Hazardous Air Pollutants (HAPs): chromium, lead, manganese, nickel and cadmium. The mobile refinisher should work with their coating supplier to review the MSDS sheets for all of the coatings that they spray apply and eliminate any coatings containing compounds made up of these targeted
pollutants. Most coatings companies now offer coating lines that do not contain the regulated HAPs.
Petition for exemption forms, sample petition forms, and information regarding coatings not containing the regulated HAP's, and other compliance information regarding the 6H NESHAP can be found on the SBEAP website at: www.ildceo.net/enviro.
Questions regarding the requirements can also be directed to the Small Business Environmental Assistance Helpline at: 800-252-3998 or emailed to: email@example.com.
Illinois Small Business Environmental Assistance Program Staff Attend National Training with USEPA
The National Steering Committee of the network of state Small Business Ombudsmen (SBO) and Small Business Environmental Assistance Programs (SBEAPs) and the United States Environmental Protection Agency's Small Business Ombudsman's Office, hosted the
National Small Business Environmental Assistance Program
s' Annual Training May 1-3rd in the Washington, D.C. area. Each year, the state Small Business Environmental Assistance Programs and Ombudsmen gather to exchange ideas, share best practices, explore opportunities to collaborate and leverage resources while learning the latest on environmental policy and regulatory compliance issues affecting small businesses.
The state SBO/SBEAPs were mandated by Section 507 of the 1990 Clean Air Act Amendments to provide free and confidential environmental compliance assistance to small businesses. For more than 25 years the programs have provided extensive, hands-on assistance in helping businesses comply with environmental regulations
This year's training, featured an open discussion with Bill Wehrum, USEPA Assistant Administrator, Office of Air and Radiation; regarding small businesses, their compliance burdens and their needs for assistance in understanding and complying with complex environmental regulations. Other sessions included presentations and discussions with Nena Shaw, USEPA Office of Policy regarding the agency's strategic plan and Smart Sector Programs, how they relate to small businesses and possible opportunities for compliance assistance efforts at the state level. The Environmental Council of States, the Small Business Administration's Office of Advocacy, USEPA's Office of Chemical Safety, and USEPA Ombudsman's Office also presented to the group.
||Bill Wehrum, USEPA Assistant Administrator.
Industry partnerships are critical to the state SBO/SBEAPs' success and the conference included an open discussion with national small business trade groups on environmental issues important to their members and ways that the programs could potentially collaborate to assist them in meeting their compliance needs.
Roundtable participants included: David Wagger with the Institute of Scrap Recycling Industries, Inc.(ISRI), Melinda Tomaino with The Associated General Contractors of America (AGC), Joe Ricci with TRSA, Association of Linen, Uniform & Facility Services, Dale Drysdale with National Stone, Sand & Gravel Association (NSSGA), and Marci Kinter with Specialty Graphic Imagining Association (SGIA). Tee Rowe with America's SBDC also joined the group for networking after the panel. The National Steering Committee plans to build on the success of this session and include industry roundtables in future conferences.
Illinois EPA to Host Additional Public Outreach Sessions on Draft Plan to Fund $108 Million in Alternate Fuel, Electric and Related Infrastructure Projects
The Illinois EPA (IEPA) will host three public outreach sessions on its Draft Plan to use the state's $108 million allocation from the Volkswagen Settlement. A public input period was initially held from February 28 to April 20, 2018. In response to the 1,600 comments and nearly 300 survey responses received, the Agency is opting to host three additional outreach sessions to communicate with the public.
The Draft Beneficiary Mitigation Plan, first unveiled in February, details Illinois' proposal to remove old, dirty diesel engines from service and replace them with new electric, alternate fuel, and cleaner diesel engines. Illinois EPA developed the draft Beneficiary Mitigation Plan (BMP) with a goal of achieving the maximum Nitrogen Oxide (NOx) emission reductions possible while recognizing the diversity of potential projects that may be available.
The draft BMP seeks to maximize NOx reductions by focusing on:
- reducing NOx emissions in areas where the affected Volkswagen vehicles are registered, while considering areas that bear a disproportionate share of the air pollution burden, including environmental justice areas; and
- maximizing emission reductions and funding.
"The public input period resulted in extensive comments from individuals, companies, advocacy groups, and potential applicants," said Illinois EPA Director Alec Messina. "Illinois' BMP is a living document that will continue to evolve as needed to benefit air quality and the health of Illinois residents."
Public Outreach Sessions will be held in the evening from 6:00 - 8:00 p.m. at the following locations:
- Wednesday, May 23, 2018, Illinois EPA Headquarters (North Entrance) Sangamo Conference Room, 1000 East Converse, Springfield
- Thursday, May 24, 2018, St. Paul Baptist Church,1500 Bond Avenue, East. St. Louis
- Wednesday, May 30, 2018, James R. Thompson Center Auditorium, 100 West Randolph, Chicago
The Volkswagen Settlement
consists of three programs: a vehicle recall and repair program ($10 billion); a zero emission vehicle investment commitment ($2 billion); and an environmental mitigation trust fund ($2.84 billion allocated to the states). The draft BMP, required by the Volkswagen Settlement, is Illinois' plan to allocate the funds.
"The substantial funding from the Volkswagen Settlement provides Illinois with the opportunity to achieve significant NOx emission reductions from mobile sources in areas that need it the most and to realize air quality benefits for its citizens," said Director Messina. "We look forward to public review of the draft Beneficiary Mitigation Plan and to the administration of Volkswagen funds in Illinois."
Following public input, the Agency intends to submit a final Beneficiary Mitigation Plan to the trustee of the Environmental Mitigation Trust Fund as required by the Settlement.
Illinois EPA Accepting Applications for Medication Takeback Program
Program Targets Opioids and Other Drugs to Protect Individuals and the Environment
The Illinois Environmental Protection Agency (EPA) is accepting applications for the Fiscal Year 2019 Medication Takeback Program. The program will provide funding to communities or organizations for the safe disposal of opioids and other harmful medications collected from residents. "Illinois EPA's proposed FY19 budget for the Medication Takeback Program is among the highest of any state environmental Agency in the nation, allowing us to assist communities in addressing opioid abuse while also preventing contamination of our water resources," said Illinois EPA Director Alec Messina. "The best way to properly dispose of medicine is through a collection program and we encourage communities to apply to be one of our partners." This improper disposal of unused or unwanted medications creates the potential for harmful chemicals to end up in lakes, rivers, streams and groundwater. For this reason, the EPA is reminding Illinoisans that the medications should always be used as directed and stored properly to avoid accidental poisoning or other complications. They should NOT be flushed down the toilet or poured into a sink.
Applications must be submitted by June 1, 2018 for collections beginning on July 1, 2018.
Note: Funding for the Medication Takeback Program is subject to final appropriation authorization from the Illinois General Assembly.
Forget Something? Businesses with Air Permits: 2017 Annual Emissions Report Forms were Due May 1st
Beginning with the 2017 reporting year, the Bureau of Air stopped mailing paper Annual Emissions Reports (AER). Instead, Illinois EPA sent each facility's report to them via e-mail as a PDF attachment for viewing and printing using the free Adobe Acrobat Reader.
Permitted sources (ROSS sources are not required to file annual emissions reports) should have received an email from Buzz Asselmeier on January 5th containing their 2017 Annual Emissions Report forms that are due to the Illinois EPA by May 1st. If you have not received your facility's 2017 report form, it is possible it was sent to your junk or spam folders. To help ensure you receive future communications regarding your AER, we recommend you add
to your address book. If you have not received your report, please e-mail Buzz Asselmeier.
If your contact information changes for your facility's Annual Emissions Report, changes can be submitted
If you have questions about your report or need assistance, contact the Illinois EPA Bureau of Air at 217-524-0934 or the Illinois Small Business Environmental Assistance Program at 800-252-3998 or
for links to helpful tools for calculating your facility's emissions as well as the Illinois EPA's Annual Emission Report Instructions.
Consider creating a dedicated e-mail address like EHS@xyzcompany.com or Compliance@xyzcompany.com for official government correspondence. This would help ensure your company continues to receive regulatory reports, billings and other notifications when staffing changes occur. Topical or dedicated e-mail addresses eliminate the need for updating multiple agencies of staff/contact changes, reduce the chances of the communications being lost or overlooked, and could allow multiple users to have access to important email communications.
IEPA Announces Program to Provide Energy Assessments to Public Wastewater Treatment Plants
Illinois EPA's Office of Energy is working to help local municipalities reduce the cost of wastewater treatment and are teaming up with the Smart Energy Design Assistance Center (SEDAC) and the Illinois Sustainable Technology Center (ISTC) to provide free energy usage assessments to publicly-owned wastewater treatment plants.
"The cost of wastewater treatment can be a significant burden for municipalities, especially when the infrastructure is aged or inappropriately sized for the community it serves," said Illinois EPA Director Alec Messina. "This partnership will help them identify ways to improve their systems and realize cost savings for their communities."
To qualify for the assessment, a wastewater treatment facility must:
- Be located in Illinois and owned by the State of Illinois or an Illinois unit of local government;
- Allow SEDAC and ISTC access to the treatment facility;
- Be willing to share facility information with SEDAC, ISTC and Illinois EPA.; and
- Share the final assessment report with the Illinois EPA.
The final assessment reports will breakdown recommendations for energy efficiency improvements at each facility. This will include information such as upfront costs for equipment upgrades or retrofits, estimated time it will take for the upgrade costs to pay-off in energy savings, and the resulting energy and monetary savings that could result from upgrades and retrofits. Similar assessments would ordinarily cost municipalities between $6,000 - $12,000.
SEDAC will be providing outreach for the assessment program, focusing on wastewater industry groups that are in regular contact with municipalities and treatment plant operators.
Interested municipalities will complete an
, created and hosted by ISTC, to ensure the municipality is qualified before submitting treatment facility information for analysis. SEDAC or
ISTC will visit qualified treatment facilities in the final step of the process before an assessment report is completed.
On March 31, 2017, Governor Rauner issued Executive Order 2017-03, transferring the Office of Energy and Recycling from the Department of Commerce and Economic Opportunity to the Illinois EPA. The programs administered by the Office of Energy and Recycling aim to reduce energy consumption, promote clean and renewable energy, and increase solid waste recycling.
US EPA Region 5 Outreach on Solvent Reduction Options
The U.S. Environmental Protection Agency's (EPA) Region 5 office has initiated a voluntary air toxic reduction effort with regulated industry sectors in the states of Illinois, Indiana, Michigan, Minnesota, Ohio and Wisconsin.
Halogenated solvents include:
* Trichloroethylene (TCE)
* Methyl chloroform (TCA, 111- trichloroethane)
* Dichloromethane (DCM, methylene chloride)
* Perchloroethylene (PERC)
* Carbon Tetrachloride (CTC)
There are alternative solvents available that are safer and as effective as halogenated solvents. Solvent substitution may allow the facility to reduce or eliminate permit or other compliance requirements under the federal standard, protect worker health and reduce costs.
For questions on how to participate, contact Rae Trine at USEPA Region 5, (312) 353-9228 or email firstname.lastname@example.org.
USEPA Clarifies New Source Review (NSR) Project Evaluations
In addition, the agency had previously issued a guidance memorandum clarifying the EPA's current understanding of certain elements of Clean Air Act's New Source Review (NSR) regulations and when they should apply to projects at facilities that may increase emissions. The primary purpose of the memo was to clarify that so long as a company complies with the procedural requirements of a preconstruction analysis, then USEPA will not "second-guess" that analysis.
EPA Office of Air and Radiation Assistant Administrator Bill Wehrum's also issued a memo withdrawing the ""Once in Always in" policy, which had posed a major deterrent to improving environmental outcomes for some facilities.
NSR provisions require covered facilities to obtain a preconstruction permit prior to the construction of a new major stationary source or a "major modification" to an existing stationary source. Determining whether a proposed project triggers the threshold to obtain an NSR permit is a two-step process, which is laid out in the Agency's comprehensive "applicability procedures" regulatory requirements. Step 1 determines whether a proposed project will, by itself, result in a significant emissions increase. If an increase is projected to occur, the process moves to Step 2 to determine whether the project, combined with other unrelated recent projects, will result in a significant net emissions increase.
Given previous inconsistent application and interpretation of the Step 1 evaluation accounting, this process has prevented environmentally beneficial projects from moving forward. The memo clarifies that companies can consider projected decreases in emissions of air pollution, as well as projected emissions increases, during Step 1. which the agency says removes regulatory obstacles, saves time and money, and reduces pollutants.
If the Step 1 evaluation shows that the proposed project will not result in a significant emissions increase, the project then proceeds under a state-issued minor source permit and avoids the complex multi-year evaluation to obtain a major NSR permit.
NESHAP for Asbestos: Request for Approval of Alternative Work Practice for Asbestos Cement Pipe Replacement
USEPA has provided
and is soliciting comments on an alternative work practice (AWP) request under the Clean Air Act, to use new technology and work practices developed for removal and replacement of asbestos cement (A/C) pipe. The USEPA is soliciting comment on all aspects of this request for an AWP. In order to be approved, the AWP should be at least environmentally equivalent to the existing work practices in the Asbestos NESHAP, which applies to the removal and replacement of A/C pipe.
For further information about the proposed action, contact Susan Fairchild of EPA's Office of Air Quality Planning and Standards, Sector Policies and Programs Division, Minerals and Manufacturing Group at (919)-541-5167 or by email at email@example.com.
The EPA must receive written comments on or before June 25, 2018. For more information regarding the proposal and how to submit comments,
USEPA Issues Guidance on Significant Impact Levels (SILs) for Ozone & Fine Particulates for Prevention of Significant Deterioration (PSD) Permitting
EPA has finalized the guidance and supporting documents recommending Significant Impact levels (SILs) for ozone and fine particle pollution that may be used in the Prevention of Significant Deterioration (PSD) permitting program. SILs have been used in the PSD permitting process for many years to help permit applicants and permitting authorities determine whether proposed construction may be authorized in a Clean Air Act (CAA) permit. These improvements will potentially reduce the cost and time for manufacturers to obtain this type of air pollution permit from states, local permitting authorities and EPA.
The memo and supporting documents are available
The Illinois Small Business Environmental Assistance Program (SBEAP) is a federally mandated program to assist small businesses with their environmental requirements. SBEAP is a free, confidential, and non-regulatory resource for small business owners to help them understand and comply with state and federal air pollution regulations.
We offer a range of services to assist small businesses, including training seminars and workshops, current permit forms and instructions, links to various Illinois state agency environmental regulations, a quarterly newsletter with regular updates and information on pending and recently amended rulemakings, fact sheets, brochures and guides related to a wide range of small businesses, and links to a directory of environmental consultants.
The SBEAP program is located within the Office of Entrepreneurship, Innovation and Technology at the Illinois Department of Commerce & Economic Opportunity. For more information please
Call our helpline at
800.252.3998 or email
Newsletter provided in partnership with
the Illinois Small Business Development Center Network.
Illinois Small Business Environmental Assistance Program