KPA Blog

Posts Tagged ‘EPA’

Now is the time to prepare, evaluate, update and implement your SPCC Plan

Sunday, August 1st, 2010

Compliance Tip of the Month

This year brings the hottest climate to the current state of environmental issues, and with the current focus of disasters such as the BP oil spill, enforcement is increasing and the consequences of non-compliance are expensive and potentially devastating.

The SPCC Rule essentially requires specific facilities to prepare, amend, certify, and implement an SPCC plan, thereby ensuring containment and countermeasures that will prevent oil discharges. Some elements of an SPCC plan include ensuring staff has undergone SPCC specific training, preparation of monthly self-inspection procedures and documentation, and a Five-year Plan review.

For more information, please see http://www.epa.gov/emergencies/content/spcc/index.htm

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Check your air conditioning service certificates

Tuesday, June 1st, 2010

With the summer approaching and temperatures rising, EPA representatives have been visiting dealerships asking to see training certification records for air conditioning service technicians. Those unable to produce their records are facing stiff fines. In brief, a dealership should take care of the following tasks:

  • Technician Training and Certification: Ensure all dealership air conditioning service technicians have successfully completed EPA approved training on refrigerant recovery, and that each holds a uniquely numbered proof of certification.
  • Training Records: Retain on-site a record of all certified air conditioning service technicians if you own refrigerant recycling/recovery equipment.
  • Equipment Certification: Certify in writing to U.S. EPA that the dealership has acquired (and is properly using) approved recovery/recycling equipment, and that each individual authorized to use the equipment has been properly trained.

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New Underground Storage Tank Operator Training Requirements

Thursday, April 29th, 2010

The US Energy Policy Act requires all States that receive federal grant money for their UST programs to ensure that all operators of UST systems demonstrate competency on how to comply with UST rules so environmental releases can be prevented. These new rules have created a training and registration program requirement for underground storage tank operators.

Operator training will require owners and their designated employees to undergo training to become certified UST operators. Once the deadline has passed, refuelers will not be allowed to deliver to facilities that have not met the new requirements. The type of training an operator receives depends on the job functions they perform at their facilities.

The deadlines and specific requirements are going to vary from one state to another, but most states seem to be looking at a 2012 deadline. Some states, like California and Louisiana, already require UST Operators to meet similar training and certification requirements. Other states, like Florida, are choosing not to take the Federal money and may look at developing their own training requirements. For more information on the upcoming requirements you can review the Energy Policy Act, check with your state’s Environmental Protection Agency or contact your local KPA Representative.

A national UST operator training firm, PASS, has also prepared a summary of the latest regulations that can be used as a reference for your state.

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Secure Oil Distribution Pumps Daily to Avoid Slippery Situations

Monday, March 1st, 2010

Recently a dealership experienced a 500-gallon release of new lube oil when overnight one of the overhead lube oil distribution lines sprang a leak. The air powered pump at the oil tank detected a pressure drop and fired off. With no one around to see the oil spewing out of the broken line, it kept operating until the entire contents of the tank had been pumped out onto the shop floor, creating a tremendous mess. Many dealerships fail to secure the supply of compressed air to these pumps at the end of each workday. Thus any pipeline failure could result in a similar incident.

If your dealership operates these air driven oil distribution pumps it is important to ensure that, after hours, the supply of compressed air to these pumps is secured. A common way to achieve this is to shut off power to your air compressor and bleed your air lines. You may have other procedures that would work as well but the key is having an employee in charge of the process every day.

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EPA 6H rule: 9 reasons not to file for an exemption

Thursday, January 7th, 2010

Steven E. Schillinger, President of GRC-Pirk Management (http://www.recomply.com/) is a KPA partner serving the collision center industry and a specialist on the EPA 6H rule. Steven lists nine reasons why filing for an exemption is a bad idea:

  1. Exemption form is an application only, not immunity, and requires written acceptance from the EPA
  2. Guarantees EPA review and/or inspection
  3. Shops can’t be conditionally exempt, all or none – paint one-time with vibrant or pearl and they’re subject to the rule for the entire year
  4. Shops will have to prove an exemption each permit renewal period
  5. Shop assumes vicarious liability if they sign a false affidavit
  6. Prohibits use of ANY products containing Target HAPs, i.e., 3-M products, cleaners, strippers, any jobbers products, etc. – not just one manufacturers product-line
  7. Many Air districts have added the rest of the EPA 188 toxic HAPs to a local rule – Delegated Authorities can be more restrictive than the 6H Rule
  8. Inspectors are instructed to cut a sample of the booth filter for lab-testing – when ANY Target HAPs appear (and they do) shops will have to defend!
  9. Why file exemption? It’s easy to be compliant and most reputable shops are already in compliance!

Steven also wrote a great article in Auto Body News how this new 6H rule could benefit shop owners as it could eliminate illicit shops.

Body Shops should review KPA’s 6H Checklist to ensure that their paint spray operations are compliant. For more information on EPA rule 6H, see our 6H Rule Overview.

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Tip of the month: check if you meet the new SPCC rule compliance dates

Friday, January 1st, 2010

Self Certification An Option Starting January 14th 2010

Compliance-TipAfter an 11 month delay for additional public comment the EPA has finalized the December 2008 amendments to the Spill Control and Countermeasures Plan (SPCC) rules. If you recall, last year’s amendments were to reduce some of the regulatory burden on smaller oil handling facilities such as yours. As it turns out, the changes resulting from the extended public comment period have not had any impact on the amendments in your business sector. As with the previous rules if your facility has an aggregate storage capacity of over 1,320 gallons (including 55 gallon drums) of petroleum products, these amendments will affect your facility.

For more information about this upcoming rule change, read more in our January newsletter or join our SPPC webinar on January 14.

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What workshops do you want to see at NADA in Orlando?

Sunday, December 27th, 2009

NADA-2010What workshops would you be interested in, in addition to the NADA workshop schedule?

I can arrange a conference room and speakers on the following topics:

  1. HR: including wage and hour law, Department of Labor regulations and trends
  2. Environmental, Health, and Safety: including anything related to OSHA, EPA, DOT
  3. Internet marketing: including SEO, and social media.

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Tip of the month: every facility conducting spray coating must file notification with EPA before January 10

Monday, December 7th, 2009

compliance tip of the month

An initial notification letter or a petition for exemption has to be filed with EPA regarding compliance with 40 CFR Part 63, Subpart HHHHHH (also referred to as the 6H rule). Every facility conducting vehicle spray coating operations must file an initial notification of compliance or a petition for exemption with the EPA by January 10, 2010. The initial notification is ordinarily submitted to both the EPA region where the facility resides, and the delegated regulatory authority, if any. Consult the list of delegated regulatory authorities (PDF) (2pp, 21k).

A free recorded webinar about the 6H rule is available to find out:

  • If you qualify for an exemption, and why you are probably better off not trying to claim the exemption.
  • Requirements for new facilities, and why your definition of a new facility is probably not the same as the EPA’s definition. For example, if you install new paint equipment the EPA may reclassify your shop as a “New Facility”

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