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Notice of Public Hearing and Public Comment Period - Draft Air Quality Permit 6962 - Smart Transportation Inc

Friday, May 3, 2019

Draft Air Quality Permit 6962, Smart Transportation Inc., Stack Modification and Operation of an existing automotive paint spray booth at 2615 Evarts Street NE

Notice is hereby given that, pursuant to 20 DCMR §210, the Air Quality Division (AQD) of the Department of Energy and Environment (DOEE), located at 1200 First Street NE, 5th Floor, Washington, DC, is proposing to issue an air quality permit (No. 6962) to Smart Transportation Inc. (also known as Smart Automotive) to modify a stack outlet on and operate one (1) semi-downdraft automotive paint spray booth at the facility located at 2615 Evarts Street NE, Washington DC 20018. The contact person for the facility is Mengstab Ghebretinsae, President, at (202) 733-3069.

Emissions Estimate:

AQD estimates that the potential to emit volatile organic compounds (VOC) from the automotive paint spray booth will not exceed 3.12 tons per year.

Emissions Limits:

The proposed emission limits for the equipment are as follows:

a.   No chemical strippers containing methylene chloride (MeCl) shall be used for paint stripping at the facility. [20 DCMR 201.1]

b.   The Permittee shall not use or apply to a motor vehicle, mobile equipment, or associated parts and components, an automotive coating with a VOC regulatory content calculated in accordance with the methods specified in this permit that exceeds the VOC content requirements of Table I below. [20 DCMR 718.3]

Table I. Allowable VOC Content in Automotive Coatings for Motor Vehicle and Mobile Equipment Non-Assembly Line Refinishing and Recoating

Coating Category

VOC Regulatory Limit As Applied*

(Pounds per gallon)

(Grams per liter)

Adhesion promoter

4.5

540

Automotive pretreatment coating

5.5

660

Automotive primer

2.1

250

Clear coating

2.1

250

Color coating, including metallic/iridescent color coating

3.5

420

Multicolor coating

5.7

680

Other automotive coating type

2.1

250

Single-stage coating, including single-stage metallic/iridescent coating

2.8

340

Temporary protective coating

0.50

60

Truck bed liner coating

1.7

200

Underbody coating

3.6

430

Uniform finish coating

4.5

540

*VOC regulatory limit as applied = weight of VOC per volume of coating (prepared to manufacturer’s recommended maximum VOC content, minus water and non-VOC solvents)

c.   Each cleaning solvent present at the facility shall not exceed a VOC content of twenty-five (25) grams per liter (twenty-one one-hundredths (0.21) pound per gallon), calculated in accordance with the methods specified in this permit, except for [20 DCMR 718.4]:

1.  Cleaning solvent used as bug and tar remover if the VOC content of the cleaning solvent does not exceed three hundred fifty (350) grams per liter (two and nine-tenths (2.9) pounds per gallon), where usage of cleaning solvent used as bug and tar remover is limited as follows:

A.  Twenty (20) gallons in any consecutive twelve-month (12) period for an automotive refinishing facility and operations with four hundred (400) gallons or more of coating usage during the preceding twelve (12) calendar months;

B.  Fifteen (15) gallons in any consecutive twelve-month (12) period for an automotive refinishing facility  and operations with one hundred fifty (150) gallons or more of coating usage during the preceding twelve (12) calendar months; or

C.  Ten (10) gallons in any consecutive twelve-month (12) period for an automotive refinishing facility and operations with less than one hundred fifty (150) gallons of coating usage during the preceding twelve (12) calendar months;

2.   Cleaning solvents used to clean plastic parts just prior to coating or VOC-containing materials for the removal of wax and grease provided that non-aerosol, hand-held spray bottles are used with a maximum cleaning solvent VOC content of seven hundred eighty (780) grams per liter and the total volume of the cleaning solvent does not exceed twenty (20) gallons per consecutive twelve-month (12) period per automotive refinishing facility;

3.   Aerosol cleaning solvents if one hundred sixty (160) ounces or less are used per day per automotive refinishing facility; or

4.   Cleaning solvent with a VOC content no greater than three hundred fifty (350) grams per liter may be used at a volume equal to two-and-one-half percent (2.5%) of the preceding calendar year’s annual coating usage up to a maximum of fifteen (15) gallons per calendar year of cleaning solvent.
 

d.   If on the container of an automotive coating, or a label or sticker affixed to the container, or in sales, advertising, technical, or product literature, a representation is made that indicates that the coating meets the definition of or is recommended for use for more than one (1) of the coating categories listed in Condition (b) (relating to coating VOC content limits), then the lowest applicable VOC content limit shall apply. [20 DCMR 718.8]

e.   The Permittee may not possess either of the following [20 DCMR 718.9]:

1.   An automotive coating that is not in compliance with Condition (b) (relating to coating VOC content limits); and

2.  A cleaning solvent that does not meet the requirements of Condition (c) (relating to cleaning solvent VOC content limits).

f.    An emission into the atmosphere of odorous or other air pollutants from any source in any quantity and of any characteristic, and duration which is, or is likely to be injurious to the public health or welfare, or which interferes with the reasonable enjoyment of life or property is prohibited [20 DCMR 903.1]

g.   Visible emissions shall not be emitted into the outdoor atmosphere from the paint booth. [20 DCMR 201.1, 20 DCMR 606, and 20 DCMR 903.1]

The permit application and supporting documentation, along with the draft permit are available for public inspection at AQD and copies may be made available between the hours of 8:15 A.M. and 4:45 P.M. Monday through Friday. Interested parties wishing to view these documents should provide their names, addresses, telephone numbers and affiliation, if any, to Stephen S. Ours at (202) 535-1747.

Interested persons may submit written comments on this subject within 30 days of publication of this notice. The written comments must also include the person’s name, telephone number, affiliation, if any, mailing address and a statement outlining the air quality issues in dispute and any facts underscoring those air quality issues.

A public hearing at which interested parties may present comments will also be held as follows:

Public Hearing: Monday, June 3, 2019

HEARING DATE:  Monday, June 3, 2019
TIME: 5:30 pm
PLACE:       
Department of Energy and Environment
1200 First Street NE, 5th Floor
Washington DC 20002

NoMa-Gallaudet (Red Line) Metro Stop

All persons present at the hearing who wish to be heard may testify in person. All presentations shall be limited to five minutes. Persons are urged to submit paper or electronic copies of any written statements.  

Written comments on the proposed permit not delivered in person at the hearing should be addressed to:

Stephen S. Ours, P.E.     
Chief, Permitting Branch - Air Quality Division

Department of Energy and Environment
1200 First Street NE, 5th Floor
Washington, DC 20002

[email protected]

All relevant comments will be considered before taking final action on the permit application.

No comments submitted after June 3, 2019 will be accepted.

For more information, please contact Stephen S. Ours at (202) 535-1747.