July 1, 2018 Deadline to Upgrade Booth (For Some) & July 1, 2019 Deadline for All, July 2016

South Coast Air Quality Management District (SCAQMD) is the regulating agency for air quality in the LA basin and has implemented emission limits on NOx that require paint booth burner upgrades.  We last wrote to you in 2014 regarding these rules that apply to body shops concerning booth maintenance and documentation of NOx emissions limits for equipment burning natural gas, such as dryers, ovens, and afterburners, located at your collision center paint booth.  The deadline for compliance was July 1, 2014 to upgrade your booth.

Almost everyone got an extension by keeping a gas usage log indicating that the gas being used in the booth is below 76 therms/day. Failure to show compliance with the rule may result in penalties of $1000/day.  So log or pay the fine!  The extension expires as soon as January 1, 2018 for some of you so it makes sense to allocate your budget of say $10-30K and upgrade your booth heater and mechanicals by installing a SCAQMD approved heater that limits NOx.  You may also choose to get new booths with upgraded burners and as such, comply with this requirement; the decision is yours.

DEADLINE IS HERE (Well Almost):

Booth Manufactured 12/31/1997 or Before: If a paint booth was manufactured before 1998, it must be in compliance by July 1, 2014, i.e., emitting less than 30 lbs/month of NOx (application for burner modification should have been submitted by 12/1/2013) (see Table 2 of Rule 1147).  If the paint booth is emitting less than 1 lb/day of NOx, proven by gas usage, the compliance date is pushed back 5 years to July 1, 2019 (application for permit to upgrade is due December 1, 2018).

Booth Manufactured 1/1/1998 or after have a 20 year deadline from date of manufacture not to exceed July 1, 2019:  Let’s say your booth was manufactured on 1/1/98 and the 15 year deadline for upgrades was July 1, 2013 per Table 2 of Rule 1147, which was extended by 5 years provided you kept the gas usage log.  The 5 year extension expires July 1, 2018.  The time to get bids from contractors, approve bid, and then apply permits from SCAQMD.  The permit application is due by December 1, 2017 so get the ball rolling.  In the absence of upgrades, the SCAQMD can suspend your permits, essentially shutting your bodyshop.  For a booth installed in say 2005-2010 time frame, they all have a deadline of July 1, 2019.

ANNUAL SYSTEM MAINTENANCE, RECORDKEEPING, AND RATING PLATE:  The combustion systems on the booth have to be maintained in accordance with the manufacturer’s scheduled specifications as outlined in the operating manual or other documentation available from the manufacturer or distribution along with the booth rating plate.  Also, maintain on site a copy of the manufacturer’s instructions, retain records of maintenance for three years, and retain test records, if completed under the option as listed above for ten years.

SUMMARY: Our recommendation to you is that you complete your spray booth upgrades by replacing the booth heater and mechanicals (approximate cost is $30K-40K for a pre-approved SCAQMD heater) or retrofit your existing heater with a low NOx burner component (approximate cost is $13K) and have an approved third party perform a NOx test ($4500-$7500 for NOx test). The retrofit is not a guarantee of passage. Good news is that the booths installed after 2011 (and on SCAQMD list) had the low emission burners and need no upgrades!

Authority Cited:  SCAQMD Rule 1147 http://www.aqmd.gov/docs/default-source/rule-book/reg-xi/rule-1147.pdf?sfvrsn=4

SCAQMD RULE 1147 (C)(6) NOx REDUCTIONS FROM MISCELLANEOUS SOURCES

Booth Compliance

Download:  July 2016 Newsletter

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