Air permits are needed for operations that emit air pollutants.  Examples of equipment that may need an air permit include paint booths, solvent parts washers, abrasive grinding or blasting operations, and gasoline dispensing pumps and tanks. However, not all of this equipment automatically needs a permit - it depends on the size of the equipment and the amount of pollutants (emissions) being released.

For all your shop's operations, you should look at the following three categories to see which operations are exempt and which may need an air permit:

---

UNDER CONSTRUCTION...

National Emission Standards for Hazardous Air Pollutants (40 CFR 63, Subpart HHHHHH)	(Note: This federal EPA rule applies nationwide to shops spraying coatings or using paint strippers and cleaners containing methylene chloride)
Subpart HHHHHH Brochure (English)   Subpart HHHHHH Brochure (Spanish)	Explains requirements of the federal NESHAP rule
Frequently Asked Questions (FAQ) for 6H Rule	This helpful FAQ guide answers common questions about applicability, compliance and reporting for the NESHAP rule. Also contains supplemental contact information for Ohio.  Revised 2/15/11
NESHAP Initial/Compliance Combined Notification Form (Ohio version)	Ohio combined form covering initial notification and compliance certification for Subpart HHHHHH (English) Due Jan 10, 2010
NESHAP Notice of Compliance Status (Ohio version)	Ohio form for certifying compliance with Subpart HHHHHH    Due March 11, 2011
NESHAP Petition for Exemption form	Generic form to apply to U.S. EPA for an exemption from the NESHAP rule. To qualify, you must certify you use no products that contain methylene chloride and no coatings that contain heavy metals (chromium, lead, nickel, manganese, or cadmium.)
EPA NESHAP Video & training	Link to EPA's Collision Repair Campaign’s training info and 20-minute video featuring NASCAR’s Jeff Gordon explaining the NESHAP rule requirements. (English and Spanish options) Contact OCAPP at 800-329-7518 for a copy of the DVD.
Compliance resource page for 6H rule	Link to resources from the network of state small business assistance programs. Contains paint manufacturer’s lists of paints containing heavy metals, lists of approved HVLP guns, and other state information.
U.S. EPA Area Source Rules Web Page	This web site contains the official rule language, notification form templates, implementation tools, and background information for numerous area source NESHAP rules promulgated by U.S. EPA.

OAC 3745-21-18 - Commercial motor vehicle and mobile equipment refinishing operations.	This rule specifies VOC per gallon limits for auto refinishing coatings, cleanup practices, and paint technician training. Applicable in the Akron, Cleveland, Cincinnati, and Dayton metro counties. (NOTE: These rule requirements are independent of the federal NESHAP rule)
OAC 3745-17-11 - Particulate Matter Standards	Generally, this rule requires spray painting operations to employ booth enclosures and filters to control particulate overspray.  However, paragraph (A)(1)(k) of the rule exempts spray operations that employ hand-held cup spray guns from this requirement.  Note that the federal NESHAP 6H rule requires spray operations to be enclosed and to have 98% efficient filtration.
Used Oil Regulations	Link to Ohio's regulations and related guidance for the proper management of used oil.

Environmental Compliance Guide for Auto Repair Shops	This guidebook summarizes some of the major environmental requirements that could apply to your auto body/repair shop and includes checklists to self-evaluate your operations. It provides you with a starting point to identify areas where you business might be subject to regulation. It may not cover every requirement and should not be used as your only source of information on the regulations.
Permit-by-Rule User's Guide for Auto Body Refinishing	This guidebook provides information on how to properly use and comply with the permit-by-rule (PBR) provisions for auto body refinishing facilities specified in OAC 3745-31-03(A)(4)(g). The PBR exempts small auto body refinishing shops from complex air pollution permits provided the spray booths meet certain design criteria and the company follows certain operating practices.
De minimis exemption guidance	Copy of OAC 3745-15-05 (De minimis source exemption) and example emission calculations and recordkeeping forms to document a de minimis exemption for a paint booth.

Any discharge of industrial wastewater to “waters of the state” requires a discharge permit from Ohio EPA’s Division of Surface Water. This permit is called a national Pollutant Discharge Elimination System (NPDES) permit. Examples of waters of the state include streams, rivers, lakes, ponds, marshes, watercourses, waterways, wells and springs. Wastewater discharges entering a conveyance system (like a ditch or storm sewer) that leads to a waterway may also require an NPDES permit.

You may also be required to treat wastewater to remove harmful contaminants (for example, metals, chemicals, oils or grease) before it is discharged. If treatment is required, a separate permit is needed to construct wastewater treatment units, called a permit-to-install (or PTI). The PTI application is reviewed by Ohio EPA’s Division of Surface Water.

Often, the local publicly owned treatment works (POTWs) are responsible for regulating the companies that discharge wastewater to them. A large POTW may be able to handle the wastewater from your business. However, even large wastewater treatment plants are not generally designed to handle industrial wastes like chemicals, metals, oils, etc. They are designed to handle sewage related wastes and wastewater. Because of this, the treatment plant may require you to conduct “pretreatment” (for example, removal of metals, oil or grease, etc.) before discharging your wastewater to them.

If you want to discharge industrial wastewater to a local POTW, discuss it with the treatment plant directly. Permission to discharge to the POTW and/or obtaining a permit may be necessary. If you must construct wastewater treatment or storage units, a PTI from Ohio EPA is required.

Contact the Division of Surface Water at your local Ohio EPA district office for more information on the wastewater discharge and permitting requirements.

Many small businesses have floor drains. A common floor drain system can include a concrete trench that runs down the center of a shop floor. The trench is designed to capture water, cleaners, oil, dirt or other materials. Some shops have small rectangular or round floor drains connected to underground piping.

Some floor drains are necessary for day-to-day operations. Others are used for emergency purposes only.  And some floor drains don’t seem to have any apparent use. Do you know where the floor drains in your business go? Are you discharging wastewater or other fluids into your floor drains?

It is very important that you know where all your floor drains lead, and are aware of Ohio EPA’s regulations that apply to your dis-charge activities. If you do not know where your drains lead, or if you are using floor drains improperly, you could be contaminating nearby surface waters or drinking waters.

Some floor drains lead into a sanitary sewer, where wastewater goes directly to a POTW. Other floor drains lead to an on-site sewage treatment system like a septic tank. Sometimes floor drains lead directly to an underground holding tank or discharge to a waterway or to the ground outside. Ohio EPA’s water pollution control regulations apply to all of these activities.

Any company that wants to discharge industrial wastewater to waters of the state needs to obtain a NPDES permit from Ohio EPA. If your floor drains lead to any water of the state, you must have a discharge permit for this activity.

Companies that discharge industrial wastewater directly to a POTW are also regulated. Often, the POTW regulates the dis-charge activities. If you are discharging to a POTW, you need to contact the plant to discuss your activities. You may be required to obtain a permit for the discharge. In addition, you may be required to treat the wastewater before discharging (for example, oil/water separation, removing solids, chemicals, etc.).

If you have a floor drain which leads to an injection well, you are subject to Ohio’s underground injection control (UIC) regulations. The UIC regulations are in place to protect underground drinking water sources from becoming contaminated. If you are discharging industrial wastewater to a floor drain that leads to a septic system or other injection well system, you could be in violation of Ohio’s water pollution control laws. Examples of injection wells include dry wells, drain fields and cesspools. In addition, a floor drain that is tied to a septic tank, mound system or leach field is defined as an injection well system.

Under Ohio EPA’s water pollution control regulations, a company cannot discharge industrial wastewater into an injection well. This activity is strictly prohibited unless a company has obtained a permit to drill and a permit to operate (UIC permit) from Ohio EPA’s Division of Drinking and Ground Waters. This includes discharging industrial wastewater to an on-site sewage treatment system (for example, a septic tank or leach field). Not only would this activity without a permit be a violation, the discharged materials (chemicals, solids, oil, etc.) could also damage your on-site system.

The use of some disposal wells has been completely banned, including the use of motor vehicle waste disposal wells.

• Check all your floor drains and make sure you know where they drain.
• If you are using floor drains to discharge industrial wastewater into a septic system or onto the ground, you must stop these discharge activities immediately. You must find another way to manage your wastewater.
• If you are using floor drains to discharge industrial wastewater to a water of the state, and you do not have an NPDES permit, you must stop these discharge activities immediately. You must either obtain a permit or find another way to manage wastewater.
• If you are using floor drains to discharge wastewater to a local wastewater treatment plant, make sure the treatment plant knows about this activity. You may be required to conduct treatment on the wastewater before discharging it. You may also need to get a permit for the discharge.
• Do not put other fluids like oil, solvents, paints or chemicals into a floor drain. This could contaminate your property and lead to large fines and cleanup costs.
• Consider installing an emergency shut-off on the drain pipes to prevent accidental spills from entering the sewer.
• If you have floor drains at your company that you are not using, think about having them capped or plugged. Good housekeeping and planning can help avoid costly problems later.

If you have any questions about floor drains and Ohio’s water pollution control requirements, contact your local Ohio EPA district office, Division of Surface Water (DSW) for assistance.

Contact Ohio EPA’s Division of Drinking and Ground Water, UIC Program at (614) 644-2752 for more information about injection wells.

• Keep ALL solvent containers closed to limit evaporation
• Avoid use of coatings that contain toxic metals (chromium, lead, cadmium, nickel, and manganese) by asking suppliers for alternative formulations
• Use Paintless dent repair techniques
• Avoid use of methylene-chloride based paint strippers
• Use an automatic enclosed gun washer
• Use water-based or low-solvent coatings (primers, basecoats and painting)
• Use low-VOC solvents or thinners
• Employ a two-stage solvent cleaning procedure:  Wash first with used solvent, then wash with clean solvent.  When first wash solvent no longer cleans, replace with second wash solvent, replace second wash solvent with fresh solvent, recycle first wash waste solvent.
• Recycle solvents with on-site distillation unit or off-site recovery service
• Have an inventory system (first-in, first-out) in place to prevent products from going out of date
• Use computerized paint mixing system to minimize mistakes/over-mixing
• Use non-solvent based putty/fillers
• Reusable aerosol or pump spray containers

• Use a disposable paint cup system to minimize unused paint and emissions
• Use a ventilated sander or self-contained media plaster to minimize emissions from preparing parts
• Employ wet sanding techniques
• Use Roll-on Primer

• Turn on paint booth only when necessary
• Keep booth lights clean
• Change booth filters regularly to ensure good airflow (which reduces draw on HVAC motors)
• Select variable speed drives and motors for paint booth fans
• Use heated air recirculation
• Purchase new or replacement energy efficient equipment (motors, fans, lighting, spray guns)
• Install timers/motion sensors on booth lighting to reduce energy use

• Install specialized controls (timers, motion sensors) that turn off or throttle back lights, heat, or equipment when areas are not occupied and/or in use
• Install programmable thermostat for heating/cooling
• Install efficient fluorescent lights (T-8 or better)
• Encourage employees to turn off lights with reminder signs
• Clean light fixture reflectors to increase available light
• Reduce lighting intensity where acceptable
• Take advantage of day-lighting if possible
• Complete an energy audit/aware of monthly electricity/fuel use
• Insulate building, windows and hot/cold ducts or pipes
• Use electric tools like shop-vacs or blow dryers instead of the compressed air system
• Purchase energy efficient office products/machines (computers, copiers, etc.)

• Regularly check  compressed air system for leaks and repair all leaks found 
• Regularly check  air compressor to ensure the pressure setting isn’t higher than it needs to be
• Do a quick leak check:  Walk along compressor pipes/hoses right after turning off the compressor, and listen for hissing.  Keep a record of whether the compressor cycles on and off frequently when not in use.  A ¼-inch leak can cost you $2,800 per year.
• Consider buying an ultrasonic leak detector.  Many are inexpensive and can save about $500/year for each leak repaired.
• Think about whether the air compressor is properly sized for your foreseeable future needs.  Every 2 PSI reduced can save you 1% in electricity usage and cost.
• Consider individual turbines for HVLP or small electric tools for specific purposes like buffing or sanding.  It may be preferable for certain types of high-CFM pneumatic equipment.