Director Philip J. Wittek Provides Additional Information

February 27, 1998

The Johnson County Environmental Department provided the following letter addressing emissions from the Metcalf Autobody Shop and from the Reno Construction site. If you have any comments, please feel free to contact either me, phillips@kcnet.com or Mike Boothe, michael.boothe@jocoks.com.

Following the letter are links about MACT standards, which are mentioned in the letter and to NeighborhoodNet articles:

February 20, 1998

Mr. Bob Phillips
16315 Dearborn Drive
Stilwell, KS 66085

Re: Metcalf Autobody

Dear Mr. Phillips:

Thank you for your interest and concern about possible emissions from Metcalf Autobody located at 7235 W. 162nd Street, Overland Park. Johnson County Environmental Department (JCED) staff and the Kansas Department of Health and Environment (KDHE) have reviewed the facility at your request. Listed below are the results from this inquiry:

  1. Attached are the Material Safety Data Sheets (MSDS) you requested for the materials used by Metcalf Autobody. On several of these sheets, you will notice for some of the ingredients the term "proprietary." The paint manufacturer, Spies-Hecker, has legally protected these ingredients as trade secrets and as such are not released to the general public.

  2. A computerized dispersion model was conducted for this body shop by Mr. Dana Morris of KDHE. Toluene was used in the model as it occurs in the greatest quantity at the Metcalf Autobody site. His report states the model predicted a maximum annual average in the air around the day care center to be 1.6-2.5 micrograms per cubic meter of air (ug/m3). Currently there are no ambient standards for hazardous air pollutants such as toluene, so Mr. Morris compared the model results to the workplace standard of 188,000 ug/m3established by the American Conference of Governmental Industrial Hygienists (ACGIH). The predicted levels are far lower than the workplace standard.

    Please keep in mind that even though a chemical may be listed as "hazardous," that does not mean that an individual is at risk from any exposure. This is true of chemicals whether they are listed as hazardous or not.

  3. It is also very important to note that odor does not necessarily equate to danger. Some substances, such as hydrogen sulfide (sewer gas, rotten egg gas) are quite noticeable at levels far below what is considered dangerous. Others, such as carbon monoxide, are dangerous but are odorless at any concentration. Olfactory senses can differ greatly from individual to individual. What is noticeable or offensive to one may not be noticeable or offensive to another.

    There may be paint odors that come from Metcalf Autobody, but odor alone is not conclusive as to the actual amount of emissions. Emissions are calculated on the actual amount of paint and solvent used as well as their rate of exhaust to the ambient air from Metcalf Autobody's facility. As the computer modeling shows (Item #2, above) the amount of emissions elaborated to distance from this site is very low.

  4. Currently the Environmental Protection Agency (EPA) is establishing a series of standards based on Maximum Available Control Technology, also known as MACT standards, for certain source categories of industries, of which auto body coatings is one. These rules will directly affect only those sources which are "major sources." There are currently 188 chemicals listed by the Clean Air Act as hazardous, and EPA is first writing standards for those chemicals believed to be most hazardous to human health and the environment. MACT standards have already been written for a number of industries such as, bulk gasoline terminals and dry cleaners. The rules for auto body paints are tentatively scheduled to be published by EPA on November 15, 2000. The proposed implementation schedule is unknown at this time. These rules are designed to change the chemical formulation of the paint itself and will be addressed by the manufacturers rather than the end users. While Metcalf Autobody is not a major source, it will be using the same paints as the major sources and emissions from the facility will decrease even further.

  5. Metcalf Autobody's emissions are not sufficient to require any air quality permit or approval from KDHE. Based on their past paint and solvent purchases, their total emissions would be substantially less than three tons per year. This assumes that all of the paint, including pigment which normally stays on the car, is emitted into the air. The pigment would account for approximately 20% less emissions. To be subject to KDHE's rules for the emissions of Volatile Organic Compounds (VOC), Metcalf Autobody would need to emit a minimum of 40 tons per year. The VOC's at the site are primarily found in the thinner and paint. In the case of chemicals that are listed as hazardous in Title III of the Clean Air Act Amendments of 1990, such as toluene, the emissions would need to be minimum of 10 tons per year for one chemical or 25 tons per year for all hazardous chemicals to require a permit. Sources that exceed either of these amounts are known as "major sources." Since the emission from the body shop are less than three tons per year, and the toluene is only a percentage of the total emissions, Metcalf Autobody is not required to obtain an air quality permit because emissions are less than the 10 ton per year minimum.

  6. The odors you describe coming from the Reno Construction site were caused primarily by stagnant water at the bottom of the quarry. This problem has been corrected. The asphalt plant operated by Reno Construction does have an air quality operating permit issued by KDHE. These types of plants have been tested in the past and the emissions characterized. The pollutant of concern at an asphalt plant is particulate matter. This is from the aggregates (sand and rock) used in the process. It is not necessary to test every asphalt plant as data obtained from tests on similar plants conducted during the development of air regulations by EPA and other similar agencies can be used for the Reno facility. Additionally, the Reno plant has air pollution control equipment called a wet scrubber which removes most of the particulate matter. This facility is inspected at least once per year by Environmental Department staff. The inspectors are certified Official Observers for opacity observations and conduct such observations during the inspection. Opacity observations are used to visibly estimate the amount of particulate matter being emitted to the ambient air. If a facility exceeds their allowable limit, a violation is issued. The Reno Construction plant is fueled by clean-burning natural gas. The plant may produce a slight petroleum odor which is caused by the heated asphalt as it is added to the aggregate mix.

I hope that this information on Metcalf Autobody's operations will help address your concerns. Should you have any additional questions, please contact Mike Boothe, Air Quality Program Manager, in this office.


Philip J. Wittek


Enclosure [Editor: Enclosure not included in this article]

c: Annabeth Surbaugh, Commissioner, District No. 3
E.H. Denton, County Administrator
Mr. Don Dewey, Metcalf Autobody
Tom Gross, Environmental Scientist, KDHE
Dana Morris, Professional Engineer, KDHE
Betsy Betros, Director, Pollution Control Division, JCED
Mike Boothe, Air Quality Program Manager, JCED

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