ENVIRONMENTAL DEPARTMENT ON METCALF AUTOBODY EMISSIONS
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, firstname.lastname@example.org or Mike Boothe, email@example.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
- 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.
- 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.
- 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.
- 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.
- 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.
- 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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