Autobody Surface Coatings Statistically-Valid Pilot

On-Site Survey 

SEEK ANSWER TO ALL QUESTIONS UNLESS SPECIFICALLY DIRECTED TO SKIP A
QUESTION.  

Ask the respondent to answer all questions even if the indicator is not
a requirement in his/her state.   In such cases, please consider the
indicator a Best Management Practice and evaluate whether the facility
is engaged in the practice.

Date of Interview: ________________________________

Name of Interviewer: ______________________________

Facility
Name:___________________________________________________________________
_____

Facility
Address:________________________________________________________________
______

Name of Person Interviewed &
position____________________________________________________

Telephone number of Person Interviewed:
_______________________________________________

Generator ID Number: _____________________________  SIC:
_______________________________

Please choose the category that best describes you:

	__   Owner of an autobody shop 

	__   Manager 

	__   Person who performs spray coatings

	__   Other: (please specify)__________________________________________

Do the operations in your company include the application of spray
coatings to vehicles?

         __  Yes

         __  No (End the survey here)

Does your business perform surface coating of automobiles for
compensation, or for

      more than two vehicles or pieces of mobile equipment per year?

               __  Yes

               __  No (End the survey here)

         

Is your business:

               __  An individually owned and operated company

               __  A part of a chain

                           __  A subsidiary of a bigger corporation

                           __  Other: (please
specify)___________________________________________

  

On average, how many vehicle spray paint jobs (including applying 
primer, basecoats and or clear coats) does your business perform every
week (e.g., the number of automobiles that comes through the shop)?

             __ 1-10 parts or vehicles

             __ 10-20 parts or vehicles

             __ More than 20 parts or vehicles

             

How many mechanics at your shop apply spray coating? ________________

6a. Have these mechanics been trained on selection, set-up, use &
maintenance of spray equipment?  

      	       ___Yes

       ___ No

6b. How are the mechanics and technicians at your shop trained to
perform spray coatings? (Check all that apply) 

   ___ On the job training with more experienced employees

   ___ Periodic training conducted by in-house personnel

  	___ Outside training

 ___ Other: (please specify)_________________________________________

 

How does your shop usually receive information (e.g., online resources,
training, guidance manual, fact sheets, and site visits) to help you
understand or comply with EPA and state environmental requirements? 
(Please check all that apply)

	___ Corporate environmental manager or staff 

   ___ Owner or shop manager 

   ___ U.S. Environmental Protection Agency 

   ___ State regulatory agencies 

               ___ Local government

   ___ Trade Association

               ___ Coating manufacturers

               ___ Coating suppliers

               ___ Fire department 

            ___ OSHA

            ___ Educational institutions (vocational technical school,
community college, 

                   specialized training center, etc)

___ Friends or other shops

___ Other: (please explain)_________________________________________

Has your shop been inspected or visited by a government official in the
last 6 months?

                __ No

                __ Not sure or don’t recall 

                __Yes	

                     If yes, please identify all those who have
inspected or visited your operations:

                       ___ EPA

                       ___ State

                       ___ Local government (environmental, health or
fire department)

                       ___ OSHA

                       ___ Other: (please
specify)____________________________________

            

        

 If your answer to question 8 above is yes, have you made any changes of
your spray-coating operations as a result of the visit, the inspections,
or associated enforcement actions?

              ___ No

  ___ Yes.  If yes, please identify all actions taken:
__________________________

        _______________________________________________________________

        

 Have you heard of EPA’s recently published “Paint Stripping and
Miscellaneous Surface Coating Operations at Area Sources?” (New
requirements impacting autobody spray coating operations)?

             

              __ Yes

                          __ No 

10a. Please indicate where you heard about EPA’s new air quality
regulations: (Check all that apply)

            __ EPA outreach materials (e.g., DVDs, CDs, post cards, fact
sheets, Websites and  

                 other online resources) 

           __ State outreach materials (e.g., DVDs, CDs, post cards,
fact sheets, Websites and  

                other online resources) 

           __ EPA workshop 

           __ Facility visit by EPA 

           __ OSHA 

           __ Local government

           __ Trade association

           __ Friends or other autobody shop

           __ Not sure, don’t recall

           __ Other: (please
specify)_____________________________________________

Who is your primary supplier of paint coating products?  (Please provide
contact information if available) 
_______________________________________________________________________

  

If you have heard of these new requirements as indicated in question 10
above, please indicate the month and year you first heard it: (Fill in
all that apply)

_______  (month/year) of EPA Outreach materials (e.g., DVDs, CDs, post
cards, fact 

                 sheets, Websites and other online resources) 

_______  (month/year) of EPA workshop 

            _______  (month/year) of EPA facility visit 

_______  (month/year) of Other: (please
specify)_______________________________

Air Indicator

Are all spray-applied coatings applied using an HVLP spray gun or an
equivalent high transfer efficiency technology?

Visual inspection of spray gun for HVLP mark.   If no HVLP mark on spray
gun, surveyor will ask facility for any documentation that demonstrates
spray gun achieves the transfer efficiency of an HVLP spray gun.  

If no documentation is available, surveyor will collect spray gun
manufacturer’s name: ______________________________

and model number: ________________________________________

13a. When was the HVLP spray gun first used at your facility?

                      _____________________ (month/year)

14. Does the facility have a high transfer efficiency painting training
in place?

IF YES, Check all that Apply: 

____Surface preparation; 

____Spray gun setup and operation for different types of coatings to
improve transfer

        efficiency and minimize coating usage and overspray; 

____Routine spray booth and filter maintenance; 

____Safety precautions; 

____Environmental compliance;

____Other: (please describe) ________________________________

IF NO, SKIP to Question 15

14a. When was the training program first put in place?

_____________________________ (month/year) 

14b. If yes, is this training documented?  

Surveyor will ask to see documentation.  

15.  Does the facility use ventilated sander (dustless vacuum) equipment
that captures paint dust and body filler, or an overhead capture system?

Surveyor will perform visual inspection.  

15a  When was the ventilated sander equipment or overhead capture system
first implemented at your facility?
__________________________(month/year

16. When sanding, does the facility keep the shop doors closed to avoid
releasing dust outdoors?    

Surveyor will perform visual inspection of doors when shop is sanding. 
If no sanding activity is done during site visit, surveyor will ask
facility if they keep the shop doors open when sanding.

16a. When was this policy first implemented? 

             ___________________________ (month/year)

17. Are all spray-applied coatings applied in an enclosed ventilated
spray booth or preparation station?

Surveyor will perform visual inspection to confirm that spray booths and
prep stations, where coatings are applied for full vehicles, are fully
enclosed with a full roof, four complete walls or side curtains and an
exhaust fan.

Spray booths or prep stations where coatings are applied on vehicle
components only, i.e. not full vehicle, must be fully enclosed with a
full roof and at least three complete walls or side curtains and an
exhaust fan. 

IF NO, SKIP to Question 22

17a. When was this policy first implemented?

__________________________ (month/year)

 17b. If yes, is the spray booth and/or station fitted with a particle
filter(s) on the exhaust?

Surveyor will perform visual inspection of pipe and filter as well as
ask the facility if station is fitted with a particle filter(s) on the
exhaust.

18. Do you know the capture efficiency rating of your booth exhaust
system? 

Surveyor will ask for any documentation, e.g. on filter package or from
distributor, of the filter efficiency.

18a. When was this filter technology or system first used at your
facility?

            ___________________________  (month/year)

	

19. Are the spray booth or prep station’s ventilation system and
particulate filters in good operating condition?

20. Are the particulate filters changed regularly, in accordance with
manufacturers recommendations, so that they will maintain the full
particulate capture efficiency?

21. Is all paint spray gun cleaning done with a fully enclosed spray gun
washer or in a manner that avoids creating an atomized mist or spray of
gun cleaning solvent?

Surveyor will ask facility to demonstrate how guns are cleaned.  

Acceptable methods of spray gun cleaning include: Hand cleaning of parts
of the disassembled gun in a container of solvent; flushing solvent
through the gun without atomizing the solvent and paint residue, by
using a fully enclosed spray gun washer, or by a combination of these
non-atomizing methods. 

21a.  When was this practice first implemented at your facility?

            ____________________________ (month/year)

Record Keeping Indicators

22.  Does the facility have MSDS or formulation data supplied by
manufacturer for all the solvents and coatings that they use?

Surveyor will ask to see documentation.  If no physical documentation is
available, surveyor will confirm if facility uses a color matching
computer technology on-site that has formulation data in it, and if so,
ask to see data.

23. Does the facility have documentation of the amount of coatings used
that contain chromium, lead, cadmium, nickel, and manganese (especially
hexavelent chromium, most common in corrosion control undercoats and
red, orange, and yellow paint colors) and the metals content of these
coatings?

Surveyor will ask to see documentation.

24. Does the facility use paint strippers containing Methylene Chloride
(MeCl)?

Surveyor will ask facility.

IF NO, SKIP to Question 25

24a. If yes, does the facility keep records to document annual usage?

Surveyor will ask to see documentation 

24b. If the facility uses MeCI for paint stripping, is there a written
MeCl minimization plan?

Surveyor will ask to see minimization plan.

HAZARDOUS WASTE INDICATORS

25. What is the maximum amount of RCRA hazardous waste the facility
generates in a month ___________________________  

      NOTE: Includes satellite accumulation

26. Do you know your generator status? 

 ______________________________________________

       

Container Management Indicators

27. Are all hazardous waste containers properly labeled with the words
“hazardous waste” and clearly marked with the date on which
accumulation began?

Surveyor will determine if all containers have labels; if labels are
marked with both items; if labels are clear and legible

28. Are all hazardous waste containers closed unless waste is being
added or removed?

Surveyor will confirm that all containers are closed at the time of
inspection unless waste was being added or removed.  

29. Are all hazardous waste containers in good condition, (i.e., free of
severe rusting or apparent structural defects, and not leaking)?

Surveyor will perform visual inspection of conditions of all containers
looking for leaks and/or severe corrosion, bulging, rusting or dents. 

Proper Hazardous Waste Management Indicators

30. At the time of inspection, has the facility exceeded the state’s
time limits for the amount of RCRA hazardous waste that can be stored
on-site by this category generator (excludes satellite accumulation)?

As applicable, surveyor will verify conformance based on dates on
containers which detail when accumulation begins (if no containers are
labeled, then surveyor will circle: no labels.  

31. At the time of the inspection, has the facility exceeded the
state’s accumulation limits for hazardous waste for this category of
generator (excludes satellite accumulation)?

As applicable, surveyor will inventory all hazardous waste accumulated
on-site in containers and tanks to determine total weight of waste being
accumulated at one time.

32. Is a manifest required for this type of facility to ship hazardous
waste?

            IF NO, SKIP to Question 32b

32a.  If yes, does the facility use a hazardous waste manifest to ship
its hazardous waste when a manifest is required?

Surveyor will look at one (1) year of manifest records as well as ask
the facility if they have kept three (3) years of records.  If there are
gaps in the shipments or shipping records, the surveyor will ask
facility to explain gaps.  Surveyor will use professional judgment to
determine if explanation of gaps is valid.

32b. If a hazardous waste manifest is not required, does the facility
document its hazardous waste shipments, e.g. non-hazardous manifest,
bill of lading, other documentation?

Surveyor will ask to see documentation.

33. Has the facility identified all of its hazardous waste streams?

Conformance will be determined based on: review of production processes,
type of wastes generated at these processes and whether or not the
facility has made hazardous waste determinations on all waste streams.

Emergency Response Indicators

34. Is the facility required to have emergency procedures?

         IF NO, SKIP to Question 34b

34a. If yes, is the facility in compliance with the applicable
requirements for emergency procedures for this category of generator?

Compliance is based on individual state requirements for this category
of generator.  

34b. If emergency procedures are not required, does the facility have
emergency procedures in place?

Visual inspection and inquiry into whether the information is up to
date.

35. Does the facility have an employee training program that teaches
employees proper hazardous waste management procedures?

Surveyor will ask facility to describe program as well as ask to see any
documentation.  The compliance verification will be to determine if the
facility is following the practice of having an employee training
program.  If the facility demonstrates its existence, then the
requirement is met.  We will not evaluate the “quality” of the
training program.  

36. Is there any indication of spills in or near the shop?

Surveyor will check for stains on the ground and in and around manholes,
leaking tanks and containers and/or pooled liquids.

INDUSTRIAL WASTEWATER INDICATORS (IWW)

37.  Do you wash vehicles on-site? 

  

             _____  Yes

             _____  No

37a. Does the facility discharge industrial wastewater to surface water?

             IF NO, SKIP to Question 38

37b. If yes, is facility in compliance with the applicable requirements
for the discharge(s)?

Based on individual state requirements for the discharge(s).

38. Does the facility discharge industrial wastewater to a sewer system?

Sewer system includes sanitary, stormwater or combined sewers

IF NO, SKIP to Question 39

38a. If the answer is yes, which type of sewer system does the facility
discharge industrial wastewater to:

___________ sanitary only  

____________ combined sewer (sewer conveys both sanitary wastewater and 
         stormwater)

__________ stormwater sewer

__________  not sure

38b. If discharging to a sanitary, storm, or combined sewer, does the
facility discharge hazardous waste or or allow the discharge of
hazardous waste through any sewer connection?

38c.  If yes, is facility in compliance with the applicable requirements
for the discharge(s)?

Based on individual state requirements for the discharge(s).

38d. If discharging to a sanitary, storm, or combined sewer, does the
facility discharge hazardous waste or allow the discharge of hazardous
waste through any sewer connection?

39. Does the facility discharge industrial wastewater to groundwater
(e.g., discharge to an on-site septic system, drywell, etc.)?

IF NO, SKIP to Question 40

39a. If yes, is facility in compliance with the applicable requirements
for the discharge(s)

40. Does the facility have any unsealed floor drains?

Surveyor will perform visual inspection of floor drains to see if
sealed.  If no floor drains, answer no.

IF NO, SKIP to Question 41

40a. If yes, is the facility in compliance with the state standard for
discharges to unsealed floor drains?

Based on individual state requirements for the discharge(s)

POLLUTION PREVENTION INDICATORS

41. Has anyone in your shop taken conservation actions in the past 3
years to conserve water or energy? 

Surveyor will ask the facility manager to describe any initiatives in
the past three years.

                         IF NO, SKIP to Question 42.

41a.  IF YES, Briefly Describe The Water Conservation Projects
____________________

________________________________________________________________________
_

42. Provide a short list of conservation options likely to be
implemented (e.g., lights on timers, burn used oil with permit, EE
bulbs…etc).  _______________________________

________________________________________________________________________
___

Surveyor will ask the facility manager to describe any initiatives in
the past three years.

IF NO, SKIP to Question 43

42a. IF YES, Briefly Describe The Energy Conservation/Alternative Energy
Projects

43. Has the facility taken one or more actions to reduce toxics the past
three years?  Check all that apply:

             ____ Use water-based or low-solvent coatings (primers,
basecoats and painting)?

           ____ Attempt to avoid use of coatings that contain toxic
metals (chromium, lead,   

                  cadmium, nickel, and manganese) by asking suppliers
for alternative formulations?

          _____ Avoid use of methylene-chloride based paint strippers?

          _____ Recycle any solvents?

          _____ Use recycled solvent for gun cleaning?

         _____ Have an inventory system in place to prevent products
from going out of date?  

         ____non-solvent based putty/fillers

         ____Other 

	

IF NO, STOP.  Performance Checklist is Complete. 

43a. IF YES, Briefly Describe The Toxic Use Reduction Projects:

Do you routinely monitor the amount of wastes you generate from your
surface coating operations? 

                __  Yes 

                __  No (End of survey)

Please indicate the average amount of solvent-containing automotive
coatings and

      hazardous wastes you generated PRIOR TO receiving any assistance
on EPA's 

      new regulations for auto body shops, "Paint Stripping &
Miscellaneous Surface     

     Coating Operations at Area Sources."

                _________ (gallons/month) of automotive coatings using
solvents

                         _________ (gallons/month) of hazardous wastes 

Please indicate the average amount of solvent-containing automotive
coatings and 

      hazardous wastes you generated AFTER receiving the assistance on
EPA's new 

            regulations for auto body shops, "Paint Stripping &
Miscellaneous Surface 

           Coating Operations at Area Sources":

                 _________ (gallons/month) of automotive coatings using
solvents

                 _________ (gallons/month) of hazardous wastes



Collision Repair Campaign

Survey of Shop Practices

First, please tell us the basic facts about your shop.

Shop Staff

How many employees work at the shop?

How many of these employees are painters?

How many of your painters are certified or have been trained in using
HVLP spray guns?

Operating Hours

What are the operating hours of the shop?

How many days/week is the shop open?

Frequency of Jobs

How many jobs do you perform each month?

Now, please tell us about the spray painting tools and techniques you
use.

Spray Booths

Does this shop contain a spray booth?  If no, continue to section B.2.

Is the spray booth equipped with 98% efficient filters?

What fraction of coating jobs are performed in the spray booth?

What fraction of prepping is performed in the spray booth?

Is there any other form of ventilated prep station?

Does the prep station contain an infrared heater or any other type of
heater (please specify)?

If yes, what fraction of the time is the prep station heated to promote
drying?

HVLP Spray Guns

How many HVLP guns are owned in this auto shop ?  If you do not own any,
continue to section B.3..

What fraction of the time are HVLP guns used?

What fraction of time are HVLP guns used in applying the following
coating types:

Primer

Base coat

Clear coat

HVLP Training

How many of your painters have attended training or are certified in the
use of HVLP guns?  

Who provided the training (paint/gun manufacturer, community/technical
college, local permitting agency, U.S. EPA)?

When was the most recent training attended?

Gun Cleaning

Do you use an enclosed gun cleaning system?  If so, how many guns does
it clean?

Do you recycle cleaning solvents?  If not, what are the barriers to
recycling?

Sanding

Does your shop use the following sanding methods, and if so, what
percentage of your total sanding operations do you use of each:

Wet sanding methods (y/n, % of total sanding):

Ventilated sander (dry vacuum) equipment that captures paint dust and
body filler (y/n, % of total sanding):

Overhead capture system (y/n, % of total sanding):

Other sanding systems (y/n, % of total sanding):

If you do not use vacuum sanding, what are the reasons?

Paint Usage

How many gallons of paint do you use each week?

What percentage of the paint that you use is water-based paint?

If you use water-based paint, please give the percentage of water-based
paint used for each application compared to other coating types and the
average VOC content of the paint, if known:

Primer (y/n, % of total primer use, avg. VOC content)

Base coat (y/n, % of total base coat use, avg. VOC content)

Clear coat (y/n, % of total base coat use, avg. VOC content)

Solvent Usage

How many gallons of solvent do you use each week during solvent
wipe-down and equipment cleaning?

Do you use methylene chloride?  If not, what have you replaced it with?

What percentage of the solvent that you use does not contain any
hazardous air pollutants (zero HAP)?

What percentage of the solvent that you use is called “low-VOC”
solvent?

Work Practices

Do you keep all paint, solvent, and waste liquid containers closed when
not in use?

Paint Mixing

Do you use a computerized paint mixing system?

Now, please tell us about changes you plan to make in the next 6 months.

Spray Booths

Do you plan to purchase and/or install a spray booth?  Will it have 98%
efficient filters?

Do you plan to purchase and/or install a ventilated prep station?

Will the prep station contain an infrared heater or any other type of
heater (please specify)?

HVLP Spray Guns

Do you plan to purchase any HVLP guns?  If so, how many?

What percentage of coating operations will use the new gun(s):  primer,
base coat, and/or clear coat?

Do you plan to send any of your painters to training in spray gun use? 
If so, how many and what type of training?

Gun Cleaning

Do you plan to purchase and/or install an enclosed gun cleaning system? 
If so, how many guns will  it clean?

Do you plan to start or expand cleaning solvent recycling?

Sanding

Do you plan to start using wet sanding methods?  If so, what is the
total percentage of sanding it will cover?

Do you plan to purchase and/or install a ventilated sander (dry vacuum)?
 If so, what is the total percentage of sanding it will cover?

Do you plan to purchase and/or install an overhead sanding system?  If
so, what is the total percentage of sanding it will cover?

Paint Usage

Do you plan to start using more water-based paint?  If so, please give
the percentage of water-based paint used for each application compared
to other coating types: and the average VOC content:

Primer (y/n, % of total primer use, avg. VOC content)

Base coat (y/n, % of total base coat use, avg. VOC content)

Clear coat (y/n, % of total base coat use, avg. VOC content)

Solvent Usage

Do you plan to replace use of methylene chloride with another solvent? 
If so what percentage will you replace with what product?

Do you plan to start using more solvent that does not contain any
hazardous air pollutants (zero HAP)?  If so, what percentage of solvent
use will this be?

Do you plan to start using more “low-VOC” solvent?  If so, what
percentage of solvent use will this be?

Work Practices

Do you plan to start keeping all paint, solvent, and waste liquid
containers closed when not in use?

Paint Mixing

Do you plan to purchase and/or install a paint mixing system?

DRAFT 

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