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HomeMy WebLinkAboutDraft Design Guidelines and Best Management Practices for Auto Body ShopsDesign Guidelines and Best Management Practices for Auto Body Shops A Guide for Auto Body Shop Owners and Operators April 2011 Introduction The purpose of this brochure is to provide design guidelines and best management practices (BMPs) relating to auto body shops in National City. This brochure is intended to support the City's effort to improve the environmental performance of auto body shops in the City, and in turn, eliminate to the extent possible, impacts currently created by auto body operations throughout National City by providing owners and operators of auto body shops general design guidelines and BMPs. When both the design guidelines and BMPs are exercised for auto body shops, maximum benefits to worker safety, public health and the environment can be achieved. Auto body shop owners and operators are encouraged to review the general design guidelines and BMPs presented here for incorporation into their auto body business operations. These guidelines are intended to operate in conjunction with existing Municipal Code requirements. References for further information on each topic are also provided. In some cases, specific regulatory requirements may apply. In these cases, applicable regulations are also provided in the references. General Design Guidelines and Best Management Practices for New Construction of Auto Body Shops Design guidelines and BMPs are most effective when jointly coordinated. Design guidelines provide the physical facility to support effective and efficient protection of health safety and the environment while well -executed BMPs provide the mechanism to achieve and maintain protection of health safety and the environment during the operation of the auto body shop. It is arguable that an auto body shop that is a high performance and state-of-the-art facility without BMPs will underperform an auto body shop without a high performance facility, but with well -established BMPs. This brochure introduces a series of design guidelines and BMPs related to auto body shops. It is recommended that for new construction of auto body shops these design guidelines and BMPs be jointly implemented. New Construction Compared to Reusing Buildings or Retrofitting an Existing Auto Body Shop The design guidelines proposed in this brochure are intended for new construction of auto body shops BUT do not exclude their application to the reuse of an existing building for an auto body shop or the retrofitting of an existing auto body shop. It should be noted that reusing a building or retrofitting an existing auto -body shop may add more challenges, but overall is considered a more sustainable option when factoring in the life cycle costs of the materials both in the deconstruction and construction of a new.facility., The BMPs proposed in this brochure are a 1 Design Guidelines and Best Management Practices for Auto Body Shox Design Guidelines for New Construction 1. Office and customer accessible areas • Offices and customer areas should have sufficient barriers (e.g., walls, doorways) from the auto body workplace areas and separate ventilation systems to minimize potential exposures by office workers and customers to hazardous materials and equipment that may pose a health or safety risk. • Daylight measures with lighting controls and thermostats to control HVAC systems should be installed for office and customer areas, as well as in the workplace areas. 2 References 1. Nonresidential Compliance Manual for California's `2005 Energy EffciencyStandards (http://www.energy.ca.gov/title24/2005standards/nonresidential_manual.html) 2. California Building Standards Code (http://pu blicecodes.citation.com/st/ca/st/CA-P-2010-000008. htm) Figure 1: Roof Monitors 4 Design Guidelines and Best Management Practices for Auto Body, Shops' 2. Paint spray booth designs • Install and operate filter technology on all spray booths to achieve at least 98% capture efficiency. • Spray booths used for refinishing vehicles AND coating miscellaneous parts should be fully enclosed and ventilated at negative pressure or up to 0.05 inches water gauge positive pressure for booths that have seals on all doors and other openings and an automatic pressure balancing system. • All spray booths should have downdraft ventilation systems and be physically separated from mixing rooms. References 1: San Diego County Rule .6720 requires 85%. capture efficiency by weight (httpa/www.sdapcd:org/rules/rules/ROg4pdf/R67.20.pdf) 2. Federal NESHAPSubpart'HHHHHH requires 98% capture efficiency by weight; booths used for refinishing vehicles must be fully enclosed- (http://www.epa.govittn/atw/area/paintistript.pdf) 3. California Department of Toxic Substance Control 4. Cal/EPA Unified Program 5. Global Finishing Solutions 6. JunAir Technologies 7. watermasters.finishmaster.com Figure 2: Paint Spray Booth 3 5 Design Guidelines and Best Management Practices for Auto Body Slip 3. Hazardous waste storage areas • Storage areas for hazardous wastes should be enclosed and/or separate secured areas within an auto body shop. • All storage areas should have sufficient capacity for the maximum storage time for the Resource Conservation and Recovery Act (RCRA) category for the individual auto body shop. • Storage areas should be designed to contain a spill or release of hazardous waste. • Flammable and combustible materials should be kept away from property lines to assure better control and monitoring over the waste materials. This provides greater protection for neighboring facilities from exposure and potential fires. References 1: California Department of Toxic Substance Control 2. National City Fire Department 3. 2010 California Fire Code 4. Cal/EPA Unified Program 4. Mixing rooms and storage rooms for hazardous materials (inventory) • A well -designed ventilation system in a separate mixing room will vent harmful vapors and significantly improve air quality in the mixing room. • Since this has the potential to be used more frequently than the storage room, a separate room for mixing is recommended. Having a separate storage room has the advantage of providing better inventory controls and tracking. References 1 2010 California Fire Code 2. EPA Design for the Environment 5. Ventilation • All enclosed spaces should be continuously ventilated during occupied hours with outdoor air using either natural or mechanical ventilation. • Spaces where occupancy will be brief and intermittent (e.g., storage rooms), and that do not have any unusual sources of air contaminants, do not need to be directly ventilated. • High -Velocity Low -Volume orbital vacuum sanding systems, either central or portable should be installed to improve ventilation. • Paint mixing rooms should use both local and general exhaust ventilation systems in combination. 4 There are two basic types of ventilation: general exhaust ventilation and local exhaust ventilation. General exhaust ventilation systems typically consist of an exhaust fan, mounted in the ceiling or wall that pulls air out of the workroom and discharges it outdoors. Replacement air is brought into the work area by either natural means, such as windows and vents, or by a mechanical system that includes a separate make-up air fan, duct work and air registers that provide clean air to the work space. Local exhaust ventilation systems, on the other hand, 6 1 oat resign Guidelines and Best Management Practices for Auto Body Shops" remove chemicals and other contaminants at their source. Local systems are recommended for controlling hazardous vapors because, if designed properly, they remove the vapors before workers are exposed to them. All local exhaust ventilation systems need to have three basic components: a hood, ductwork and a fan. References 1. California Building' Standards Code(http://publiceco)es.catafion.corn/st/ca/st(CA-P-2010- 000008.htm) 2.2010 California'Fire Code 3. EPA Design for the Environment Clean Solvent Drum \<—r IGun Washer 0 Mixing Bench /\ Paint 1 — Waste �/ Drum E#uust Vent Top view of room — Locate exhaust vent near vapor sources Figure 3: Combination Ventilation System 6. Floor drains and water pollution control • The use of floor drains should be minimized in favor of low volume or non -liquid floor cleaning methods. • Where floor drains are needed, floor drains should have separators and holding areas in order to capture potentially hazardous wastes and allow the facility to properly dispose of the waste, if necessary, before it is discharged. • Floor drains cannot connect to any stormwater system and cannot connect to any sanitary sewer systems near any spray booth areas, hazardous material storage areas (e.g., mixing rooms), or hazardous waste storage areas, in order to remove the possibility of excess paint or other hazardous liquids from discharging in to a stormwater or sanitary sewer system. • Floors should be sealed with epoxy or suitable sealant to improve spill cleanups. • A wastewater recycling system is an excellent design measure that improves environmental and economic benefits by supplying recycled water to car washing operations and other operations instead of using City water. References 1 California Department of ToxicSu_ bstance Control 2. Caltrans Division of Construction 7 5 DesignGuidelines and Best Management Practices for Auto Body Shop Figure 4: Floor Drains 7. Site Layout • Auto body shops should be located a least 500 feet away from schools or residential areas. • The area in front of the bay doors should not allow more than four cars to be queued in front of bay doors. • Auto loading/unloading areas should be located behind buildings to assist in traffic and parking circulation. Reference National City Land Use Code 8. Parking • Parking should be provided at an appropriate allocation amount with easily accessible parking for customers and employees. • All parking for employees should be located behind buildings. • It is best if driveways and entrances are wide enough to prevent trucks from reversing into public rights -of -ways and allow maneuvering on the property for better traffic circulation. Reference National City Land Use Code 9. Vehicle storage • A time limit on vehicle storage should be enforced to ensure that vehicles awaiting repair are not kept onsite for extended periods, which helps control the amount of space dedicated to vehicle storage. • A minimum amount of storage should be provided to require facilities to create a dedicated area for storage and not rely on using onsite parking areas or storing vehicles on the street. A maximum storage area avoids large and hard -to -maintain storage areas. Vehicles awaiting repair should be stored in the storage area, not in parking or other open areas. 10. Building access • Buildings should be oriented in such a way that customers can enter the facility without crossing or interfering with repaired vehicles. • Employees should have the same building access but from the rear of the building when possible. 6 8 "«, a CA'IIFO,gJPfA - . resign Guidelines and Best Management Practices • for Auto Body Shops References 1 National City Land Use Code 2. California Building Standards Code (http://publicecodes.citation.com/stica/stlCA-P-2010-000008.htm) 3.2010 California Fire Code 11. Fire safety and access • All auto body shops should have a minimum of two access locations suitable for the access of fire fighting vehicles. • Hazardous material and hazardous waste storage areas should be identified and be easily accessible. The primary source for fire safety, the California Fire Code, provides an option for a Hazardous Materials Management Plan (HMMP) where required by the fire official. It is recommended that a HMMP or similar plan be considered for an auto body shop and include the following: • Storage and use areas • Maximum amount of each material stored or used in each area • Range of container sizes • Locations of emergency isolation and mitigation valves and devices • Product conveying piping containing liquids or gases, other than utility -owned fuel gas lines and low-pressure fuel gas lines • On and off positions of valves for valves that are of the self -indicating type • Storage plan showing the intended storage arrangement, including the location and dimensions of aisles • The location and type of emergency equipment References 1.'National City Land Use Code 2.2010 California Fire Code 12.Fencing and security measures • All vehicle storage areas should be screened in order to regulate the appearance and avoid unsightly parking Tots of vehicles awaiting repair. • Fencing or screening should be solid and decorative and no more than eight feet in height, except at the front property line, where it should be no more than six feet in height. • Screening vehicle storage areas is a simple and easy way to regulate the appearance and avoid unsightly parking lots of vehicles awaiting repair. Mandating a type and height of fencing or screening ensures that the fencing acts as a screen from the surrounding neighborhood, without becoming a visual distraction. 9 7 Design Guidelines and Best Management Practices for Auto Body Sho, Reference National City Land Use Code Figure 5: Proper Fencing Best Management Practices 1. Low -Volatile Organic Compound (VOC) paint • Low VOC paint products should be used. • The use of low VOC content paints reduces the amount of VOCs that may be released into the air during spraying. References San Diego County Rule 67.20.provides•guidance on the appropriate VOC ,-ciipint for various processes (e.g..,pretreatment coating, primer). 2. Spray gun cleaning The City of National City promotes the use of aqueous cleaners for paint spray gun cleaning applications. However, if solvent cleaners are used the following guidelines apply: • Extend the effective life of the cleaning solvent with two -stage cleaning. Spray gun equipment should be rinsed first with used solvent (if a waterborne product is not used) and then cleaned with clean solvent. • Paint guns should be cleaned with enclosed automatic paint gun washing equipment. • Disposable paint cup liners should be used as well as alternative gun cleaning technology. 8 10 Design Guidelines and Best Management Practices for Auto Body Shops References 1. Federal NESHAP Subpart HHHHHH requires that paint spray gun cleaning be done so that an atomized mist or spray of the cleaning solvent is not created outside a container that collects used gun cleaning solvent. 2. California Department of Toxic Substance Control 3. http://www.dtsc.ca.gov/PublicationsForms/prog_pubs.cfm?prog=Pollution%20Prevention 3. High Volume Low Pressure spray guns • Employees should be properly trained for the use of HVLP spray guns. • The Spray Technique Analysis and Research (STAR) program at the Iowa Waste Reduction Center has the most thorough training which teaches its students the proper paint mixture content, spray equipment type, spray equipment maintenance and spray technique (including pressures settings, spray distance and spray angle). References 1.San Diego Gounty Rule 6720 allows;'for multiple methods for coating applications that include HVLP spray guns; HVLP spray guns must have on site pressure gauges, Federal NESHAP Subpart HHHHHH allows for multiple methods for coating applications that include HVLP spray guns; cleaning requirements, training requirements 2. tIttp://waterrnasters.finishmaster.com 4. Solvent recycling The City of National City promotes the use of aqueous cleaners for paint spray gun cleaning applications. However, if solvent cleaners are used the following guidelines apply: • On -site recycling should be implemented. However, this may not be an option if the reclaimed solvent has a higher VOC content than is allowed for paint gun cleaning (California Department of Toxic Substances Control, 2006b). • If solvent is recycled on -site, the reclaimed solvent should be used only for paint spray gun cleaning. Reference http.//www.dtsc.ca.gov/PublicationsForms/prog_pubs.cfm?prog=Pollution%20Prevention 5. Sanding process and High Velocity Low Volume sanding systems • Dry sanding should be considered over wet sanding because it does not introduce a new waste stream. • A High -Velocity Low -Volume (HVLV) system should be provided. • A vacuum sanding unit with high efficiency particulate air (HEPA) filtration should be used. 9 11 Design Guidelines and Best Management Practices for Auto Body Shoff • HVLV orbital vacuum sanding systems can protect workers and others nearby from harmful dust. A HVLV sanding system uses industrial vacuum cleaners to trap sanding dust before it becomes airborne and has a compressed air driven sanding disc that is perforated with a series of holes. • Washing of dust collection systems should not be done in such a way that it collects in stormwater drains. Reference EPA Design for the Environment 6. Hazardous waste generation and disposal • Hazardous waste should be handled and disposed of in accordance with the applicable RCRA and California requirements. • There should be a separation of waste streams with clear labels. Maintaining separation of recyclable wastes (e.g., used oil, solvents) can avoid the creation of hazardous waste. Many fluids can be recycled or reclaimed, but mixing can render the fluids non - recyclable and create hazardous waste. • Containers should be in good condition and compatible with the material they are holding. Each container should remain closed except when adding or subtracting wastes. Containers should be clearly labeled with the following: ✓ The date hazardous wastes began accumulating in that container ✓ The lettering, "Hazardous Waste" visible on the outside of the container ✓ The composition and physical state (solid or liquid) of the waste ✓ The hazardous properties of the waste (toxic, ignitable, corrosive, reactive) ✓ The name and address of the generator • Reusable cloth rags and towels should be used at permitted facilities to reduce trash volume and possibly ihcreased hazardous waste generation. Used rags or towels that are contaminated with automotive fluids or gasoline may be considered hazardous materials. • To the extent practical, reusable cloth rags and towels should be used and laundered at an appropriate laundry facility. Rags and towels that are to be disposed should be stored in an appropriate, marked container and disposed of at an approved permitted facility that can handle these materials. References 1. California Department of Toxic SubstanceControl 2. California Code of Regulations 3. San Diego County Hazardous Materials Division 4. http://www.dtsc.ca.gov/PublicationsForms/prog pubs.cfm?prog=Pollution%20Prevention 10 12 !esign Guidelines and Best Management Practices,for Auto Body Shops UNIVERSAL WASTE CONTCNTS ACCUMULATION START IIATE SHIPPER AOORESS CITY, STATE, ZIP HAZAR.PcDUS WASTE Ew[A�+,.AWPAprymnyzAA n.,.. �> HANP4,£'WITh CARE! Figure 6: Proper Hazardous Waste Labels 7. Pollution prevention Pollution prevention refers to activities that reduce the amount of pollution generated by a process such as the handling, use and disposal of hazardous materials. Pollution prevention should include the most basic steps first, such as: • Improving inventory control • Reducing the amount of products in storage • Using first -in, first -out for paint and materials • Inventorying storage areas regularly • Keeping containers closed and inspecting for leaks • Using good housekeeping practices References 1. San Diego County Hazardous 'Materials Division 2 California Department of Toxic Substance Control 3. EPA Region 9: Waste Programs 8. Stormwater Pollution Prevention Plan (SWPPP) A Stormwater Pollution Prevention Plan (SWPPP) should be implemented for each auto body shop. A SWPPP provides a systematic approach to preventing contamination of the stormwater system. SWPPP requirements can be found in Chapter 14.22 of the National City Municipal Code. References 1. National City Storm Water Division 2. National City Municipal Code 3. California Department of Toxic Substance Control 9. Sanding waste Sanding waste, especially with wet sanding, may contain toxic metals that can contaminate surface waters. 11 13 Design Guidelines and Best Management Practices for Auto Body Shoi • This waste should not be washed to gutters, streets, or storm drains whether or not it is hazardous waste. • With wet sanding, minimal water would be used and then collected before entering the sanitary sewer when possible. Also the wash water should be collected in a clarifier before discharging to the sanitary sewer. • The clarifier should be inspected and serviced regularly. • A vacuum sanding unit can also minimize the uncontrolled discharge of sanding waste during dry sanding operations. References 1 California Department of Toxic Substance Control 2 http://www.dtsc ca.gov/PublicationsForms/prog pubs.cfm7progPollution%20Prevention 10. Wastewater and storm drains In general: • Waste water from wash areas should flow AWAY from storm drains. • Cars should be washed in a bermed and covered wash area. • A contained wash pad should be installed prior to the sanitary sewer. If a permanent wash pad cannot be installed, a portable wash pad should be used with a pumping system to the sanitary sewer drain. • A closed loop water recycling system should be installed to reduce water use and trap contaminants. References 1. California Department of Toxic Substance Control: 2. http //www.dtsc ca.gov/PublicationsForms/prog_pubs.cfm'?prog=Pollution%o20Prevention 11. General environmental regulation and compliance All businesses should determine applicable regulatory requirements, appropriate compliance options and permitting requirements. • If operations where usage exceeds 20 gallons or 150 pounds of VOC emissions per consecutive 12-month period, then the businesses must follow San Diego County Rule 67.20, Motor Vehicle and Mobile Equipment Refinishing Operations. • An Integrated Maintenance and Operational Plan (iMOP) should also be considered. This plan would outline the types of equipment and maintenance procedures used at the facilities and integrate environmental and occupational sectors. The plan would be maintained and provided upon request, but not required for submittal to the City. 12 References 1..San Diego County Rule 67 20srequires_submission of an Operation and Maintenance Plan to local': Air Pollution Control Officer for air pollution controldevice and emission collection systems. 2. San Diego County Department of Environmental Health 3. National City.Planning Division, National City Fire Department 14 SRCOttrOisATBP coign Guidelines and Best Management Practices for Auto Body Shops 12. Waterborne coatings and paints • Waterborne coatings and paints are considered less toxic and have lower VOC levels compared to solvent -borne products. It is possible to use less product with waterborne coatings and paints when compared to solvent -based products. This can lead to an immediate cost savings. • Waterborne products may have a shelf life between 24 and 60 months. In some cases, waterborne products may have an advantage over solvent -borne products, such as with the use of waterborne primer where solvent primer would react with existing substrate materials or coatings. • There is a concern about added drying times with waterborne coatings. This can be easily addressed with the proper air movement in a spray booth. Depending on the booth cycles per day, there are different methods to improve air movement in a booth, which will improve drying times. References 1.'San Diego County Rule 67.20 proposed revisiohs to' Rule 67.20 but not with current rule 2.PPG. 3. DuPont 4. http://watermasters finishmaster c om 13.Inventory control practices An inventory control practice reduces costs and potential hazards, such as a spill or fire. • It is essential to minimize inventory and purchase only what is needed. The first -in, first - out principle is also important to ensure that the older materials are used first. • All materials should to be stored to maintain proper temperature, humidity and to reduce material degradation. • Inventory limits should not exceed emergency response capacity. • It is recommended that shops minimize the use of similar solvents and use waste exchange programs. • Excess materials that are not needed at one auto body shop can be of value to another auto body shop which may have a use for that material. If a network of auto body shops can be identified and created, an exchange program can be developed to exchange excess materials. This can help transfer valuable materials to facilities that may need these materials rather than disposing of the excess materials as a waste. In addition, the network could include local or regional vocational or technical schools that would benefit from excess materials that would have otherwise been wasted. References 1 California "Department of Tozi 2. National City `Fire Departmertc 15 ut tance i 13 esign Guidelines and Best Management Practices for Auto Body Sho 14. Personal protection equipment As mentioned earlier: • Cal/OSHA requires California employers to have a written Injury and Illness Prevention (IIP) Program and Respiratory Protection Program (RPP) for its employees. • Auto body shops should have an IIP and RPP to ensure health and safety in the workplace. These programs address such measures as worker evaluation, selection of appropriate air -purifying or supplied -air respirators, fit -testing, training and maintenance. This includes wearing goggles or face shields when operating sanding or grinding equipment, installing dust collectors on sanders and grinders and installing splash guards on grinders that use coolants. • Also it is essential to have safety guards on any mechanical equipment as well as always wearing the appropriate clothing (e.g., no loose clothing). • Employers need to enforce these practices with employees and provide periodic training that is culturally respective and effective. References 1.:Cal/OSHA 2OSHA 15. Training • Training should be provided for all employees of auto body shops. • Training needs may vary for different job functions such as painters. • Training can include in-house training performed by management or equipment and material suppliers or external training using local technical schools and manufacturer training programs. Currently in San Diego there are two small colleges that have established training programs for auto body shops. The Cuyamaca College in El Cahon and the Southwestern College in Chula Vista both have training programs intended for auto body shop employees References Federal NESHAP Subpart HHHHHH'requires'training/certification of all painters on spray` gun equipment selection, spray techniques, maintenance, and environmental compliance 2. San Diego County Department of Environmental Health 3. httpa/watermasters.finishmaster com 16. Recordkeeping Recordkeeping can play an important role in evaluating an auto body shop's operating practices. Records should be maintained for the following: • Hazardous material inventories including paints, solvents, and other chemicals • Volumes and types of hazardous wastes generated • Volumes and disposition of hazardous wastes disposed of or recycled • Annual usage of paint strippers containing McCI 14 16 .CTIONSUCI esgn Guidelines and Best Management Practices for Auto Body Shops • Employee training • Any accidents References San Diego County Department of Environmental Health San Diego County Air Pollution Control District EPA Region 9; National City Fire Department For more information on National City's effort, please contact: Ms. Patricia Beard Redevelopment Manager City of National City pbeard@nationalcityca.gov (619) 336-4255 Mr. Martin Reeder Assistant Planner City of National City mreeder@nationalcityca.gov (619) 336-4313 17 15 Design Guidelines and Best Management Practices for Auto Body Sho; References California Building Standards Code (2010). California Fire Code, California Code of Regulations, Title 24, Part 9 (http://publicecodes.citation.com/st/ca/st/CA-P-2010-000008.htm) California Code of Regulations (CCR). Title 22, Division 4.5. http://www.dtsc.ca.gov/LawsRegsPolicies/Title22/index.cfm California Department of Toxic Control Substances. Auto Body and Paint Shops Project. http://www.dtsc.ca.gov/PollutionPrevention/ABP/index.cfm California Department of Toxic Control Substances. Pollution Prevention and Compliance Opportunities Checklist. http://www.dtsc.ca.gov/InformationResources/local_contacts.cfm California Department of Toxic Control Substances. Pollution Prevention Publications, Auto Body and Paint Shops. http://www.dtsc.ca.gov/PublicationsForms/prog_pubs.cfm?prog=Pollution%20Prevention California Department of Toxic Substances Control, Hazardous Waste Management. http://www.dtsc.ca.gov/InformationResources/local_contacts.cfm California Division of Occupational Safety and Health. Respiratory Protection. http://www.dir.ca.gov/title8/5144.html California Division of Occupational Safety and Health. Guide to Developing Your Workplace Injury and Illness Prevention Program. http://www.dir.ca.gov/dosh/dosh_publications/IIPP.html California Energy Commission. Nonresidential Compliance Manual for California's 2005 Energy Efficiency Standards. (http://www.energy.ca.gov/title24/2005standards/nonresidential_manual.html) California Environmental Protection Agency (Cal EPA). Unified Program. http://www.calepa.ca.gov/CUPA/ Caltrans Division of Construction. Storm Water and Pollution Control. http://www.dot.ca.gov/hq/construc/stormwater/stormwater1.htm DuPont Automotive Paints and Coatings. http://www2. dupont.com/Automotive/en_US/products_services/paintCoatings/paintCoatings. html Global Finishing Solutions. http://www.globalfinishing.com/ JunAir Technologies. http://www.junairamericas.com/pdfs/qads.pdfNational City Fire Department National City, California. Planning and Building Divisions. http://www.anational- City.ca.us/index.aspx?page=160 National City, California. Fire Department. http://www.ci.national-city.ca.us/index.aspx?page=126 National City, California. Stormwater Division. http://www.ci.national-city.ca.us/index.aspx?page=164 National City, California. Land Use Code, http://www.nationalcityca.gov/index.aspx?page=175 PPG Industries. Auto Refinish. http://corporateportal.ppg.com/Refinish/default.htm San Diego County Air Pollution Control District. Auto Repair and Auto Body. Stormwater Best Management Practices (BMPs). http://www. sdcounty. ca.gov/dpw/watersheds/watershedpdf/bmp_2009_auto_repai r+body. pdf San Diego County Air Pollution Control District. http://www.sdapcd.org/index.html San Diego County Air Pollution Control District. Rule 67.20 Motor Vehicle and Mobile Equipment Refinishing Operations. http://www.sdapcd.org/rules/rules/Reg4pdf/R67-20.pdf 16 18 esign Guidelines and Best Management Practices for Auto Body ,Shops San Diego County Department of Environmental Health. (2009), San Diego Area Green Business Program. http://www.sdcounty.ca.gov/deh/doing_business/chd_greenbus.html San Diego County Hazardous Materials Division, Waste and Recycling. http://sdpublic. sdcounty.ca.gov/portal/page?_pageid=93,298343&_dad=portal&_schema=PORTAL U.S. Department of Labor, Occupational Health and Safety Administration. 1910.94 Ventilation. http://www.osha.gov/pls/oshaweb/owadisp. show_document?p_id=9734&p_table=standards Unites States Environmental Protection Agency (USEPA). National Emission Standards For Hazardous Air Pollutants (NESHAP) (Subpart HHHHHH), Final Rule, Summary Of Regulations Controlling Air Emissions From Paint Stripping And Miscellaneous Surface Coating Operations. http://www.epa.govittn/atw/area/paint_stripb.pdf USEPA. Design for the Environment. http://www.epa.gov/dfe/index.htm USEPA. Hazardous Wastes. http://www.epa.gov/osw/hazard/index.htm USEPA. Improving Air Quality in Your Community. Retrieved June 6, 2009 from: http://www.epa.gov/air/community/details/autobody_shops.html USEPA. Reducing Air Pollution from Auto Body Shops. http://www.epa.gov/oar/toxicair/community/guide/autobody_comm jnfo. pdf USEPA. Summary of Regulations Controlling Air Emissions from Paint Stripping and Miscellaneous Surface Coating Operations. http://www.epa.gov/ttn/atw/area/paint_stripb.pdf Watermasters. http://watermasters.finishmaster.com 17 19