Document RpYemwkeqndZBo6qnKBkX1Mqz

Report Title: Inspection Date(s): Regulatory Program(s): Company Name: Facility Name: Facility Location: Latitude: County/Parish: AFS/ICIS-Air Number: Permit Number: NAICS Code: DSBID #: Clean Air Act Inspection of Capital Benz Auto Service 12/06/2023 NESHAP, SIP Capital Benz Auto Service Same as above 1801 Adams Street NE Washington, D.C. 20018 38.92023 District of Columbia Longitude: -76.97847 03000DC00007 N/A 811111, 811121 ECAD-79 SIC: 7538 Facility Representatives: Point of Contact Desalegn Zeleke, Manager Phone: 202-560-5889 Email: Capitalbenz1801@gmail.com EPA Inspectors: Carly Joseph, Air Inspector, 3ED21 Phone: 215-814-2127 Email: Joseph.Carly@epa.gov Dean DeLuca, Physical Scientist, 3ED21 Phone: 304-234-0264 Email: DeLuca.Dean@epa.gov State/Local Inspectors: Kush Kharod, DOEE Phone: 202-924-5647 Email: Kush.Kharod@dc.gov EPA Lead Inspector Signature Supervisor Signature Digitally signed by Carly Carly Joseph Date: 2024.01.30 Joseph 13:24:48 -05'00' Carly Joseph 701 Mapes Road Fort Meade, MD 20755-5350 KRISTEN HALL Digitally signed by KRISTEN HALL Date: 2024.01.31 14:34:33 -05'00' Kristen Hall Date Date DSBID #: ECAD-79 Table of Contents I. Introduction ............................................................................................................................... 3 A. Summary of the Facility......................................................................................................... 3 B. Inspection Opening Conference............................................................................................ 3 II. Site Activity/Process Description .............................................................................................. 3 III. Observations ............................................................................................................................ 4 IV. Closing Conference .................................................................................................................. 4 V. List of Attachments ................................................................................................................... 6 2 DSBID #: ECAD-79 I. Introduction The United States Environmental Protection Agency (EPA) conducted a Clean Air Act (CAA) inspection at Capital Benz Auto Service (Capital Benz or Facility) to verify compliance with applicable State and Federal regulations. The Department of Energy and Environment (DOEE) was notified of the inspection on November 20, 2023 via email. The inspection included an evaluation of the Facility's processes and its compliance with the CAA. All information included in this report is the result of statements by the Facility representatives, materials shown to the inspectors by the Facility representatives, and/or documents provided by the Facility representatives to the inspectors at the time of, or subsequent to, the inspection. In addition, information gathered prior to the inspection from a review of EPA and State records may be included in Section A. Summary of the Facility. A. Summary of the Facility The Facility is located at 1801 Adams St. NE, Washington, DC 20018. Capital Benz performs general maintenance and mechanical work on cars. The Facility specializes in all Mercedes Benz vehicles and quality service. The Facility does not have any federal or state air permits. The Facility is subject to, or potentially subject to, the following federal regulations: 40 CFR Part 63 Subpart HHHHHH - National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources (NESHAP 6H) B. Inspection Opening Conference At 10:37 AM on December 6, 2023, EPA inspectors arrived at the Facility for a CAA Inspection and conducted a brief opening conference. Capital Benz was represented by Manager, Desalegn Zeleke. Also, Kush Kharod from DOEE was present. EPA inspectors, Carly Joseph and Dean DeLuca, presented their credentials and explained the purpose of the visit was to conduct a CAA inspection to determine compliance with their permit and any applicable regulations. Additionally, EPA informed the facility representatives of their right to claim any confidential business information (CBI). At that time, Desalegn Zeleke did not claim any photos or documentation as CBI. II. Site Activity/Process Description Customer Service Representative, Samrawit Haite, of Capital Benz greeted inspectors upon arrival and explained the manager, Desalegn Zeleke, would assist us shortly. Mrs. Haite stated she's worked at Capital Benz for the past two years. Desalegn Zeleke stated that the Facility has been operating at its current location for approximately eight years. Capital Benz has three full time employees and a contracted painter. Mr. Zeleke explained that he's been renting the property from Mr. Gupta since 3 DSBID #: ECAD-79 2017. Mr. Gupta owns the enclosed paint booth. The Facility's hours of operation are 8am-6pm Monday through Friday and Saturday's 8am- 2pm. Capital Benz consists of a single building with a two-bay garage, three lifts, and an enclosed paint booth that vents to the atmosphere. Capital Benz performs mechanical work and general maintenance on cars with the services offered including tune-ups, engine repair, transmission, suspension, and more. Ms. Joseph inquired whether the Facility conducts paint stripping utilizing methylene chloride. Mr. Zeleke indicated that Capital Benz does not conduct any chemical paint stripping. The Facility conducts sanding to prepare a vehicle for painting. Mr. Zeleke explained that sometimes Capital Benz takes vehicles across the street for painting and minor painting is conducted in the bay of the Facility. III. Observations EPA inspectors were led on a walkthrough of the Facility by Desalegn Zeleke of Capital Benz and Kush Kharod from DOEE was also present for the walkthrough. EPA inspectors noted Dean DeLuca would take photos during the Facility walkthrough (Attachment 1). The inspection team entered the garage through the bay and observed five cars in one bay receiving maintenance. The inspection team walked through the garage and observed a pile of engines and a separate pile of three transmissions. Mr. Zeleke indicated the Facility removes engines and transmissions and replaces them with new ones. The team observed a Safety Kleen parts cleaner inside the bay. Mr. Zeleke led the inspection team to the enclosed paint booth. The inspection team entered the paint booth that contained a white vehicle inside. The filters were located on the top of the paint booth and on bottom lower side walls of the paint booth. The observed filters were heavily laden with dirt, dust, or paint overspray. Mr. Deluca requested that Mr. Zeleke turn on the paint so the inspection team could observe how the paint booth operates. Some air could be felt going into the paint booth through the vehicle door. However, the airflow of the booth was unable to demonstrate that the booth was operating under negative pressure. The inspection team exited the paint booth and observed the outside of the booth. The enclosed paint booth had two stacks on top that vent to the atmosphere. Mr. Zeleke stated the Facility paints about one car a month and changes the filters 1-2 times a year. Next, the inspection team observed the Facility's paint storage area. Mr. Zeleke stated Capital Benz purchases paint from Paint Shop Supply and Paisanos Auto Supply. Mr. Zeleke also explained that the Facility's painter is a contractor and he's unsure if the painter has any certifications. The inspections team observed Capital Benz's spray guns which included: six HVLP spray guns, one SATA KLC spray gun, and one Devilbiss Pro Lite spray gun. IV. Closing Conference After the walkthrough, EPA inspectors, Desalegn Zeleke, and Kush Kharod had a brief closing conference to ask additional questions and discuss observations. Mr. Zeleke allowed the inspection team to observe a record of the Facility's hazardous waste offsite shipment generated from the 4 DSBID #: ECAD-79 Facility's Safety Kleen parts washer. The EPA inspectors noted that the investigation is on-going, and any areas of concern identified in the final report do not necessarily reflect a violation or deviation, rather, they are areas that will require further investigation. EPA also noted that they would issue an inspection report within 60 days, with a copy to the DOEE. The inspection concluded at 11:34 AM. The following have been identified as potential issues during the inspection. They are issues that require either further investigation by EPA or additional information or explanation by Capital Benz. During the inspection, the Facility did not provide any documentation showing their painters are certified as required in NESHAP 6H. During the inspection, the Facility did not provide any documentation showing their filter technology achieved at least 98% capture of the paint overspray and exhaust filters were missing in the spray booth. During the inspection, the spray booth did not demonstrate that it was ventilated at a negative pressure and drawing air into the spray booth. EPA will review the paint spray guns observed at the Facility to determine if all spray guns are high volume low pressure (HVLP), electrostatic application, airless, air-assisted airless, or an equivalent technology. During the inspection, the Facility did not demonstrate that any records were being maintained as required in NESHAP 6H. 5 DSBID #: ECAD-79 V. List of Attachments Attachment 1: Photo Log 6 Attachment 1: PHOTO LOG Facility: Capital Benz Auto Service Location: 1801 Adams Street NE, Washington, DC 20018 Inspection Date: December 6, 2023 EPA Inspector(s): Carly Joseph and Dean DeLuca Photographer: Dean DeLuca Photo Number: 58 Photo Description: Exterior of Capital Benz Auto Service Capital Benz Auto Service, December 6, 2023 Page 2 of 14 Photo Number: 59 Photo Description: Interior of Garage Capital Benz Auto Service, December 6, 2023 Page 3 of 14 Photo Number: 60 Photo Description: Exterior of paint booth Capital Benz Auto Service, December 6, 2023 Page 4 of 14 Photo Number: 61 Photo Description: Safety Kleen Parts Cleaner Capital Benz Auto Service, December 6, 2023 Page 5 of 14 Photo Number: 62 Photo Description: Interior of paint booth Capital Benz Auto Service, December 6, 2023 Page 6 of 14 Photo Number: 63 Photo Description: Interior of paint booth Capital Benz Auto Service, December 6, 2023 Page 7 of 14 Photo Number: 64 Photo Description: Top of paint booth Capital Benz Auto Service, December 6, 2023 Page 8 of 14 Photo Number: 65 Photo Description: storage area behind the paint booth Capital Benz Auto Service, December 6, 2023 Page 9 of 14 Photo Number: 66 Photo Description: interior of paint booth Capital Benz Auto Service, December 6, 2023 Page 10 of 14 Photo Number: 67 Photo Description: paint storage area Capital Benz Auto Service, December 6, 2023 Page 11 of 14 Photo Number: 68 Photo Description: stack on top of paint booth Capital Benz Auto Service, December 6, 2023 Page 12 of 14 Photo Number: 69 Photo Description: Hazardous waste removal record Capital Benz Auto Service, December 6, 2023 Page 13 of 14 Photo Number: 70 Photo Description: Hazardous waste removal record Capital Benz Auto Service, December 6, 2023 Page 14 of 14