February 1, 2012

1. Pinal County Air Quality Control DistrictOwner / Operator Training for compliance with the Area Source Rule for Painting and Stripping and Miscellaneous Surface Coating Operations February 1, 2012

2. Course Objective • Objective • Train owners and operators of painting operations on how to comply with the National Emission Standard for Hazardous Air Pollutants (NESHAP) for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources • Title 40 Code of Federal Regulations (CFR) Part 63 Subpart HHHHHH • Here after referred to as the 6H Paint Rule

3. World's most expensive accident? • Eight Ferraris, a Lamborghini, and two Mercedes pile up on 12/4/11 in Japan

4. Course Overview • Area source background • Resources • Who is subject to the rule • Operation requirements • Training requirements • Recordkeeping requirements • Notification requirements • Reporting requirements

5. Area Source Rules Background • The Clean Air Act (CAA) lists 187 Hazardous Air Pollutants (HAPs) • National Emission Standards for Hazardous Air Pollutants (NESHAP) are utilized to control emissions of these HAPs • Major source – a facility that emits or has the potential to emit a least 10 tons per year of a single HAP or 25 tons per year of multiple HAPs • Maximum Achievable Control Technology (MACT) standards are developed for major sources • Area source – HAP emitters that are not a major source • MACT standards must be considered, but EPA may establish area source rules based on Generally Available Control Technology (GACT)

6. Area Source Rules Background • The Environmental Protection Agency (EPA) was required to identify at least 30 HAPs that pose the greatest potential health threat in urban areas • EPA identified 33 such HAPs • The EPA was required to identify area sources that account for 90% of the emissions of those 33 HAPs • EPA identified 70 such area sources • Autobody Refinishing and Paint Stripping are two of these sources • The 6H Paint Rule was developed to require the use of Best Management Practices (BMPs), considered to be GACT, to reduce HAP emissions from paint stripping and surface coating operations.

7. 6H Paint Rule status • 40 CFR 63 Subpart HHHHHH has been adopted into the Pinal County Air Quality Control District Code of Regulations (PCAQCD Code) • The EPA has not yet delegated Pinal County Air Quality Control District (PCAQCD) the authority to enforce 40 CFR 63 Subpart HHHHHH • The compliance date for this rule has already occurred and PCAQCD permits have been issued incorporating the rule provisions

8. EPA Video • 19 minute video featuring Jeff Gordon and large and small shop owners • http://www.epa.gov/collisionrepair/training.html • Includes information on: • 6H Paint Rule • Best practices • Saving money • Worker protection • Outreach resources

9. Additional Resources • http://www.epa.gov/collisionrepair/ • http://www.ccar-greenlink.org/index.php • http://www.sbeap.org/aqrules/page/6h-rule

10. Who is subject to the 6H Paint Rule? • Paint Stripping operations that use chemical strippers that contain methylene chloride (MeCl) • Motor vehicle and mobile equipment spray applied surface coating operations • Spray applications of coating containing compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadium (Cd) to plastic or metal products and parts other than motor vehicles or mobile equipment. • The target HAPs

11. Who is not subject to the 6H Paint Rule? • Coating or paint stripping performed at US military installations • Coating or paint stripping of military munitions or equipment used exclusively for transporting military munitions • Coating or paint stripping that is considered a “research or laboratory” or “quality control” or “maintenance” activity • The activity must meet the strict definitions of “research or laboratory” or “quality control” or “maintenance” as found in the rule • Normal activities at a paint shop do not meet any of these definitions • Coating or paint stripping activities covered under another area source NESHAP

12. Who might be subject to the 6H Paint Rule • Coating or paint stripping performed by individuals on their own personal vehicles • If 2 vehicles or less are painted per year the 6H Paint Rule will not apply, • A PCAQCD permit is still required for all spray painting operations • The 6H Paint Rule applies to all motor vehicle and mobile equipment surface coating operations. • Shop owners may petition for an exemption by demonstrating that no coatings containing the target HAPs are used in the shop • Target HAPs = coatings containing compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadium (Cd) • Example Form http://www.epa.gov/collisionrepair/pdfs/petitionforexemption.pdf

13. What does the 6H Paint Rule require • Use of specific practices to minimize evaporative losses of MeCl from paint strippers • Use of specific practices to minimize paint overspray and other sources of paint emissions • Painter training on the required BMPs and compliance with the Rule • Recordkeeping • Notification and reporting

14. Paint Stripping Requirements • Minimize MeCl use • Evaluate each job on the need for paint stripping (e.g. can it be recoated as is) • Evaluate each job for alternatives to MeCl strippers (e.g. mechanical stripping and blasting – both of which trigger PCAQCD permitting requirements ) • Reduce exposure of all MeCl containing paint strippers to the air • Optimize application conditions to reduce MeCl evaporation (e.g. minimize heating temperatures) • Practice proper storage (e.g. closed and air tight containers) and disposal of MeCl strippers • Maintain records of annual usage of MeCl strippers

15. Paint Stripping Requirements • Additional requirements if you use more than 1 ton per year of MeCl • Develop a written MeCl minimization plan explaining how the management practices on the previous slide are to be implemented • Post a placard or sign outlining the plan in areas where paint stripping activities are performed • Maintain a copy of the plan on site • Document an annual plan review and update as necessary

16. Surface Coating Booth Requirements • Coatings must be applied in a prep station, spray booth or mobile enclosure that meets the following requirements • Equipped with filter technology capable of achieving at least 98% capture of paint overspray • If large enough to hold a complete vehicle • Be fully enclosed with a full roof and four complete walls or curtains and be ventilated at negative pressure • If used for parts or products • Have a full roof, three complete walls or curtains and be operated at negative pressure • If used for mobile spot repairs • Enclose the part and if necessary seal to the part to retain and direct overspray to a filter

17. Spray Gun Requirements • All spray-applied coatings must be applied with: • A High Volume Low Pressure (HVLP) spray gun • By electrostatic precipitation • An airless spray gun • An air assisted airless spray gun • Equivalent technology that has been preapproved and meet specific transfer efficiency requirements

18. Spray Gun Cleaning Requirements • All gun cleaning must be done so that atomized mist or spray of cleaning solvents and paint residue are not released outside of a collection container • Options include • Disassemble gun in a container of solvent • Flush solvent thru the gun without atomizing • Using a fully enclosed washer

19. Painter Training Requirements • All new, existing and contract personnel who spray apply coatings must have hands-on and classroom training • This class will not fulfill these training requirements • Develop your own in house training or, • Work with a paint supplier as many conduct classes or, • Work with a trade school or community college

20. Painter Training Requirements • The training must cover: • Spray gun selection, set up and operation, including: • Measuring coating viscosity, • Selecting the proper fluid tip or nozzle • Achieving the proper spray pattern • Achieving the proper air pressure and volume and fluid delivery rate • Spray techniques for different types of coatings to improve transfer efficiency and minimize coating usage and overspray, including: • Maintaining the correct spray gun distance and angle to the part • Using proper banding and overlap • Reducing lead and lag spraying for each stroke • Spray booth maintenance including filter selection, installation and maintenance • Environmental compliance with the 6H Paint Rule • e.g. where painting can be done, gun selection, cleaning requirements, etc.

21. Painter Training Requirements • Owners and operators must: • Maintain a list of the names and job descriptions of all current painters who are required to be trained • Train painters within 180 days of hire • Supply painters refresher training within 5 years from previous training date • Record painter’s name and date of initial or refresher training • Record a description of the methods used to demonstrate, document and provide certification of successful completion of the required training • e.g. Your plan, training outline, handouts, who conducted it • Optional form to record this information • http://www.epa.gov/ttn/atw/area/ex_painter_training_cert_form.pdf

22. Reporting Requirements • Initial Notification under the 6H Paint Rule • Submit to PCAQCD and USEPA within 180 days of startup • Example form http://www.epa.gov/collisionrepair/pdfs/initialnotification.pdf • PCAQCD rules require a permit be issued prior to any equipment being installed and/or used • Compliance Status notification under the 6H Paint Rule • If you were not able to certify compliance in your initial notification you must submit a compliance status notification to PCAQCD and USEPA • Example form http://www.epa.gov/collisionrepair/pdfs/6h_compliance_ex.pdf • Your PCAQCD permit will also require an annual compliance certification to be submitted to PCAQCD by January 30 of each year documenting continuous compliance or any deviations and corrections made • Annual notification of changes report under the 6H Paint Rule • Submit to PCAQCD and USEPA by March 1 of each year if you had any changes or deviations • Document all rule deviations and increases in MeCl use • Your PCAQCD permit will require deviations to be reported to PCAQCD with 10 days • Your PCAQCD permit will require annual or semi-annual product usage reporting

23. Recordkeeping Requirements • Keep all records for 5 years • Most recent 2 years must be on-site, older records can be off-site • Owners or operators must keep the following: • Records of painter training dates • Documentation of filter efficiency of all spray booth exhaust filter material (e.g. data from the manufacturer) • If using equivalent spray guns documentation of approval • Copies of notifications and reports submitted • Records of MeCl containing paint stripper usage (e.g. MSDS, purchase receipts, amounts used per month) • If you use more than 1 ton per year of MeCl maintain your MeCl minimization plan and proof of an annual review / updates • Date and time of any deviations and corrective actions taken • Documentation of self compliance assessments

24. Contact information Pinal County Air Quality www.pinalcountyaz.gov Bob Farrell Bob.farrell@pinalcountyaz.gov 520-866-6949 Kale Walch Kale.walch@pinalcountyaz.gov 520-866-6960