national emission standards for hhazardous air pollutants

11

National Emission Standards for National Emission Standards for Hazardous Air Pollutants (NESHAP):Hazardous Air Pollutants (NESHAP):

EPA’s Paint Stripping and EPA’s Paint Stripping and Miscellaneous Surface Coating Miscellaneous Surface Coating

0perations at Area Sources Rule0perations at Area Sources Rule(40 CFR Part 63, Subpart HHHHHH)(40 CFR Part 63, Subpart HHHHHH)

Deborah Craig, EPA Region 2 (NY, NJ, PR & VI)Deborah Craig, EPA Region 2 (NY, NJ, PR & VI)[email protected]@epa.gov212.637.3521212.637.3521http://www.epa.gov/region2/autohttp://www.epa.gov/region2/autoOn web site, scroll past green banner, see On web site, scroll past green banner, see Auto Body Shops: Compliance ReminderAuto Body Shops: Compliance Reminder

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Presentation will cover:Presentation will cover:�� Background: Why did EPA create this rule?Background: Why did EPA create this rule?�� Enforcement of rule Enforcement of rule �� Regulated sources Regulated sources �� Exempted sourcesExempted sources�� Opportunity to apply for exemption from ruleOpportunity to apply for exemption from rule�� Compliance dates for new and existing sourcesCompliance dates for new and existing sources�� Compliance requirementsCompliance requirements�� Submittal of Initial Notification, Notification of Compliance and, if Submittal of Initial Notification, Notification of Compliance and, if applicable, Notification of Annual Changesapplicable, Notification of Annual Changes�� Recordkeeping Recordkeeping �� Summary Table of Key DatesSummary Table of Key Dates�� Contact/ResourcesContact/Resources

33

Background: Why did EPA Create this Rule?Background: Why did EPA Create this Rule?

�� National Emission Standard for Hazardous Air National Emission Standard for Hazardous Air Pollutants (NESHAP): Paint Stripping and Pollutants (NESHAP): Paint Stripping and Miscellaneous Surface Coating Operations at Miscellaneous Surface Coating Operations at Area Sources Area Sources �� Published January 9, 2008 amended on February Published January 9, 2008 amended on February 13, 200813, 2008�� Found in the Code of Federal Regulations (CFR) Found in the Code of Federal Regulations (CFR) at 40 CFR Part 63 Subpart HHHHHH at 40 CFR Part 63 Subpart HHHHHH �� Copy of rule, guidance documents and forms Copy of rule, guidance documents and forms available at: available at: http://www.epa.gov/region2/autohttp://www.epa.gov/region2/auto

44

Background Cont’dBackground Cont’d�� Under the Clean Air Act, EPA has identified Under the Clean Air Act, EPA has identified 70 small industrial “area sources” that 70 small industrial “area sources” that emit most of the hazardous air pollutants emit most of the hazardous air pollutants known as “HAPs” or air toxics in urban known as “HAPs” or air toxics in urban areas. areas.

�� An area source has the potential to emit An area source has the potential to emit less than 10 tons per year of any single less than 10 tons per year of any single HAP and less than 25 tons per year of any HAP and less than 25 tons per year of any combination of HAPscombination of HAPs

55

Background Cont’dBackground Cont’d�� Many coatings used in motor vehicle and mobile Many coatings used in motor vehicle and mobile equipment refinishing contain HAPs: Chromium, Lead, equipment refinishing contain HAPs: Chromium, Lead, Cadmium, Manganese and Nickel compounds (“target Cadmium, Manganese and Nickel compounds (“target HAPs” under the rule)HAPs” under the rule)

�� The Clean Air Act requires EPA to reduce exposure to The Clean Air Act requires EPA to reduce exposure to HAPs because these chemicals are known, or suspected, HAPs because these chemicals are known, or suspected, to cause cancer, respiratory problems, eye and skin to cause cancer, respiratory problems, eye and skin irritations, and other serious health effects.irritations, and other serious health effects.

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Enforcement of Rule in EPA Region 2Enforcement of Rule in EPA Region 2(NY, NJ, PR and VI)(NY, NJ, PR and VI)

�� Currently, EPA Region 2 is the agency Currently, EPA Region 2 is the agency responsible for enforcing the Federal rule responsible for enforcing the Federal rule in New York and New Jersey in New York and New Jersey �� State environmental agencies may elect to State environmental agencies may elect to accept enforcement authority accept enforcement authority -- Puerto Puerto Rico and Virgin Islands have been Rico and Virgin Islands have been delegated the authority for this ruledelegated the authority for this rule

77

Regulated SourcesRegulated Sources40 CFR40 CFR § 63.11170 and definitions under 63.1118063.11170 and definitions under 63.11180

�� Paint stripping using Paint stripping using any amountany amount of Methylene Chloride (also known as of Methylene Chloride (also known as Dichloromethane). Dichloromethane). �� SpraySpray--apply surface coating using a apply surface coating using a hand heldhand held device such as HVLP device such as HVLP gun to create atomized mist of coating onto gun to create atomized mist of coating onto assembledassembled::

-- motor vehiclesmotor vehicles: cars, light duty trucks, golf carts, vans : cars, light duty trucks, golf carts, vans and motorcycles and motorcycles

-- mobile equipmentmobile equipment: heavy duty trucks, truck trailers, fleet delivery : heavy duty trucks, truck trailers, fleet delivery trucks, buses, mobile cranes, bulldozers, street cleaner, agricultural trucks, buses, mobile cranes, bulldozers, street cleaner, agricultural equipment, motor homes and other recreational vehiclesequipment, motor homes and other recreational vehicles-- includes fixed locations at shops and mobile refinishing operationsincludes fixed locations at shops and mobile refinishing operations--includes hobbyists that coat includes hobbyists that coat more thanmore than two motor vehicles or pieces two motor vehicles or pieces of mobile equipment per year regardless of whether payment is receivedof mobile equipment per year regardless of whether payment is received

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Regulated SourcesRegulated Sources40 CFR40 CFR § 63.11170 and definitions under 63.1118063.11170 and definitions under 63.11180

�� “Miscellaneous” spray“Miscellaneous” spray--apply surface coating use a hand held device apply surface coating use a hand held device such as HVLP gun to create atomized mist of coating onto:such as HVLP gun to create atomized mist of coating onto:-- any metal or plastic or combination of metal and plastic any metal or plastic or combination of metal and plastic partsparts or or

products that products that are notare not motor vehicles or mobile equipment (e.g., motor vehicles or mobile equipment (e.g., car bumpers or mirrors not attached to cars)car bumpers or mirrors not attached to cars)

-- ifif coatings contain target HAPs: compounds of Chromium, Lead, coatings contain target HAPs: compounds of Chromium, Lead, Manganese, Nickel or Cadmium Manganese, Nickel or Cadmium

-- if no target HAPs, automatically exempted from rule unless you if no target HAPs, automatically exempted from rule unless you use Methylene Chloride (also known as Dichloromethane) for use Methylene Chloride (also known as Dichloromethane) for paint strippingpaint stripping

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Exempted SourcesExempted Sources40 CFR40 CFR § 63.11169(d)(3)63.11169(d)(3)

Surface coating or paint stripping operations:Surface coating or paint stripping operations:

�� Performed by individuals on personal vehicles, Performed by individuals on personal vehicles, possessions, or property as a hobby or for possessions, or property as a hobby or for maintenance, or maintenance, or done by individualsdone by individuals for for othersothers without compensation are without compensation are exemptedexempted. “Hobby exemption”. “Hobby exemption”

--However, if you sprayHowever, if you spray--apply coatings to apply coatings to more thanmore thantwo motor vehicles or pieces of mobile equipment per two motor vehicles or pieces of mobile equipment per year, year, you are subject to ruleyou are subject to rule regardless of regardless of whether compensation is receivedwhether compensation is received

1010

Exempted Sources Cont’dExempted Sources Cont’d(Definition of spray applied coating operations (Definition of spray applied coating operations -- 40 CFR 40 CFR § 63.11180)63.11180)

�� SpraySpray--applied applications:applied applications:�� using handusing hand--held device with a cup capacity of 3.0 held device with a cup capacity of 3.0 fluid ounces (89 cc) or lessfluid ounces (89 cc) or less�� powder coatingpowder coating�� handhand--held, nonheld, non--refillable aerosol containersrefillable aerosol containers�� nonnon--atomizing technology atomizing technology �� brushes, rollers, hand wipingbrushes, rollers, hand wiping�� coating techniques coating techniques –– flow, dip, electrodeposition, web, coilflow, dip, electrodeposition, web, coil�� touch up markers or marking penstouch up markers or marking pens

�� thermal spray operations using solid metallic or nonthermal spray operations using solid metallic or non--metallic materialsmetallic materials

1111

Exempted Sources Cont’dExempted Sources Cont’dCoating DefinitionCoating Definition -- 40 CFR40 CFR § 63.1118063.11180

�� affected coatings do not include:affected coatings do not include:�� decorative, protective, or functional materials that decorative, protective, or functional materials that consist only of protective oils for metal, acids, bases, consist only of protective oils for metal, acids, bases, or any combinationor any combination�� paper film or plastic film that may be prepaper film or plastic film that may be pre--coated with coated with adhesiveadhesive�� adhesives, sealants, maskants, or caulking materialsadhesives, sealants, maskants, or caulking materials�� temporary protective coatings, lubricants, or surface temporary protective coatings, lubricants, or surface preparation materialspreparation materials�� inin--mold coatings that are spraymold coatings that are spray--applied in the applied in the manufacture of reinforced plastic composite partsmanufacture of reinforced plastic composite parts

1212

Exempted Sources Cont’dExempted Sources Cont’d40 CFR40 CFR § § 63.11169 (d) and 63.11170(a)(2) 63.11169 (d) and 63.11170(a)(2)

Surface coating or paint stripping: Surface coating or paint stripping: �� Facility Maintenance Facility Maintenance �� Research and laboratory activitiesResearch and laboratory activities�� Quality control activitiesQuality control activities�� Certain military activitiesCertain military activities�� Activities covered under any other area Activities covered under any other area source NESHAPsource NESHAP

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Opportunity to Apply forOpportunity to Apply forExemption Exemption

40 CFR 40 CFR § 63.11170(a)(2 ))63.11170(a)(2 ))�� Owner or operator of motor vehicle or mobile equipment surface Owner or operator of motor vehicle or mobile equipment surface coating operation may request from EPA Regional Office an coating operation may request from EPA Regional Office an exemption from rule. See “EPA Region 2 Example Petition for exemption from rule. See “EPA Region 2 Example Petition for Exemption Form” at: Exemption Form” at: http://www.epa.gov/region2/autohttp://www.epa.gov/region2/auto

�� Exemption not automatic, request must be approved by EPA. No Exemption not automatic, request must be approved by EPA. No exemption available for paint stripping.exemption available for paint stripping.�� Owner or operator must certify that they do not spray apply any Owner or operator must certify that they do not spray apply any coatings that contain compounds of the target HAPscoatings that contain compounds of the target HAPs

--coatings containing compounds of Hexavalent Chromium (Cr+6), coatings containing compounds of Hexavalent Chromium (Cr+6), Lead (Pb), Nickel (Ni) and Cadmium (Cd) that are Lead (Pb), Nickel (Ni) and Cadmium (Cd) that are carcinogenscarcinogens and and are present at more than 0.1% of the coating by mass are target are present at more than 0.1% of the coating by mass are target HAP containing coatingsHAP containing coatings--coatings containing compounds of Trivalent Chromium (Cr+3) or coatings containing compounds of Trivalent Chromium (Cr+3) or Manganese (Mn) that are Manganese (Mn) that are not carcinogensnot carcinogens and are present at more and are present at more than 1.0% of the coating by mass are also target HAP containing than 1.0% of the coating by mass are also target HAP containing coatingscoatings

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Opportunity to Apply for Exemption Cont’dOpportunity to Apply for Exemption Cont’d�� Petition by the owner or operator must also include a Petition by the owner or operator must also include a description of the coatings that are spray applied (e.g., description of the coatings that are spray applied (e.g., specify manufacturer and product line). specify manufacturer and product line). �� Refer to coating Material safety data sheets (MSDSs) or Refer to coating Material safety data sheets (MSDSs) or obtain documentation from supplier. MSDSs are not obtain documentation from supplier. MSDSs are not required to be submitted with petition.required to be submitted with petition.�� Consider switching to alternative coatings w/out target Consider switching to alternative coatings w/out target metal HAPs. metal HAPs. �� Still must submit Initial Notification form of coating Still must submit Initial Notification form of coating activities activities –– EPA must approve exemption, not automatic.EPA must approve exemption, not automatic.

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When Are New and Existing Sources Required to When Are New and Existing Sources Required to Be In Compliance With Rule?Be In Compliance With Rule?

40 CFR 40 CFR § 63.1117263.11172�� New source is a source that commenced construction New source is a source that commenced construction after September 17, 2007 by installing new paint after September 17, 2007 by installing new paint stripping or miscellaneous surface coating equipment stripping or miscellaneous surface coating equipment and and it had no paint stripping or miscellaneous surface it had no paint stripping or miscellaneous surface coating activity prior to that date.coating activity prior to that date.�� Existing source is a source that conducted paint stripping Existing source is a source that conducted paint stripping and/or miscellaneous surface coating operations on or and/or miscellaneous surface coating operations on or before September 17, 2007. before September 17, 2007. �� Purchase and installation of new equipment (e.g., spray Purchase and installation of new equipment (e.g., spray booth, HVLP guns, etc.) in order to comply with rule will booth, HVLP guns, etc.) in order to comply with rule will not make it a new sourcenot make it a new source

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When Are New and Existing Sources Required to When Are New and Existing Sources Required to Be In Compliance With Rule Cont’d? Be In Compliance With Rule Cont’d?

40 CFR 40 CFR § 63.1117263.11172

�� New source must comply by January 9, 2008 or New source must comply by January 9, 2008 or if initial startif initial start--up of operations was after this up of operations was after this date, then comply by initial startdate, then comply by initial start--up date. up date. �� Existing sources must comply by January 10, Existing sources must comply by January 10, 20112011�� See following requirements for paint stripping See following requirements for paint stripping and surface coating operationsand surface coating operations

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Requirements forRequirements forPaint Stripping Paint Stripping

(40 CFR (40 CFR § 63.11173 (a)(1)63.11173 (a)(1)--(5))(5))�� Minimize emissions of Methylene ChlorideMinimize emissions of Methylene Chloride using using the following management practices the following management practices �� Evaluate each application for need to remove paint Evaluate each application for need to remove paint (e.g. can part be re(e.g. can part be re--coated)coated)�� Evaluate each application for alternative to Methylene Evaluate each application for alternative to Methylene ChlorideChloride�� Reduce exposure of Methylene Chloride strippers to Reduce exposure of Methylene Chloride strippers to airair�� Optimize conditions when using Methylene Chloride to Optimize conditions when using Methylene Chloride to reduce evaporation (e.g., if heating, use lowest reduce evaporation (e.g., if heating, use lowest possible temperature)possible temperature)�� Use proper storage and disposal techniques (e.g., Use proper storage and disposal techniques (e.g., store stripper in closed, airtight containers)store stripper in closed, airtight containers)

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Requirements forRequirements forPaint Stripping Cont’dPaint Stripping Cont’d

(40 CFR (40 CFR § 63.11173 (b) 63.11173 (b) –– (d))(d))

�� If operation uses more than one ton of If operation uses more than one ton of Methylene Chloride in a yearMethylene Chloride in a year�� Develop and implement a written Methylene Develop and implement a written Methylene Chloride minimization planChloride minimization plan�� Post the plan in areas where activity occursPost the plan in areas where activity occurs

�� If operation uses one ton of Methylene If operation uses one ton of Methylene Chloride or lessChloride or less�� No written plan is required, but must comply No written plan is required, but must comply with minimization management practices with minimization management practices

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Requirements for Requirements for Surface Coating Cont’dSurface Coating Cont’d

(40 CFR (40 CFR § 63.11173 (e)(2)(i))63.11173 (e)(2)(i))�� SpraySpray--applied coatings must be applied in spray booth, applied coatings must be applied in spray booth, preparation station, or mobile enclosure that is:preparation station, or mobile enclosure that is:�� Fitted with filter system demonstrated to have at least 98% Fitted with filter system demonstrated to have at least 98% collection efficiency of capturing paint overspray. collection efficiency of capturing paint overspray. �� Keep record of manufacturer data for 98% or better filter Keep record of manufacturer data for 98% or better filter efficiency (American Society of Heating, Refrigerating and efficiency (American Society of Heating, Refrigerating and AirAir--Conditioning Engineers “ASHRAE” Method 52.1) Conditioning Engineers “ASHRAE” Method 52.1) �� Filter requirement does not apply to waterwash spray booths Filter requirement does not apply to waterwash spray booths operated and maintained to manufacturer’s specsoperated and maintained to manufacturer’s specs

2020


(40 CFR (40 CFR § 63.11173 (e)(2)(ii))63.11173 (e)(2)(ii))

�� Spray booths and prep stations used to refinish Spray booths and prep stations used to refinish complete motor vehicles or mobile equipment must:complete motor vehicles or mobile equipment must:�� Be fully enclosed with a full roof and four complete Be fully enclosed with a full roof and four complete walls or complete side curtains, and ventilated at walls or complete side curtains, and ventilated at negative pressure so that air is drawn into any negative pressure so that air is drawn into any openings in the booth walls or prep station curtains; openings in the booth walls or prep station curtains; OROR�� Spray booth must be fully enclosed with seals on all Spray booth must be fully enclosed with seals on all openings and have an automatic pressure balancing openings and have an automatic pressure balancing system operated at system operated at << 0.05 inches water gauge 0.05 inches water gauge positive pressurepositive pressure

2121


(40 CFR (40 CFR § 63.11173 (e)(2)(iii))63.11173 (e)(2)(iii))

�� Spray booths and prep stations used to Spray booths and prep stations used to coat miscellaneous parts or products or coat miscellaneous parts or products or vehicle subassemblies must:vehicle subassemblies must:�� Have full roof, at least 3 complete walls or Have full roof, at least 3 complete walls or

side curtains, and ventilated so air is side curtains, and ventilated so air is drawn into the boothdrawn into the booth�� Roof and walls may have openings for Roof and walls may have openings for

conveyors and parts to enter booth during conveyors and parts to enter booth during coating processcoating process

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(40 CFR (40 CFR § 63.11173 (e)(2)(iv))63.11173 (e)(2)(iv))

�� Mobile ventilated enclosures for spot Mobile ventilated enclosures for spot repairs must:repairs must:�� Enclose and seal against the surface Enclose and seal against the surface around the area being coatedaround the area being coated�� Retain paint overspray within the Retain paint overspray within the enclosure and direct it to a filter with at enclosure and direct it to a filter with at least 98% collection efficiency to capture least 98% collection efficiency to capture paint overspraypaint overspray

2323


(40 CFR (40 CFR § 63.11173 (e)(3))63.11173 (e)(3))

�� SpraySpray--applied coatings must be applied with one applied coatings must be applied with one of the following gun technologies:of the following gun technologies:�� High volume, low pressure (HVLP)High volume, low pressure (HVLP)�� ElectrostaticElectrostatic�� AirlessAirless�� AirAir--assisted airlessassisted airless�� With written approval from EPA, other spray With written approval from EPA, other spray technology demonstrated by gun manufacturer to technology demonstrated by gun manufacturer to achieve equivalent transfer efficiency (California achieve equivalent transfer efficiency (California South Coast Air Quality Management District’s Test South Coast Air Quality Management District’s Test Procedure). Confirm if State approval is needed also. Procedure). Confirm if State approval is needed also.

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(40 CFR (40 CFR § 63.11173 (e)(3))63.11173 (e)(3))

�� Listed spray technologies are not required Listed spray technologies are not required if:if:�� Painting is performed by students and Painting is performed by students and instructors at paint training centersinstructors at paint training centers�� Coating certain aerospace vehicle coating Coating certain aerospace vehicle coating applications applications

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(40 CFR (40 CFR § 63.11173 (e)(4))63.11173 (e)(4))

�� Spray gun cleaning must prevent atomized Spray gun cleaning must prevent atomized (sprayed) mist of cleaning solvent and (sprayed) mist of cleaning solvent and paint residue directly into the air outside paint residue directly into the air outside the container used to collect waste solventthe container used to collect waste solvent�� Acceptable options include:Acceptable options include:�� Hand cleaning of parts of disassembled gunHand cleaning of parts of disassembled gun�� Flush gun with solvent, without atomizing (i.e., Flush gun with solvent, without atomizing (i.e., spraying) the solvent & paint residuespraying) the solvent & paint residue�� Combination of nonCombination of non--atomizing methods atomizing methods �� Use fully enclosed spray gun cleanerUse fully enclosed spray gun cleaner

2626

Painter Training Requirements forPainter Training Requirements forSurface Coating Surface Coating (40 CFR (40 CFR § 63.11173 (g))63.11173 (g))

�� Train all painters, including contractors, who spray apply coatings. Train all painters, including contractors, who spray apply coatings. Except students of accredited surface coating training program who Except students of accredited surface coating training program who are under the direct supervision of an instructor who is certified are under the direct supervision of an instructor who is certified �� See “EPA Region 2 Example Owner/Operator Certification for See “EPA Region 2 Example Owner/Operator Certification for Painter Training Form” at: Painter Training Form” at: http://www.epa.gov/region2/autohttp://www.epa.gov/region2/auto�� Initial trainingInitial training

�� New sources must train workers by July 7, 2008 or 180 days after New sources must train workers by July 7, 2008 or 180 days after hire, whichever is later. hire, whichever is later. �� Existing sources must train new workers 180 days after hire or by Existing sources must train new workers 180 days after hire or by January 10, 2011January 10, 2011�� New and existing sources can use training completed up to five New and existing sources can use training completed up to five years prior to date training is required (see above dates). Painter years prior to date training is required (see above dates). Painter work experience or combo of experience and training can be used.work experience or combo of experience and training can be used.

�� Refresher trainingRefresher training�� Once every five years Once every five years –– painter work experience may not be used painter work experience may not be used

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Painter Training Requirements for Painter Training Requirements for Surface Coating Cont’dSurface Coating Cont’d(40 CFR (40 CFR § 63.11173(f))(1)63.11173(f))(1)--(3))(3))

�� Training program must include:Training program must include:�� List of names and job description of painters List of names and job description of painters requiring trainingrequiring training�� Description of owner/operator methods to Description of owner/operator methods to demonstrate, document and certify successful demonstrate, document and certify successful completion of training completion of training (Training certificate (Training certificate alone is not sufficient.)alone is not sufficient.)�� Hands on and classroom instruction covering Hands on and classroom instruction covering initial and refresher training program topicsinitial and refresher training program topics

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Painter Training Requirements for Painter Training Requirements for Surface Coating Cont’dSurface Coating Cont’d

(40 CFR (40 CFR § 63.11173 (f)(2)(i)63.11173 (f)(2)(i)--(iv))(iv))�� Hands on and classroom instruction including: Hands on and classroom instruction including: �� Spray gun equipment selection, set up, and operation, including Spray gun equipment selection, set up, and operation, including measuring coating viscosity, selecting the proper fluid tip or measuring coating viscosity, selecting the proper fluid tip or nozzle, and achieving the proper spray pattern, air pressure and nozzle, and achieving the proper spray pattern, air pressure and volume, and fluid delivery ratevolume, and fluid delivery rate�� Spray techniques for different types of coatings to improve Spray techniques for different types of coatings to improve transfer efficiency and minimize coating usage and overspray, transfer efficiency and minimize coating usage and overspray, including maintaining the correct spray gun distance and angle including maintaining the correct spray gun distance and angle to the part, using proper banding and overlap, and reducing lead to the part, using proper banding and overlap, and reducing lead and lag spraying at the beginning and end of each stroke. and lag spraying at the beginning and end of each stroke. �� Routine booth and filter maintenance, filter selection and Routine booth and filter maintenance, filter selection and installationinstallation�� Compliance with environmental requirements of the rule (e.g., Compliance with environmental requirements of the rule (e.g., classroom training using this presentation)classroom training using this presentation)

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Initial NotificationInitial Notification40 CFR 40 CFR § 63.11175(a)(1) 63.11175(a)(1) –– (8)(8)

�� Initial NotificationInitial Notification�� New sources New sources -- due 180 days after start up, or July 7, due 180 days after start up, or July 7, 2008, whichever is later. Must include compliance 2008, whichever is later. Must include compliance certification with initial notification.certification with initial notification.�� Existing sources Existing sources –– due by January 11, 2010. May due by January 11, 2010. May include Notice of Compliance Status certification with include Notice of Compliance Status certification with Initial Notification or submit later.Initial Notification or submit later.�� “EPA Region 2 Example Initial Notification Form” “EPA Region 2 Example Initial Notification Form” (includes Notice of Compliance Status certification on (includes Notice of Compliance Status certification on same form) is available at:same form) is available at:http://www.epa.gov/region2/autohttp://www.epa.gov/region2/auto

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Notification of Compliance StatusNotification of Compliance Status40 CFR 40 CFR § 63.1117563.11175

�� Notification of Compliance Status Notification of Compliance Status �� Existing sources not able to certify compliance in the Initial Existing sources not able to certify compliance in the Initial

Notification under 40 CFR 63.11175(a) (8) must submit the Notification under 40 CFR 63.11175(a) (8) must submit the Notification of Compliance Status under 40 CFR Notification of Compliance Status under 40 CFR § 63.11175(b) by 63.11175(b) by March 11, 2011March 11, 2011

�� Include same contact information as Initial NotificationInclude same contact information as Initial Notification

�� Certify compliance with all relevant requirements, see “EPA Region 2 Certify compliance with all relevant requirements, see “EPA Region 2 Example Notification of Compliance Status Form” at: Example Notification of Compliance Status Form” at: http://www.epa.gov/region2/autohttp://www.epa.gov/region2/auto

�� Paint stripping sources using more than one ton of Methylene Paint stripping sources using more than one ton of Methylene Chloride in a year must certify they have written and are Chloride in a year must certify they have written and are implementing their minimization planimplementing their minimization plan

3131

Annual Notification of ChangesAnnual Notification of Changes40 CFR 40 CFR § 63.11176 (a)63.11176 (a)

�� Annual Notification of Changes Report Annual Notification of Changes Report �� Sources must submit report each year prior to Sources must submit report each year prior to March 1March 1stst if if any previously reported any previously reported information changed during the previous year information changed during the previous year

�� Deviations from requirements are considered Deviations from requirements are considered changeschanges

�� Send letter, no EPA Example FormSend letter, no EPA Example Form

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Where to Send NotificationsWhere to Send Notifications�� Send Initial Notifications, Notifications of Compliance Send Initial Notifications, Notifications of Compliance Status and Notifications of Annual Changes to EPA Status and Notifications of Annual Changes to EPA Region 2 with a copy to the State. If State is delegated, Region 2 with a copy to the State. If State is delegated, send original to State and a copy to EPA. PR and VI are send original to State and a copy to EPA. PR and VI are delegated, NY and NJ are not . delegated, NY and NJ are not .

EPA Region 2EPA Region 2Director, Division of Enforcement and Compliance Director, Division of Enforcement and Compliance AssistanceAssistance290 Broadway290 BroadwayNew York, N.Y. 10007New York, N.Y. 10007--18661866

See EPA Region 2 Example Forms for EPA Region 2 and See EPA Region 2 Example Forms for EPA Region 2 and State addresses at: State addresses at: http://www.epa.gov/region2/autohttp://www.epa.gov/region2/auto

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RecordkeepingRecordkeeping(40 CFR (40 CFR § 63.11177 (a) 63.11177 (a) –– (h))(h))

�� Paint strippingPaint stripping�� Records of paint strippers containing Methylene Records of paint strippers containing Methylene Chloride, including the Methylene Chloride content Chloride, including the Methylene Chloride content sufficient to verify annual usagesufficient to verify annual usage�� Copy of minimization plan kept on site, only if Copy of minimization plan kept on site, only if Methylene Chloride usage is over 1 tonMethylene Chloride usage is over 1 ton�� including annual review and updates to planincluding annual review and updates to plan

�� Records of any deviations (failures to meet a Records of any deviations (failures to meet a requirement in the rule), including date and time period requirement in the rule), including date and time period it occurred, a description of deviation, and corrective it occurred, a description of deviation, and corrective actions takenactions taken�� Records of any assessments of compliance performed in Records of any assessments of compliance performed in support of Initial Notification, Notification of Compliance support of Initial Notification, Notification of Compliance Status or Annual Notification of Changes Report Status or Annual Notification of Changes Report

3434


�� Surface coating Surface coating �� Initial/refresher training documentation and Initial/refresher training documentation and certification by owner or operator for each painter.certification by owner or operator for each painter.�� Manufacturer’s documentation of 98% or better filter Manufacturer’s documentation of 98% or better filter efficiency efficiency �� If spray gun does not meet definition of acceptable If spray gun does not meet definition of acceptable technologies, documentation from spray gun technologies, documentation from spray gun manufacturer that EPA has determined equivalent manufacturer that EPA has determined equivalent transfer efficiency to HVLP gun transfer efficiency to HVLP gun �� Copies of Initial Notification, Notification of Compliance Copies of Initial Notification, Notification of Compliance Status, and if applicable, Annual Notice of Changes Status, and if applicable, Annual Notice of Changes Report. Report.

3535


�� Surface coating cont’d:Surface coating cont’d:�� Records of any deviations from requirements Records of any deviations from requirements in the rule, including date and time period it in the rule, including date and time period it occurred, a description of deviation, and occurred, a description of deviation, and corrective actions takencorrective actions taken�� Records of any compliance assessments Records of any compliance assessments performed in support of the Initial performed in support of the Initial Notification, Notification of Compliance Status Notification, Notification of Compliance Status or Annual Notification of Changes Report or Annual Notification of Changes Report

3636

How Long Must Records Be Kept?How Long Must Records Be Kept?(40 CFR (40 CFR § 63.11178)63.11178)

�� Maintain records for 5 years after date of Maintain records for 5 years after date of each recordeach record�� Copies must be kept onCopies must be kept on--site in print or site in print or electronic form for first 2 yearselectronic form for first 2 years�� Copies may be kept offCopies may be kept off--site after the first site after the first 2 years2 years

3737

Summary of Key Dates Summary of Key Dates Requirement Requirement Existing Source Existing Source ––

Initial startInitial start--up of up of operationoperation onon or beforeor beforeSept. 17, 2007Sept. 17, 2007

New SourceNew Source -- Initial Initial startstart--up of operation up of operation after after Sept. 17, 2007Sept. 17, 2007

Initial Notification (see form) Initial Notification (see form) Submit & keep record Submit & keep record

January 11, 2010January 11, 2010 July 7, 2008 or 180 days July 7, 2008 or 180 days after initial startup after initial startup (whichever is later)(whichever is later)

Painter Training/owner Painter Training/owner certification (see form) certification (see form) Keep record (don’t submit)Keep record (don’t submit)

January 10, 2011 or 180 January 10, 2011 or 180 days after hiring days after hiring (whichever is later) plus (whichever is later) plus refresher every 5 yearsrefresher every 5 years

July 7, 2008 or 180 days July 7, 2008 or 180 days after hiring (whichever is after hiring (whichever is later)later)

booth, prep station, mobile booth, prep station, mobile enclosure, spray gun, gun enclosure, spray gun, gun cleaning & filter. cleaning & filter. Keep record (don’t submit) of Keep record (don’t submit) of 98% filter &, if applicable, EPA 98% filter &, if applicable, EPA approval of “compliant nonapproval of “compliant non--HVLP HVLP gun” from manufacturergun” from manufacturer

January 10, 2011January 10, 2011 January 9, 2008 or date January 9, 2008 or date of initial startup of initial startup thereafterthereafter

Notification of Compliance Status Notification of Compliance Status (compliance certification). See (compliance certification). See form. Submit & keep recordform. Submit & keep record

March 11, 2011 March 11, 2011 July 7, 2008 or 180 days July 7, 2008 or 180 days after start up (whichever after start up (whichever is later)is later)

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Initial startInitial start--up of up of operation operation on oron orbeforebefore Sept. 17, 2007Sept. 17, 2007


Annual Notification of Changes Annual Notification of Changes ––send only if there were changes & send only if there were changes & nonnon--compliance. No form, send compliance. No form, send letter.letter.Submit & keep record Submit & keep record

March 1 of every year March 1 of every year for prior calendar yearfor prior calendar year

March 1 of every yearMarch 1 of every year

Deviations from rule (record date, Deviations from rule (record date, time & description of deviation) time & description of deviation) and corrective actions taken. No and corrective actions taken. No form. form. Keep record (don’t submit) Keep record (don’t submit)

January 10, 2011 January 10, 2011 January 9, 2008 or date January 9, 2008 or date of initial startup of initial startup thereafterthereafter

Assessments of compliance to Assessments of compliance to support Initial Notification, support Initial Notification, Notification of Compliance Status Notification of Compliance Status & Annual Notification of Changes & Annual Notification of Changes Report. No form. Keep record Report. No form. Keep record (don’t submit) (don’t submit)


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Initial startInitial start--up of up of operation operation on oron or beforebeforeSept. 17, 2007Sept. 17, 2007


Keep record (don’t submit) of Keep record (don’t submit) of paint strippers containing paint strippers containing Methylene Chloride, including Methylene Chloride, including Methylene Chloride content Methylene Chloride content sufficient to verify annual usage. sufficient to verify annual usage. No form.No form.


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Additional ResourcesAdditional ResourcesEPA Region 2EPA Region 2 ((NY, NJ, PR, & VI) NY, NJ, PR, & VI) http://www.epa.gov/region2/autohttp://www.epa.gov/region2/autoTo download forms for EPA Region 2 area, guidance and rule, see “Auto To download forms for EPA Region 2 area, guidance and rule, see “Auto Body Shops Body Shops –– Compliance Reminder” (scroll down the web page, past the Compliance Reminder” (scroll down the web page, past the green banner). Forms contain EPA Region 2 and State mailing addresses. green banner). Forms contain EPA Region 2 and State mailing addresses. Region 2 Web site has links to EPA HQs national Web sitesRegion 2 Web site has links to EPA HQs national Web sites below.below.

EPA HQs Collision Repair - DVD/poster (see next slide)http://www.epa.gov/collisionrepairDownload forms, guidance and rule for other EPA Regions across the U.S. Scroll down the web page to “Auto Body Rule.” See also “State Delegations” link for EPA/State mailing addresses for forms.

EPA HQs Design for Environment http://www.epa.gov/dfe/pubs/projects/autoDownload fact sheets on benefits of waterborne basecoats and vacuum sanders plus a checklist that covers voluntary best practices along with some EPA and OSHA requirements.

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Order Free Copy of EPA DVD Order Free Copy of EPA DVD and Poster Featuring Jeff Gordonand Poster Featuring Jeff Gordon

� Copy of EPA's Collision Repair Campaign Training DVD -Spanish and English on same DVD. Includes some information on rule and interviews with shop personnel. Not required viewing, 19 minutes (#456V09001) � Copy of Collision Repair Campaign Poster (#456H09001) � National Service Center for Environmental Publications (NSCEP), NSCEP Toll Free Number: 1-800-490-9198� Online Ordering: http://www.epa.gov/ncepi/

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Additional Resources Cont’dAdditional Resources Cont’dFor more information call the EPA/State contacts below : Deborah CraigEPA Region 2 (NY, NJ, PR and VI)[email protected]://www.epa.gov/region2/autoKy Asral or Ed BakosNJ Department of Environmental ProtectionSmall Business Assistance Program609.292.3600http://www.nj.gov/dep/opppc/small.htmlNY Small Business Assistance ProgramEnvironmental Facilities Corporation1-800-780-7227http://www.nysefc.org/home/index.asp?page=855

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Additional Resources Cont’dAdditional Resources Cont’dNancy GarciaNancy GarciaSmall Business Assistance ProgramSmall Business Assistance ProgramPuerto Rico Environmental Quality BoardPuerto Rico Environmental Quality Board787.767.8181 x 3275787.767.8181 x [email protected]@jca.gobierno.prMarylyn StapletonMarylyn StapletonOmbudsman/Small Business Environmental Ombudsman/Small Business Environmental Assistance Program CoordinatorAssistance Program CoordinatorVirgin Islands Department Planning & Natural ResourcesVirgin Islands Department Planning & Natural Resources340.714.9529340.714.9529marylyn.stapleton@[email protected]

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Additional Resources Cont’dAdditional Resources Cont’dFor Pennsylvania businesses attending EPA Region 2 workshops, here’s the EPA Region 3 contact information:� EPA Region 3 (Pennsylvania, Delaware, District of Columbia, Maryland, Virginia and West Virginia) contact:Cathleen KennedyCathleen [email protected]� Download Notification and Petition for Exemption Forms from EPA HQs Collision Repair web site: http://www.epa.gov/collisionrepair� See instructions for mailing of forms on EPA Region 3’s web site: www.epa.gov/reg3artd/airquality/autobody.html

national emission standards for hhazardous air pollutants

Documents