Automotive Refinishing Policy Manual - Sacramento Metropolitan Air ...

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777 12 TH STREET, 3 RD FLOOR (916) 874-4800SACRAMENTO, CA 95814-1908 FAX (916) 874-4899SACRAMENTO METROPOLITANAIR QUALITY MANAGEMENT DISTRICTNATIONAL EMISSION STANDARD FOR HAZARDOUS AIR POLLUTANTS – PAINT STRIPPING ANDMISCELLANEOUS SURFACE COATING OPERATIONS (40 CFR 63 SUBPART HHHHHH)Applicability: This regulation applies to paint stripping operations that involve the use of chemical strippersthat contain methylene chloride (MeCl), Chemical Abstract Service number 75092, in paint removal processesand/or autobody refinishing operations that encompass motor vehicle and mobile equipment spray-appliedsurface coating operations.If spray applied coatings do not contain chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), orcadmium (Cd), and you have filed a petition for exemption, and have received written confirmationfrom the U.S. Environmental Protection Agency (U.S. EPA) approving your petition, and also do notperform paint stripping activities using methylene chloride (MeCl), then your source is not subject tothis NESHAP (40 CFR 63 Subpart HHHHHH) or any of the following conditions (Condition Nos. 19-28).NOTIFICATIONS:19.. Initial Notification: Existing sources shall notify the U.S. EPA, no later than January 11, 2010, that thefacility is subject to the standards and if not yet in compliance, when the source will be in compliance bysubmitting an initial notification form.[Basis: 40 CFR 63 Subpart HHHHHH, Section 63.11175(a)]20.. Notice of Compliance: Existing sources shall be in compliance with the applicable requirements no laterthan March 11, 2011. The facility shall submit to the U.S. EPA a certification of compliance on or beforethat date.[Basis: 40 CFR 63 Subpart HHHHHH, Section 63.11175(b)]GENERAL:21. All spray painting must be performed inside a spray booth or prep station with a roof and at least threewalls or curtains (when refinishing vehicle subassemblies), or a roof and four complete walls or completeside curtains (when refinishing complete vehicles or mobile equipment) and must be ventilated so that airis drawn into the booth. The exhaust must be equipped with a filter system that is designed to capture atleast 98% of paint overspray.[Basis: 40 CFR 63 Subpart HHHHHH, Sections 63.11173(e)2(i)-63.11173(e)2(iii)]22. Spray guns used in the coating operation must be one of the following types:A. High-Volume Low-Pressure (HVLP)B. ElectrostaticC. Any other equivalent spray method demonstrated to achieve a transfer efficiency equal to one of theother allowed types of spray guns, which has been approved in writing by the <strong>Air</strong> Pollution ControlOfficer, and submitted to and approved by the U.S. EPA.[Basis: 40 CFR 63 Subpart HHHHHH, Section 63.11173(e)3]23. Paint spray gun cleaning must be done so that an atomized mist or spray of the cleaning solvent is notcreated outside a container that collects used gun cleaning solvent.[Basis: 40 CFR 63 Subpart HHHHHH, Section 63.11173(e)4]PAGE 7 OF 9 PAGESREVOCABLE AND NON-TRANSFERABLEPERMIT NOS.: XXXXX
777 12 TH STREET, 3 RD FLOOR (916) 874-4800SACRAMENTO, CA 95814-1908 FAX (916) 874-4899SACRAMENTO METROPOLITANAIR QUALITY MANAGEMENT DISTRICTMANAGEMENT PRACTICES/TRAINING:24. Each painter must undergo training that includes, but not limited to: painting techniques to minimize paintoverspray and equipment maintenance. Initial painter training will be valid for five years and a refreshercourse will be required once every five years.[Basis: 40 CFR 63 Subpart HHHHHH, Section 63.11173(f)2(i)-63.1173(f)2(iv)]25. All painters must complete training no later than 180 days after being hired or January 10, 2011,whichever is later.[Basis: 40 CFR 63 Subpart HHHHHH, Section 63.11173(g)2]RECORD KEEPING:26. The following records shall be maintained on-site and shall be made available for review by the U.S. EPAor the <strong>Air</strong> Pollution Control Officer upon request.A. Records of notifications submitted to the U.S. EPA.B. Painter training certifications.C. Documentation of spray booth filter efficiency.D. Documentation of spray gun transfer efficiency.E. Any relevant documentation on deviations and corrective actions.Additional Record Keeping Requirements for Paint Stripping Operations Using MethyleneChloride:F. Each paint stripping operation must maintain copies of annual usage of paint strippers containing MeClon site at all times (tons/year).G. Each paint stripping operation with annual usage of more than one ton of MeCl must maintain a copy oftheir current MeCl minimization plan on site at all times.[Basis: 40 CFR 63 Subpart HHHHHH, Section 63.11177(a)-63.11177(g)]MANAGEMENT PRACTICES FOR STRIPPING OPERATIONS:27. Each paint stripping operation that is an affected area source must implement management practices tominimize the evaporative emissions of MeCl. The management practices must address, at a minimum,the practices listed below, as applicable, for your operations:A. Evaluate each application to ensure there is a need for paint stripping (e.g., Evaluate whether it ispossible to re-coat the piece without removing the existing coating).B. Evaluate each application where a paint stripper containing MeCl is used to ensure that there is noalternative paint stripping technology that can be used.C. Reduce exposure of all paint strippers containing MeCl to the air.D. Optimize application conditions when using paint strippers containing MeCl to reduce MeCl evaporation(e.g., If the stripper must be heated, make sure that the temperature is kept as low as possible toreduce evaporation).E. Practice proper storage and disposal of paint strippers containing MeCl (e.g., Store stripper in closed,air-tight containers).[Basis: 40 CFR 63 Subpart HHHHHH, Section 63.11175(b)]PAGE 8 OF 9 PAGESREVOCABLE AND NON-TRANSFERABLEPERMIT NOS.: XXXXX
Page 1 and 2: Automotive, Truck and Heavy Equipme
Page 3 and 4: Materials for Vehicles - The requir
Page 5 and 6: 2. State Requirementsa. California
Page 7 and 8: Temporary Protective Coating 60 (0.
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Page 17 and 18: Authority to Construct EvaluationA/
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