1. NESHAP For Paint Stripping and Miscellaneous Surface Coating Operations 40 CFR 63, Subpart HHHHHH (a.k.a. 6H) 1

2. 2 Erin Conley, Annette Fulgenzi, and Brooke Doggett Small Business Environmental Assistance Program with the Illinois Department of Commerce and Economic Opportunity Jackie Sims Illinois Environmental Protection Agency Bureau of Air

3. 3 National Emission Standards for Hazardous Air Pollutants (NESHAPs)  Federal Rules, not State Rules  30 Hazardous Air Pollutants (HAPs) identified in urban areas  New rules being promulgated to limit HAP emissions from small but numerous sources

4. 4 NESHAP For Paint Stripping and Miscellaneous Surface Coating Operations  Reduce emission of HAP metals from spray coating of:  Motor vehicles and mobile equipment (e.g. auto collision repair)  Miscellaneous metal and plastic parts (e.g. parts manufacturers)  Reduce usage of methylene chloride paint strippers.

5. Methylene Chloride Paint Stripping  Evaluate need for stripping  Explore alternatives  Minimize evaporation  Proper disposal and storage  If use more than 1 ton/yr Develop and implement a written plan Post placard 5 Picture Courtesy of AzkoNobel

6. Targeted HAPs  cadmium  chromium  lead  nickel  manganese  methylene chloride 6

7. Spray Apply  Paint cup capacity equal to or less than 3 fluid ounces  Powder coating  Non-refillable aerosol cans  Non-atomizing applications like rollers, brushes, and flow and dip coating 7 Coatings applied using hand-held device that atomizes the coating. It does not include:

8. Coating Coating  Decorative, protective or functional purposes such as primers, base coats, clear coats.  Excludes: Adhesives Sealants Maskants Temporary protective coatings Cleaning solvents 8

9. CLARIFICATION on use of 3 ounce cups Small amounts of any type of paint may be sprayed on the shop floor if spray gun cups 3 ounce or less are used. HOWEVER, be aware that excessive amounts being sprayed using 3 ounce cups (i.e., a whole vehicle) may be seen by USEPA as circumvention of the rule and could then be considered a violation. 9

10. Motor Vehicles and Mobile Equipment  Motor Vehicles include: automobiles, light-duty trucks, golf carts, vans and motorcycles.  Mobile Equipment includes: heavy-duty trucks, truck trailers, fleet delivery trucks, buses, mobile cranes, bulldozers, street cleaners, agricultural equipment, motor homes, and recreational vehicles. 10

11. Who is Subject?  Brick and Mortar Auto Body Repair Facilities.  Mobile Refinishers that use spray guns with cup capacity > 3 ounces.  Paint Training Centers.  Individuals that coat more than 2 vehicles in a year without compensation.  Individuals that coat any number of vehicles in a year with compensation. 11

12. Is an auto dealership obligated to make sure the independent mobile refinishing company he/she hires to do on ‐ the ‐ lot touchups is in compliance with all NESHAP requirements?  All independent mobile refinishing companies are subject to the NESHAP requirements if they use one or more spray guns with a cup size over three ounces. The NESHAP specifically states in Section 63.11173(f) that the training requirements apply to “all new and existing personnel, including contract personnel, who spray apply surface coatings.”  Mobile contractors need to be prepared to: provide a copy of their Notification of Compliance Status that they sent to Illinois EPA and USEPA, provide proof that they always use a spray gun cup size of three ounces or less and are therefore not covered by the rule, or provide a copy of their exemption granted by the USEPA.  Since the training requirements apply to contract painters, a hosting facility is required to verify and maintain a record of the painters’ certification, and should obtain that from the contractor. 12

13. Petition For Exemption Shop owners must certify that all of your coatings will contain less than:  0.1 % or more by mass of cadmium, hexavalent chromium, lead, or nickel, and  1.0 % or more by mass of manganese or non-hexavalent chromium. You can make a change to your paint lines at any time and still apply for an exemption to the rule. Exemption petitions must be sent to the USEPA with a copy sent to the Illinois EPA. In Illinois, the USEPA is the agency granting any exemptions. 13

14. Petition For Exemption  Go to ww.ienconnect.com/enviroww.ienconnect.com/enviro for a form.  Paint stripping requirements still apply.  Still need to comply with all other state and federal environmental regulations. 14

15. 15 Answering the “WHAT” General Requirements Enclosures and filters Type and cleaning of application equipment Training Paperwork Requirements Notifications Recordkeeping

16. Coating Complete Vehicles Booths and stations must have:  full roof,  4 complete walls or side curtains and  ventilated so air is drawn into the station or booth or positive pressure (<0.05 inches water gauge) 16

17. 17 Curtained booths

18. Mind the gaps Here is what we do know that would be considered upon a USEPA inspection:  The NESHAP requires spray painting to be performed within an enclosure (roof and walls or curtains) that is maintained under a negative pressure so that the overspray is captured on a filter as opposed to the overspray being exhausted into the air or landing on the floor of the shop.  Agencies enforcing environmental regulations would look for evidence of overspray staining structures outside of the prep station. Items that they would check, but not be limited to, would be the operation of the fan, the integrity of the paint filters and the actual operation of prep station before making any determination of compliance with the NESHAP.  Methods that ensure proper capture of overspray in the prep station will decrease the chance of being cited in violation of the NESHAP. 18

19. 19 Spraying with incomplete/ no booth

20. 20 Filter Technology Filter Technology Section 63.11173(e)(2)(i) Demonstration consistent with the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) Method 52.1

21. 21 Filter Technology Filter Technology Section 63.11173(e)(2)(i)

22. 22 Application Equipment All spray-applied coatings must be applied with:  HVLP*,  electrostatic*,  air-assisted airless, or  equivalent technology. NOTE: *only guns allowed in Cook, Lake, DuPage, Kane, Will, McHenry, Kendall (Oswego township only), Grundy (Goose Lake and Aux Sable Townships only), Madison, Monroe and St. Clair Counties.

23. Cleaning of Paint Spray Guns  Cleaning cannot involve atomized mist or spray of gun cleaning solvent and paint residue into the booth filters.  For shops located in the previous listed counties and use over 20 gallons of coating, cleaning must: include a process that re-circulates solvents during the cleaning process collects used solvents for disposal or recycling and minimizes evaporation during cleaning, rinsing, draining and storage. 23

24. Cleaning of Paint Spray Guns  Acceptable options include enclosed gun washers or manual cleaning of parts of the disassembled paint spray gun for most of state, except counties mentioned previously. 24

25. 25 Training and Certification Training and Certification Section 63.11173(f)  Hands on and classroom instruction addressing: Spray gun selection, setup and operation. Spray technique to improve transfer efficiency. Booth and filter maintenance. Environmental compliance with rule.  Initial certification and recertification every 5 years

26. 26 Initial Notification/Compliance Status Form Initial Notification  Basic information about facility Notification of Compliance Status  Stating your compliance with the rule Annual Notification of Changes Report  Due March 1 st each year if changes See combination form on our web page

27. 27

28. 28 Recordkeeping Training certification Paint Filter Documentation Initial Notification Compliance status Deviations

29. Small Business Environmental Assistance Program www.ienconnect.com/enviro 800-252-3998 Erin.Conley@illinois.gov Annette.Fulgenzi@illinois.gov Brooke.Doggett@illinois.govJackie.Sims@illinois.gov 29