2010 sign sales meeting neshap subpart 6h national emission standards for hazardous air polutants

2010 Sign Sales Meeting

NESHAP Subpart 6HNATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR

POLUTANTS


Objectives

• Discuss who the rule affects• Understand the requirements of the rule• Review AkzoNobel’s position on initial

compliance• Review compliance package mailing• Look at class supplemental material• Understand Subpart 6H training plan going

forward


Who Does the Rule Affect?

• Paint stripping operations that involve the use of chemical strippers that contain methylene chloride

• Auto body refinishing operations that encompass motor vehicle and mobile equipment spray-applied surface coating operations

• Spray application of coatings containing compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd), collectively referred to as the target HAP to any part or product made of metal or plastic, or combinations of metal and plastic that are not motor vehicles or mobile equipment


Sign Materials Affected

NOTE:

•These are our materials only. As we cannot control other materials in the shop, we can only guide them to compliance.

•GGBC MM 431 should be replaced Q1 2011

•GGWP is set to STOP sale on July 31, 2010

•GG MM923 has been stopped

Sign Products

SAP Item #

Brand Material description Target HAP

354671 Sign SIG GG W-PRIM NA 1GL Chromium compound

386394 Sign SIG GG MM 923 NA 1L Nickel compound

399867 Sign SIG GGBC MM 431 NA 1L Nickel compound


Requirements of the Rule

Paint Stripping Operations:• Each paint stripping operation must implement

management practices to minimize the evaporative emissions of MeCl by evaluating the following:– Ensure there is a need for paint stripping– Ensure that there is no alternative paint stripping

technology that can be used– Reduce exposure of all paint strippers containing

MeCl to the air


Requirements of the Rule continued

Paint Stripping Operations continued

– Optimize application conditions when using paint strippers containing MeCl to reduce MeCl evaporation

– Practice proper storage and disposal of paint strippers containing MeCl

– Each paint stripping operation must maintain copies of annual usage of paint strippers containing MeCl on site at all times


Painter training must include:

– Proper spray application of surface coatings– The proper selection, setup, operation, and

maintenance of spray equipment – Proper fluid tip selection– Achieving the proper spray pattern– Adjusting air pressure, volume, and fluid delivery

rate– Proper spray technique for different types of

coatings to improve transfer efficiency and minimize coating usage and overspray


Painter training must include: continued

– Maintaining the correct spray gun distance and angle to the part, using proper banding and overlap, and reducing lead and lag spraying at the beginning and end of each stroke

– Measuring paint viscosity– Routine spray booth and filter maintenance– Filter selection and installation

Note: The spray application of surface coatings is prohibited by persons who are not certified as having completed the training


Certification Period

• Training and certification is valid for five (5) years from the date of training

• All painters must re-certify every five (5) years via a course or refresher training that meets the requirements of the regulation


Additional Requirements

• All spray-applied coatings must be applied with a high volume, low pressure (HVLP) spray gun, electrostatic application, airless spray gun, air-assisted airless spray gun, or an equivalent technology

• All paint spray gun cleaning must be done so that an atomized mist or spray of gun cleaning solvent and paint residue is not created outside of a container that collects used gun cleaning solvent


Additional Requirements continued

• All spray-applied coatings must be applied in a spray booth, preparation station, or mobile enclosure

• All spray booths, preparation stations, and mobile enclosures must be fitted with a type of filter technology that is demonstrated to achieve at least 98-percent capture of paint overspray



• Spray booths and preparation stations used to refinish complete motor vehicles or mobile equipment must be fully enclosed with a full roof, and four complete walls or complete side curtains, and must be ventilated at negative pressure– However, if a spray booth is fully enclosed and has

seals on all doors and other openings and has an automatic pressure balancing system, it may be operated at up to, but not more than, 0.05 inches water gauge positive pressure



– Spray booths and preparation stations that are used to coat miscellaneous parts and products or vehicle subassemblies must have a full roof, at least three complete walls or complete side curtains, and must be ventilated so that air is drawn into the booth (negative pressure)

– Mobile ventilated enclosures that are used to perform spot repairs must enclose and, if necessary, seal against the surface around the area being coated such that paint overspray is retained within the enclosure and directed to a filter to capture paint overspray


Record Keeping

• A list of all current personnel by name and job description who are required to be trained (any technician that applies coatings)

• Copies of all submitted notifications• Annual notification of change if you have had

any changes from the initial notification• Certification that each painter has completed

the specified training including the date of initial training and the most recent re-certification


Record Keeping continued

• Documentation of the exhaust filter material efficiency• Documentation from the spray gun manufacturer of non-

HVLP spray gun transfer efficiency (RP, etc)• Records of paint stripper containing MeCl to include

MeCl content and annual usage• Records of any assessments of source compliance

performed in support of initial notification, notification of compliance status, or annual notification of change

• Records must be kept for five (5) years and on site and readily accessible for inspection for the first two (2) years and may be kept off site after that two year period


Compliance Dates

• Initial Compliance for existing shops: January 10, 2010– Initial compliance form must be filled out and sent to

the EPA Regional Office governing the state

• Initial Compliance for New Shop: at Start Up• Full Compliance of an existing shop:

January 10, 2011• New technician: within 180 days of date of hire


Initial Compliance

• Owners and operators who can show by documentation or certification that a painter’s work experience and/or training has resulted in training equivalent to the training required in this regulation [paragraph (f)(2) of this section] are not required to provide the initial training required to these painters.

• Previous training that meets the requirements will be allowed back for a period of five (5) years


AkzoNobel Resource Site

http://www.akzonobelcarrefinishes.net/6H


Questions

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2010 sign sales meeting neshap subpart 6h national emission standards for hazardous air polutants

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