Transcript Assistance Outreach Opportunities for EAN Partners: Paint

Assistance Outreach
Opportunities for EAN
Partners: Paint Stripping &
Miscellaneous Surface
Coating Rule
Mary Dever-Putnam, EPA Region I
Holly Wilson, EPA OAQPS
1
Background
NESHAP: Paint Stripping and
Miscellaneous Surface Coating
Operations at Area Sources published
1/9/08 (73 FR 1738)
Area Sources - federal HAP emissions
less than 10 tons per year (TPY) of any
one, and less than 25 TPY of all
combined
2
Why the need for this rule?
The CAA requires EPA to develop emission
standards for a list of 187 hazardous air pollutants
(HAPs). EPA developed standards for “major
sources”.
The CAA also requires EPA to identify and regulate
the sources that pose the greatest potential health
threats from these pollutants in urban areas. In
urban areas, these are generally small sources but
large in number and collectively may pose health
risks. These are known as “area sources”.
70 area source categories have been identified as
needing regulation. Auto body is one of these
source categories needing regulation.
3
Why the need for this Rule?
The CAA requires EPA to reduce
exposure to HAPs because these
chemicals are known or suspected to
cause cancer or other serious health
effects such as birth defects. Data
from paint suppliers has shown that
coatings used in automobile and
mobile equipment refinishing contain
HAPs such as chromium, lead,
cadmium, manganese, and nickel
compounds (targeted HAPs).
4
Three Affected Source Categories
Paint stripping operations

using Methylene Chloride (MeCl) to remove
dried paint from wood, plastic, metal or other
Motor vehicle and mobile equipment
spray-applied surface coating operations
Miscellaneous surface coating

spray application of coatings containing Cr,
Pb, Mn, Ni, or Cd (target HAPs) to any metal
or plastic parts or products that are not motor
vehicles or mobile equipment
5
Compliance Dates
New sources must comply by
January 9, 2008 or start-up of
operations
Existing sources must comply by
January 9, 2011
6
General Requirements
Paint Stripping
Minimize emissions of MeCl using the following
management practices
 evaluate each application for need to remove paint
(e.g. can part be re-coated)
 evaluate each application for alternative to MeCl
 reduce exposure of MeCl strippers to air
 optimize conditions when using MeCl to reduce
evaporation (e.g., if heating, use lowest possible
temperature)
 use proper storage and disposal techniques
7
General Requirements
Paint Stripping
If operation uses > 1 ton of MeCl per year

Develop, implement & post a written MeCl
minimization plan
If operation uses ≤ 1 ton of MeCl

no written plan is required, but must comply with
minimization management practices
8
Broad requirements for Surface
Coating (rule details requirements)
1: Painters must be certified as
completing training in proper
spray application of surface
coatings, setup and
maintenance of spray equipment
2: Spray-applied coatings
must be applied in spray
booth, preparation station, or
mobile enclosure that meets
certain requirements
9
Broad requirements for Surface
Coating (rule details requirements)
3: Spray-applied coatings must be applied with
one of the following gun technologies:
 high volume, low pressure (HVLP)
 electrostatic
 airless
 air-assisted airless
 with written approval from EPA, other spray
technology demonstrated to achieve
equivalent transfer efficiency
10
Broad requirements for Surface
Coating (rule details requirements)
4: Spray gun cleaning operation should prevent atomized
mist or avoid spraying cleaning solvent and paint residue
outside container used to collect waste solvent
5: Train all personnel, including contractors, who spray
apply coatings:

List of personnel requiring training

Hands on and classroom instruction including:
spray gun equipment selection, set up, and
operation
best spray technique for different types of coatings
to improve transfer efficiency and minimize overspray
routine booth and filter maintenance, filter selection
and installation
compliance with requirements of the NESHAP

Description of methods to document and certify
training
11
Notification and Reporting
Initial Notification
 new sources - due 180
days after start up, or
January 9, 2008,
whichever is later
 existing sources - due by
January 9, 2010
12
Notification and Reporting
Notification of Compliance Status




existing sources not able to demonstrate compliance
in the initial notification must submit this notification
within 60 days after January 9, 2011
include same basic information as initial notification
indicate date of compliance with all relevant
requirements
paint stripping sources using more than one ton of
MeCl in a year must certify they have written and are
implementing their minimization plan
13
Notification and Reporting
Annual Notification of Changes Report


sources must submit report annually prior to March
1 if any previously reported information changed
during the previous year
changes include paint stripping sources that
increase usage of MeCl to more than one ton in a
calendar year
submit the changes report by March 1 following the year
usage went over one ton of MeCl
develop and implement a written minimization plan by
December 31
submit a notification of compliance status by March 1 of the
following year
14
Recordkeeping
Paint stripping
 Records of paint strippers containing MeCl,
including the MeCl content sufficient to verify
annual usage
 copy of minimization plan kept on site, if required
including annual review and updates to plan
 records of any deviations from requirements in
the rule, including date and time period it occurred,
a description of deviation, and corrective actions
taken
15
Recordkeeping
Surface coating
 painter training certification
 documentation of filter efficiency
 if spray gun does not meet definition of acceptable
technologies and has cup capacity at least 3.0 oz,
documentation from spray gun manufacturer that
Administrator has determined equivalent transfer
efficiency
 copies of all notifications and reports required
 records of any deviations from requirements in the
rule, including date and time period it occurred, a
description of deviation, and corrective actions taken
16
Opportunities for Assistance
OAQPS Collision Repair Campaign (framework for
providing assistance, network, share tools)
Many federal, state and local programs can provide
outreach:










Compliance Assistance
Pollution Prevention Assistance
Small Business Assistance
Environmental Justice
Public Health organizations (fed, state and local)
Community Outreach organizations
Vocation Technical Schools
Trade Associations
OPEI supported innovative programs: Environmental Results
Program (ERP) and Common Measures Projects
Community Action for a Renewed Environment (CARE) grant
projects
17
Opportunities for Assistance
Workshops & Training



Shop training
Assistance providers (train-the-trainer)
Partner in events w/trade assns, voc techs, LBOH, etc
Onsite Assistance
Distribution of tools
Universe identification
Agree to desired outcomes & share outcome data
18
What is the Collision Repair
Campaign ?
A joint initiative of the EPA and communities to
address health threats and to drastically reduce
auto body emissions across the nation.
In addition, shops owners and operators can
achieve early compliance with Paint Stripping &
Miscellaneous Surface Coating Rule by
implementing these voluntary measures.
19
Voluntary Campaign Program to
Complement Rule - Goals
 Work with 400+ shops to institute BMPs and/or work
toward early compliance
 Create 10 regional partnerships with trade associations,
state programs and technical providers
 Initiate 10 community based projects in neighborhoods
Create a sustainable Campaign that can be transferred
to Tribes, States, locals, and NGOs partners
Expect up to 90% emissions reductions for participating
shops with high concentrations of collision repair shops
20
Potential Benefits
from the Campaign
Environmental Benefits
 Decrease solvent use by more than 50%
 Decrease air pollution by 70% to 90%
Economic Benefits to Operators
 95% reduction in operating cost by using waterbased cleaning system
 Saving up to $13000/year at a shop spraying 15
cars/week
 Reduced clean up cost if installing vacuum
sanding system - investment of $9000 results in
annual saving of $7000
21
Best Practices
HVLP spray guns *

increase transfer efficiency to 65%
Spray booths *

Spray booth filters are >90% efficient for particulates
Vacuum or wet sanding
Low VOC or water based paint
Low VOC solvents
Closed containers
Computer paint mixing system
22
% Reduction
in Emissions
Reduction in Auto Body Shop Emissions with
Best Practices
100
80
60
40
20
0
Conventional
spray gun
HVLP spray
gun
Booth +
Conventional
spray gun
Booth + HVLP
spray gun
Best Practice
Diisocyanates
Lead, Chromium
Organic Solvents
23
How Do We
Promote Best Practices?
EPA’s Design for the Environment


Train-the-Trainer course
Best Practices Tool Kit
Partnerships for nonregulatory visits





Collision Repair Associations
Trade Schools (secondary and post secondary)
Pollution Prevention Programs
Small Business Programs
Air Programs
24
Who’s Doing What?
OAQPS - Overall coordination
Regions – Implementation
CARE – Community implementation
OPPT/DfE – Training support
OECA – Compliance assistance
ORD/NERL – Science & Research Support
for Community-based Initiatives e.g. CARE
projects
ORIA – Contractor support
25
Regional Campaigns
Each Region identifies a Campaign
strategy from a range of possibilities




Partner with states and small business
programs
Conduct DfE’s train-the-trainer workshops
locally
Roll out an expansive outreach campaign
Work with regional trade associations and votech schools
26
Some Campaign Results
Partners and Participants:
•
•
•
•
•
•
•
10 EPA Regions,
5 EPA program offices,
25 states and locals
20 Community Colleges & Vo-tech schools
10 Industry & Trade Associations
5 Community for a Renewed Environment (CARE)
grantees
4 Paint Suppliers
27
Some Campaign Results cont.
DfE training workshop results:
Auto body Owners/workers/stakeholders: 361
Students: 167
Teachers: 47
Outreach Packets distributed for students in other
classes: 130
Self-evaluation sheets distributed& returned: 256
Shop Site Visits: 6
School Site Visits: 7
Over 81% of participants made changes that will reduce shop
emissions and provide better health in the workplace
and environment.
28
Next Steps Over 12 Months
Complete and distribute CRC DVD to
shops nationwide - Jeff Gordon (
NASCAR) will be spokesman.
Additional workshops and trainings with
states, trade organizations, vocational
schools, community colleges, shop
owner and staff.
Solicit input from Region, OPPT,OGC,
OCEA to explore SEP opportunities.
Launch CRC website http://www.epa.gov/air/toxicair/comm
unity/collision.html
Work S/L/T to calculate emission
reductions using “DfE Emission
Reductions Calculations”.
Webcast in late June or mid July
29
Next Steps Over 12 Months cont’d
Enroll 25 new partners to carry message and
conduct training workshops.
Further outreach and consensus building
with Regions, States, and industry, as
appropriate.
Have in place in 50 target communities the
infrastructure (public/private organizations)
that work with auto body shops to (a) have
them adopt the “five best practices” and (b)
come into compliance with local, state and
national standards.
Enroll 15 local and national leaders in the
collision repair industry committed to the
“five best practices.”
30
Tools Available & More Planned
Slide show materials covering the requirements
Fact Sheet summarizing the requirements
Video in development
Design for the Environment Tools including Self
Assessment Checklist, emission reduction
calculator, workshop offerings for shops and
assistance providers
GIS mapping protocols to help target
assistance
31
Options for targeting assistance
through GIS mapping
32
Tools & Actions Needed
Common Evaluation Methods: ICR, common
measures, data gathering & Reporting
Techniques, etc.
Fact Sheets:


How to examine MSDSs to determine if your
coatings have targeted HAPs
How to Petition for Exemption (if no HAPs in
coatings)
Info from Major Paint Manufacturers:


their coatings containing HAPs
their alternative coatings
Procedures for processing compliance
notifications, exemption petitions, etc.
Model training certificates
33
For more information
www.ccar-greenlink.org - OECA’s Coordinated Committee for Auto
Repair – an Automotive Sector Compliance Assistance Center
http://www.epa.gov/ttn/atw/area/arearules.html - EPA’s Air Toxics
Website for Area Source Standards
http://www.paintcenter.org/paintstripping.cfm - OECA’s Paints &
Coatings Resource Center
http://www.epa.gov/air/toxicair/community/collision.html - Collision
Repair Website
Holly Wilson, OAQPS (919) 541-5624
[email protected]
Mary Dever-Putnam, EPA Region I, (617) 918-1717
[email protected]
This presentation available at http://www.paintcenter.org/ean.ppt
34