Can the Little things come back to bite you

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Can the Little things come back to bite you?
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The short answer is

• Yes!

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Coating Line Inspections

• Differ from inspections of other types of
  industry
• Particular to the type of coating done. (i.e.
  dip coating, roll coating, spray, or e-coating)

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Inspector Preparation

• Review permits
• Review other applicable rules (i.e. subject to
  632, but not detailed in permit)
• Review malfunction abatement plans/preventative
  maintenance plans
• Review previous inspection reports and/or letters
  of violation.

Rules? Permits? MAPs/PMPs?
All this preparation leads to an Inspection Plan
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Inspection Plan

• Each facility is unique and each coating line
  has its own set of attributes.
• Each inspection plan will be exclusive to the
  facility to be inspected.

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Permit Review

• Inspector will pull all permits that apply to
  your facility
• Permits will be reviewed by the inspector before
  the inspection
• Concentration on special conditions that will
  require a visual confirmation.
• Thoroughly examine record keeping requirements
• Copies will be brought along on the inspection
  for reference

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Other Applicable Rules

• Processes that are exempt from permitting
• Facility subject rules that are not detailed in
  the permit
• Copies of these rules may be brought along for
  the facilitys reference

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MAPs and PMPs

• Review Malfunction Abatement Plans and/or
  Preventative Maintenance Plans that are kept on
  file
• Items in these documents, if a MAP or PMP is
  required by the permit, are enforceable
• This will also likely be brought along on the
  inspection for reference

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Previous Inspections and Letters of Violation

• Any previous inspection report will also be
  reviewed for any areas that need special
  attention
• Any letters of violation and their responses will
  also be reviewed to ensure that the facility
  following a compliance plan as stated in the
  response
• If deemed necessary copies of these documents may
  also be brought on the inspection

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Its All In The Details
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Just Painting?

• Of course not!
• Your inspector will look at the entire painting
  process from parts racking to purging solvents to
  storage of these solvents to filter replacement
  and disposal. (As well as all other processes in
  the facility)

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Well, Jenifer what are you looking for?

• In the overall sense, I am looking for a
  well-run facility, clean paint lines, and a
  person who knows the ins and outs of production
  and the capacity of the lines. This person
  should know how the lines operate, proper
  operation of any control devices and how and
  where the records are kept. (Or at least know
  the person who does know these things.)

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So As An Inspector What Will I Ask You?
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Parts Washing

• What type of cleaning of the parts is done?
• Do you use water or solvents based cleaners?
• Are there any VOCs?
• Do you have the MSDS readily available?
• Are these internally or externally vented?
• What are the main operating requirements for your
  cleaning system?

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Stacks

• Where does this stack go?
• What portion of the process leads to it?
• Is it a hot or cold gas stack?
• Is this stack covered in your permit?
• Does it have a manual or automatic shut off?
• Can you bypass it, if you want to?
• How often do you do emissions observations? Do
  you record them?
• What are the normal visible emissions observed?

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Gauges

• What does this gauge tell you?
• How often do you check and or record the data
  from it?
• What does that data mean?
• How do you know it is operating properly?
• Is proper operation of this gauge defined in your
  MAP/PMP?

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Spray Coating

• What media is run through the line?
• What type of spray technology do you use?
• If HVLP, do you keep test caps onsite and use
  them? If so, how often?
• Manual or robotic spray?
• Have you ever done a transfer efficiency test?
• How is usage measured?

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E-Coat/Dip Coat

• What size tank do you have?
• How often do you add paint or other constituents
  to the tank?
• How are the adds measured?
• Is the coating water or solvent based?
• How much time do parts spend in the coating?

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Other Coating Operations

• These may include, but are not limited to, roll
  coating and hand application.
• Generally you will get the same type of
  questions regardless of your coating operation.
  The important thing is to have a good working
  knowledge of how your system operates.

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Filters

• What portions of the coating lines are controlled
  by filters?
• What type of filters are used?
• How often are the filters changed?
• Are the filters changed because of process
  indications or because of PMP?
• If changed because of process indications, what
  are these indications?

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Ovens

• At what temperature is your oven set?
• What is the temperature range indicated for
  proper operation?
• How do you monitor this temperature? Strip chart?
• If you do not have a strip chart, how often do
  you observe and record the operating temperature?
• Does the oven automatically shut off if the
  temperature is out of the range of proper
  operation?
• What other indicators do you have that the oven
  is not operating properly?

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Control Equipment

• What type of control, if any, does the line
  utilize?
• What are the main operating parameters of the
  device?
• How is the device monitored? (i.e. temperature
  strip chart)
• Does the device have an automatic shutdown if not
  operating properly?
• If so, what would have to happen to cause a
  shutdown?

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Purge and Clean up

• What type of purge/cleanup solvent do you use?
• How does your system purge?
• To where does your system purge?
• How is this waste stored?
• Do you account for reclaim? If so, how is that
  measured?
• What type of cleanup system do you use? Hand
  wiping?
• Are the solvent containers stored closed when not
  in use?

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The Bottom Line Is

• Know what it takes to operate your system and
  what parameters constitute proper operation

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Recordkeeping

• What do you need to know?
• Based on your permit or exemptions, what are your
  record keeping obligations?
• What date do you need to have your last months
  record keeping done?
• Who is responsible for what records?
• Where and by what means do you file your records?
• Are you keeping records for each of the permit
  conditions as specified?
• If required, have you determined whether or not
  your record keeping system is acceptable to the
  AQD District Supervisor/your inspector?
• What calculations are you using to determine each
  of the emissions or usages required?

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VOC Content

• How is your VOC content determined? Manufacturers
  formulation data or Method 24 analysis?
• If you use manufacturers formulation data, how
  does your manufacturer get their information?
• How often does your manufacturer update their
  information to you?
• Do you account for the VOCs in any additives you
  put into your coating?

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HAP Content

• Know that your HAP and VOC content may not
  necessarily be the same thing.
• You usually will have to keep VOC emission
  records on a per emission unit basis, while your
  HAP emissions will typically be on a facility
  wide basis
• Are you adding in your HAPs from all facility
  emission units exempt and grandfathered units?
• Generally speaking, accurate HAPs data is a
  little more difficult to come by. Make sure your
  manufacturer knows what information you need from
  them.

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MMMM PPPP and Work Practice Standards

• Good News!!! You only have to know, follow, and
  formulate a work practice plan for these MACTs if
  you have add-on controls.

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If you have add-on controls...

• You must develop a work practice plan to reduce
  HAPs emissions that contains at a minimum
• All HAP containing materials must be stored in
  closed containers
• Spills of HAP containing materials must be
  minimized
• HAP containing materials must be conveyed between
  locations in closed containers or pipes
• Mixing vessels that utilize or contain HAP
  containing materials must be closed except when
  additions are taking place
• HAP emissions must be minimized during the
  cleaning of storage, mixing, and conveying
  equipment.
• 63.4493 and 63.3893 a through c

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Any Questions?
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Thank You!