previously selected for the Common Measures SQG sector, as well as to develop industrial waste water and pollution prevention indicators.
A conference call was held on November 20, 2007 to further discuss the auto body indicators. Project states and EPA were asked to review draft language prepared by the Project Management Team and approve, reject or modify the draft indicators. Below is an example of how the data was collected:
DRAFT AIR INDICATORS (from AREA SOURCE RULE):
1. Are all spray-applied coatings applied using an HVLP spray gun or an equivalent high transfer efficiency technology?
2. Have the painters been properly trained in high transfer efficiency within the last five
Suggests waiting to develop training question until Area Source Rule released to know what is and is not going to be required.
Training not yet a regulatory requirement in NY. Suggests question be a BMP with space to provide specific type of training.
Training is not a regulatory requirement in RI.
Suggests adding the word high transfer efficiency “Spraying” within the last five years.
I think we should define the word “properly” by describing in detail exactly what
should be included in the training ( as EPA elaborates on below) We don’t think it should be required until the date that the NESHAP or our state specifies that it’s required. We want to include it in the checklist now, but with a date in the future that they will need to comply. This way we don’t need to rewrite our checklist later and the shops know what is coming.
Training consists of hands-on and classroom training that includes initial and refresher training in the following: Surface preparation; spray gun setup and operation for different types of coatings to improve transfer efficiency and minimize coating usage and overspray; routine spray booth and filter maintenance; safety precautions; and environmental compliance.
As a result of this discussion, draft auto body indicators were revised over several months and final auto body indicators were issued in February 2008. See Exhibit 5.1 in Section 5.4 for the list of Auto Body indicators.
The States Common Measures Project Final Report