AUTHORIZATION TO OPERATE (ATO) UNDER PDEQ CLASS

Attachment 4 to the ATO – Surface Coating and Abrasive Blasting RequirementsSuitable Enclosure means a confined area, completely enclosed (side curtains or small openings are allowed as longas the ventilation air maintains the enclosure under negative pressure such that air is drawn into the booth openingsor side curtains, where all exhaust from the controls is controlled as described in Condition 2.a.i of this Attachment.Volatile Organic Compounds (VOC) means any compound of carbon, excluding carbon monoxide (CO), carbondioxide (CO2), carbonic acid, metallic carbides, or carbonates, and ammonium carbonate, which participates inatmospheric photochemical reactions. This includes any organic compound other than those in the definition inPCC 17.04.340.A(250), which have been determined to have negligible photochemical reactivity.VOC Containing means a material that contains two percent by weight or more VOC as determined by themanufacturer’s safety data sheet (SDS) or technical product data sheet, or ASTM 2369, or methods set forth in 40CFR 60, Appendix A. For the purpose of determining whether materials used contain the VOC compounds, thePermittee may rely on formulation data provided by the manufacturer or supplier, such as the safety data sheet(SDS).VHAP Containing means a HAP containing material that contains volatile HAP constituents.Emission Limitations and Standards1.[PCC 17.13.020.A.2]Operating Limitations[PCC 17.12.350.A.3.a][Material Permit Conditions]For the purpose of these provisions, surface coatings include but are not limited to paints, diluents, adhesives,sealants, wash, and clean-up solvents. This provision shall apply to VOC containing and HAP containingsurface coatings or solvents used at the facility.[PCC 17.04.340.A.219 & 40 CFR 63.11180]a. The Permittee shall not use surface coatings and solvents combined (including those used for architecturaland/or outdoor spot painting activities) in excess of the daily and annual amounts listed in the ATO.b. The Permittee shall not use abrasive blasting media in excess of the daily and annual amounts listed inthe ATO.2.Organic Solvents and Surface Coating Operation Standardsa.Suitable EnclosureThe Permittee shall not conduct any spray coating or spray paint operation without minimizing organicsolvent emissions. Such operations, other than architectural coating and spot painting, shall be conductedin an enclosed area equipped with controls containing no less than ninety-six percent of the overspray.[PCC 17.16.400.C.1 & PDEQ Tech Policy 202]i.An approvable operation shall be one that is conducted in any suitable enclosure where the oversprayis directed to either:(a) A filtering system designed for controlling the particulate portion of the overspray;(b) A commercially designed water curtain or equivalent;(c) A baffle system designed for the purpose, along with a statement by the manufacturer that the96% overspray control requirement will be met; or(d) Any other system, which can be shown to meet the 96% overspray control requirement.Use of one or more of the controls in Condition 2.a.i demonstrates compliance, unless evidence ofoverspray is observed outside of the enclosure.ii.For the purpose of approving filtering or other systems in Condition 2.a.i the Control Officer mayapprove any system where the overspray is exhausted through one or more filters commerciallydesigned for the primary purpose of removal of particulate matter from spray applied surface coatingand painting operations. Such spray booths shall be installed and maintained in accordance with themanufacture’s recommendations or an operation and maintenance plan developed by the Permittee.iii. The spray booth exhaust must be directed vertically up into the atmosphere and at a reasonable stackheight as described in Condition 14.c of the permit.General Air Quality Permit for Fuel Burning Equipment(Boilers, Heaters, and Generators) Permit # 6205Page 2 of 5May 6, 2020

Attachment 4 to the ATO – Surface Coating and Abrasive Blasting Requirementsb.Solvent Degreasing/Cleaningi.Solvent degreasing units shall be equipped with lids that are kept closed when not in use and/orequipped with a drain-back system to keep the basin empty when not in use.[PCC 17.16.400.A]ii.All VOC and HAP containing solvent washings of painting equipment shall be directed intocontainers that minimize emissions and prevent evaporation into the atmosphere.[PCC 17.16.400.A, PCC 17.16.400.C.1 & 7]c.Prohibited Activitiesi.ii.The Permittee is prohibited from conducting or performing paint stripping operations that involvethe use of methylene chloride (MeCl, CAS 75092), and except for facility maintenance, the Permitteeis prohibited from conducting any spray application of coatings that contain target HAP to metal orplastic parts or products, without having first submitted an Initial Notification in accordance with 40CFR Part 63, Subpart HHHHHH to the Control Officer and complying with the applicablerequirements. The Control Officer may provide a supplement to this Attachment containing SpecificConditions for applicable sources (See Supplement to Attachment 4 for NESHAP Subpart HHHHHHaffected sources).[PCC 17.12.350.A.3.a, PCC 17.16.530.B111, 40 CFR 63.11169 & 63.11180][Material Permit Condition]The Permittee is prohibited from using halogenated solvents in solvent degreasing/cleaning units ina total concentration that is greater than 5 percent by weight HAP, without having first submitted anInitial Notification in accordance with 40 CFR 63, Subpart T to the Control Officer and complyingwith the applicable requirements. The Control Officer may provide a supplemental attachmentcontaining Specific Conditions for sources subject to 40 CFR 63, Subpart T.[PCC 17.12.350.A.3.a, NESHAP Subpart T Applicability][Material Permit Condition]d.Architectural Coating StandardThe Permittee (or contractor) shall not employ, evaporate or dry any architectural coating containingphotochemically reactive solvents (PRS) for industrial or commercial purposes, or thin or dilute anyarchitectural coating with a PRS. A PRS shall be any solvent with an aggregate of more than 20% of itstotal volume composed of the chemical compounds as classified below, or which exceeds any of thepercentage composition limitations as stated below. Whenever any organic solvent or any constituent ofan organic solvent may be classified from its chemical structure into more than one of the groups oforganic compounds described below, it shall be considered to be a member of the group having the leastallowable percent of the total volume of solvents:[PCC 17.16.400.C.2-4]i.ii.A combination of the following types of compounds having an olefinic or cyclo-olefinic type ofunsaturation-hydrocarbons, alcohols, aldehydes, esters, ethers, or ketones: 5%.A combination of aromatic compounds with eight or more carbon atoms to the molecule, exceptethylbenzene: 8%.iii. A combination of ethylbenzene, ketones having branched hydrocarbon structures, trichloroethyleneor toluene: 20%.3.Abrasive Blasting Operationsa.b.The Permittee shall not cause, suffer, allow or permit the use of any abrasive blasting agent other thanclean sand (i.e. washed, and without use of recycling), slag, specialized mineral abrasives (garnet, olivine,et. al.), synthetic abrasives (cut plastic, glass beads, crushed glass, plastic bead, et. al.), or various nutshells.[Material Permit Condition]Emissions from sandblasting or other abrasive blasting operations shall be controlled by applying waterto suppress visible emissions (wet blasting), enclosing the operation, or use of other equivalently effectivecontrols. For the purpose of this provision, air blast (or dry) systems that use low emitting blast agents asprovided in Condition 3.a of this attachment, that can readily comply with the opacity limits and visibilitylimiting standards in Conditions 17 and 18 of the permit, while in operation, shall be considered to be anequivalently effective control.[PCC 17.16.100.D]General Air Quality Permit for Fuel Burning Equipment(Boilers, Heaters, and Generators) Permit # 6205Page 3 of 5May 6, 2020

Attachment 4 to the ATO – Surface Coating and Abrasive Blasting RequirementsCompliance Determination4.Organic Solvents and Surface Coating Operationsa.The Permittee shall maintain documentation demonstrating that enclosed surface coating operations (paintspray booths) meet the overspray control requirements in Condition 2.a of this attachment by using filtersthat have a minimum arrestance rating to contain at least 96% of the overspray, or an equivalent systemwhich can be shown to meet the over-spray control requirement, and the Permittee shall ensure that theenclosure and controls are operated and maintained consistent with manufacturer’s guidelines or goodengineering practice.b.As applicable, the Permittee shall monitor and keep the following records of the VOC containing andHAP containing surface coating materials (including but not limited to coatings, paints, adhesives,sealants, diluents, wash, and clean-up solvents) used (in gallons) onsite in a complete and consistentmanner and shall make them available for review by the Control Officer without delay during normalbusiness hours to demonstrate compliance with Conditions 1.a and 2.d of this attachment.i.ii.c.d.5.[PCC 17.12.185.A.3, 4 & 5]The following records of usage (in gallons):The Permittee shall maintain purchase records of the volume (in gallons) of each surface coatingmaterial used each month and the resulting 12-consecutive month facility total. The 12-consecutivemonth total is defined as the sum of the usage for the current month and usage for the previous elevenmonths.The name, indexed ID, and Safety Data Sheet, for VOC containing and HAP containing surfacecoating materials used onsite including the identification of coatings which fall into the followingsubcategories:(a) Architectural coatings(b) Coatings used for outdoor spot paintingThe Permittee shall keep daily logs of the amount (in gallons) and the indexed ID (as provided inCondition 4.b.ii, above) of surface coatings and solvents used in each spray booth or enclosure and forarchitectural coating or spot painting activities (as provided in Condition 4.d, below) and total the amountused within 30 days of the end of the month. These records shall be kept in addition to the records inCondition 4.b of this attachment.When conducting architectural or outdoor spot painting activities not normally applied in an enclosure,the Permittee shall maintain daily logs of the following:i. The location of the activity, application method (airless, air assisted airless, HVLP, spray can, (et.al.) and the controls used (if any); andii. The type of coating applied and applicable SDS or indexed ID (as provided in Condition 4.b, above);andiii. The amount of coating and solvents (excluding water) used, in gallons.Abrasive Blasting OperationsThe Permittee shall total the amount, in pounds, of abrasive blasting agents used in abrasive blasting operationsas provided in Conditions 5.a and 5.b, below, within 30 days of the end of the month and maintain a record ofthe 12-month rolling totals to demonstrate compliance with the limits in the ATO.a.For each enclosed abrasive blasting operation listed in the ATO, the Permittee shall log the daily andmonthly amounts of abrasive blasting agents used, in pounds. For the purpose of this provision, smallcommercial abrasive blasting cabinets shall be deemed by the Control Officer to be insignificant activitiesand exempt from this requirement provided the cabinet is equipped with filtration control devices.General Air Quality Permit for Fuel Burning Equipment(Boilers, Heaters, and Generators) Permit # 6205Page 4 of 5May 6, 2020

Attachment 4 to the ATO – Surface Coating and Abrasive Blasting Requirementsb.When conducting non-enclosed outdoor abrasive blasting operations, the Permittee (or contractor) shallmaintain daily logs of the following information for each day of operation. If no operations occur, nologs shall be required.i.The location of the activity and controls used (if any); andii. The abrasive blasting agent used; andiii. The amount of abrasive blasting agent used, in pounds.Additional Applicable RegulationsPima County Code Title 17, Chapter 17.16 – Emission Limiting StandardsArticle III – Emissions from Existing and New Nonpoint Sources17.16.100.D Particulate materials (abrasive blasting)Pima County Department of Environmental Quality – Technical ProceduresPDEQ Tech Policy 202 – Controlling Overspray in Paint Spray OperationsGeneral Air Quality Permit for Fuel Burning Equipment(Boilers, Heaters, and Generators) Permit # 6205Page 5 of 5May 6, 2020

Supplement to Attachment 4 for NESHAP Subpart HHHHHH – Autobody Refinishing & Miscellaneous Surface Coating OperationsSupplement to Attachment 4 for NESHAP Subpart HHHHHH –Autobody Refinishing & Miscellaneous Surface Coating OperationsIn accordance with Condition 119.f.v of the permit, the terms and Conditions in this Supplement apply to allNESHAP Subpart 6H affected Autobody Refinishing Operations and Miscellaneous Surface CoatingOperations listed in the ATO. This Supplement does not apply to surface coating of military munitions, orsurface coating that meets the definition of quality control or research and laboratory activities. ThePermittee must comply with Conditions 1 through 5 of Attachment 4 to the ATO as well as the additionalterms and Conditions in this Supplement. All provisions of this section are federally enforceable unlessotherwise noted.DefinitionsThe following definitions shall have the meaning as defined in the Clean Air Act or Title 17 of the PimaCounty Code, and NEHSAP Subpart HHHHHH, unless otherwise defined in this Supplement. Terms belowmarked with an asterisk are terms defined in 40 CFR § 63.11180. If a term is not defined, it shall beinterpreted in accordance with normal business use:Aerospace vehicle or component* means any fabricated part, processed part, assembly of parts, or completedunit, with the exception of electronic component, of any aircraft including but not limited to airplanes;helicopters; missiles; rockets; and space vehicles.Airless and air-assisted airless spray* means any paint spray technology that relies solely on the fluidpressure of the paint to create an atomized paint spray pattern and does not apply any atomizing compressedair to the paint before it leaves the paint nozzle. Air-assisted airless spray uses compressed air to shape anddistribute the fan of atomized paint, but still uses fluid pressure to create the atomized paint.Appurtenance* (See also Facility maintenance) means any accessory to a stationary structure coated at thesite of installation, whether installed or detached, including but not limited to bathroom and kitchen fixtures;cabinets; concrete forms; doors; elevators; fences; hand railings; heating equipment, air conditioningequipment, and other fixed mechanical equipment or stationary tools; lamp posts; partitions; pipes and pipingsystems; rain gutters and downspouts; stairways, fixed ladders, catwalks, and fire escapes; and windowscreens.Autobody Refinishing Operation* means an operation that encompasses motor vehicle and mobileequipment spray-applied surface coating operations that perform spray application of coatings as definedherein to motor vehicles and mobile equipment including operations that are located in stationary structuresat fixed locations, and mobile repair and refinishing operations that travel to the customer's location, exceptspray coating applications that meet the definition of facility maintenance.Coating* means a material spray-applied to a substrate for decorative, protective, or functional purposes.For the purposes of this definition, coating does not include the following materials:a. Decorative, protective, or functional materials that consist only of protective oils for metal, acids, bases,or any combination of these substances.b.Paper film or plastic film that may be pre-coated with an adhesive by the film manufacturer.c.Paper film or plastic film that may be pre-coated with adhesive by the film manufacturer.d.Adhesives, sealants, maskants or caulking materials.e.Temporary protective coatings, lubricants or surface preparation materials.f. In-mold coatings that are spray-applied in the manufacture of reinforced plastic composite parts.Electrostatic application* means any method of coating application where an electrostatic attraction iscreated between the part to be coated and the atomized paint particles.General Air Quality Permit for Fuel Burning Equipment(Boilers, Heaters, and Generators) Permit # 6205Page 1 of 10May 6, 2020

Supplement to Attachment 4 for NESHAP Subpart HHHHHH – Autobody Refinishing & Miscellaneous Surface Coating OperationsFacility Maintenance* means surface coating performed as part for the routine repair or renovation of thetools, equipment, machinery, and structures that comprise the infrastructure of the affected facility and thatare necessary for the facility to function in its intended capacity. Facility maintenance also includes surfacecoating associated with the installation of new equipment or structures, and the application of any surfacecoating as part of the janitorial activities.a.Facility Maintenance includes the application of coatings to stationary sources or theirappurtenances at the site of installation; portable buildings at the site of installation; and pavementsor curbs.b. Facility Maintenance also includes the refinishing of mobile equipment in the field or at the sitewhere they are used in services and at which they are intended to remain indefinitely afterrefinishing, including, but not limited to farm equipment and mining equipment, for which it is notpractical or feasible to move to a dedicated mobile equipment refinishing facility. Such mobileequipment also includes items such as fork trucks that are used in a manufacturing facility andrefinished in that same facility.c. Facility Maintenance does not include surface coating of motor vehicles, mobile equipment, oritems that routinely leave and return to the facility, such as delivery trucks, rental equipment, orcontainers used to transport, deliver, distribute, or disp

Emergency Generator/ Bldg. 3 . Detroit/Kohler : TBD . 315 : Pre-2006 . Unknown : 100 hrs . Diesel : 13 . Aircraft Power Ground Unit (Moves on Site) Hobart . Unknown : 90 HP . Unknown : Unknown . None : Diesel/ Unlimited - Aircraft Power Ground Unit (Moves on Site) Hobart : Unknown .