What Is The Compliance Date?
• Existing Sources: January 10, 2011.
• New Sources: Upon startup after January 9, 2008.
• An affected source is a new source if you
commenced construction of the source after
September 17, 2007 by installing new paint
stripping or surface coating equipment at a source not
actively engaged in paint stripping and/or
miscellaneous surface coating prior to
September 17, 2007.
• An affected source is an existing source if it is not a
new source or a reconstructed source (An affected
source is reconstructed if it meets the definition of
reconstruction in section 63.2.).
What are the Permitting Requirements?
• Affected facilities are exempt from Title V permit
requirements provided they are not required to obtain
a permit for another reason.
What Reporting\Recordkeeping is Required?
Reporting:
• Initial Notification (informs EPA that the facility is
subject to the standards and when the source will be
in compliance).
New Sources: July 7, 2008 or 180 days after
startup
Existing Sources: January 11, 2010
• Notification of Compliance (certifies that the source is
in compliance with the applicable requirements).
New Sources: As part of the Initial Notification
Existing Sources: March 11, 2011
• Annual notification of changes report—required each
calendar year any reportable changes occur.
Recordkeeping (keep these records on file)
• Records to include copies of Notifications
submitted to EPA.
• Painter training certifications.
• Spray booth filter efficiency documentation.
• Spray gun transfer efficiency.
• MeCI content information such as MSDS.
• Annual usage of MeCI for paint stripping, and
written MeCI minimization plan if annual usage > 1 ton
per year.
• Deviation and corrective action documentation.
Records to be maintained in a form suitable and readily
available for expeditious review.
You can also contact your Regional EPA air toxics
office at the following numbers:
Address
Region 1
5 Post Office Square, Suite 100
Mail code: OES04-2
Boston MA 021 09-391 2
Region 2
290 Broadway
New York, NY 10007-1 866
Region 3
1650 Arch Street
Philadelphia, PA 191 03-2029
Region 4
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, GA 30303-8960
Region 5
77 West Jackson Blvd.
Chicago, IL 60604-3507
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
Region 7
901 North Fifth Street
Kansas City, KS 661 01
Region 8
1595WynkoopSt.
Denver, CO 80202-1 129
Region 9
75 Hawthorne Street
San Francisco, CA 941 05
Region 10
1200 6th Ave.
Suite 900, AWT-1 07
Seattle, WA 981 01
States
CT, MA,
ME, NH,
RI.VT
NJ, NY,
PR, VI
DE, MD,
PA, VA,
WV, DC
FL, NC,
SC, KY
TN.GA,
AL, MS
IL, IN,
MI.WI,
MN.OH
AR, LA,
NM.OK,
TX
IA, KS,
MO, NE
CO, MT,
ND.SD,
UT.WY
CA.AZ,
HI, NV, GU,
AS, MP
AK, ID
WA.OR
Website/
Phone Number
www.epa.gov/region1
(888)372-7341
(617)918-1650
www.epa.gov/region2
(212)637-4023
www.epa.gov/region3
(215)814-2746
(800)228-8711
www.epa.gov/region4
(404)562-9131
(800)241-1754
www.epa.gov/region5
(312)886-6812
(312)353-6684
(312)886-6798
www.epa.gov/region6
(800) 887-6063*
(214)665-7250
(214)665-7224
www.epa.gov/region7
(800) 223-0425
(913)-551-7003
www.epa.gov/region8
(800)227-8917*
(303)312-6460
www.epa.gov/region9
(415)947-8715
www.epa.gov/region10
(800) 424-4372*
(206) 553-6220
* For sources within the region only.
For More Information
Copies of the rule and other materials are located at:
http://www.epa.gov/ttn/atw/area/arearules.html
For more information on state requirements, please contact
your state representatives at:
http://www.epa.gov/ttn/atw/area/table_state_contacts.doc
or,
http://www.4cleanair.org/contactUsaLevel.asp
United States
Environmental Protection
Agency
April 2008
www.epa.gov/ttn/atw/eparules.html
Office of Air Quality Planning & Standards (El 43-02)
vvEPA
Summary of Regulations
Controlling Air
Emissions from
PAINT STRIPPING AND
MISCELLANEOUS SURFACE
COATING OPERATIONS
NATIONAL EMISSION
STANDARDS FOR
HAZARDOUS AIR
POLLUTANTS
NESHAP
(SUBPART HHHHHH)
FINAL RULE
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PAINT STRIPPING AND
MISCELLANEOUS SURFACE
COATING OPERATIONS
TSUBPART HHHHHH)
What Is an Area Source?
• Any source that is not a major source.
(A major source is a facility that emits, or has the
potential to emit in the absence of controls, at
least 10 tons per year (TRY) of individual
hazardous air pollutants (HAP) or 25 TRY of
combined HAP.)
Who Does This Rule Apply To?
• Area sources that engage in any of the following:
> Paint stripping operations that use
methylene chloride (MeCI)-containing paint
stripping formulations;
> Spray application of coatings to motor
vehicles and mobile equipment;
> Spray application of coatings to a plastic
and/or metal substrate where the coatings
contain compounds of chromium (Cr), lead
(Pb), manganese (Mn), nickel (Ni), or
cadmium (Cd).
This rule does not apply to:
• Surface coating or paint stripping performed on
site at installations owned or operated by the
Armed Forces of the United States.
• Surface coating or paint stripping of military
munitions or equipment directly and exclusively
used for the purposes of transporting military
munitions.
• Surface coating or paint stripping performed by
individuals on their personal vehicles, property
or possessions, either as a hobby or for
maintenance of their personal vehicles,
possessions, or property provided they coat no
more than two vehicles per year.
• Surface coating or paint stripping that meets the
definition of "research and laboratory activities."
• Surface coating or paint stripping that meets the
definition of "quality control activities."
• Surface coating or paint stripping that meets the
definition of "quality control activities."
• Surface coating or paint stripping activities that are
covered under another area source NESHAP
Motor vehicle or mobile equipment surface coating
operations may petition the Administrator for an
exemption from this subpart if you can demonstrate, to the
satisfaction of the Administrator, that you spray apply no
coatings that contain compounds of chromium (Cr), lead
(Pb), manganese (Mn), nickel (Ni), or cadmium (Cd).
What Am I Required To Do?
• Paint Stripping Operations—implement management
practices that minimize emissions of MeCI.
> Evaluate the need for paint stripping (e.g., is it
possible to re-coat without stripping?).
> Evaluate each application to identify potential
alternative stripping methods.
> Reduce exposure of strippers to air.
> Optimize application conditions.
> Practice proper storage and disposal.
• For each paint stripping operation with > 1 ton MeCI
annual usage, develop and implement a written MeCI
minimization plan. No implementation plan is needed if
usage is < 1 ton MeCI; however, sources must still
utilize work practices to minimize emissions of MeCI.
Consult the MSDS sheet to identify the amount of MeCI
contained in the paint stripper, but note that annual
usage should not exceed 181 gallons of MeCI.
• Maintain records of annual usage of paint strippers
containing MeCI.
• Motor Vehicle/Mobile Equipment/Miscellaneous
Surface Coating Operations.
> Train/certify all painters on spray gun equipment
selection, spray techniques, maintenance, and
environmental compliance (consult 73 FR 1738, pg.
1762, section 63.11173(f)(2)(i)-(iv)).
> Install/operate filter technology on all spray
booths/stations/enclosures to achieve at least 98%
capture efficiency.
> Spray booths/stations used to refinish complete
motor vehicles or mobile equipment must be fully
enclosed and ventilated at negative pressure or up
to 0.05 inches water gauge positive pressure for
booths that have seals on all doors and other
openings and an automatic pressure balancing
system.
> Spray booths/stations used to coat
miscellaneous parts or products or vehicle
subassemblies must have a full roof, at least three
complete walls or side curtains, and ventilated so
that air is drawn into the booth.
> Spray-applied coatings must be applied with a
high volume, low pressure (HVLP) spray gun,
electrostatic application, airless or air-assisted
airless spray gun, or an equivalent technology.
> Paint spray gun cleaning must be done so that an
atomized mist or spray of the cleaning solvent is
not created outside a container that collects used
gun cleaning solvent.
> Train and certify all personnel who spray apply
surface coatings no later than 180 days after hiring
or by July 7, 2008 (new sources) or by January 10,
2011 (existing sources).
What are the Impacts?
• Most paint stripping facilities already comply with the
rule requirements. Estimate 1,000 facilities will need to
take action to comply.
> Reduce 1,000 tons MeCI annually,
> Capital costs = $1.5 million.
> Annual benefit = $0.9 million.
• Most surface coating facilities already comply with the
rule requirements. Estimate < 25% of existing facilities
will need to take some action to comply.
> Reduce 6,900 tons of HAP annually including 11
tons of metal HAP.
> Capital costs = $20 million; however, initial cost to
be offset and recovered over time by cost savings
as a result of more efficient use of labor and
materials.
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