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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