Surface Coating and Paint Stripping

** New Federal Rules Affecting Paint Stripping, Autobody Refinishing and Miscellaneous Surface Coating Operations at Area/Small Sources **

On January 9, 2008, the U.S. Environmental Protection Agency published rules to reduce air toxics including methylene chloride and other hazardous air pollutants (HAPs) from surface coating operations at area sources. The final rule is the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources, 40 CFR Parte 63 Subpart HHHHHH (6H). See rule.

**Note: Affected Sources have an Initial Notification Due by January 11, 2010**

What are the Rule’s compliance dates?

New Operations [started after September 17, 2007] (New)

» Must be in compliance with the new rules upon start-up

» Must submit an Initial Notification and Notification of Compliance Status no later than 180 days after initial start-up (Call 1800-734-3619 for additional new source information)

Existing Operations [started on or before September 17, 2007]

» Must submit an Initial Notification no later than January 11, 2010. See sample initial notification.

» Must be in compliance by January 10, 2011

Who is affected by this Rule?

Area sources that conduct any of the following:

» Paint stripping operations that use methylene chloride for the removal of dried paint.

» Motor vehicle (Autobody) and mobile equipment spray coating operations

» Miscellaneous surface coating operations (All of the following must apply):

• Perform hand-held spray painting
• Spray paint metal, plastic or a combination of the two

• Use surface coating material that contain chromium, lead, manganese, nickel, or/and cadmium

What are the Rule’s Exemptions (please check-you could be exempt!)?

What is an Area Source?

An area source is a source that does not have the potential to emit more than the following:

» 10 tons or more per year of a single HAP or

» 25 tons or more of a combination of one or more HAPS or

» 100 tons or more per year of a criteria pollutant

What are the significant rule requirements?

» Spray painting must be conducted in a booth

» Painters must use HVLP spray guns or equivalents

» All painters must complete a training course on proper spray gun use and maintenance

» Specific spray gun cleaning requirements

» Paint stripping operations must implement management practices that minimize emissions of methylene chloride

Note:

The Tennessee Technology Centers may offer hands on training classes required by the new air pollution control rule. Please visit http://www.tbr.state.tn.us/schools/default.aspx?id=2436 to find the location nearest you.

Resources:

» Brochure on the rule

» Initial Notification Sample

» Compliance Letters

• Autobody

• Miscellaneous Surface Coating and Paint Stripping Operations

• Sample Opt Out Petition Letter, if applicable

EPA publications:

» Collision Repair Video

» Federal Register Rule

» Rule summary brochure

» Brief Autobody Rule Summary

• English

• Spanish

» Brief Miscellaneous Surface Coating Rule Summary

• English

• Spanish

» Brief Paint Stripping Rule Summary

• English

• Spanish