Surface Coating & Paint Stripping

e-CFR Subpart HHHHHH [ecfr.gov]

This subpart applies to Area Sources* of HAPs that:

1. Perform paint stripping using methylene chloride (CAS # 75092).
2. Spray-apply coatings to motor vehicles and/or mobile equipment.
3. Spray-apply coatings to plastic or metal parts or products.
4. *Area Sources of HAPs emit or have the potential to emit:
   • < 10 tons per year of a single HAP, or
   • < 25 tons per year of combined HAPs.
   • Major Sources emit more than Area Sources.

Definition of Spray-apply Coating:

• Use of a hand-held device that creates an atomized mist that is desposited on a substrate. This does not include:
  • Coatings applied from a hand-held device with a paint cup capacity ≤ 3.0 fluid ounces.
  • Applications using powder coating, hand-held non-refillable aerosol containers, or non-atomizing applications (e.g., dip coating, electrodeposition coating, coil coating, etc).
  • Thermal spray operations.

Definition of Mobile Equipment:

• Any device that may be drawn or driven on a roadway (e.g., heavy-duty trucks, truck trailers, buses, bulldozers, agriculture equipment, recreational vehicles, etc).

Exemption from this rule:

Motor vehicle or mobile equipment surface coating operations may petition NDEQ for exemption from this rule if they can demonstrate that they do not spray-apply any coatings containing the target HAPs (i.e., compounds of chromium, lead, manganese, nickel, or cadmium).

NESHAP - 40 CFR Part 63

Subpart XXXXXX - Metal Fabrication & Finishing
Subpart MMMM - Misc. Metal Parts Surface Coating
Subpart PPPP - Plastic Parts & Products Surface Coating

e-CFR Subpart HHHHHH [ecfr.gov]

Source Classification

1. Existing Source
   • Constructed or reconstructed on or before Sept 17, 2007
2. New Source
   • Constructed or reconstructed after Sept 17, 2007
   • Installed new coating or stripping equipment or if the facility was not engaged in paint stripping or surface coating before that date.
3. Existing facilities that add new equipment to comply with the rule (e.g., add booth to reduce emissions, etc.), are still considered existing.

Initial Notification

1. Existing Source
   • Due by Jan 11, 2010
2. New Source
   • Due by July 7, 2008 or 180 days after startup, whichever is later.

Compliance Dates

1. Existing Source
   • Must comply by Jan 10, 2011
2. New or Reconstructed Source
   • Must comply by Jan 9, 2008 or upon startup, whichever is later.
3. Painter training must be completed within 180 days after the hiring date and repeated every 5 years.

Compliance Status Notification

1. Existing Source
   • Due by March 11, 2011
2. New Source
   • Due by July 7, 2008 or 180 days after startup, whichever is later.

Annual Notification of Changes Report

1. Must be submitted each calendar year in which information previously submitted has been changed, or:
   • If deviations have occurred, or
   • Methylene chloride paint stripping usage exceeds 1 ton/yr
2. Due by March 1 of each year

**** Please check with LLCHD or OAQC if you are located within Omaha city limits or Lancaster County. They may have notification or reporting requirements that differ from NDEQ.

EPA’s Collision Repair Campaign to Reduce Air Toxics - information, training, and tools to reduce auto body emissions. This site contains a link to a free 19 minute training video (Windows Media File) (59 MB) starring NASCAR driver Jeff Gordon and featuring testimonies from large and small shop owners, which addresses:

Paint Strip Rule
Best practices
Saving money
Worker protection
Outreach resources

Iowa DNR Area Source NESHAP website [iowadnr.gov] - fact sheets, guidance documents, and presentations

EPA's Area Source Website [epa.gov] - guidance documents for all area source rules