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PAINT STRIPPING AND
<br />MISCELLANEOUS SURFACE
<br />COATING OPERATIONS
<br />(SUBPART HHHHHH)
<br />What Is an Area Source?
<br />• Any source that is not a major source.
<br />(A,major source is a facility that emits, or has the
<br />potential to emit in'the absence of controls, at
<br />least 10 tons per year (TPY) of individual
<br />hazardous air pollutants (HAP) or 25 TPY of
<br />combined HAP.)
<br />Who Do'es'T'is Rule Apply To?
<br />• Area sources that engage in any of the following:
<br />> Paint stripping operations that use
<br />methylene chloride (MeCi)-containing paint
<br />stripping formulations;
<br />> Spray. application of coatings to motor
<br />vehicles and mobiieequiprent;
<br />> Spray application of coatings to a plastic
<br />and/or metal substrate where the coatings
<br />contain compounds of chromium (Cr), lead
<br />(Pb),,manganese (Mn), nickel (NI), or
<br />cpdmi6m (06).
<br />This rule does not apply to:
<br />• Surface coating or paint stripping performed on
<br />site at installations owned or operated by the
<br />Armed Forces of the United States.
<br />• Surface coating or paint sinppifi6 of military
<br />munitions
<br />s or-equipmentAirecty and exclusively
<br />used forthe purposes"bf iransp6rtini- g military
<br />munitions,
<br />• Surface coating or paint stripping performed by
<br />individuals on their personal vehicles, property
<br />or possessions, oitheras.a hobby or for
<br />maintenance of their personal, vehicles,
<br />possessions, or property provided they coat no
<br />more than two vehicles per year.
<br />• Surface coating or paint stripping that meets the
<br />definition of "research and laboratory activities.'
<br />• Surface coating or paint stripping that meets the
<br />definition of "quality control activities."
<br />Surface coating or paint stripping that meets the
<br />definition of "quality control activities."
<br />• Surface coating or paint stripping activities that are
<br />covered under another area source NESHAP
<br />Motor vehicle or mobile equipment surface coating
<br />operations may petition the Administrator for an
<br />exemption from this subpart if you can demonstrate, to the
<br />satisfaction of the Administrator, that you,spray apply no
<br />coatings that contain compounds of chromium (Cr), lead
<br />(Pb), manganese (Mn), nickel (Ni), or cadmium (Cd).
<br />• Paint Stripping Operations—implement management
<br />practices that minimize emissions of MeCl.
<br />> Evaluate the need for paint stripping (e.g., is it
<br />possible tore -coat without stripping?).
<br />> Evaluate each application to identify potential
<br />alternative stripping methods.
<br />> Reduce exposure of strippers to air.
<br />> Optimize application conditions.
<br />> Practice proper storage and disposal.
<br />* For each paint stripping operation with > I ton MeCl
<br />annual usage, develop and implementa written MeCl
<br />minimization plan. No implementation- plan is needed if
<br />usage is < I ton MeCl; however, sources must still
<br />utilize work practices to minimize emissions of MeCl.
<br />Consult the MSDS sheet to identify the amount of MeCl
<br />contained in the paint stripper, but note that annual
<br />usage should notexceed181 gallons of MeCi.
<br />* Maintain records of annual usage of paint strippers
<br />containing MeCl. 1 44 2
<br />* Motor Vehicle/Mobile EaUiDmenVMi§cell6neous,
<br />Surface Coating Operations.
<br />> Train/certify all painters on spray gun equipment
<br />selection, spray techniques, maintenance, and
<br />environmental compliance (consult 73 FR 1738, pg.
<br />1762, section 63.11173(f)(2)(i)-(iv)).
<br />> Instaff/operate filter technology on all spray
<br />b6oths/stations/enclosures to achieve at least 98%
<br />capture efficiency.
<br />X ),D-7 ) /, t, 'I 'I,- -L I (, P '7-, t 0
<br />Spray booths/stations used to refinish complete
<br />motor vehicles or mobile equipment must be fully
<br />enclosed and ventilated at negative pressure or up
<br />to 0.05 inches water gauge positive pressure for
<br />booths that have seals on all doors and other
<br />openings and an automatic pressure balancing
<br />system.
<br />> Spray booths/stations used to coat
<br />miscellaneous parts or products or vehicle
<br />subassemblies must have a full roof, at least three
<br />complete walls onside curtains, and ventilated so
<br />that air is drawn into the booth.
<br />> Spray -applied coatings must be -applied with a
<br />high volume, low pressure (HVLP) spray gun,
<br />electrostatic application, airless or air -assisted
<br />airless spray gun, or an equivalent technology.
<br />> Paint spray gun cleaning must be done so that an
<br />atomized mist or spray of the cleaning solvent is
<br />not created outside a container that collects used
<br />gun cleaning solvent.
<br />Train and certify all personnel who spray apply
<br />surface coatings no later than 180 days after hiring
<br />or by July 7, 2008 (new sources) or by January 10,
<br />2011 (existing sources).
<br />What are the Impacts?
<br />• Most paint stripping facilities already comply with the
<br />rule requirements. Estimate 1,000 facilities Will need to
<br />take action to, comply.
<br />> Reduce 1,000 tons MeCl annually,
<br />> Capital costs = $1.5 million.
<br />> Annual benefit '= $0.9 million.
<br />• Most surface coating facilities already comply with the
<br />I I
<br />rule requirements. Estimate 1<` 25% of axistt.hg facilities
<br />will need to take some action to comply.
<br />> Reduce 6,900 tons of HAP annually including 11
<br />tons of metal HAP.
<br />> Capital costs = $20 million; however, initial cost to
<br />be offset and recovered over time by cost savings
<br />as a result of more efficient use of labor and
<br />materials.
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