Filtration Requirements Under 40 CFR Part 63 Subpart HHHHHH

On January 9, 2009, the Environmental Protection Agency (EPA) published the final rule for 40 CFR Part 63 Subpart HHHHHH, National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operating at Area Sources, also known as 40 CFR Part 63 (6H). The rule applies to all motor vehicle and mobile equipment surface coating operations that paint with hazardous air pollutants (HAPs), including the collision repair industry.

40 CFR Part 63 (6H) created many new regulations ranging from the very broad (develop and document key operating practices) to the very specific (use only approved, high volume, low pressure (HVLP) spray guns and clean such spray guns in an enclosed cleaner or by disassembling gun parts and cleaning by hand). Recognizing both the complexity and questions these new regulations have generated, the EPA developed a website (http://www.epa.gov/collisionrepair/) to provide tools and resources to collision repair businesses, including sample notification forms and training checklists, as well as a copy of the final rule itself (http://www.epa.gov/ttn/atw/area/fr09ja08.pdf).

With respect to filtration, 40 CFR Part 63 (6H) outlines three basic and straight-forward requirements: (i) all coating operations must be conducted in a spray booth or prep station that is fully enclosed by a roof, floor and four walls or full side curtains, (ii) the spray booth or prep station must be ventilated at negative pressure so that air is drawn into rather than out of any openings in the booth walls or prep station curtains, and (iii) the spray booth or prep station must be fitted with exhaust filters demonstrated to achieve at least 98% filter capture efficiency of paint overspray in accordance with a prescribed testing method. Test records must be maintained on-site and demonstrate compliance with this minimum efficiency standard.

PAINT STRIPPING AND

MISCELLANEOUS SURFACE COATING

OPERATIONS (SUBPART HHHHHH)

The purpose of this rule is to reduce emissions of lead, nickel, cadmium, chromium and manganese. These chemicals are designated hazardous air pollutants known or suspected to cause cancer and other adverse health effects and can be found in paint used in the automotive refinishing industry.

The NESHAP 6H Rule requirements include:

Spray gun cleaning does not allow atomization of thinner through gun for cleaning and recommends an automated enclosed gun wash.

Compliance Solution:

Invest in a fully enclosed automatic gun wash system as the best management practice to protect your employee�s health.

Acceptable options include:

Hand cleaning of disassembled gun. Flush gun with solvent, with gun configured so solvent is not atomized.  Use fully enclosed gun cleaner or a combo of non atomizing methods.

USA Environmental Websites:    

• www.epa.gov
• www.dtsc.ca.gov/informationresources/local_contacts.cfm
• www.aqmd.gov/rules/reg/reg11_tofc.html (refer to Rule 1171)

• www.performancecoatings.dupont.com 
• www.basfrefinish.com
• www.sherwin-automotive.com 
• www.akzonobelcarrefinishes.net 
• www.ppgrefinish.com 

• www.ciia.com
• www.cdnpaint.org

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).

� Notification of Compliance (certifies that the source is in compliance with the applicable requirements).

New Sources: July 7, 2008 or 180 days after startup

Existing Sources: January 11, 2010

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.

� MeCl content information such as MSDS.

� Annual usage of MeCl for paint stripping, and written MeCl 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 yourRegional EPA air toxics office at the following numbers:

* 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

PAINT STRIPPING AND

MISCELLANEOUS SURFACE COATING OPERATIONS

(SUBPART 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 (TPY) of individual hazardous air pollutants (HAP) or 25 TPY 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 (MeCl)-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 MeCl.

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 MeCl annual usage, develop and implement a written MeCl minimization plan. No implementation plan is needed if usage is < 1 ton MeCl; however, sources must still utilize work practices to minimize emissions of MeCl. Consult the MSDS sheet to identify the amount of MeCl contained in the paint stripper, but note that annual usage should not exceed 181 gallons of MeCl.

� Maintain records of annual usage of paint strippers containing MeCl.

� 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 MeCl 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.