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National Emission Standard for Hazardous Air Pollutants (NESHAP) for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources 40 CFR Part63 Subpart HHHHHH (6H)

Overview
Applicability
Requirements
Enforcement Authority
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Overview

On January 9, 2008 EPA published the Final Area Source Rule for Paint Stripping and Miscellaneous Surface Coating Operations, which includes autobody refinishing. This rule requires many important changes to these types of facilities, among them are the following requirements:

  • Affected facilities must ensure and certify that all new and existing personnel who spray surface coatings are trained. Minimum training requirements are defined in the regulation.
  • All shops need to have a filtered spray booth, and all spraying of coatings would need to be done in the spray booth or in a similar filtered enclosure, such as a prep station.
  • All spraying of coatings need to be done with an HVLP spray gun, or one with equivalent transfer efficiency.
  • All shops need to have an enclosed spray gun cleaner.

This rule also regulates paint stripping operations that use contain methylene chloride (MeCl).

Existing sources must be in compliance with the regulation by January 10, 2011. New sources must be in compliance when they begin to operate.

Applicability

Area Source: sources that emit less than 10 tons annually of a single hazardous air pollutant or less than 25 tons annually of a combination of hazardous air pollutants

Hazardous Air Pollutants & Sources

Subpart 6H applies to area sources (i.e., not major sources) that perform:

  • Paint stripping operations that use methylene chloride (MeCl);
  • Autobody refinishing operations that spray-apply surface coatings; and
  • Spray application of coatings containing compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd), (collectively referred to as the target HAP) to any part or product made of metal or plastic, that are not motor vehicles or mobile equipment.

Subpart 6H does not apply to (see text of 6H rule for full list of exemptions):

  • Surface coating or paint stripping performed on site at installations owned or operated by the U.S. Armed Forces.
  • Surface coating or paint stripping performed by individuals on their personal vehicles, possessions, or property, either as a hobby or for maintenance. Subpart 6H also does not apply when these operations are performed by individuals for others without compensation, unless the individual who spray paints two motor or more vehicles per year.
  • Surface coating or paint stripping activities that are covered under another area source NESHAP. For example, if your facility is covered by Subpart 6X, then, Subpart 6X applies and Subpart 6H does not apply.

The areas/activities that are impacted by Subpart 6H include:

  • Mixing rooms and equipment;
  • Spray booths, ventilated prep stations, curing ovens, and associated equipment;
  • Spray guns and associated equipment;
  • Spray gun cleaning equipment;
  • Equipment used for storage, handling, recovery, or recycling of cleaning solvent or waste paint; and
  • Equipment used for paint stripping at paint stripping facilities using paint strippers containing MeCl.

Requirements

The following summarizes the requirements. For additional details, see the full text of the regulation.

An affected methylene chloride paint stripping operation must:

  • Implement management practices to minimize the evaporative emissions of MeCl. The management practices must address, at a minimum:
  • Evaluate each application to ensure there is a need for paint stripping (e.g., evaluate whether it is possible to re-coat the piece without removing the existing coating).
  • Evaluate each application where a paint stripper containing MeCl is used to ensure that there is no alternative paint stripping technology that can be used.
  • Reduce exposure of all paint strippers containing MeCl to the air.
  • Optimize application conditions when using paint strippers containing MeCl to reduce MeCl evaporation (e.g., if the stripper must be heated, make sure that the temperature is kept as low as possible to reduce evaporation).
  • Practice proper storage and disposal of paint strippers containing MeCl (e.g., store stripper in closed, air-tight containers).
  • Maintain copies of annual usage of paint strippers containing MeCl on site at all times.
  • If annual usage of MeCl is more than one ton, develop and implement a written MeCl minimization plan to minimize the use and emissions of MeCl and maintain a copy of the MeCl minimization plan on site at all times.

An affected spray painting/coating operation must meet the following requirements:

  • All painters must be trained and certified in the proper spray application of surface coatings and the proper setup and maintenance of spray equipment (see full text of the regulation for details of required training and certification). Training and certification must be renewed every five years or sooner.
  • All spray-applied coatings must be applied in a spray booth, preparation station, or mobile enclosure that meets specific requirements:
  • All spray booths, preparation stations, and mobile enclosures must be fitted with a type of filter technology that is demonstrated to achieve at least 98-percent capture of paint overspray. This requirement does not apply to waterwash spray booths that are operated and maintained according to the manufacturer's specifications.
  • Spray booths and preparation stations used to refinish complete motor vehicles or mobile equipment must be fully enclosed with a full roof, and four complete walls or complete side curtains, and must be ventilated at negative pressure so that air is drawn into any openings in the booth walls or preparation station curtains. However, if a spray booth is fully enclosed and has seals on all doors and other openings and has an automatic pressure balancing system, it may be operated at up to, but not more than, 0.05 inches water gauge positive pressure.
  • Spray booths and preparation stations that are used to coat miscellaneous parts and products or vehicle subassemblies must have a full roof, at least three complete walls or complete side curtains, and must be ventilated so that air is drawn into the booth. The walls and roof of a booth may have openings, if needed, to allow for conveyors and parts to pass through the booth during the coating process.
  • Mobile ventilated enclosures that are used to perform spot repairs must enclose and, if necessary, seal against the surface around the area being coated such that paint overspray is retained within the enclosure and directed to a filter to capture paint overspray.
  • All spray-applied coatings must be applied with a high volume, low pressure (HVLP) spray gun, electrostatic application, airless spray gun, air-assisted airless spray gun, or an equivalent technology that is demonstrated by the spray gun manufacturer to achieve transfer efficiency comparable to one of the spray gun technologies listed above for a comparable operation, and for which written approval has been obtained from EPA.
  • All paint spray gun cleaning must be done so that an atomized mist or spray of gun cleaning solvent and paint residue is not created outside of a container that collects used gun cleaning solvent. Spray gun cleaning may be done with, for example, hand cleaning of parts of the disassembled gun in a container of solvent, by flushing solvent through the gun without atomizing the solvent and paint residue, or by using a fully enclosed spray gun washer. A combination of non-atomizing methods may also be used.
  • The U.S. Environmental Protection Agency, may choose to grant you permission to use an alternative to the emission standards in this section after you have requested approval to do so. See full text of the regulation for details.

Enforcement Authority

Subpart 6H can be implemented and enforced by EPA or a delegated authority such as your state, local, or tribal agency. If the EPA has delegated authority to your state, local, or tribal agency, then that agency, in addition to EPA, has the authority to implement and enforce this regulation. You should contact your EPA Regional Office to find out if implementation and enforcement of this subpart is delegated to your state, local, or tribal agency.

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