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Paint Stripping and Surface Coating



NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS:

PAINT STRIPPING AND MISCELLANEOUS SURFACE COATING OPERATIONS

AT AREA SOURCES – FINAL RULE

Miscellaneous Surface Coating Operations
40 CFR Part 63, Subpart HHHHHH (6H NESHAP)

Compliance and Training Materials (Iowa Waste Reduction Center

Brief Summary

New EPA regulations for Autobody Refinishing Shops

40 CFR Part 63 Subpart HHHHHH

August 2008

 

EPA has new requirements to reduce air pollution of metals such as chrome, lead, cadmium, manganese and nickel compounds, and also to reduce methylene chloride fumes, from autobody refinishing work.  These compounds pose health risks to anyone who breathes the air when these fumes are present. Many paints used in autobody refinishing work contain these compounds.  The new regulations require autobody shops and refinishing businesses to do several things to prevent these metals from getting into the air during spray painting. 

 

This is a short summary of things an existing shop must do before January 2011.  New autobody shops must do all these before beginning to paint.  Although EPA has no requirements for hobbyists or private citizens, two things should be noted:

·         The following are also good practices to improve the air for anyone exposed to autobody paint overspray.

·         The new regulations strictly define what qualifies one as a hobbyist or private citizen when it comes to autobody painting

 

For more details and assistance, please call (319) 892-6000.

 

1)       All spray painting must be done in a spray booth

         Full cars must be painted in a spray booth with four walls, a roof and a ventilation system.   (Filters in the booth have to remove at least 98% of the particulates.  Your filter provider can give you the right filters and necessary paperwork.)

         Parts of cars must be painted in a booth with at least three walls or flaps, a roof and a ventilation system that pulls air into the spray booth.

         Spot repairs must be done in an enclosure which prevents any mist from getting out of the enclosure.  

2)      Painters must use spray guns and techniques which reduce overspray (such as HVLP).

3)      All painters must receive training.  Owners must keep records of the training of each painter.

         For information on techniques and information your painters need to know and workshops available see the Collision Repair Campaign website with upcoming trainings -

         http:/www.epa.gov/air/toxicair/community/collision.html

4)      Paint spray gun cleaning cannot create any mist of cleaning solvent to the air.  You may spray solvent through the gun for cleaning purposes using an enclosed gun cleaner or you may clean the gun manually.

5)      All shops must also send a notification to EPA with some general information by January 2010:

         Location of facility

         Description of spray painting equipment

         Confirmation that shop has necessary equipment and training.

         An example of this notification is found above.

6)      Exemptions to the rule are facility maintenance activities, which include the application of coatings to stationary structures or their appurtenances at the site of installation, to portable buildings at the site of installation, and to pavements and curbs,

7)       You can send this notice that you are an owner or operator, to Linn County Public Health.    

New EPA Regulations for Miscellaneous Surface Coating Operations

August, 2008

40 CFR Part 63 Subpart HHHHHH

 

EPA has new requirements to reduce air pollution of methylene chloride, chromium, lead, manganese, nickel, and cadmium from surface coating (painting) operations.  These pollutants pose health risks to anyone who breathes the air that contains them.  Many paints used in surface coating work contain these metals.  The new regulations require surface coating businesses to do several things to prevent these pollutants from getting into the air during spray painting. 

 

This is a short summary of things a paint shop must do before January 2011.  New shops must do all these before beginning to paint.  Although EPA has no requirements for hobbyists or private citizens, the following are also good practices to improve the air for anyone exposed to surface coating fumes.  Most paint shops already do these things.

 

The surface coating rules will annually reduce about 14 million pounds of hazardous air pollutants.  Any initial costs to you when beginning to meet this rule will quickly be made up by your cost savings as a result of better use of labor and materials.  The rule can be found at: http://www.epa.gov/ttn/atw/area/fr09ja08.pdf  Also a minor correction notice is at: http://www.epa.gov/ttn/atw/area/fr13fe08.pdf

 

For more details and assistance, please talk to your paint providers or call (319) 892-6000.

 

All surface coating facilities must:

·         Train/certify all painters on spray gun selection, spray techniques, maintenance, and environmental rules.

·         Install and operate filters in ALL spray booths, stations and enclosures to catch at least 98% of the fumes. 

·         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 similar application method. 

·         Paint spray gun cleaning must be done so that no fumes escape during cleaning.

·         Send a notice that you are an owner or operator, to Linn County Public Health

 

Additionally, facilities must keep the following records on file:

      ●   Copies of Notifications submitted to EPA

      ●    Painter training certifications.

      ●    Spray booth filter efficiency documentation.

      ●    Spray gun transfer efficiency.

Please note exemptions to the rule are facility maintenance activities, which include the application of coatings to stationary structures or their appurtenances at the site of installation (such as bridges), to portable buildings at the site of installation, to pavements, or to curbs.

Brief Summary

New EPA Regulations for Paint Stripping Operations

August 2008

40 CFR Part 63 Subpart HHHHHH

 

EPA has new requirements to reduce air pollution of Methylene Chloride (MeCl), which is found in many paint stripping formulations.  Methylene Chloride poses health risks to anyone who breathes air that contains it.  The new regulations require paint shops and refinishing businesses to do several things to prevent methylene chloride from getting into the air during paint stripping.    The rule can be found at: http://www.epa.gov/ttn/atw/area/fr09ja08.pdf

 

This is a short summary of things a shop must do before January 2011.  New paint shops must do all these before beginning to strip paint.  Although EPA has no requirements for hobbyists or private citizens, the following are also good practices to improve the air for anyone exposed to paint stripping fumes:

  • Paint Stripping Operations—use methods to limit the fumes of MeCl.
  • See if it’s possible to re-coat without stripping before you start
  • For all work, look for other ways to strip that don’t use MeCl
  • Try not to expose the strippers to air
  • Use the best possible application conditions
  • Store and dispose of equipment properly
  • Make a plan for minimizing the use of MeCl if you use more than 2,000 pounds of MeCl per year

 

Send a notice that you are an owner or operator, or call (319) 892-6000. 

 

Additionally, facilities must keep the following records on file:

•    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 is greater than 2,000 pounds per year.

•    Documentation for events higher in MeCl and a plan to deal with them.    

.   For more details and assistance, please talk to your paint stripper providers or Linn County Public Health.


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