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  • Writer's pictureTom Petersen

New Surface Coating Regulations - Are You Up To Date?

Updated: Aug 29, 2023

Please contact Tom Petersen at tom@eesolutions.net (www.eesolutions.net) for further details related to the following article, which appeared in a recent edition of our email newsletter EES Essential Elements, and was written by Trish Carney.


The U.S. EPA passed two new Hazardous Air Pollutant (HAP) rules last year regarding painting and paint stripping plus metal fabrication and finishing operations that might have an effect on your business. This brief outline provides an overview of the rules from 40 CFR Part 63 – National Emission Standards for Hazardous Air Pollutants for Source Categories: a.k.a. Maximum Achievable Control Technology (MACT).


Subpart HHHHHH

On January 9, 2008 Subpart HHHHHH of the National Emission Standards for Hazardous Air Pollutants titled ‘Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources’ was added. This subpart establishes national emission standards for HAP for area sources involved in any of the following activities:

  1. Paint stripping operations using chemical strippers that contain methylene chloride (MeCl) in paint removal processes;

  2. Autobody refinishing operations that encompass motor vehicle and mobile equipment spray-applied surface coating operations;

  3. 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, or combinations of metal and plastic that are not motor vehicles or mobile equipment.

This subpart also establishes which activities are not applicable, and the necessary requirements to demonstrate initial and continuous compliance with the emission standards stated within it.


In a nutshell, the use of paints that contain cadmium, chromium, lead, manganese, or nickel may subject you to the new requirements for your painting operation. The requirements include:


A. All painters must be properly trained in suitable spray application techniques, and the set-up and maintenance of the spray equipment.

B. Spray booths in which you apply coatings must meet the following:

* use dry filters that achieve minimum of 98% collection efficiency OR use a water wash booth * plastic and/or metal parts must be contained within a booth having three sides and a roof, and openings for conveyors are allowed

C. Use of one of the permitted spray application technologies:

* high volume, low pressure (HVLP) * electrostatic * airless * air-assisted airless * any technology approved by EPA with equivalent transfer efficiency

D. Use of a spray gun cleaning operation that does not spray solvent and waste coatings outside of collection container; alternatives include:

* hand cleaning * flushing gun with solvent * fully enclosed gun cleaner

E. Additionally, stripping procedures must eradicate, curtail and reduce the use of methylene chloride (depending on the material being stripped).

Subpart XXXXXX


On July 23, 2008 Subpart XXXXXX titled ‘Area Source Standards for Nine Metal Fabrication and Finishing Source Categories’ was enacted. You are subject to this subpart if you own or operate an area source operation in one of these nine source categories:

  1. Electrical and Electronic Equipment Finishing Operations;

  2. Fabricated Metal Products;

  3. Fabricated Plate Work (Boiler Shops);

  4. Fabricated Structural Metal Manufacturing;

  5. Heating Equipment, except Electric;

  6. Industrial Machinery and Equipment Finishing Operations;

  7. Iron and Steel Forging;

  8. Primary Metal Products Manufacturing; and

  9. Valves and Pipe Fittings

This subpart applies to each metal finishing HAP (MFHAP) for new and existing affected source as defined:


A dry abrasive blasting affected source is the collection of all equipment and activities necessary to perform dry abrasive blasting operations which use materials that contain MFHAP or that have the potential to emit MFHAP.

A machining affected source is the collection of all equipment and activities necessary to perform machining operations which use materials that contain MFHAP or that have the potential to emit MFHAP.


A dry grinding and dry polishing with machines affected source is the collection of all equipment and activities necessary to perform dry grinding and dry polishing with machines operations which use materials that contain MFHAP, or have the potential to emit MFHAP.


A spray painting affected source is the collection of all equipment and activities necessary to perform spray-applied painting operations using paints which contain MFHAP, and includes all equipment used to apply cleaning materials used for surface preparation or to remove dried paint; used for paint application and to dry or cure the paint after application; or to clean paint operation equipment.


A welding affected source is the collection of all equipment and activities necessary to perform welding operations which use materials that contain MFHAP, or have the potential to emit MFHAP.


Essentially, the regulation applies if you use materials that contain, or have the potential to emit, metal fabrication or finishing metal HAP. These are defined as the compounds of cadmium, chromium, lead, manganese, and nickel, or any of these metals in the elemental form with the exception of lead, and independant of the quantities present. This subpart also establishes which area sources are not applicable, and the necessary standards and compliance requirements.


Compliance Deadlines

Compliance deadlines for Subpart HHHHHH vary depending on your situation. If the initial startup of your new or reconstructed affected source is after September 17, 2007, the compliance date was January 9, 2008. If the initial startup of your new or reconstructed affected source occurred after January 9, 2008, the compliance date is the date of initial startup of your affected source. For an existing affected source, the compliance date is January 10, 2011.


Compliance dates for Subpart XXXXXX could come on one of two dates. If you own or operate an existing affected source, you must get compliant by July 25, 2011. If you own or operate a new affected source, you must achieve compliance by July 23, 2008, or on startup of your affected source, whichever is later.


Resources

The National Archives Electronic Code of Federal Regulations spells out each subpart with all of its details, and can be accessed via the following links: Subpart HHHHHH and Subpart XXXXXX


The Archives also provides the standards, management, monitoring, recordkeeping and reporting practices necessary for compliance. Don’t hesitate to contact EES with questions or concerns regarding your operations or facilities and these new regulations. We’ll work with you to achieve your initial compliance and continually help to keep you within the guidelines as required.


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