Surface Coating and Paint Stripping
Federal Rules Affecting Paint Stripping, Autobody Refinishing, and Miscellaneous Surface Coating Operations at Area/Small Sources
On January 9, 2008, the U.S. Environmental Protection Agency published rules to reduce air toxins including methylene chloride and other hazardous air pollutants (HAPs) from surface coating operations at area sources. The final rule is the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources, 40 CFR Part 63 Subpart HHHHHH (6H). See rule. The rule has been in effect since January 10, 2011. All existing facilities subject to this rule should be in compliance or Opted Out (for Auto Body Shops) at this time. New facilities subject to this rule will need to be in compliance upon start-up. To help determine what requirements affect your facility or if it can opt out of being covered by the rule, a regulatory navigation tool was recently launched. Please note that it currently uses Adobe Flash or may not be supported by all browsers. If this occurs, a different browser may allow the website to function normally.
There are two main industry groups affected by this rule: Auto Body Shops and most other facilities that do surface coating (i.e. painting). The Division of Air Pollution Control has developed a Permit-by-Rule for Auto Body Shops for faster and simplified permitting. Other facilities subject to the rule would use the standard permitting forms. Many facilities that do surface coating may not be subject to the rule.
Who is Affected by this Rule?
Area Sources (those that are not Title V or Major sources of air emissions) that Conduct any of the Following are Subject to the 6H Rule:
- Paint stripping operations that use methylene chloride for the removal of dried paint
- Motor vehicle (Auto Body Shops) and mobile equipment spray coating operations
- Miscellaneous surface coating operations with:
- Hand-held spray painting
- Spray painting of metal, plastic or a combination of the two
- Use of surface coating materials that contain compounds of chromium, lead, manganese, nickel, and/or cadmium. These are known as the target Hazardous Air Pollutants (HAPs)
What are the Rule’s Exemptions? (Please check, you could be exempt!)
For Auto Body Shops, the Two Most Common Exemptions are:
- The facility does not use surface coating material that contains compounds of cadmium (Cd), chromium (Cr), lead (Pb), nickel (Ni), and/or manganese (Mn) (Target HAPs).
- The facility paints/coats two or fewer vehicles per year
There are two ways to check to see if surface coating materials contain the above listed metals, known in the 6H rule as target Hazardous Air Pollutants (HAPs). One is to look through the Safety Data Sheet in Section 3 Composition/Information on Ingredients or Section 15 Regulatory Information to see if any compound contains the target HAPs. Another is create a list of all surface coating materials used and compare that list to lists developed by the main manufacturers of surface coating materials to see if they appear on the list. If they are on the list, then the surface coating material is subject to 6H.
Most auto body shops that are subject to the 6H rule will only need to apply for Permit-by-Rule. Excluding auto body shops, other types of facilities that are subject to the 6H rule will need to apply for an air permit, unless they are an insignificant source of air emissions. An insignificant source of air emissions is one that has the potential to emit less than 5 tons per year of each air contaminant and each regulated air pollutant that is not a hazardous air pollutant, and less than 1,000 pounds per year of each hazardous air pollutant unless specifically excluded from designation as an insignificant activity or insignificant emissions unit in Division 1200-03 or Division 0400-30. If you think your facility is an insignificant source of air emissions, a written notification must be submitted to the Technical Secretary. The notification for designation shall include calculations and sufficient documentation to substantiate the applicant’s claim. Upon receipt of the notification, the Technical Secretary will respond with a determination of agreement or disagreement with the applicant’s claim. In issuance of determination as “insignificant”, the Technical Secretary may base the determination upon any criteria that are relevant to the determination. For new sources, the request for designation must be made at least 30 days prior to the estimated starting date of construction. For new sources, if it is determined that the emissions unit does not qualify as an “insignificant emissions unit”, the source must apply for a construction permit. The request for designation as an “insignificant emissions unit” may be made at any time for an existing source.
Auto Body Shops
Auto Body Shops will fall into one of six different categories as to whether the 6H rule affects them, what steps they will need to take, and which agency they will need to work with.
- Auto Body Shops in Davidson, Hamilton, Knox, and Shelby Counties are within local air programs. They should contact the local air program for permitting requirements.
- Auto Body Shops that are not subject to the 6H rule and are not located in Davidson, Hamilton, Knox, Rutherford, Shelby, Sumner, Williamson, or Wilson Counties are currently considered exempt from needing to apply for and obtain an air pollution control permit. Complete the Opt Out Petition.
- Auto Body Shops that are subject to the 6H rule that are not located in Davidson, Hamilton, Knox, Rutherford, Shelby, Sumner, Williamson, or Wilson Counties should submit a Notice of Intent for Permit-by-Rule.
- Auto Body Shops that are not subject to the 6H rule and are located in Davidson, Rutherford, Sumner, Williamson, or Wilson Counties are currently considered exempt from needing to apply for and obtain an air pollution control permit if they do not emit greater than 15 pounds of volatile organic compounds per day. Complete the Opt Out Petition. The Division of Air Pollution Control may also require these facilities to submit records or calculations to substantiate that emissions of volatile organic compounds are less than 15 pounds per day.
- Auto Body Shops that are subject to the 6H rule and are located in Davidson, Rutherford, Sumner, Williamson, or Wilson Counties and do not emit greater than 15 pounds of volatile organic compound emissions per day should submit a Notice of Intent for Permit-by-Rule. The Division of Air Pollution Control may also require these facilities to submit records or calculations to substantiate that emissions of volatile organic compounds are less than 15 pounds per day.
- Auto Body Shops that are located in Davidson, Rutherford, Sumner, Williamson, or Wilson Counties and emit greater than 15 pounds of volatile organic compound emissions per day should apply for a standard air permit using APC 100 and APC 107 application forms.
Surface coating facilities that are not auto body shops do not need to submit the Opt Out Petition. If they are not subject to the 6H rule, they would still need to submit a standard permit application either because they are still subject to general air emissions rules or to be approved as an insignificant source of air emissions.
What are the Significant Rule Requirements?
- Surface coating of motor vehicles must be conducted in a booth with four enclosed sides or side curtains. Booth must also be equipped with filter technology that is demonstrated to achieve at least 98 percent capture of 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 spray gun, or an equivalent technology.
- All painters must complete a training course on proper spray gun use and maintenance within 180 days of hiring and every 5 years after.
- 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.
- Paint stripping operations must implement management practices that minimize emissions of methylene chloride
Painters at your facility are required to have training and certification every 5 years. There are several options for training, some of which are presented below for your convenience:
The Tennessee Collision Repairers Association. Contact TCRA at firstname.lastname@example.org
Additional resources for automotive industry from the National SBEAP website. Some may include training for 6H.
As new sources should be in compliance upon startup, within 180 days of startup, a Notification of Compliance Status is required. A sample notification is available that outlines the needed information. Facilities have the option of using this or one of their own design so long as it contains the required information.
If there have been changes to the information previously submitted in an Initial Notification or Notification of Compliance Status report, you must prepare and submit an Annual Report. All changes in a facility's operation or submitted information must be logged by December 31st of the year that the change occurred.
For Each Change, the Logged Information Must Include the Following:
- Date and time period of the change,
- A description of the nature of the change and
- The actions taken to correct the change
The logged information must be submitted in an Annual Report to the appropriate air agencies by March 1st of the following year after the change(s). The Annual Report is only required if there have been changes to the information previously submitted in an Initial Notification or Notification of Compliance Status report. If the information in an Initial Notification or Notification of Compliance Status report did not change during the year, you do not need to submit an Annual Report.
No Changes to Report:
January 1st, note this information in your records.
Keep copies of all Notifications, Logs, and Reports available at the facility at least 5 years. This includes training certifications, documentation of filter efficiency, documentation on the spray guns used, and any records relating to Methylene Chloride paint stripping.
For additional information on the 6H rule, EPA developed the Collision Repair Campaign. Please go to the National SBEAP website for Collision Repair and Auto Body Shops.