NPCA Offers Members Fact Sheet on Paint Stripping and Miscellaneous Surface Coating Operations

NPCA has developed a fact sheet for members to guide them through the particulars of the final rule for the National Emission Standard for Hazardous Air Pollutants (NESHAP) for Paint Stripping Miscellaneous Surface Coating Operations at Area Sources. The rule covers the following three "area sources" of HAPs sources — sources too small to meet the definition of "major sources," (i.e., emit less than 10 tons a year of a single hazardous air pollutant (HAP) or less than 25 tons per year of a combination of HAPs):

• Paint stripping operations using methylene chloride (MeCl);

• Automotive refinish and mobile equipment spray coating operations, unless certification is made that no coatings being used contain the HAPs targeted by the rule — metal compounds containing cadmium, chromium, lead, manganese and nickel; and

• General spray application of coatings to plastic or metal substrates if the coatings contain the HAPs targeted by the rule — metal compounds containing cadmium, chromium, lead, manganese and nickel.

For an existing affected source, the compliance date is Jan.  10, 2011 (defined as engaged in the regulated activity on Jan. 7, 2007). For a “new” or reconstructed affected source, the compliance date is the applicable date defined by either (1) if the initial startup of the new or reconstructed affected source is after Sept. 17, 2007 (by installing new paint stripping or surface coatings equipment at a source not actively engaged in paint stripping and/or miscellaneous surface coating prior to Sept. 17, 2007), the compliance date is January 9, 2008; or, (2) if the initial startup of the new or reconstructed affected source occurs after January 9, 2008, the compliance date is the date of initial startup of the affected source.

While the preamble to the rule suggests there are three separate rule sections for the three activities, in fact, refinish and the plastic parts/miscellaneous metal coatings work practice and painter training/ certification requirements are the same and are in the same provisions. One key difference between the two, however, is that refinish facilities using targeted HAP-free coatings must petition to be exempted from the rule; plastic parts/miscellaneous metal coatings facilities do not need to petition.

The fact sheet also reviews, in detail, sources not covered by the rule, activities and coatings specifically excluded from the rule, general agency notification requirements, standards specific to paint stripping operations, standards specific to vehicle refinish coating operations: "motor vehicle and mobile equipment coating operations," and "miscellaneous surface coating."

The fact sheet is accessible to members under the Environmental Management Committee page.  The final rule may be viewed at: http://www.epa.gov/EPA-AIR/2008/January/Day-09/a24718.pdf.

For more information: contact NPCA’s John Hopewell or Alison Keane.

Source: June 2008 Coatings, posted 4/30/08