Air Toxics Notebook
Surface Coating & Paint Stripping -  Subpart HHHHHH

Applicability: e-CFR Subpart HHHHHH [ecfr.gov]

This subpart applies to Area Sources* of HAPs that:
  1. Perform paint stripping using methylene chloride (CAS # 75092).
  2. Spray-apply coatings to motor vehicles and/or mobile equipment.
  3. Spray-apply coatings to plastic or metal parts or products.
  4. *Area Sources of HAPs emit or have the potential to emit:
    • < 10 tons per year of a single HAP, or
    • < 25 tons per year of combined HAPs.
    • Major Sources emit more than Area Sources.
Definition of Spray-apply Coating:
  • Use of a hand-held device that creates an atomized mist that is desposited on a substrate. This does not include:
    • Coatings applied from a hand-held device with a paint cup capacity ≤ 3.0 fluid ounces.
    • Applications using powder coating, hand-held non-refillable aerosol containers, or non-atomizing applications (e.g., dip coating, electrodeposition coating, coil coating, etc).
    • Thermal spray operations.
Definition of Mobile Equipment:
  • Any device that may be drawn or driven on a roadway (e.g., heavy-duty trucks, truck trailers, buses, bulldozers, agriculture equipment, recreational vehicles, etc).

Exemption from this rule:

Motor vehicle or mobile equipment surface coating operations may petition NDEQ for exemption from this rule if they can demonstrate that they do not spray-apply any coatings containing the target HAPs (i.e., compounds of chromium, lead, manganese, nickel, or cadmium).
Rules apply to small, area sources? Yes
Known Sources in NDEQ Jurisdiction:
(See attached file: 6H - Initial Notifications Received 2013-07-23.pdf)

SizeFile Name
393 KB 6H - Initial Notifications Received 2013-07-23.pdf
Date of Original Final Rule: 1/9/08
Amendments Dates: 02/13/2008 - Correction
01/09/2008 - Final Rule
State Regulations (Title 129): Title 129, Chapter 28, Section 001.107. Sources are also responsible for ensuring they are in compliance with current federal requirements found for this subpart in the CFR.
Federal Regulations: 40 CFR 63.7980
Related Rules:

NESHAP - 40 CFR Part 63

Subpart XXXXXX - Metal Fabrication & Finishing
Subpart MMMM - Misc. Metal Parts Surface Coating
Subpart PPPP - Plastic Parts & Products Surface Coating
Regulations and Federal Registers:
e-CFR Subpart HHHHHH [ecfr.gov]

(See attached file: 6H - Fed. Reg. 2008-02-13 - Correction.pdf)

(See attached file: 6H - Fed. Reg. 2008-01-09 - Final Rule.pdf)

(See attached file: 6H - Fed. Reg. 2007-09-17 - Proposed Rule.pdf)

SizeFile Name
60 KB 6H - Fed. Reg. 2008-02-13 - Correction.pdf
229 KB 6H - Fed. Reg. 2008-01-09 - Final Rule.pdf
205 KB 6H - Fed. Reg. 2007-09-17 - Proposed Rule.pdf
Forms:
(See attached file: 6H - Initial Notification and Notification of Compliance Status Form.pdf)(See attached file: 6H - Initial Notification and Notification of Compliance Status Form.docx)

(See attached file: 6H - Compliance Status Notification Form.pdf)(See attached file: 6H - Compliance Status Notification Form.docx)

(See attached file: 6H - Exemption Petition Form.pdf)

SizeFile Name
201 KB 6H - Initial Notification and Notification of Compliance Status Form.pdf
38 KB 6H - Initial Notification and Notification of Compliance Status Form.docx
185 KB 6H - Compliance Status Notification Form.pdf
34 KB 6H - Compliance Status Notification Form.docx
54 KB 6H - Exemption Petition Form.pdf
Important Dates:
Source Classification
  1. Existing Source
    • Constructed or reconstructed on or before Sept 17, 2007
  2. New Source
    • Constructed or reconstructed after Sept 17, 2007
    • Installed new coating or stripping equipment or if the facility was not engaged in paint stripping or surface coating before that date.
  3. Existing facilities that add new equipment to comply with the rule (e.g., add booth to reduce emissions, etc.), are still considered existing.
Initial Notification
  1. Existing Source
    • Due by Jan 11, 2010
  2. New Source
    • Due by July 7, 2008 or 180 days after startup, whichever is later.
Compliance Dates
  1. Existing Source
    • Must comply by Jan 10, 2011
  2. New or Reconstructed Source
    • Must comply by Jan 9, 2008 or upon startup, whichever is later.
  3. Painter training must be completed within 180 days after the hiring date and repeated every 5 years.
Compliance Status Notification
  1. Existing Source
    • Due by March 11, 2011
  2. New Source
    • Due by July 7, 2008 or 180 days after startup, whichever is later.
Annual Notification of Changes Report
  1. Must be submitted each calendar year in which information previously submitted has been changed, or:
    • If deviations have occurred, or
    • Methylene chloride paint stripping usage exceeds 1 ton/yr
  2. Due by March 1 of each year
**** Please check with LLCHD or OAQC if you are located within Omaha city limits or Lancaster County. They may have notification or reporting requirements that differ from NDEQ.

FAQs, Fact Sheets, and Rule Summaries:
(See attached file: 6H - NDEQ Rule Citations by Facility Operations.pdf)

(See attached file: 6H - EPA brochure.pdf)

(See attached file: 6H - EPA summary for autobody shops.pdf)

(See attached file: 6H - EPA summary for misc. coating.pdf)

(See attached file: 6H - EPA summary for paint stripping.pdf)

SizeFile Name
41 KB 6H - NDEQ Rule Citations by Facility Operations.pdf
69 KB 6H - EPA brochure.pdf
28 KB 6H - EPA summary for autobody shops.pdf
31 KB 6H - EPA summary for misc. coating.pdf
21 KB 6H - EPA summary for paint stripping.pdf
Presentations, Training and Articles:
EPA’s Collision Repair Campaign to Reduce Air Toxics - information, training, and tools to reduce auto body emissions. This site contains a link to a free 19 minute training video (Windows Media File) (59 MB) starring NASCAR driver Jeff Gordon and featuring testimonies from large and small shop owners, which addresses:
Paint Strip Rule
Best practices
Saving money
Worker protection
Outreach resources
(See attached file: 6H - Kansas small business training 01-22-09.pdf)

SizeFile Name
3,784 KB 6H - Kansas small business training 01-22-09.pdf
Other Information and Resources:
(See attached file: 6H - EPA DeVilbiss Gun Equivalency Approval.pdf) (See attached file: 6H - EPA SATA Gun Equivalency Approval.pdf)

Iowa DNR Area Source NESHAP website [iowadnr.gov] - fact sheets, guidance documents, and presentations

EPA's Area Source Website [epa.gov] - guidance documents for all area source rules

SizeFile Name
106 KB 6H - EPA DeVilbiss Gun Equivalency Approval.pdf
113 KB 6H - EPA SATA Gun Equivalency Approval.pdf
Notes:
Page Last Updated: 7/24/18