EPA is close to promulgating the first national emission standards for hazardous air pollutants (NESHAP) for area sources engaged in paint stripping, surface coating of motor vehicles and mobile equipment, and miscellaneous surface coating operations. We predict this will go into the Federal Register early next year. This NESHAP potentially could apply to everyone in the above industry categories regardless of whether they are a major source of Hazardous Air Pollutants (HAPs) or not. (A major source of HAPs is one that produces more than 10 tons per year of one individual HAP, or more than 25 tons per year of all HAPs combined.)
This rule will be applicable only if methylene chloride (MeCl) is used for paint stripping; or, if coatings using any of the “target HAPs;” which include compounds of Chromium (Cr), Lead (Pb), Manganese (Mn), Nickel (Ni), or Cadmium (Cd); are used in the motor vehicle and mobile equipment or miscellaneous surface coating operations.
There will be an initial notification requirement, a notice of compliance status report, a MeCl minimization plan with an annual review for paint stripping operations, an annual notification of changes report, training for employees within 180 days and every 5 years, a requirement to keep records of the training, a requirement to keep records on the paint booth filters and documentation of the transfer efficiency of the sprayers, and records of any deviations from the standards.
DECA can help you evaluate whether this rule applies to your facility, submit the required reports, generate the proper records and plans, implement training, and track training. Please contact us at deca@indy.net for more information.
