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Thursday, March 18, 2010
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Environmental Affairs

Paint Stripping & Surface Coating Operations

This section of our website was developed to assist businesses conducting paint stripping and surface coating operations. The information provided here is intended only as a guide and may not be complete. Businesses that may be subject to this rule should refer to the federal rule, 40 CFR Part 63, Subpart HHHHHH. A brochure about this rule is also available from the USEPA.

On January 9, 2008, the Environmental Protection Agency (EPA) published the final rule for 40 CFR Part 63, Subpart HHHHHH National Emissions Standards for Hazardous Air Pollutants (NESHAP): Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources. This rule applies to:

New sources must comply with this rule immediately upon startup. Existing sources must be in compliance by January 10, 2011. This standard is adopted by reference in the Forsyth County Air Quality Technical Code (Section 3D .1111).

How Do I Comply?

This rule requires you to submit an Initial Notification and Notification of Compliance Status, use certain Management Practices including operator training, and keep records. You may also have to submit an Annual Notification of Changes Report.

Initial Notification: New sources must notify the USEPA and this Department that they are subject to this rule by 180 days after operations begin. Existing sources must notify the USEPA and this Department by January 11, 2010. An Initial Notification form can be found in the Paint Stripping & Miscellaneous Surface Coating Operations Section of our forms page.

Notification of Compliance Status: New Sources must submit this along with the Initial Notification. Existing sources are required to submit this notification only if the initial notification did not certify that your source is already in compliance with this rule. This notification must be submitted to the USEPA and this Department by March 11, 2011. A Notification of Compliance Status form can be found in the Paint Stripping & Miscellaneous Surface Coating Operations Section of our forms page.

Management Practices
  - Paint Stripping Operations
  - Vehicle and Mobile Equipment Coating Operations - Auto Body Shops and
  - Other Miscellaneous Surface Coating Operations

Record Keeping: You are required to keep records and submit annual reports. Records must be kept for five years and records for the most recent 2 years must be kept on site. The specific records you are required to keep are listed in the federal rule § 63.11177 What records must I keep?

Annual Notification of Changes Report: You are required to submit an Annual Notification of Changes Report before March 1st of each calendar year if there has been a change to any information previously reported or if there have been any deviations from your management practices. More information about when you must submit this report and what to include can be found in the federal rule § 63.11176 What reports must I submit?

Important Dates to Remember:

  New Sources Existing Sources
Initial Notification July 7, 2008 or 180 days after startup, whichever is later January 11, 2010
Compliance with Rule Immediately January 10, 2011
Notification of Compliance Included with Initial Notification March 11, 2011
MeCl Minimization Plan Review and Update Annually before March 1 to report any changes or deviations Annually before March 1 to report any changes or deviations
Annnual Reporting March 1 each year if changes or deviations occurred March 1 each year if changes or deviations occurred

For assistance please contact Michael Hastings by email or by calling (336) 703-2433.