Spray-Applied Surface Coating Operations

Facilities must comply with this rule if they spray-apply coatings containing either chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni) or cadmium (Cd). If they apply these on any part or product made of metal or plastic or combination of both and emit less than 10 tons per year of a single pollutant or less than 25 tons per year of a combination of hazardous air pollutants.

Spray-applied surface coating facilities must:

• Submit the Initial Notification/Compliance Form to EPA and North Carolina Division of Air Quality
• Train/certify all painters on spray gun selection, spray techniques, maintenance, and environmental rules
• Install and operate filters in ALL spray booths, stations and enclosures to catch at least 98% of the fumes
• Apply spray coatings with a high volume, low pressure (HVLP) spray gun, electrostatic application, airless or air-assisted airless spray gun, or similar application method.
• Clean paint spray guns so that no fumes escape during cleaning.

Reporting

• Initial Notification

  Every facility must submit an initial notification to report spray-coating operations. The report includes facility information, address, owner/contact information, as well as the kind of operation that is performed at the facility. Every facility, by January 11, 2010, must submit notification of its operations to both the NC Division of Air Quality and EPA.
   

• Compliance Certification Notification

  A Compliance Certification Notification includes a written certification demonstrating that the facility is in compliance with all requirements of the rule. It must be signed by the responsible official and sent to both the NC Division of Air Quality and EPA, no later than January 11, 2011.
   

• Annual Change Notification

  Annual Change Notification should be filled out if you want to report changes in your operations previously notified at the Compliance Certification Notification. The Annual notification must be submitted to both the NC Division of Air Quality and EPA, prior to March 1 following each calendar year in which a change occurred.
   

Recordkeeping

Additionally, facilities must keep the following records on file for at least five years after the date of each record:

• Copies of Initial Notification/Compliance Forms submitted
• Painter training certifications
• Spray booth filter efficiency documentation
• Spray gun transfer efficiency

Compliance dates

• Existing Sources: January 10, 2011
• New Sources: Upon startup after January 9, 2008
  An affected source is a new source if construction commenced after September 17, 2007, or if new surface coating equipment was installed at a source not actively engaged in miscellaneous surface coating prior to September 17, 2007

Training Deadlines

• Painters at new sources have 180 days after hire to complete training
• Painters at existing sources must complete training by January 10, 2011
• Refresher training is required at least once every five years following the initial training date

EPA Rule- Miscellaneous Surface Coating Operations - Brief Summary

EPA Brochure

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