How Do Surface Coating Regulations (6H)* Apply to My Operation?

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Presentation transcript:

How Do Surface Coating Regulations (6H)* Apply to My Operation? No Not Subject to 6H regulations Do you perform spray coating of metal or plastic parts? Yes Do you ONLY apply coatings from a hand-held device with a capacity of less than 3.0 fluid ounces or do you ONLY have surface coating operations using powder coatings, hand-held non-refillable aerosol containers, or non-atomizing technology? Yes No Do any of your coatings spray-applied to an underlying material for decorative, protective or functional purposes contain any of the following compounds: 1. Chromium (Cr), nickel (Ni), cadmium (Cd), or lead (Pb) at a concentration > 0.1%? 2. Manganese (Mn) at a concentration > 1.0%? No Yes Does your facility emit less than 10 tons per year of any hazardous air pollutant or less than 25 tons per year of any combination of hazardous air pollutants? No Yes A new source An existing source Operation started after September 17, 2007 Operation started before September 17, 2007 Compliance is required upon start-up Initial Notification is due by January 11, 2010 Initial Notification & Notification of Compliance is due within 180 days of start-up Compliance is required by January 10, 2011 Compliance Notification due by March 11, 2011 Annual Notification of Changes Report (if applicable) due by March 1 of each year. Annual Notification of Changes Report (if applicable) due by March 1 of each year. *6H refers to the National Emission Standards for Hazardous Air Pollutants (NESHAP): Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources [40 Code of Federal Regulations (CFR) Part 63, Subpart HHHHHH]. 6H does not apply to surface coating operations that are covered under a different area source NESHAP, such as the area source NESHAP for metal fabrication and finishing [40 CFR, Part 63, Subpart XXXXXX]. For assistance, contact the Iowa Waste Reduction Center at 1-800-422-3109. Additional information is available at http://www.iowadnr.gov/air/prof/NESHAP/. The publication of this document has been funded in part by the Iowa Department of Natural Resources. This document is intended solely as guidance, cannot be used to bind the Iowa Department of Natural Resources and is not a substitute for reading applicable statutes and regulations.