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Proposed EPA NESHAP for Painting and Coating Operations

On September 6, the EPA issued a proposal for air toxic standards for smaller emitting sources (area sources) in three industry sectors that involve paint stripping and surface coating operations. The area sources refer to those that have the potential to emit less than 10 tons per year of a single toxic air pollutant or less than 25 tons per year of any combination of toxic air pollutants. The practices are designed to reduce overall toxic material consumption which can result in savings for facilities as well.

The standards apply to the area sources that engage in the following:

Paint stripping operations that use methylene chloride (MeCl)-containing paint stripping formulations

Surface coating operations that involve paints that contain metal HAP compounds

Auto body refinishing

Requirements for Paint Stripping Operations

New as well as existing area sources need to implement management practices to minimize evaporative loss of MeCl.

Sources consuming more than 150 gallons per year of paint stripping formulation must also develop and implement a minimization plan designed to reduce the consumption of MeCl.

Requirements for Surface Coating Operations

Implement equipment practices to minimize amount of coating required

Include confining spray operations to within properly filtered spray booth or preparation station

Use HVLP or equivalent spray equipment

Clean spray guns manually or by using enclosed spray gun washer

Implement management practices to minimize amount of coating used

Proper training and certification of HVLP equipment operators

Capture toxic metal particulates from the process

These include compounds containing cadmium, chromium, lead, manganese and nickel

For more information, download a copy of the notice from EPA’s Worldwide Web site at:

http://www.epa.gov/ttn/oarpg/t3pfpr.html

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