For Immediate Release

Friday, October 05, 2007

EPA Proposes Paint Stripping and Surface Coating Standards for Area Sources


Chicago, IL

The Environmental Protection Agency (EPA) has proposed a paint stripping and surface coating rule that will impose workplace standards and reporting requirements on companies that engage in paint stripping using methylene chloride or use hazardous air pollutants (HAP) for surface coating.  The proposed National Emission Standard Hazardous Air Pollutant (NESHAP) rule could affect marine-related industries such as engine part manufacturers, vessel accessory manufacturers, boat trailer manufacturers, and any company that applies HAP surface coating to finish plastic or metal parts.

 

“NMMA plans to support the work practice standards, but we’re requesting clarification on issues such as major source boatbuilders which are exempt from the plastic and metal parts MACT (maximum achievable control technology standard) and should be exempt from the area source NESHAP,” said John McKnight, NMMA director of Environmental and Safety Compliance. “With no exemption for minor sources, are they covered and major sources exempt?”

The rule does not apply to facilities where these processes are already regulated under a MACT standard. In its proposed rule, EPA identifies the primary sources of emissions from miscellaneous coating operations as the heavy metal pigments that are found in coatings and refinish material. EPA identifies the main HAPs for these source categories as cadmium, chromium, lead and manganese. HAPS can also include solvents such as toluene and xylene, often found in surface coatings.

This proposed regulation would come under part of Title III of the Clean Air Act where other MACT standards are found.  While the boatbuilder MACT standards only cover plants with greater than 10 tons of a single HAP or greater than 25 tons of a combined HAP, the area source regulations which are referred to as GACT (generally available control technology) cover all plants that trigger the rule, regardless of size or emissions. 

EPA is proposing that GACT for miscellaneous surface coating operations include:

• All spray painters are trained and certified;
• Any spray booth filters or particulate controls that are not fiberglass or polyester fiber filters achieve at least 98 percent efficiency;
• Any spray guns that do not meet the definition of HVLP or electrostatic spray guns that have been demonstrated to achieve at least 98 percent efficiency;
• Spray gun cleaning is being performed manually or in an enclosed gun cleaner when solvent is being atomized through the gun as part of the cleaning process;
• Affected sources would need to maintain records documenting workplace practices are being followed.

“In our comments NMMA will also emphasize to the EPA the importance of funding needed training support for manufacturers that would be subjected to this proposed rule,”  McKnight said. 

EPA has requested written public comments on the proposed rule be submitted by October 17.  To access the proposed rule or to view NMMA’s comments when submitted click here; or you can find it at nmma.org/government/environmental under the Area Source Rules tab. For more information, questions or comments contact John McKnight at (202) 737-9757 or jmcknight@nmma.org

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