Take It Off

On Jan. 9, 2008, the U.S. Environmental Protection Agency (EPA) published National Emission Standards for Hazardous Air Pollutants (NESHAP) for: 1) operations that use methylene chloride (MeCl)-based paint strippers; 2) motor vehicle and mobile equipment surface coating operations; and 3) miscellaneous surface coating operations located at area sources. Potentially affected industries include construction, vehicle body and trailer manufacturers, municipal solid waste landfills, materials recovery facilities, and medical equipment and supply manufacturers.

Paint stripping operations are defined as those that use strippers containing MeCl for the removal of dried paint from wood, metal, plastic and other substrates. Paint stripping can be the primary activity at the source or an activity incidental to the principal activity at the source.

Motor vehicle and mobile equipment surface coating operations involve the spray application of coatings to automobiles, light trucks, heavy duty trucks, construction equipment, self-propelled vehicles and equipment, and equipment that may be drawn or driven on a roadway. Miscellaneous surface coating operations are those that involve the spray application of coatings that contain compounds of chromium, lead, manganese, nickel, or cadmium (i.e., the target HAPs) to parts and products made of metal or plastics.

If your firm performs miscellaneous surface coatings, but does not use any coatings that contain the target HAPs, the rule does not apply. The final rule applies to all motor vehicle and mobile equipment surface coating operations. However, owners and operators of motor vehicle or mobile equipment surface coating operations may petition EPA for an exemption from this rule if they can demonstrate that they do not spray apply coatings that contain the target HAPs. If a firm intends to spray apply coatings containing the target HAPs, the owner or operator must notify EPA and comply with the requirements of the rule.

Regulated paint stripping sources must implement management practices that reduce emissions by minimizing evaporative losses of MeCl. These practices involve only using a MeCl-containing paint stripper when alternative on-site stripping methods are incapable of accomplishing the work.

The prescribed management practices also include optimizing stripper application conditions, reducing exposure of the stripper to the air, and practicing proper storage and disposal of materials containing MeCl. Owners and operators must also maintain records of annual usage of strippers containing MeCl. In addition, firms that use more than one ton of MeCl per year need to develop and implement a MeCl minimization plan.

All motor vehicle and mobile equipment surface coating operations and those miscellaneous surface coating operations that spray apply coatings containing the target HAPs must apply the coatings with a high volume, low pressure (HVLP) spray gun, electrostatic spray gun, airless spray gun, air-assisted airless spray gun or a gun demonstrated to be equal in transfer efficiency to an HVLP spray gun.

All spray-applied coatings must be applied in a prep station or spray booth. The exhaust from the prep station or spray booth must be fitted with filters demonstrated to achieve at least 98 percent filter efficiency of paint overspray. Additionally, surface coating sources subject to the standards are required to demonstrate compliance with management practices.

Ed Repa is director, environmental programs, at NSWMA. E-mail him at erepa@envasns.org.