Paint Stripping

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Paint Stripping Misc. Surface Coating
OperationsDan Nickeynickey_at_uni.edu

• UNIVERSITY OF NORTHERN IOWA
• 800/422-3109
• WWW.IWRC.ORG

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Covers

• Area sources EPA estimates 38,000
• Paint stripping activities using Methylene
  Chloride
• Surface coating of all materials and/or products
• Finishing and refinishing of motor vehicles and
  mobile equipment

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Affected Sources

• Mixing rooms and equipment
• Spray booths and prep booths
• Spray guns
• Spray gun cleaning equipment
• Equipment used for paint stripping

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Exemptions

• Military operations
• Stripping operations using less than 150 gallons
  of Methylene Chloride per year
• Wood coating operations
• Air brushes
• Aerosol cans

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Important Dates

• CFR date - September 17, 2007
• Comment date October 17, 2007
• Implementation date December 17, 2007
• Compliance date
• Existing sources - December 17, 2009
• New sources Upon promulgation

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Four Pillars of the Regulation

• Paint booth requirements
• Training requirements
• Spray gun requirements
• Spray gun cleaning requirements

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Paint Booth Requirements

• Auto Body (cars, construction agriculture)
• Four complete walls
• Negative pressure
• Filtered (Polyester or Fiberglass)
• Misc. Coating
• Three complete walls or side curtains
• Filtered (Polyester or Fiberglass)

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Training Requirements

• All painters
• Every five years
• 60 days after hire
• Employee can transferred training from one
  employer to another

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Training must Include

• Surface preparation
• Spray gun setup and operation
• Spray technique improve transfer efficiency
• Spray booth and filter maintenance
• Paint mixing, matching and applying

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Training must Include cont.

• Resolving paint application problems
• Finish defects causes and cures
• Safety precautions
• Environmental compliance

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Spray Gun Requirements

• HVLP Between 0.1 and 10 lbs/square inch of air
  pressure at the tip
• Electrostatic Uses a electrical charge to
  attract paint particles to the substrate
• Gun demonstrated to be equal in transfer
  efficiency (must be approved by EPA)

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Gun Cleaning Requirements

• Automated gun cleaning machine
• Hand clean equipment with non HAP solvents
• Can not spray cleaning solvent through spray gun

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Reporting and Record Keeping Requirements

• Certify
• All coating applied in a spray booth
• All spray guns are HVLP, electro static or
  equivalent
• All painters have completed the required training
• All gun cleaning is performed in enclose machine
  or by hand

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Reporting and Record Keeping Requirements (cont.)

• Initial notification
• New Source 120 days after startup
• Existing Source 1 year after promulgation
• Notification of compliance
• New Source 120 days after the compliance date
• Existing Source 30 days after the compliance
  date
• Annual compliance report

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NSC Comments

• The number of impacted sources
• Training requirements are vague
• No demises
• Exclusion of painting large objects
• The use of paint brushes and rollers
• The use of non hap paints
• Major sources have no training requirements
• Cost to impacted sources