UNIVERSITY OF NORTHERN IOWA 800/422-3109 WWW.IWRC.ORG Paint Stripping & Misc. Surface Coating Operations Dan Nickey nickey@uni.edu UNIVERSITY OF NORTHERN IOWA 800/422-3109 WWW.IWRC.ORG

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

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

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

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

Four Pillars of the Regulation Paint booth requirements Training requirements Spray gun requirements Spray gun cleaning requirements

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

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

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

Training must Include cont. Resolving paint application problems Finish defects causes and cures Safety precautions Environmental compliance

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)

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

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

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

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