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

2. 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

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

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

5. 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

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

7. 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

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

9. 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

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

11. 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)

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

13. 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

14. 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

15. 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