The Environmental Protection Agency proposed a paint-stripping and surface-coating rule for companies using methylene chloride for paint-stripping or hazardous air pollutants for surface coating.
The proposed National Emission Standard Hazardous Air Pollutant rule could affect engine part manufacturers, vessel accessory manufacturers, boat trailer manufacturers, and any company that applies HAP surface coating to finish plastic or metal parts.
The National Marine Manufacturers Association plans to support the work practice standards, but requests clarification on several issues, including 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, the NMMA’s director of environmental and safety compliance, in a statement.
In its proposed rule, EPA identifies the primary sources of emissions as the heavy metal pigments found in coatings and refinish material. The main HAPs for these source categories are cadmium, chromium, lead and manganese. HAPS can also include solvents such as toluene and xylene, often found in surface coatings.
The rule does not apply to manufacturing plants where these processes are already regulated under a MACT standard.
The MACT standards cover plants, emitting greater than 10 tons of a single HAP or greater than 25 tons of a combined HAP. The area source regulations or 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 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.
Public comments on the proposed rule are due by Oct. 17. Visit www.nmma.org/government/environmental under the Area Source Rules tab or contact John McKnight at (202) 737-9757 or jmcknight@nmma.org.
