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SSPC Addresses Proposed EPA NESHAP Rule on Paint Stripping

Published on 2007-11-19. Author : SpecialChem

SSPC has submitted comments to the U.S. EPA in response to the agency's proposal to include North American Industry Classification System (NAICS) Code 332212 - Fabricated Structural Metal Manufacturing and related codes under the National Emission Standards for Hazardous Air Pollutants (NESHAP) on Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources. In its comments, SSPC states that the control technology (and scope of the regulation) in the proposed rule is not specific to the structural steel fabrication industry. Instead, SSPC proposes that this industry sector is removed from coverage under the proposed rule so that one set of industry-specific rules (i.e., those applicable to the 9 metal fabrication area source categories) is used to provide a clear, singular regulatory framework for emissions from structural steel surface coating.

SSPC also included specific comments on the proposed EPA emission control requirements for solvent strippers, indicating that the use of alternatives to MeCl paint strippers may pose a greater health hazard. In its remarks on the EPA's stance regarding the transfer efficiency of coatings with high-volume, low-pressure (HVLP), electrostatic spray, or a spray application to be equal in transfer efficiency to HVLP, SSPC identified airless spray as achieving the minimum 50% transfer efficiency required while often emitting less hazardous air pollutants (HAPs) than HVLP since protective coatings require thinning (using solvents) prior to HVLP spray application due to its limitation in atomization energy.

SSPC concluded its position statement by advising the EPA that its C12: Airless Spray Certification, Plural Component Certification, and Applicator Train-the-Trainer Programs meet the EPA's proposed mandatory training requirements for painters to be certified through classroom and hands-on training in their ability to properly select, mix, and apply coatings.

The National Emissions Standards for Hazardous Air Pollutants (NESHAPS) are emissions standards set by the EPA for an air pollutant not covered by National Ambient Air Quality Standards (NAAQS) that may cause an increase in fatalities or in serious, irreversible, or incapacitating illness. The standards for a particular source category require the maximum degree of emission reduction that the EPA determines to be achievable, which is known as the Maximum Achievable Control Technology (MACT). These standards are authorized by Section 112 of the Clean Air Act and the regulations are published in 40 CFR Parts 61 and 63.

"Area" sources consist of smaller-size facilities, such as coating application operations, that release lesser quantities of toxic pollutants into the air than "major" sources do. Area sources are defined as sources that emit less than 10 tons per year of a single air toxic, or less than 25 tons per year of a combination of air toxics, while "major" sources are defined as sources that emit 10 tons per year of any of the listed toxic air pollutants, or 25 tons per year of a mixture of air toxics.

The EPA published the initial list of "source categories" in 1992 (57FR31576, July 16, 1992) and since that time has issued several revisions and updates to the list. For each listed source category, EPA indicates whether the sources are considered to be "major" sources or "area" sources.

Through its Government Affairs Committee overseen by SSPC Protective Coating Professional Heather Bayne, SSPC regularly participates in advising the government and regulatory agencies, such as the EPA and OSHA, on pending rulemaking and legislation that would have a major impact on the protective coatings industry.

Source: SSPC


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