- Email: [email protected]
Environmental coating problems
Environmental Coating Problems by Ron Joseph
Use the Shop Problem Card in this issue for free expert advice.
How to Take Responsibility When You Have No Control c i I work on an Air Force base that has several paint shops, one of is the Hobby Shop. Here, anyone can come at all hours of the day and night to paint personal items. For instance, they can repaint their own cars, kitchen cabinets, and anything else that they don't want to paint at home. My problem is that I am not in the shop all day and night, and, therefore, have no control over what paint they use, how much thinner they add, the records they keep, etc. How can I protect myself against an air-quality violation, particularly given that we are a major source subject to the aerospace National Emission Standards for Hazardous Air Pollutants (NESHAP)? RK. A
Your problem is real and must be dealt with in an appropriate way. Having worked with the Air Force for several years, I am familiar with your concern. You have said that your base is a major source for HAPs; therefore, you are also automatically subject to Title V, the permit rule. The following are some options I might suggest. Ask your base environmental manager if the permit can be written to exempt the Hobby Shop from using VOC-compliant materials, spray guns, keeping records, and other requirements. My guess is that total coating usage in your facility is very low, and I presume that most, if not all, of the painting will be nonaerospace related; therefore, most of the provisions of the NESHAP will not apply. If, however, you live in a state that has Reasonably Available Control Technology (RACT), rules for individual source categories (such as automotive refinishing, painting of miscellaneous metal parts, coating of wood furniture, etc.), METAL FINISHING
• M A R C H 1997
compliance in the Hobby Shop can be complex. Somehow, I doubt that you will be successful in getting an exemption, but it's worth a try, as this would relieve you of the responsibility of compliance. Set up procedures that must be followed by all those who enter the shop. These would need to be clear instructions describing what type of paint they can use, how the users must mix their paint, the types of spray gun they must use, solvent wiping, etc. This sounds like a daunting job, and it probably is just that. You might need to insist that all users meet with you during working hours to explain what they intend to paint and what materials they will be using. You can then sanction these items on a one-on-one basis and explain all of the procedures that are controlled by the regulations. You can also emphasize the need for proper record keeping. I am familiar with the difficulty you face in ensuring that compliance is met after you leave the shop at quitting time. The Commander of your base will need to sign the Title V permit. The buck stops at his/her desk, and ultimate responsibility for compliance resides in that office. Before having the Commander sign the permit, your environmental manager will need to explain the risk that goes along with providing free access to the Hobby Shop. Because of the potential damages that are associated with violations, the Commander might decide simply to close it down altogether. This would not be popular with the troops, but it would solve the problem. I strongly suggest that you do not underestimate the importance of your responsibility for compliance; therefore, before it's too late, bring this to the attention of your environmental manager, and don't go away until you get a satisfactory response. © Copyright Elsevier Science Inc.
Chromate Conversion Coatings We use a chromate conversion • coating to treat aluminum. this have an effect on air quality? C.T.B. A
Chromates are not volatile o r ganic compounds (VOCs); therefore, they will not be covered by the organic paints and coatings regulations. They are covered, however, by regulations for the plating industry, and if your facility is large, they might also be covered by the chrome plating NESHAP.
/%
Painting Outside a Spray Booth touQc,o Can you use two-component
polyurethane coatings -up outside a booth?
for
J.I.L. A~
The question is relevant even if the touch-up coating is not a two-component polyurethane. Because you have raised the issue of painting outside a booth, I will answer the question in a broader sense. First, many regulations exempt touch-up painting altogether because it is assumed that only small amounts of coating are used in these operations. If your facility falls into this category, then touch-up painting can be performed outside a booth; however, it is important for the user to understand what is meant by touch-up painting. In most of the California rules, touch-up is defined as areas in which small scratches, dings, etc. must be reworked. Touch-up does not mean repainting surface areas of several square inches or even square feet. A paint brush, air brush, or other application device that applies only small quantities of paint is permitted. In facilities for which VOCs are not controlled by an abatement device, the concern with painting outside a booth 69
I
is not related to emission of VOCs. The VOCs will get into the ambient air regardless of where the object is painted; however, EPA does have concerns with the emission of particulates (PM10), particularly if chromate-containing paints are being used. One need only look at the new aerospace NESHAP to see how rigorously the EPA will regulate such emissions. When doing touch-up with a paint brush, particulate emissions are essentially zero, and with an air brush, they are negligible. If, on the other hand, a highvolume low-pressure (HVLP) or conventional air-atomizing gun is used, then particulate emissions do become a problem. Now, to address the issue of applying polyurethanes outside a booth. Bear in mind that approximately 2% of the population is sensitive to inhalation of polyisocyanates. The curing agent (Component B) of a two-component polyurethane is a polyisocyanate, which can cause severe respiratory
I
I
problems. Painters who wear National Institute for Occupational Safety and Health (NIOSH)-approved face masks (or better still, in-line air-supplied respirators) tend to be safe. On the other hand, factory personnel working outside the booth where the workpiece is being painted might be exposed to polyisocyanate emissions in excess of their sensitivity thresholds; therefore, the use of polyurethane outside a booth can have severe health-related consequences and can result in avoidable Worker's Compensation claims. The last issue concerning painting outside a booth is that paint overspray that is not abated by spray booth filters or a water-wash spray booth system can get into the ambient air. Numerous factories have suffered the nightmare of having employees who park their cars in the company parking lot report that their car's finishes have been damaged by overspray. I have been involved in several such incidents, and in all cases, after paying thousands in
damage claims, company management has had to go to great lengths to prevent overspray from getting out into the ambient air. While it is sometimes necessary to paint very large workpieces outside a booth, it is critical that every effort be made to capture most of the particulate emissions. This can be done by surrounding the workpiece with a large tarpaulin or plastic sheeting.
Communications If you can contribute to this column
by providing some of your ideas or comments regarding coating-related environmental issues, please feel free to write to me at Metal Finishing. For those readers who have an on-line computer service, you can also correspond with me via the following Email address: [email protected] Ron Joseph is an independent coating consultant in Saratoga, Calif. MF
The fastest-growing in t h e USA!
liner c o m p a n y
Call and Find out why/ Manufacturing PVC Liners exclusively for the Plating and Metal Finishing Industries, Flexible, one-piece, drop-in liners are made f r o m the best materials available. Free of flaws and fillers.
Many sizes in stock and ready for delivery to your valued customer!
G "His supplier finally got the order right..."
Call today for a referral to your distributor or for available distributor territories.
Global Industrial Liner, Inc. when i t s time f o r a break f r o m the ordinary/
Is your metals supplier hazardous to your health?
?
A L L I E D - H U N T E R
800 887 6633 ¢. fax 215 628 4040
HOURS OF OPERATION 8 AM Eastern - 5 PM Pacific TOLL FREE NUMBERS PH 1-888-543-7544 FAX 1-888-534-4357 PH 512-574-9131 FAX 512-574-7818 1514 A. Ben Jordan • Victoria, Texas 77901 i
Circle 006 on reader informationcard
70
Circle
035 on
reader information card
METAL FINISHING • MARCH 1997
Use the Shop Problem Card in this issue for free expert advice.
How to Take Responsibility When You Have No Control c i I work on an Air Force base that has several paint shops, one of is the Hobby Shop. Here, anyone can come at all hours of the day and night to paint personal items. For instance, they can repaint their own cars, kitchen cabinets, and anything else that they don't want to paint at home. My problem is that I am not in the shop all day and night, and, therefore, have no control over what paint they use, how much thinner they add, the records they keep, etc. How can I protect myself against an air-quality violation, particularly given that we are a major source subject to the aerospace National Emission Standards for Hazardous Air Pollutants (NESHAP)? RK. A
Your problem is real and must be dealt with in an appropriate way. Having worked with the Air Force for several years, I am familiar with your concern. You have said that your base is a major source for HAPs; therefore, you are also automatically subject to Title V, the permit rule. The following are some options I might suggest. Ask your base environmental manager if the permit can be written to exempt the Hobby Shop from using VOC-compliant materials, spray guns, keeping records, and other requirements. My guess is that total coating usage in your facility is very low, and I presume that most, if not all, of the painting will be nonaerospace related; therefore, most of the provisions of the NESHAP will not apply. If, however, you live in a state that has Reasonably Available Control Technology (RACT), rules for individual source categories (such as automotive refinishing, painting of miscellaneous metal parts, coating of wood furniture, etc.), METAL FINISHING
• M A R C H 1997
compliance in the Hobby Shop can be complex. Somehow, I doubt that you will be successful in getting an exemption, but it's worth a try, as this would relieve you of the responsibility of compliance. Set up procedures that must be followed by all those who enter the shop. These would need to be clear instructions describing what type of paint they can use, how the users must mix their paint, the types of spray gun they must use, solvent wiping, etc. This sounds like a daunting job, and it probably is just that. You might need to insist that all users meet with you during working hours to explain what they intend to paint and what materials they will be using. You can then sanction these items on a one-on-one basis and explain all of the procedures that are controlled by the regulations. You can also emphasize the need for proper record keeping. I am familiar with the difficulty you face in ensuring that compliance is met after you leave the shop at quitting time. The Commander of your base will need to sign the Title V permit. The buck stops at his/her desk, and ultimate responsibility for compliance resides in that office. Before having the Commander sign the permit, your environmental manager will need to explain the risk that goes along with providing free access to the Hobby Shop. Because of the potential damages that are associated with violations, the Commander might decide simply to close it down altogether. This would not be popular with the troops, but it would solve the problem. I strongly suggest that you do not underestimate the importance of your responsibility for compliance; therefore, before it's too late, bring this to the attention of your environmental manager, and don't go away until you get a satisfactory response. © Copyright Elsevier Science Inc.
Chromate Conversion Coatings We use a chromate conversion • coating to treat aluminum. this have an effect on air quality? C.T.B. A
Chromates are not volatile o r ganic compounds (VOCs); therefore, they will not be covered by the organic paints and coatings regulations. They are covered, however, by regulations for the plating industry, and if your facility is large, they might also be covered by the chrome plating NESHAP.
/%
Painting Outside a Spray Booth touQc,o Can you use two-component
polyurethane coatings -up outside a booth?
for
J.I.L. A~
The question is relevant even if the touch-up coating is not a two-component polyurethane. Because you have raised the issue of painting outside a booth, I will answer the question in a broader sense. First, many regulations exempt touch-up painting altogether because it is assumed that only small amounts of coating are used in these operations. If your facility falls into this category, then touch-up painting can be performed outside a booth; however, it is important for the user to understand what is meant by touch-up painting. In most of the California rules, touch-up is defined as areas in which small scratches, dings, etc. must be reworked. Touch-up does not mean repainting surface areas of several square inches or even square feet. A paint brush, air brush, or other application device that applies only small quantities of paint is permitted. In facilities for which VOCs are not controlled by an abatement device, the concern with painting outside a booth 69
I
is not related to emission of VOCs. The VOCs will get into the ambient air regardless of where the object is painted; however, EPA does have concerns with the emission of particulates (PM10), particularly if chromate-containing paints are being used. One need only look at the new aerospace NESHAP to see how rigorously the EPA will regulate such emissions. When doing touch-up with a paint brush, particulate emissions are essentially zero, and with an air brush, they are negligible. If, on the other hand, a highvolume low-pressure (HVLP) or conventional air-atomizing gun is used, then particulate emissions do become a problem. Now, to address the issue of applying polyurethanes outside a booth. Bear in mind that approximately 2% of the population is sensitive to inhalation of polyisocyanates. The curing agent (Component B) of a two-component polyurethane is a polyisocyanate, which can cause severe respiratory
I
I
problems. Painters who wear National Institute for Occupational Safety and Health (NIOSH)-approved face masks (or better still, in-line air-supplied respirators) tend to be safe. On the other hand, factory personnel working outside the booth where the workpiece is being painted might be exposed to polyisocyanate emissions in excess of their sensitivity thresholds; therefore, the use of polyurethane outside a booth can have severe health-related consequences and can result in avoidable Worker's Compensation claims. The last issue concerning painting outside a booth is that paint overspray that is not abated by spray booth filters or a water-wash spray booth system can get into the ambient air. Numerous factories have suffered the nightmare of having employees who park their cars in the company parking lot report that their car's finishes have been damaged by overspray. I have been involved in several such incidents, and in all cases, after paying thousands in
damage claims, company management has had to go to great lengths to prevent overspray from getting out into the ambient air. While it is sometimes necessary to paint very large workpieces outside a booth, it is critical that every effort be made to capture most of the particulate emissions. This can be done by surrounding the workpiece with a large tarpaulin or plastic sheeting.
Communications If you can contribute to this column
by providing some of your ideas or comments regarding coating-related environmental issues, please feel free to write to me at Metal Finishing. For those readers who have an on-line computer service, you can also correspond with me via the following Email address: [email protected] Ron Joseph is an independent coating consultant in Saratoga, Calif. MF
The fastest-growing in t h e USA!
liner c o m p a n y
Call and Find out why/ Manufacturing PVC Liners exclusively for the Plating and Metal Finishing Industries, Flexible, one-piece, drop-in liners are made f r o m the best materials available. Free of flaws and fillers.
Many sizes in stock and ready for delivery to your valued customer!
G "His supplier finally got the order right..."
Call today for a referral to your distributor or for available distributor territories.
Global Industrial Liner, Inc. when i t s time f o r a break f r o m the ordinary/
Is your metals supplier hazardous to your health?
?
A L L I E D - H U N T E R
800 887 6633 ¢. fax 215 628 4040
HOURS OF OPERATION 8 AM Eastern - 5 PM Pacific TOLL FREE NUMBERS PH 1-888-543-7544 FAX 1-888-534-4357 PH 512-574-9131 FAX 512-574-7818 1514 A. Ben Jordan • Victoria, Texas 77901 i
Circle 006 on reader informationcard
70
Circle
035 on
reader information card
METAL FINISHING • MARCH 1997