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Ind ust r i aln d u s t r i a lPai nt i ng &a i n t i n g &

Co at i ngo a t i n g

Ind ust r i aln d u s t r i a lPai nt i ng &a i n t i n g &

Co at i ngo a t i n g

Ind ust r i alPai nt i ng &

Co at i ng

Prep ared b y t he Kansas Small Busine ss Enviro nment al Assist ance Pro gram

Regulatory

Requirements

and

Pollution

PreventionIdeas

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What Is SBEAP?

The Small Business Environmental

Assistance Program , SBEAP, was in i-

tiated as a result of the Clean Air Act

Amendments of 1990. SBEAP helps

small businesses comply with envi-

ronmental regulations by providing

techn ical assistance, int roducing

businesses to pollution prevent ion

pract ices, and offering compliance

assistance to help with environmen-

tal permitting and reporting require-

men ts. In Kansas, the Pollut ion

Prevention Institute at Kansas StateUniversity is the techn ical assistance

provider for SBEAP. All SBEAP serv-

ices are completely confidential,

non-regulatory, and free.

Because services are free, SBEAPprovides guidance in compliance and

techn ical matt ers to businesses that

otherwise would not have access to

such help because of financial con-

straints. Its staff can introduce you

to such practices as changes in prod-

uct design, subst itution of materials,

process optimization, waste mini-

mization, and recyclingall of

which can help diminish the burden

of compliance and protect the envi-

ronment.

SBEAP operates independently of

the Kansas Departm ent of Health

and Environment, KDHE, but coordi-

nates with the agency to ensure th at

SBEAPs interpretation of Kansas

regulations is consisten t with

KDHE's intent.

To obtain technical assistance or

request an on-site assessment, call

800-578-8898. SBEAP also operates

a Web page at www.sbeap.org. Itcontains SBEAP publications, includ-

ing our quarterly newsletter, Kansas

AIRlines. It also has indust ry-specific

information an d a calendar of

events.

1

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2

Table of ContentsInt roduct ion .....................................................................................................................3

Substrate Surface Preparation..............................................................................4

Coating Applicat ion ..............................................................................................6

Drying and Cur ing ................................................................................................8

Coating Applicat ion Types and Technologies ..................................................................9Low-Volume High-Pressure Spray (LVHP) System s ...........................................10

High-Volume Low-Pressure (HVLP) Systems ....................................................11

Powder Coatings .................................................................................................13

Elect rostatic Paint Systems ................................................................................14

Airless and Air-Assisted Airless Systems............................................................15

Oth er Tech nologies.............................................................................................16

Comparison of Coatings .................................................................................................19

High-Solids Coatings...........................................................................................20

Water-Based Coatings .........................................................................................21

Powder Coating...................................................................................................22

Ultraviolet (UV) Radiation-Cured Coatings........................................................23

Pollution Prevention for the Coating Industry...............................................................24Hierarchy of Pollution Prevention Strategies.....................................................26

Priority 1 : Source Reduction ..............................................................................27

Priority 2: Recycle and Reuse ............................................................................33

Coating Operator Techn iques ........................................................................................35

Regulatory Issues ............................................................................................................37

Waste Disposal Regulat ions ................................................................................38

Air Regulat ions ...................................................................................................49

Wastewater Regulat ions ......................................................................................57

Water Regulat ions ...............................................................................................59

Comm unity Right -to-Know Regulat ions .............................................................60

Health and Safety ...............................................................................................63

Where to Find Help ........................................................................................................64

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3

Paint usage has environmental

impacts at all stages of its life cycle,

including manufacturing, applica-

tion, and eventual disposal. The pur-

pose of th is manual is to provide

general background information onenvironmental compliance require-

ments for painting application opera-

tions, with specific emphasis on

minimizing wastes th rough pollution

prevention. The manual reviews var-

ious coating applications, coat ingtypes, pollution prevention opportu-

nities, and environmental regula-

tions. If you have quest ions or

would like further information on

mater ials presented h ere, you can

contact an SBEAP specialist by call-ing 800-578-8898, or view any of our

publications by visiting our Web site

at www.sbeap.org.

Why paint? Paints and other surface

coatings provide protection to a

product, as well as being decorative

and eye-catch ing. Generally, paint

type and means of application are

dependent upon what function thecoating must perform. General steps

for painting and coating applications

typically include th e following:

s substrate surface preparation

s application of the coat ings drying of the coat ing

Preparatory, application, and drying

processes chosen depend on many

factors, including your client s

demands and anticipated rate atwhich you have to get products fin-

ished and delivered.

Introduction

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4

Surface preparation of the material

(substrate) to be painted is very

impor tan t. As high as 80% or more of

all coating adhesion failures can be

directly attributed to improper sur-face preparation.1 A substrate must

be clean before a coating is applied.

Improper preparation can lead to a

lower quality or defective product,

or one th at is not visually appealing.

The most common forms of surfacedebris are oils or greases that origi-

nated from mechanical processing,

or are deliberately applied for pur-

poses of corrosion prevention during

temporary storage or shipping. Other

surface contaminants comm onlyinclude oxidation, rust, corrosion,

heat scale, tarnish, and in some

cases, old paint. Dirt, grease, or

other similar materials will block the

bonding surface and create an

imperfection on the finished part.Proper preparation improves the

bond between th e coating mater ial

and the surface, and ensures the

coating is applied and adheres in a

uniform manner. Examine your

operations and see if there is a wayto minimize the am ount of cleaning

required by keeping your substrat e

from getting dirty during storage or

processing.

Mechanical Cleaning

The first step in your preparation

process should be mechanical clean-

ing. Wiping loose dust and dirt off

your parts with a rag is an easy

example. More vigorous action maybe needed to remove rust or other

contaminants strongly attached to

the part. For wood surfaces, sanding

followed by wiping with a lint-free

cloth is effective. For metal sub-

strates, metal scale and rust can beremoved by brushing the part with a

wire brush, a sand or grit blaster, or

plastic wool pads.

Surface Preparation

1 North Carolina Division of Pollution Preventionand Environmen tal Assistance, April 1998,

Pollution Prevent ion in Metal Painting and

Coating Operations

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5

Chemical-assisted Cleaning

Another option for preparing your

parts for paint ing includes chemical-

assisted cleaning. Traditionally, sol-

vents have been used to remove oily-

type contaminants through wiping,

spraying, dipping, or vapor degreas-ing. But there are problems associat-

ed with solvent cleaning. Spraying

can be wasteful, dip tan ks can lead

to large quan tities of hazardous

waste being generated, and vapor

degreasers are regulated under envi-ronmental laws and pose a potential

health hazard. Also, solvent-contam -

inated rags may need to be disposed

of as hazardous waste.

With such issues in mind, some haveswitched from solvent to aqueous

cleaning, which is generally more

environmentally friendly. Acidic

solutions effectively remove rust,

scale, and oxides from metal sur-

faces, but can cause hydrogen

embrittlement as hydrogen gas

formed penet rates the metal and

reduces its strength. Mild alkaline

solutions are used to clean and

remove rust an d scale from m etal

substrates because n o hydrogen

embrittlement results. Elevated t em-

perature solutions are more effective

for removing greases and oils, butthe energy consumption needs to be

considered.

Conversion Coat ings

For those working with m etal sub-strates, a conversion coating may be

applied to metal prior to painting to

improve adhesion, corrosion resist-

ance, and thermal compatibility.

Conversion coatings chem ically

react with the metal surface to builda more complex physical surface

that improves the bonding of the

coating. Iron and zinc phosphate

coatings are usually used for steel.

Iron, zinc, and chromium phosphate

are all used when it comes to coat-

ings for aluminum, with the choice

of solution largely depending on the

volume of aluminum being

processed.

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6

Which paint or coat ing application

process you choose will depend on

your particular operations. What is

the material you are coating? What

are the chemical and physical char-acteristics the coating must have?

What is the shape and size of the

productdoes it have a unique

shape that might make uniform

application more difficult? How

many products must you paint eachshift?

Several factors affect how good the

paint coverage is on the piece, as

well as the transfer efficiency of the

application. Transfer efficiency is therelationship between th e amoun t of

paint you apply and the am ount of

paint actually adhering to the part

being coated. The higher the transfer

efficiency of your process, the more

paint you are getting on your partand the less overspray you have.

Your equipment and booth setup,

the type of paint youre applying, the

part icular product youre coating,

and your painting operators skill all

factor into how efficient ly youreusing your paint.

Coatings consist of resins, pigments,

solvents, an d additives. Particular

types of coatings youre applying will

have varying amount s of each of

these constituents. Resins or bindershold all paint constituents together

and enable them to cure into a thin

plastic film. Resins are made up of

polymers, which are chosen based

on ph ysical and chemical properties

desired in the finished product.Acrylics produce a shiny, hard finish

with good chemical and weather

resistance. Alkyds are relatively low

in cost an d because of their versatili-

ty are considered a general pur-

pose paint. Epoxies provide excel-lent water r esistance an d superior

chemical resistance, but do lose

their gloss from ultraviolet light.

Urethan es combine high gloss and

flexibility with chemical stain resist-

ance, and demonstrate excellentwater resistance.

Coating Applications

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7

Pigmen ts are tiny part icles insoluble

in paint incorporated to improve the

physical appearance of the coating.

Additives are also used to impart

specific physical or chemical proper -

ties to the coating. Some pigmentsor additives may contain metals

which may classify any resulting

solid wastes as hazardous. Paint per-

formance may be improved by

adding curing agent s, defoamers,

gloss modifiers, or other agents.

Solvents are used to carry the coat-

ing solids to the part being painted.

They are also added to paint to aid

in its application by reducing viscos-

ity so the coating may be easilyapplied. Solvents are a major source

of environmental concern in coating

applications because as curing

occurs, hazardous air pollutants

(HAPs) and volatile organic com-

pounds (VOCs) are released.

Many of these same chemicals may

cause an y solid wastes generated as

part of your painting operations to

become hazardous wastes.

Additionally, any discarded products

may fall under the ResourceConservation and Recovery Act

(RCRA), or hazardous waste regula-

tions.

The n ext chapter goes into detail

about different coating applicationtypes and technologies currently

being used.

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8

Getting the paint or coating to your

products sur face is only half of the

processthe other half being how

the coating will be tran sformed into

the hard, protective, decorative fin-ish that your clients will desire. Will

your paint dry by evaporation? Will

drying outside your booth be neces-

sary due to your choice of coatings

or to your product schedule?

Drying and CuringIf the resin or binder is said to be

convertible, then it undergoes some

form of chemical reaction to trans-

form it to the solid film. If the resin

is non-convertible, then it is only theevaporation of the solvents in the

paint th at causes drying and r esults

in the desired film. Some coatings

are cured by a process that can be

cont rolled, such as baking, providing

an opportunity for overspray to becollected and recycled.

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9

Besides the conventional method

of applying coatings, many choices

exist for someone who is involved in

painting or coating operat ions. The

right choice for you depends on your

particular business operationsthe

type of pieces you coat ; the finished

appearance requested by customers;

money available for equipment,

training, and maintenan ce costs; and

even h ow much room you have in

your business. The following are

summar ies of some available tech -

nologies. If you have specific ques-

tions, call SBEAP at 800-578-8898,

and we can work with you and your

vendor to determine if these systems

will work for you.

Coating Application Typesand Technologies

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10

Low-volume high-pressure spray

(LVHP) is considered the conven-

tional method of applying coatings.

It depends on air-atomizing the paint

at pressures of 4070 pounds persquare inch (psi). Air is supplied

from an air compressor or turbine.

While these spray systems create

high quality finishes at high produc-

tion rates, they do have several dis-

advantages, including extensive

overspray, increased booth cleanup

costs, and increased filter use and

related costs. Additionally, if a h igh-

er coating thickness is necessary,

more operator passes may be neces-sary to get the desired mil thickness,

and h ence application time is

increased.

LVHP

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11

The principle of high-volume low-

pressure (HVLP) has been applied to

conventional spray guns to apply

paint with a h igh volume of dispers-

ing air at low pressures. HVLP gun shave nozzles with larger diameter

openings for atomizing air, can be

bleeder or non-bleeder types, and

require air volumes of 1030 cubic

feet per minute. Air and fluid deliv-

ery to the spray gun affect the effi-ciency, ease of use, cost, an d versa-

tility of HVLP sprayers.

In a siphon -fed HVLP system, air

pressure to the sprayer is used to

pull paint from the cup locatedbelow the gun, producing a fully

atomized pattern for even surface

coverage. Gravity-fed HVLP systems

are well adapted for higher viscosity

paints, such as clears, water-based

paints, h igh-solids paints, an d epoxyprimers, given the paint cup loca-

tion. The cup, located at th e top of

the gun , allows paint to completely

drain, minimizing paint waste.

HVLP guns allow operators to finish

intricate part s with comparable qual-

ity to conventional sprayers. This

makes them a good choice for small

shops that finish smaller, more intri-cate parts which demand a higher

level of gun cont rol. Other advan-

tages of the HVLP system include

th e following:

s transfer efficiencies, from 50 to

90 percent reported, depending

on the air-delivery system used

s reduced amount of overspray,

and hence material use

s reduced VOC and HAP emis-

sions

s reduced paint booth filter use

and cleanup costs

s reduced worker exposure due to

high-pressure blowback from

the spray

s good coverage of intricate parts

s finish quality comparable to con-ventional air sprayers

HVLP

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12

s comparable tr ansfer efficiencies

to a ir-assisted airless sprayers at

low-fluid delivery rates, with low

to medium viscosity fluids

s more efficient a ir atomization

s air-spray coat ing adaptable toany size coating operation and

application rate

s equipment fitt ings allow for fast

color changes and application of

very different fluid viscosities

HVLP systems, however, do have

some disadvantages, including diffi-

culty in obtaining higher fluid deliv-

ery rates with h igh viscosity materi-

als, and a lack of sufficient atomiza-

tion required for some fine finishes.

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13

Powder constituents are very similar

to wet paint with resins, pigments,

and additives, but lack a solvent car-

rier. When powder coating, powder

is supplied to the spray gun by thepowder delivery system. This deliv-

ery system consists of a powder stor-

age container, or feed hopper, and a

pumping device that transports a

stream of powder into hoses or feed

tubes. Compressed air is often usedas a pump because it aids in sepa-

rating the powder into individual

part icles for easier t ransport. Powder

spray guns impart an electrostatic

charge to the powder being sprayed

via a ch arging electrode located atthe front of the spray gun. Managing

the electrostatic field can direct the

powders flow and con trol pattern

size and shape, and powder density

as it is released from the gun .

All spray guns can be classified as

either manual or automatic.

Although basic operating principles

of most guns are the same, an almost

limitless variety in style, size, and

shape of spray guns exists. The type

of gun chosen for a given coating

line can be matched to the perform-

ance ch aracteristics needed for the

products being coated.

Powder coating became a major fac-

tor in the metal finishing industry

when the electrostatic spray process

(see next section) was introduced in

the 1960s. Electrostatic spraying

made it possible to apply th in layersof coating for higher quality decora-

tive finishes, and allowed powders to

be used on parts not suitable for dip-

ping in a fluidized bed. As the pow-

der coating technology continues to

develop, advances have been madein powder formulations to offer a

wider range of colors, glosses, an d

textures.

The higher transfer efficiencies asso-

ciated with powder coating are par-tially due to the recycling and reuse

of powder overspray.

Powder Coating

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14

Electrostatic paint systems deliver

paint that has been atomized by var-

ious methods, such as air-atomizing,

airless, or rotary. The atomized fluid

droplets are given a negative chargeas they leave the spray gun. The

charge causes the paint particles to

be attracted to the part , and if

high en ough, can cause the paint

part icles to actually reverse direc-

tion as they pass, coating the edgesand back of the part (an effect called

wrap-around), increasing transfer

efficiency. In some cases, even

water-based paints can be applied.

An advantage of these systems is the

uniform coating thickness produced.

Electrostatic systems must be prop-

erly grounded at all stages of paint

delivery to reduce injuries and fire

hazards that can result from short ing

or sparking. Compounds or compo-nen ts that conduct electricity,

diverting electrons from the paint

circuit, decrease system efficiency.

Humidity also reduces transfer effi-

ciency.

Electrostatic Paint Systems

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15

A method of atomizing paint is to

increase the spray guns fluid pres-

sure to 5006500 psi and redesign

the fluid nozzle so paint is atomized

without pressur ized air flow. Airlessgun s are effect ive for applying high-

viscosity coatings with relative ease

since there is only one hose attached

to the gun. The airless system pro-

vides h igh delivery rates (useful for

fast-moving production lines), withthe size of the nozzle determining

quant ity and th ickness of the paint

applied to the part. This system also

has h igher transfer efficiencies than

convent ional spraying. These sys-

tems do have some disadvantages,including expensive n ozzles an d

increased maintenance, a tendency

for tip plugging, increased operator

tra ining and skill due to skin-injec-

tion danger, reduced fan pattern

control, and limited coating types.

Air-assisted airless sprayers look

very much like air-atomizing guns.

Paint is delivered to the guns at

pressures of 150 to 800 psi. Air is

used to shape the pattern of the fluidspray leaving the gun nozzle. The

major differen ce between airless and

air-assisted spray guns is the atomiz-

ing tipan air nozzle allows jets of

atomized air to exit from ports in

small projections on each side of thetip. The air jets hit the paint stream,

breaking up larger droplets of paint

and atomizing it to a finer degree.

While having a high capital cost, air-

assisted airless spray systems have

good atomization and high transferefficiencies, are capable of reaching

high production rates, can h andle a

wide range of fluid viscosities, have

improved finish appearances as com-

pared to airless technology, and have

lower equipment maintenance dueto lower operating pressures.

Airless and Air-Assisted Airless Systems

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16

Rotary Atomizers

Paint is fed to the center of a spin-

ning disk or bell, and use centrifugal

force to break the paint into

droplets. These devices use electro-

static charge to guide the paint to

the part being coated. Electrostatic

charging also plays a key role in

atomizing the paint at low speeds.

Rotary atomizers are well suited for

covering large, broad surfaces; have

high transfer efficiencies; and have

high solid, waterborne versatility.

Other advantages include th e cre-

ation of a spray without use of th in-

ner and h igher t ransfer efficiencies.

These systems do have some draw-backs, including increased equip-

ment maintenance needs and safety

hazards.

Dip Coating

Parts are coated by being dipped

into vats of paint. Dip coating

requires paint viscosity to remainconstant to assure acceptable film

quality and is not suitable for items

with cavities. This process works

well on parts that are always the

same color and have minimum deco-

rative finish requirements, such as

agricultural equipment.

Other Technologies

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17

Flow Coating

These systems use 10 to 80 separate

streams of paint that coat all the

par ts sur faces. Like dip coating, th is

process is best suited for standard-

ized color needs with low decorative

finish requirement s. Paint viscositycontrols coating thickness, and an

area must be provided for the part to

han g while dr ipping excess paint .

Autodeposition

This process relies on a chemical

reaction to deposit an organic coat-

ing onto iron, steel, zinc, an d zinc-

alloy plated materials. The par t is

immersed into a solution containing

the coating compounds. When thepart is submerged, the paint com-

pound precipitates out of the solu-

tion and coats the part . The part is

then rem oved from th e tank, rinsed,

and cured. This process does not use

organic solvents, so no VOCs are

emitted.

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18

Electrodeposition

This system, like the autodeposition

system, requires the part to be

immersed in a waterborne coating.

The cosolvent is typically an organic

solvent. The process is very much

like electroplating in that the reac-tion is driven by electricity. Direct

curren t is passed th rough the solu-

tion and causes a reaction with the

paint resin, which deposits onto

part s, creating a un iform coating.

Although the coating contains some

solvent, this process has low VOC

emissions. Electrodeposition does

have a high initial investment costand intensive maintenance require-

ments. Separate tanks and rinse

lines are needed for each color.

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19

Traditionally, paint has been consid-

ered a liquid made up of several

components that when applied and

cured impart a thin plastic film.

Paints have traditionally been organ-

ic solvent-based, with the solventsaiding in th e application process.

While being versatile, it has many

environmental issues associated with

its use, including air em issions and

hazardous waste disposal. High-

solids paints have a higher percent-age of paint solids and contain less

solvent, and while air em issions may

be less, they are still present. Water-

based paints, which utilize water as

the solvent, also have reduced VOC

emissions, as well as a reduced fire

hazard. Solid paints, such as pow-

der coatings and paints containing

no solvents (and hence h ave reduced

HAP and VOC em issions), ar e widely

available. These materials have given

rise to the term coatings instead of

paints. With catalyzed or two-com-

ponent coating systems, reactive

resins and catalysts are mixed just

before en ter ing the application

equipment . This type of coating sys-

tem can also reduce solvent use.

The following provides a comparison

of four different coating technologies

high-solids coatings (where the

paint was modified to produce a

coating with h igher solids concentra-

tion and a lower VOC concentra-tion), waterborne coatings (which

mainly use water to disperse the

paint resin, although some solvent is

still present), powder coatings

(which have become a viable alter-

native for decorative and functionalcoatings, although still predominate-

ly a metal-finishing process), and

UV-cured coatings (coatings requir-

ing UV radiation to initiate crosslink-

ing of the resin).

A Comparison of Coatings

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Pollution prevention benefits:

s reduces solvent in coatings

s less overspray compared to con-

ventional coatings

s higher transfer efficiencies

Operational benefits:

s can apply thick or th in coat

s easy color blending or

changing

s compatible with conventionaland electrostatic application

equipment

Energy savings:

s reduced air flow in work spaces

and curing ovens (low VOC)s reduced en ergy needed for h eat-

ing makeup air

Applications:

s zinc-coated steel doors

s miscellaneous metal parts

s same as conventional coatings

Limitations:

s solvent use not completely elimi-

nated

s shorter pot life than convention-

al coatings

High-Solids Coatings

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21

Pollution prevention benefits:

s eliminates or reduces solvent in

coatings

s reduced VOC emissions and fire

hazardss reduced h azardous waste

disposal

s water used for cleanup

Operational benefits:

s can apply thick or th in coats easy color blending or changing

s compatible with conventional

and electrostatic application

equipment

Energy savings:s reduced air flow in work spaces

(little or no VOC)

s reduced en ergy needed for h eat-

ing makeup air

Applications:

s wide range

s architectural trade finishers

s wood furn iture

s damp concrete

Limitations:

s coating flow propert ies and dry-

ing rates can change with

humidity, affect ing coating appli-

cations sensitive to humidity, workplace

humidity control required

s may have poor flow characteris-

tics due to high surface tension

of water

s

special equipment needed forelectrostat ic application

s water in paint can cause corro-

sion of storage tanks and trans-

fer piping, and flash rusting of

metal substrates

Water-Based Coatings

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Powder CoatingsPollution prevention benefits:

s eliminates solvent in coatings

s little or no VOC emissions

s easier to recycle and reuse over-

sprays reduces solvents for cleaning

s reduces need for solid paint

waste disposal

Operational benefits:

s can apply thick coat in oneapplication

s no mixing or stirring

s efficient material use, possible to

ach ieve near ly 100% transfer

efficiency if a reclaim system is

used

Energy savings:

s little air flow needed for worker

protection (no VOC)

s little energy needed for heating

makeup air

Applications:

s steel

s aluminum

s zinc and brass castings

Limitations:

s requires handling of heated parts

s part must be electrically conduc-

tive, complex shapes difficult to

coat

s difficult to apply th inner coat-ings

s need special equipment or extra

effort to make color changes

s difficult to incorporate metal

flake pigments

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Ultraviolet (UV) Radiation-Cured CoatingsPollution prevention benefits:

s eliminates solvent in coating

s allows for increased production

rates

s 100% react ive liquid

Operational benefits:

s can apply thin coats

s easy color blending or changing

s efficient m ater ial use, near ly

100% tr ansfer efficiency

Energy savings:

s little air flow in work spaces (no

VOC)

s cure with UV instead of an oven

s

little energy needed for heatingmakeup air

Applications:

s some metal applications

s filler for ch ipboard

s wood

s wet look finishes

Limitations:

s styren e volatility

s typically best applied to flat

materials

s limited to thin coatingss high capital cost of equipment

s yellow color

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What is Pollution Prevention?

Pollution prevention, or P2, meanspreventing wastes rather than using

expensive treatment and control

technologies on end-of-pipe wastes.

P2 can decrease environmental lia-

bilities, reduce waste disposal costs,

and improve working conditions. It

may be as simple as prevent ing spills

and leaks through bet ter housekeep-

ing and m aintenance, or as complex

as switching solvent-cleaning sys-

tems.

Development of Pollution

Prevention Concepts

In 1990, beginn ing with the

Pollution Prevention Act, EPA shift-

ed focus from end-of-pipe pollut ion

treatm ent and cleanup to policies,

technologies, and processes that pre-

vent and m inimize the generat ion of

pollution. The underlying theory

behind P2 is that it is economically

Pollution Prevention for theCoating Industry

more sensible to prevent wastes than

implement expensive treatment and

control technologies to ensure wastedoes not threaten human h ealth and

the environmen t.

P2 and the Coating Industry

Paint application wastes include left-over paints, dirty thinner from

cleaning spray guns and paint cups,

air emissions of volatile organic com-

pounds (VOCs) and hazardous air

pollutants (HAPs), dirty spray booth

filters, dirty rags, and disposal of

out-dated supplies. Ways to reduce

these wastes include rigid inventory

control, better housekeeping prac-

tices, mixing paint according to

need, better operator training, prop-

er cleaning methods, using alterna-

tive coatings, using styrofoam filters,

recycling solvents on and off site,

and using waste exchanges.

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Better operat ing practices, or good

housekeeping applies to all waste

streams and requires minimal capital

investmen t, yet can be very effective

in reducing the amount of wastes

generated. Good housekeepingincludes management initiatives to

increase employee awareness of the

need for and benefits of pollution

prevention, and preventive mainte-

nance to reduce the n umber of leaks

and spills.

Waste assessments help identify the

amounts and types of wastes gener-

ated a t your facility. Knowing th is

makes it easier to kn ow how waste

can be reduced and where to con-

centrate your efforts. Any wastemanagemen t program is an organ-

ized and con tinuous effort to sys-

tematically reduce waste generation,

and should reflect th e goals and poli-

cies of management. An effective

program also includes the involve-

men t and enthusiasm of employees,

especially those who have an under-

standing of the processes being

examined.

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Hierarchy of Pollution Prevention Strategiesfor Coating Operations

Inventory control

Better housekeeping practices

Operator training

High-transfer efficiency equipment

Alternative coatings

Better cleaning methods

On-site solvent recycling

Off-site solvent recycling

Waste exchanges

Proper

disposal

Priority 1: Source Reduction

Priority 2: Recycling & Reuse

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Source reduct ion tech niques are

designed to reduce the amount of

waste initially generated. Simple

housekeeping changes and conduct-

ing periodic inspections of all equip-ment can be less expensive than fix-

ing malfunctions when they appear,

or cleaning up a preventable spill.

Inventory Control

Inventory control is an effective and

efficient way of reducing indiscrimi-

nate use of raw materials. By reduc-

ing the amount of paint th at

becomes unusable, you not only save

costs associated with waste disposal,

but you also save costs associated

with in itial product purchase. Mark

receiving dates on your incoming

paint products, and use a first in,

first out procedure to use older

paint materials first.

Priority 1: Source ReductionLook at standardizing the paint

types an d colors you offer your cus-

tomers. This can help minimize the

number of different paint products

you keep in inventory, again lessen-ing the chan ce for paint product to

go bad. Stan dardizing your paint

types an d colors also provides you

with another benefitit minimizes

the chan ce that a client s particular

paint selection will provide you witha surprise and cause what m ay have

previously been a non-hazardous

waste to become a new hazardous

waste for you to handle. If justified

by volume demand, purchase your

chief coating colors in 15-, 30-, or

55-gallon reusable drums rather than

5-gallon pails. Just be sure th at prod-

uct won't sit around too long.

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If you have paint material that for

one reason or another will not meet

your clients specifications or expec-

tations as a finished coat, use it as

an undercoat or primer; or see if you

can find a business that can use thepaint and sell it, even at reduced

cost.

Monitor the amount of paint used by

differen t workers to get the same

jobs done. Shop owners may moni-

tor employee operations and m ake

verbal or written comm ents on prod-

uct usage. Limit employee access to

material storage areas, or develop

some kind of accounting system to

track material use.

Better HousekeepingPractices

Basic housekeeping techniques can be

very effective in reducing pollution.

Many methods are available to control

and minimize material losses, which

can be implemented easily and at lit-

tle or no cost to the operator. Specific

approaches to bulk material drum

location, mater ial transfer methods,

evaporation, and drum transport caneffect ively limit m aterial loss.

s Keep paint and solvent contain-

ers t ight ly closed to reduce evap-

oration, emissions, and material

dry-out.

s Reduce leaks and spills by plac-

ing drums at point s of highestuse.

s Use spigots or pumps when

transferring materials from stor-

age containers to smaller con-

tainers.

s Control evaporation by using

tight -fitting lids an d spigots.

s Use drip pan s.

s Use secondary containment in

bulk storage areas.

s Move drums carefully to prevent

damage or punctures, which

could lead to leaks or ruptures

during future use.

Material Preparat ion

Look for ways to reduce the amount

of solvent used in product pre-clean-ing. Examine substituting chemical

cleaning for physical or mech anical

cleaning when preparing the product

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Paint Mixing

For small jobs, the amount of paint

prepared will often exceed th e

amount of paint actually applied.

Track usage rates for different painttypes. Have various sizes of paint-

mixing and sprayer cups available to

limit over-mixing of paint for a spe-

cific project, and to reduce the

amount of solvent n eeded for equ ip-

ment cleanup.

Better Operator Trainingand Employee Participation

Operators may be very skilled at

producing high quality finishes, but

poorly trained in minimizing paint

usage. Key points for operators

include the following:

s Do not arc the spray gun and

blow paint into the air.

s Maintain a fixed distance from

the painted surface while tr igger-

ing the gun .

s Too much or too little overlap

leads to wasted paint and heavy

or lightly coated areas. A 50%

overlap pattern is typically rec-ommended.

surface for painting application.

Sand or part icle blasting are some

examples, although they have their

own environmental issues. Plastic

media has been substituted for sand

in some blasting operat ions for bothenvironmental and worker health

issues. The plastic media can be

reused once separated from th e

stripped-paint waste, reducing both

purchasing and waste disposal costs.

Dry ice is another alternative mate-

rial for blasting processes. If solvent

cleaning is used, reduce solvent loss

due to evaporation by installing

cleaning tank lids or increasing free-

board space in vapor degreasers.

Conversion Coat ings

Avoid dirtying or soiling the sub-

strate prior to the beginning of the

cleaning process. Analyze water for

hardness and dissolved solids. Use

alkaline cleaners or phosphate com-pounds with hard water stabilizers

where necessary. Use low-tempera-

ture, energy-conserving alkaline

cleaners or phosphate compounds.

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s Air pressure should be kept

lowth is can increase transfer

efficiency from 30 to 60 percent.

s Keep the gun perpendicular to

the surface being painted.

Angling the gun leads to some ofthe spray being too far from your

product surface and a decrease

in transfer efficiency.

Ask your operators where they see

improvements could be madeafter

all they work with the equipment

daily and may have suggestions not

previously thought about . Provide

incentives to increase employee par-

ticipation in whatever waste reduc-

tion or recycling program you have.

One business tracked the savings in

material purchases and money made

from recycling activities and put this

into a general employee account to

be used by the workers to improve

their working stations and lunch-

room.

Maintenance and Use ofHigh-Transfer EfficiencyEquipment

Less overspray means fewer air

emissions. You can reduce theamount of waste you generate by

increasing the t ransfer efficiency of

your coat ing process. Remember,

transfer efficiency is a measure of

how much paint goes on the part ,

compared to h ow much is sprayed.Typical transfer efficiency from con-

ventional air guns ran ges from 20 to

40 percent, thus 60 to 80 percent of

the paint is overspray. Overspray is

a function of the design and opera-

tion of the system used an d your

operator application techn iques.

Talk to your equipment vendor

about higher transfer efficiency

equipment, and examine the pay-

back per iod by switching to such

equipment. It may be that the

amount of material saved will justify

upgrading your equipment.

Even if you've examined upgrading

your equipment and have decided to

continue with your cur rent process

equipment, make sure it is in goodworking orderyour painters' per-

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formance depends on the condition

of their tools. Poorly maintained

equipment m ay result in products

that dont meet customer demand

and can reduce the transfer efficien-

cy of your operations.

Alternative Coatings

VOC emissions are related to the

type of coating used and the num ber

of coats necessary for a high quality

finish. Acrylic lacquers are typically

thinned with solvent by 125 to 150

percent. With synthet ic enamels,

solvent th inning amounts to 15 to 33

percen t. Minimize or eliminate VOC

emissions by substitu ting solvent-

based paint with waterborne paint ,high-solids paint, or with medium-

or low-solvent paint. Consider, how-

ever, the desired final product speci-

fications and the type of product

being coated when choosing substi-

tute mater ials.

Proper Cleaning Methods

Wastes resulting from cleaning of the

application equipment can be

reduced by more efficient cleaning

methods. Reduce solvent use in

equipment cleaning by scraping

paint cups or tanks into a separate

container before rinsing the equip-

men t with solvent . Make use of

Teflon-lined metal paint containers,

which are easier to clean. Use an

enclosed gun-cleaning station. Spray

solvent th rough the gun into the

cleaning station where it is captured

for recovery and reuse. Schedule

jobs so that large batches of items of

similar color are painted, instead of

small batches of custom items, toreduce the am ount of dirty cleaning

solvent and waste paint generated

during change-out.

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Filters

Suppliers or recyclers of thinners

may replace and dispose of dirty

spray booth filters for a generator. It

is the responsibility of the generator,

however, to determine if these filters

are hazardous. Filters m ay be char -

acteristic hazardous waste (toxicity)

if they contain enough metals or

volatiles. The volatiles could come

from the paint th inners used or from

the paint itself. The m etals typically

are found in paint pigments. When

cleaning paint equipment (including

gun tips and hoses), solvent and/or

thinn ers should not be sprayed on

filters (or into the air in the paint

booth), as this could cause the filters

to become a listed waste (and this

act is considered illegal disposal).

Because the filters are in a solid

state rath er than a liquid, they are

not considered a hazardous waste in

Kansas due to ignitability (D001). It

is important to remember, however,

that paint filters have been known to

cause trash fires and th at some local

trash haulers and transfer stations

will not allow them to be disposed in

the regular trash. In th is case, the

filters should be segregated from the

regular trash and disposed under a

Special Waste Disposal Author ization

from KDHE.

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Reusing and recycling can h elp to

reduce waste disposal costs. Wastes

may potentially be used as raw

materials for a process, or mater ials

may be able to be recovered beforebeing disposed. Recovery technolo-

gies can either remove desired mate-

rials from a waste st ream before dis-

posal or can directly use waste from

one process as raw material in

another.

On-Site Solvent Recycling

Several alternatives are available for

recycling solvent on site. Gravity

separation is inexpensive and rela-

tively easy to implement by allowing

the solvent/sludge mixture to sepa-

rate under inactive conditions. The

clear solvent can th en be decan ted

with a drum pump and used for

equipment cleaning, reducing the

amount of wash solvent purchased.

Reclaimed solvent can be used for

formulating primers and base coats,

but might create problems if not suf-

ficiently pure.

For those facilities that generatelarger quantities of waste solvent,

on-site distillation may provide a

more cost-effective alternative.

Batch distillation of all high-grade

solvent wastes can virtually elimi-

nate the need for purchasing lowerquality solvents for use in prelimi-

nary painting operations an d

cleanup. An operator may reclaim

four and one-half gallons of thinner,

with one-half gallon left as sludge

from five gallons of paint and thin-ner wastes. This ratio varies depend-

ing on the operations.

When determining the am ount of

hazardous waste your company gen-

erates each month (done to deter-

mine which hazardous waste genera-

tor category you fall under), remem-

ber to count any solvent that enters

your distillation/solvent recycling

unit, each time it is placed in the

un it. So while on-site solvent recy-

cling may help you reduce your

waste disposal and solvent purchas-

ing costs, it will not reduce your

hazardous waste generat ion rate.

Read more about properly counting

your wastes in the hazardous waste

regulatory section of th is manual.

Priority 2: Recycling and Reuse

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Off-Site Solvent Recycling

Low-volume solvent users, or those

who find it uneconomical to recycle

contaminated solvents on site, usual-

ly send their waste to commercial

recyclers for recovery. Commercial

recyclers have versatile distillation

processes and can handle large vol-

umes and varieties of solvents.

Generally, solvent recyclers recover

70 to 80 percent of the incoming

spent solvents into reusable prod-

ucts. Recyclers often sell reclaimed

solvents back to the user.

In general, suppliers who offer recy-

cling services include the cost of

waste collection and recycling in th eprice of their solvent. This increases

the thinner cost, but effectively

eliminates separate hauling and dis-

posal or recycling costs. It also

reduces the administrative burden

on the owner.

Waste Exchanges andDonations

Find a business that can use your

old or off-spec coating material, or

contact a waste exchange program.Waste exchanges are organizations

that man age or arrange the transfer

of materials between industries,

where on e producers waste becomes

another industrys feed stock.

Remember, if your by-product s are

determined to h ave value as raw

mater ial to another industry, then

they are not considered waste and

are exempt from RCRA (hazardous

waste) regulations. Most exchanges

exist as information clearinghouses,

which provide information on mate-

rials available for reuse.

Opportunities exist for these

exchanges to oversee direct transfer

of used solvent from indust ries

requiring ultra-high-purity solvents

to industries that do not have suchstringent requirements.

If you can t find a business that can

use your unwanted coating material,

check around to see if local organi-

zations and community groups maybe able to use it.

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The following text was taken from

EPA pollution prevention publica-

tions.2 You can see a copy of the

complete publication at www.epa.state.oh.us/opp/paints/fact23.html.

Techn iques spray painter s use dur -

ing application have a definite effect

on transfer efficiency and offer waste

reduction poten tial. Fundamen tals ofgood spray techniques consist of the

following:

s proper overlap of the spray

pattern

s

proper gun speeds proper distance of the gun from

the part

s holding the gun perpendicular to

the surface of the part

s triggering the gun at the begin-

ning and end of each stroke

Proper overlap of spray patterns will

be determined by the coating.

Proper overlap may range from 50

percent t o 80 percent. Greater over-

lap may result in wasted strokes, and

less overlap may result in streaks.

Since the flow of coating from the

gun is consistent, the speed of the

gun as it is moved across the part

should be consistent as well. Steadygun speed will help obtain a uniform

thickness of coating. A gun speed

higher than manufacturer specifica-

tions can distort th e spray pattern

and not permit the maximum

amount of mater ial to reach the sur-face.

The distance of the gun from the

part must be consistent, since, again,

the flow of material from the gun is

consistent. Generally, this will be sixto eight inches for non-electrostatic

systems. Spray losses increase with

the distance, as does solvent loss.

This solvent loss is often corrected

by the addition of more solvent. This

does not correct t he spray loss, and

overspray still ends up in the spray

booth.

Proper Coating Techniques

for Operators

2 Ohio Environmental Protection Agency, Office

of Pollution Prevention, Septem ber 1994,

Pollution Prevention in Painting and Coating

Operations

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Except for special conditions, th e

gun should be held perpendicular to

the surface of the part . Arcing the

gun for hard-to-reach areas wastes

material by applying an uneven coat.

This also may result in streaks.

These areas should be compensated

for by changing the positioning of

the gun or operator.

If the trigger of the gun is not

released at th e end of a stroke, the

material continues to flow and when

the gun changes direction, momen-

tary stopping of the gun results in an

accumulation of coating material. To

avoid this piling, the operator may

spray past the edge of the surface,

spraying material into the spraybooth and wasting coating.

All manufacturer specifications

should be checked to ensure that

operators are using the proper tech-

nique for their equipment. Operator

training and experience will provide

operators with knowledge of various

painting techn iques needed to paint

parts of different configurations.

Differen t t echniques are helpful

when painting inside corners, out-

side corners, slender parts, round

part s, flat part s, large parts, or sm all

parts.

Standard operating techniques will

not be fully successful if other prob-

lems exist, such as room tempera-

ture changing throughout the day

(which ch anges the viscosity of thepaint) or if equipment needs repair.

Operators cannot be expected to

compen sate for broken gauges, worn

fluid tips, or other equipment prob-

lems.

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Pollution generated from indust rial

coating applications can come from

a variety of sources, including spent

paint, paint sludge, and paint filters.

Dirty thinner from the cleaning of

spray guns and paint cups, rags con-

taminated with cleaning or paint

materials, and unused coating prod-

ucts are other wastes. Inefficient

coating transfer operations and

equipment cleaning are major

sources of waste generat ion, and loss

of hazardous air pollutants (HAPs)

and volatile organic compoun ds

(VOCs) during the application and

drying processes may even cause

small businesses to be classified as

major sources of air pollution.

The potentially significant amount of

pollution generated from these and

other painting processes causes

indust rial coaters to fall under four

major categories of environmental

regulations affecting their opera-

tions: hazardous waste, air, water,

and r ight -to-know report ing.

Workplace safety must always be

considered as well. This section con-

tains br ief summar ies of these regu-

lations. A list of who to contact for

more information can be found at

the end of this publication.

Regulatory Issues

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Ignitable:The substance has a flashpoint

less than 140F.

Reactive:The material vigorously reacts with

air or water, has a t endency t o

explode, or produces toxic gases.

Toxic:It is deemed toxic according to

approved toxicity tests.

Businesses that paint or coat use

many materials in their work that

typically are h azardous waste when

they are no longer usable, and h ence

the businesses are generators of haz-ardous waste. Solvents in paints,

thinn ers, and cleanup solvents, as

well as metals in paints, may be

sources of hazardous waste.

Paint cans and used filters may be

classified as hazardous waste if the

paint is hazardous. Wet mater ials

may be classified as hazardous waste

because of their solvent content.

You, therefore, sh ould become famil-

iar with statutes and regulations that

apply to the handling and disposal of

hazardous wastes. It is your respon-

sibility to det ermine which of your

wastes are hazardous, and to ensure

that they are transported and dis-

posed according to the law. You maywant to read the Haz ardous Waste

Generator Handbook published by

KDHE for more information. You

may receive a free copy of the hand-

book by calling the SBEAP Resource

Center at 800-578-8898.

Definitions of Hazardous Waste

Tracking the movement of hazardous

wastes has become a cradle-to-

grave effort. The first step in proper

waste handling is to determine if the

waste is considered hazardous. EPA

has defined a waste as hazardous if it

has certain properties that could

pose danger to human health or the

environment. Waste is classified as

hazardous in on e of two ways, char-

acter istic or listed. First, a waste is

considered hazardous if it exhibits

one of the characteristics of a haz-

ardous waste; if it is corrosive,

ignitable, reactive, or toxic.

Waste Disposal Regulations

Corrosive:The pH of the substance is less

than or equal to 2, or greater

than or equal to 12.5.

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Paint and related solvent wastes

often display ignitable or toxic char -

acteristics. While oil- or solvent-

based paint wastes are usually

ignitable, some water-based paints

can also be ignitable because of the

drying agents they contain.3 These

wastes may also contain a regulated

metal pigmen t such as chromium or

lead.

Waste m ater ial can also be consid-

ered hazardous if it is on EPAs list ofhazardous wastes (F-list, K-list, P-

list, and U-list), found on pages 24

through 45 of the Hazardous Waste

Generator Handbook. Check your

material safety data sheets to see if

your paints, paint th inners, or clean-ers contain any of these wastes.

Common solvents in painting opera-

tions are classified as hazardous and

are found in the F001 to F005 waste

number categories (page 24).

Examples of such solvents includexylene, acetone, methan ol, meth yl

isobutyl ketone, toluene, methyl

ethyl ketone, and benzene, among

others.

Categories of Hazardous Waste

Generators

What generator class you are in is

dependent upon how much waste is

generated at your facility. In Kansas,

th ree classes existsmall quant ity,

Kansas, and EPA. You m ust det er-

mine your generator category to

determine which regulations apply

to you. Your facility may ch ange its

status from one category to another,

depending on how much waste it

generates in a given period.

In determining your status as a haz-

ardous waste generator, count all

quantities of hazardous waste that

you generate in a given month.

Reduce your quantity of hazardous

waste by separating hazardous waste

and non-hazardous waste. A mixture

of these two types of wastes m ust be

treated as hazardous.

3 Minnesota Pollution Control Agency, September

1997, Evaluatin g Paint and Ink Wastes

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Do not count wastes that

s are specifically exempt (page 3 of the Haz ardous Waste Generator

Handbook)

s may be left in the bottom of containers that have been completely emp-

tied by conventional means such as pouring and pumping.

Containers are considered empty if no more than one inch of residue

remains on th e bottom, or no more than th ree percent by weight of

the contents remain inside a container that is 110 gallons or less, or

no more than 0.3 percen t by weight of the conten ts remains inside a

container than is larger than 110 gallons. If the container contained aP-listed waste, it must be triple-rinsed before being considered empty.

s are managed in an elementary neutralizing unit, a totally enclosed treat-

ment unit, or a permitted wastewater treatment unit

s are legally allowed to be discharged directly to a publicly owned treat-

ment works (POTW)

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SQG's are required to handle haz-

ardous waste th ey generate in an

environmentally sound manner and

are not subject to any notification or

reporting requirements. Small quan-

tity generators may use any of the

following alternatives to handle their

hazardous wastes when disposed of

in quantities less than 55 pounds:

recycling, reuse, reclamat ion, dispos-

al at a permitted san itary landfill,

neut ralization and discharge to the

sanitary sewer only with permissionof the city and in conformance to

any applicable EPA pret reatmen t

requiremen ts, and disposal at a per-

mitted hazardous waste disposal

facility.

Small Quantity Generator

If the following criteria is met, the

state of Kansas considers you a small

quantity generator (SQG):

s The facility generates no

more than 55 lbs of haz-ardous waste, or no more

than 2.2 lbs of acutely haz-

ardous (P-listed) waste in a

calendar m onth.

s The facility accumulates nomore than 2,200 lbs of haz-

ardous waste or no m ore

than 2.2 lbs of acutely haz-

ardous waste, or no more

than 55 lbs of debris and con-

taminated materials from thecleanup of spillage of acutely

hazardous waste.

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However, when, as a small quantity

generator, you accumulate more

than 55 pounds, you must do the

following:

s Package, label, mark, and

placard all shipment s of haz-

ardous waste. All containers

of hazardous waste must be

marked with th e words

Hazardous Waste .

s Follow the dating and mark-

ing requirements for contain-

ers and tanks.

s Document weekly inspections

of hazardous waste storage

sites.

Small quan tities of hazardous waste

may NOT be disposed of by dum ping

on the surface of the ground or into

surface waters, burying in the

ground at an unperm itted site, or by

using wastes such as solvents for

killing weeds.

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Kansas Generator

Each of the following criteria must

be met to be considered a Kansas

generator:

Kansas generators must comply with

the following regulatory require-

ments:

a) Determine which wastes gener-

ated by the facility are haz-

ardous

b) Obtain an EPA ident ification

num ber by submitting a haz-

ardous waste notification form

to th e Kansas Department of

Health and Environment. (Thisform is available in Appen dix B

of the Hazardous Waste

Generator Handbook.)

c) Prepare a manifest for all ship-

ments of hazardous waste.Package, label, mark, and plac-

ard all shipments of hazardous

waste in accordance with pre-

transportation requirements.

(This form is can be found in

Appendix C of the HazardousWaste Generator Handbook.)

s The facility generates 55 lbs

or more of hazardous wastebut less than 2,200 lbs in a

calendar month , and the

facility does not generate 2.2

lbs or more of acutely haz-

ardous waste or 55 lbs or

more of debris and contami-nated mater ials from the

cleanup of spillage of acutely

hazardous waste.

s The facility accumulates no

more than 2,200 lbs of haz-ardous waste or 2.2 lbs of

acutely hazardous waste, and

no more than 55 lbs of debris

and contaminated materials

from the cleanup of spillage

of acutely hazardous waste.

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d) Prepare and maintain the fol-

lowing records for three years:

1) a signed copy of all manifests

initiated

2) manifest exception report(s)

3) hazardous waste analyses

4) weekly inspection reports

e) Meet all storage requiremen ts

for containers and/or tan ks.

f) Meet emergency preparedness

requirements.

g) Report all international ship-

ments of hazardous waste to the

Kansas Department of Health

and Environment and the

Environmental ProtectionAgency.

The above list is an abbreviated ver-

sion of compliance requirements.

For a complete listing of require-

men ts associated with hazardous

waste, please consult the Hazardous

Waste Generator Handbook, the

Kansas Statutes Annotated, Chapter

65Article 34, and the

Administrat ive Regulations, Art icle

31.

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EPA Generator

An EPA generator is one who fulfills

any one of the following:

EPA generators are subject to all reg-

ulations for Kansas generators,

except for th e emergency prepared-

ness requirem ent s, as well as the fol-

lowing additional requ iremen ts:

a) Provide a personnel training

program to ensure that facility

personnel are able to respond

effectively to a hazardous waste

emergency. The program must

include the following:

1) a director trained in haz-

ardous waste procedures

2) instruction which teaches

facility personnel about the

location of emergency

response and monitoring

equipment; maintenance and

operation of such equipment;

communications procedures

and response procedures for

fires, explosions, and con-

tamination incidents (train-

ing must be completed with-in six month s after the date

an employee enters a posi-

tion)

3) an ann ual review of the ini-

tial training

s The facility generates in an y

single month or accumulatesat any time 2,200 lbs or more

of hazardous waste, or gener-

ates in any single month or

accumulates at any time 2.2

lbs of acutely hazardous

waste.

s The facility generates or

accumulates at any time

more than 55 lbs of debris

and contaminated materials

from the cleanup of spillage

of acutely hazardous waste.

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47

5) an evacuation plan where

poten tial need for evacuat ion

exists

6) copies of the cont ingency

plan to be maintained at the

facility and submitted to the

local police departmen t, fire

department, hospital, and

emergency response team

7) a contingency plan that is to

be periodically reviewed and

current

The above list is an abbreviated ver-

sion of compliance requirements.

For a complete listing of require-

men ts associated with hazardous

waste, please consult the Hazardous

Waste Generator Handbook, the

Kansas Statutes Annotated, Chapter

65 Article 34, an d th e

Administrat ive Regulations, Art icle

31.

Shipping Wastes Off Site

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Shipping Wastes Off Site

The three most important things to

remember when shipping hazardous

wastes off site are

s Choosing a reputable haulerand facility with EPA ID num-

bers. If you have questions

about who to call to deter-

mine if they are reputable,

contact SBEAP at 800-578-

8898.s Packaging and labeling all

wastes appropr iately.

s Preparing hazardous waste

manifest.

You must ensure th at your trans-

porter an d waste facility meet appli-

cable state and federal regulations.

Disposal facilities must have permits

issued by EPA or the state in which

the facility is located. Under state

and federal law, you may only use

authorized hazardous waste tr ans-

porters an d disposal facilities that

have been assigned EPA identifica-

tion numbers.

The hauler you choose will transportyour waste, and the waste manage-

ment facility will be its final destina-

tion. But remember, you are still

responsible for th e wastes you pro-

duce.

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49

Air Regulations

With the enactment of the Clean Air

Act Amendments (CAAA) in 1990,

the way air emissions are regulated

was reorganized. One ch ange was

regulated hazardous air pollutants(HAPs). The current list of HAPs

contains 187 chemicals and can be

found on the internet at

w w w .epa.gov/ttn/atw /orig189.htm l.

Many paints contain significant

quantities of HAPs such as toluene,

xylene, methyl ethyl ketone (MEK),

or methyl isobutyl ketone (MIBK).

The amoun t of HAPs or volatile

organic compoun ds (VOCs) your

facility has the poten tial to release

or emit will determ ine if your busi-

ness is required to obtain an operat-

ing permit and/or comply with other

regulatory requiremen ts.

Air Operating Permits

In January 1995, the Kansas Depart-

ment of Health and Environment,

KDHE, adopted r egulations to imple-

ment provisions of the CAAA of

1990. The new clean air rules speci-

fy th ree differen t types of air operat-ing permits, depending on whether a

facility has the poten tial to emit

more than the above stated amount

of HAPs or VOCs, or if it falls under

specific air regulations or nat ional

emission standards for hazardous airpollutants (NESHAPs).

Major Sources

Painters and coaters are subject to

limits on their VOC and HAP emis-

sions from solvents used in paint s,

paint str ipping, or clean ing. Your

facility is defined as a major source

of air pollution if it has th e poten tial

to emit:

s 10 tons of any single HAP

s 25 tons of any combination

of HAPs

s 100 tons or m ore of any

other regulated air pollutant

in a single year. Such pollu-

tants include nitrous oxides,

sulfur oxides, par ticulate

matter less than 10 microns,

or VOCs.

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50

There are other regulated pollutan ts

that typically dont apply to coating

processes but may affect your facili-

ty if painting is only one part of your

total operation.

Class I Permits

The Class I operat ing permit is a sin-

gle document that contains all air

quality requirements your facility

has to meet. If your facility is

defined as a major source, then itwill need a Class I permit. As stated

above, Class I status is based on

your business poten tial to emit vari-

ous air pollutants.

Your potent ial to emit, or PTE, is

based on the maximum amount of

air pollution your facility would emit

if

The Class I permit application

process can be very involved, time

consuming, and expensive. Once

KDHE receives your application, it

has 60 days to determine whether it

is complete. Both the public and theU.S. Environmental Protect ion

Agency can part icipate in th e appli-

cation r eview process. Once issued,

your permit is good for five years,

and you will need to submit a renew-

al application at least six monthsbefore it expires.

s

each process unit is operatedat 100 percent of its physical

and operational design capac-

ity

s materials that emit the most

air pollutants are used 100

percent of the time

s all of the equipment is oper-

ating 24 hours per day, 365

days per year

s no pollution control equip-

men t is used

Class II Permits Class III Permits

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Class II Permits

If your facilitys actual emissions areless than t he m ajor source th resholds,

but the potential emissions still

exceed them , then your facility may

qualify for a Class II permit, which is

less expensive and time consuming to

complete than the Class I permit. TheClass II permit allows you to specify

how you will limit your poten tial

emissions to below the major source

threshold and thus avoid the n eed for

a Class I perm it.

The Class II permit application asks

for information KDHE needs to deter-

mine your facilitys potent ial-to-emit,

such as mater ial safety data sheets

and ch emical usage rates, and how

you will limit your potential to emit.Both the public an d EPA can review

the permits, in addition to KDHE.

Once issued, the permit r emains valid

with no required renewal unless it is

revoked or you are unable to limit

your potential emissions to below the

major source th resholds. Air emission

limits and material tracking require-

ments may be part of a Class II per-

mit. By June 1 of each year, you will

need to submit operating information,

such as material usage rates an d

MSDSs for the previous year, so KDHE

can recalculate your air emissions.

Class III Permits

The Class III permit is pr imarily aregistration form that needs to be

completed if you are not required to

obtain a Class I or Class II permit,

but are subject to a National

Emission Standard Hazardous Air

Pollutan ts (NESHAP), are located inJohnson or Wyandotte counties and

are subject to VOC regulations, have

an incinerator, or are subject to a

new source per formance standard

(NSPS). New sources required to

obtain a Class III permit have oneyear from star t-up to submit t heir

application.

Other Restrictions

Certain coun ties have additionalrestrictions. In Kansas, facilities in

Johnson an d Wyandotte count ies are

restr icted to using coatings with low

VOC content. Current regulations

mainly affect surface coating of mis-

cellaneous metal parts and productsand metal furn iture , at facilities with

have potent ial VOC emissions

greater than three tons per year. For

example, regulations limit the VOC

content to 3.5 poun ds per gallon for

coatings.

Air Construction Permits

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52

Air Construction Permits

and ApprovalsSo you are putting in a new paint

booth. Do you need a permit before

you begin con struction? Will you

need a perm it to operate your

booths now? During a pre-construc-

tion review, the Kansas Departm entof Health and Environment (KDHE)

ensures that proposed construct ion

projects at new facilities and modifi-

Pollutant Construction permit PTE thresholdLead 0.6 tons per year

PM10 15 tons per year

PM 25 tons per year

SOx 40 tons per year

VOC 40 tons per year

NOx 40 tons per year

CO 100 tons per year

HAPs (individual) 10 tons per year

HAPs (any combination) 25 tons per year

If you are not required to obtain aconstruction permit, you may need a

construction approval if you will be a

new or modified source an d

s you are subject to a New Source

Performance Standard (NSPS)

s your facility is subject to a maxi-

mum achievable cont rol technol-

ogy (MACT) standard or anational emission standard for

hazardous air pollutan ts

(NESHAP)

s your potent ial to emit (or your

increase in potential-to-emit)

equals or exceeds the followingthresholds

cations at existing facilities can meet

applicable Kansas and federal air

quality requirements.

You need a construction permit if

your potential to emit, or your

increase in potent ial to emit,exceeds the levels shown below, or if

the construction activity includes an

incinerator.

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Pollutant Construction approval PTE threshold

Lead or lead compounds 0.1 pounds per hour

SO2 or SO3 2 pounds per hour

PM10 2 pounds per hour

PM 5 pounds per hourNOx 50 pounds per 24 hours

CO 50 pounds per 24 hours

(In Wyandotte and Johnson count ies)

VOCs 3 pounds per hour

15 pounds per 24 hours

(Areas Except for Wyandotte and Johnson counties)

VOCs 50 pounds per 24 hours

The primary difference between a

construction permit and a construc-

tion approval is that t he permit

requires an application fee while the

approval does not. The fee is equiva-

lent to 0.05% of th e capital cost of

the proposed activity.

If you need to obtain an operating per-

mit or construct ion permit/approval

form, visit the KDHE Bureau of Air

and Radiat ions Web site at

w w w .kdhe.state.k s.us/bar/index .htm l,

or call SBEAP at 800-578-8898.

Do I Need an Air Permit for My Oven/Incinerator?

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First you need to decide wheth er th e

device you're using is classified as an

incinerator. If it uses a direct flame

and burns anything in addition to

paint hooks, it is an incinerator. If it

is an oven type, it still may be classi-

fied as an incinerator. If the device isclassified as an incinerator, you n eed

a permit. Otherwise, an individual

evaluation must be done to deter-

mine the types of air emissions, and

a potential-to-emit calculation must

be performed to determ ine wheth erthe oven exceeds any permitting

threshold.

If the incinerator has been approved

to burn non-hazardous paint filters,

you may use it for th at pu rpose. If it

hasn't been approved, you need to

request a modification to your per-

mit. Please note th at hazardous

waste paint filters can't be incinerat-ed without a hazardous waste tr eat-

ment, storage, and disposal facility

permit. If the paints used in your

business contain metals, there are

hazardous waste considerations as

well. Always review the materialsafety data sheets (MSDSs) for the

products you use. If you are baking

off paint hooks and have been using

a paint containing chromium, for

example, evaluate the residue metals

content.

Sample Calculation for Your Potential to Emit (PTE)

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A facility should conduct an emis-

sions inventory to know what kind

of permit is needed. Information on

calculating poten tial solvent emis-

sions, including solvent emissions

from painting and cleaning, follow.

Air emissions that r esult from evapo-

rat ion of solventssuch as those in

paints - can be calculated using a

material balance approach. What

comes in to th e facility is considered

to be emitted into the air. Theamount of volatile organic com-

pounds (VOCs) and hazardous air

pollutant s (HAPs) in each product

(such as coatings and solvents) can

be calculated and totaled for an

entire year. The potential to emit(PTE)what would be em itted if the

facility operat ed at maximum design

capacity, 24 hours a day, 365 days

per year, or 8760 hours per year -

can be calculated by multiplying

actual em issions of HAPs and VOCsby the rat io:

Actual emissions of HAPs and VOCscan be determined if you know the

total quantity of product used annu-

ally, density of the product, an d

weight percent of HAPs or VOCs.

This information will allow you to

calculate the amount of HAPs and

VOCs in the product.

The quan tity of product used can be

taken from purchasing records, pro-

vided you maintain an essentially

constant inventory. If you are dis-

posing of waste materials and have

records to show the am ount of HAPsor VOCs in the waste, that amount

can be subtracted from th e total

used since it was not emitted into

the air.

Typically, total density of the prod-uct can be found on the MSDS sheet.

Either the density will be specifically

listed as pounds per gallon, or it will

be given as specific gravity. If specif-

ic gravity is given, multiplying the

reported number by 8.3 pounds pergallon will give the density of the

product.

p ( )

(8760 hours) (actual operating hours)

density = (specif ic gravity) x (8.3 lbs/ gal)

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Wastewater Regulations

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Wastewater Regulations

The primary objective of the Clean

Water Act (CWA) is to restore an d

maintain the chemical, physical and

biological integrity of th e nations

surface waters. Pollutants regulated

under the CWA are classified as pri-

ority pollutant s. These include vari-

ous toxic pollutants; convent ional

pollutants, such as biochemical oxy-

gen demand (BOD), total suspended

solids (TSS), fecal ch loroform, oil

and grease, and pH; and non-con-ventional pollutant s, including any

pollutant not identified as either

convent ional or priority.

Under the Clean Water Act, point

sources of wastewater (dischargepipes or sewers) discharging to

waterways require a National

Pollutant Discharge Elimination

System (NPDES) permit. Permits,

issued by the Kansas Department of

Health and EnvironmentBureau ofWater, specify levels of toxicity and

other characteristics that must be

achieved pr ior to discharge. Some

businesses discharge wastewaters

from phosphating processes or

water fall paint booth units via their

NPDES permit. Treatment of the

wastewater is generally necessary.

Wastewater generated from coating

applications might be regulated

because of the presen ce of organic

solvents or heavy metals.

Use of wastewater treatment systems

which do not discharge or direct

waste to a POTW are also regulated

by KDHE. Wastewater ponds which

do not discharge are not regulatedunder the NPDES program but will

still require a Kansas water pollution

control permit. Wastewater ponds

which receive industrial waste have

special requirements regarding their

construction an d permitt ing. KDHEshould be consulted.

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Another type of discharge regulatedby the Clean Water Act is one that

goes to a publicly owned treatm ent

works (POTW). The nat ional pre-

treatm ent program controls the indi-

rect discharge of pollutant s to

POTWs by industr ial users.Facilities regulated under this pro-

gram must meet certain pretreat-

ment standards. Recent rules require

facilities that utilize the phosphating

process and discharge to a POTW be

permitted due specifically to th istype of discharge. If discharging to a

POTW, contact KDHE to determine

the applicability of pretreatment

requirements and permitting

requirements.

The goal of the pretr eatmen t pro-

gram is

s to protect municipal wastewater

treatm ent plants from dam age

that can occur when hazardous,

toxic, or other wastes are dis-charged into a sewer system

s to protect the quality of sludge

generat ed by these plants

Directing industr ial waste to a septic

tank is prohibited. Contact KDHE orSBEAP if you have questions.

Reduced water use is the primarywaste reduction option for phospha-

tizing. Water needed to maintain the

bath solution can be reduced by

monitoring temperature, chemical

concentration, and the pH level. Re-

use solution or rinse water from onebath to others when possible. What

is your source of water? Is it deion-

ized or tap water? City water can

bring in considerable amounts of dis-

solved solids, and these contaminants

can vary seasonally. Properly match-ing the phosphating chemicals with

the metal substrate is another key

issue in minimizing waste from phos-