United States Federal Facilities Enforcement EPA 300-B-96-009B
Environmental Protection Office (2261A) May 1996
AgHH
Pollution Prevention and
the Clean Air Act:
Benefits and Opportunities
Federal Facilities - Volu
Part I Cleaning and Degreasing
Part II Painting and Depainting
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Table of Contents
Executive Summary i
Introduction 1
Part I Cleaning and Degreasing
Chapter 1 Cleaning- and Degreasing-Specific Environmental Factors 5
Cleaning and Degreasing Process 5
Environmental Factors 6
Chapter 2 Cleaning and Degreasing Solvents and the Clean Air Act 7
Clean Air Act Programs 7
-ControlofVOCs 7
- Control of HAPs 10
- Control of ODCs 11
- Reporting to TRI 11
Requirements for Solvent Cleaning and Degreasing 12
- VOCs Limitations 12
- HAP Rules 13
- Halogenated Solvent Cleaning 13
- Aerospace Manufacturing and Rework Facilities 14
- Control of ODCs 15
Living with the Clean Air Act 15
Chapter 3 Pollution Prevention Opportunities in
Cleaning and Degreasing 17
Information Sources 17
Pollution Prevention Alternatives in Cleaning and Degreasing 18
Partn Painting and Depainting
Chapter 4 Painting- and Depainting-Specific Environmental Factors 31
Painting 31
-Environmental Factors 31
Depainting 32
-Environmental Factors 32
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Chapter 5 Painting and Depainting Solvents and the Clean Air Act 35
Clean Air Act Programs 35
- Control of VOCs * 35
- Control of HAPs 38
- Control of ODCs 38
- Reporting to TRI 39
Requirements for Painting Operations 40
-VOC limitations 40
-RACT 40
- NSPSs 40
- HAP Rules 41
-Aerospace Manufacturing and Rework Facilities 43
-Shipbuilding and Ship Repair 43
-Wood Furniture Manufacturing 44
Requirements for Depainting Operation 45
-Aerospace Manufacturing and Rework Facilities 46
Living with the Clean Air Act 46
Chapter 6 Pollution Prevention Opportunities in Painting 49
Information Sources 49
Pollution Prevention Alternatives in Painting 49
Chapter 7 Pollution Prevention Opportunities in Depainting 57
Information Sources 57
Pollution Prevention Alternatives in Depainting 57
Appendix A Information Sources on Pollution Prevention
Appendix B Composite SNAP Program Alternatives Listings for Cleaning and Degreasing
Appendix C Solvent Information Data Systems
Appendix D Example Limits for VOCs from Surface Coating Operations
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List of Tables
Parti Cleaning and Degreasing
Table 1 Solvent Categories and Applicability of the Clean Air Act
and Toxic Release Inventory Reporting Requirements 8
Table 2 Prevention Technologies for Cleaning and Degreasing 20
Table 3 Prevention Technologies for Cleaning
and Degreasing: Benefits and Limitations 21
Table 4 Examples of Pollution Prevention Opportunities for
Cleaning/degreasing for Clean Air Act Compliance 23
Part II Painting and Depainting
Table 5 Applicability of the Clean Air Act and Toxic Release Inventory
Reporting Requirements to Painting and Depainting Solvents 36
Table 6 Available Application Technologies for Painting SO
Table 7 Available Paint Coating Formulations 53
Table 8 Examples of Pollution Prevention Opportunities for
Painting for Clean Air Act Compliance 54
Table 9 Prevention Technologies for Coating Removal 59
Table 10 Prevention Technologies for Coating
Removal: Benefits and Limitations 62
Table 11 Examples of Pollution Prevention Opportunities
for Paint Removal for Clean Air Act Compliance 68
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EXECUTIVE SUMMARY
Federal facilities are under increased scrutiny to control their use of chemical solvents to
meet requirements under the Clean Air Act. Opportunities exist to move away from the use of
regulated solvents through the use of pollution preventative approaches.
Several programs established under the Clean Air Act limit the use of solvents. These
programs are intended to control:
• Volatile Organic Compounds (VOCs) which react in the atmosphere and
contribute to ground level ozone formation. A National Ambient Air Quality
Standard (NAAQS) has been set to protect public health from ozone. This
standard is exceeded in major urban areas (Los Angeles, Houston, etc.) and in
extended geographic areas (Northeast Corridor). States are required to control
VOC emissions in these areas. Cleaning and degreasing processes and painting
and depainting activities are traditionally major users of VOCs.
• Hazardous Air Pollutants (HAPs), listed substances with potentially significant
health effects. HAP air emissions are to be reduced through the application of
Maximum Achievable Control Technology (MACT) standards to major stationary
sources. MACT standards have been set for cleaning and degreasing and for
painting and depainting in the aerospace industry. MACT standards have also
been set for cleaning and degreasing processes using halogenated solvents.
Additional MACT standards have been proposed for painting and depainting
activities in the shipbuilding and ship repair, and wood furniture manufacturing
industries.
• Ozone Depleting Chemicals (ODCs) which react in the stratosphere and destroy
the ozone layer. The production and use of the most significant ODCs, the Class 1
chemicals, is to end by January 1,1996. ODCs are used in cleaning and
degreasing processes. They have had limited use in painting formulations.
These programs create limits which can be met through the use of control equipment, or through
the use of alternative processes and substitute materials or pollution prevention.
Federal facilities have the opportunity to investigate pollution preventative approaches
when developing strategies to comply with the requirements of the Clean Air Act. Examples
include:
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• Replacing vapor degreasers and cold cleaners with aqueous cleaning systems;
• Converting to powder coatings from conventional solvent-based spray coatings;
• Using media blasting instead of chemical-based paint strippers.
In these examples, the applicability of the Clean Air Act is eliminated including the
associated compliance demonstration burdens for monitoring, recordkeeping, and reporting.
Eliminating emissions means the elimination of emission fees. Potential additional benefits include
reduced material costs, elimination of worker exposure to solvents, reduced expenses for
protecting workers, elimination of hazardous waste streams, and potential labor savings.
This report provides information on the applicability of specific Clean Air Act
requirements to these processes and identifies sources of information on pollution prevention
opportunities. Pollution prevention examples are identified. Federal facilities are encouraged to
investigate the pollution preventative approaches available for complying with the Clean Air Act
requirements for cleaning and degreasing and for painting and depainting activities.
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INTRODUCTION
This is the second of two reports that form a pilot effort to provide information to
environmental management personnel at Federal facilities to assist in their decision making
process on how to comply with the Clean Air Act. The first report, "Pollution Prevention and the
Clean Air Act: Benefits and Opportunities for Federal Facilities," provides an overview of the
breadth and scope of programs established under the Clean Air Act and describes how Federal
facilities can incorporate pollution prevention approaches into compliance decision making.This
report summarizes the applicability of the Clean Air Act as it applies to cleaning and degreasing
activities in Part I, and to painting and depainting activities in Part n. Cleaning and degreasing
and painting and depainting processes are the focus of this report because they traditionally rely
on the use of organic solvents. Opportunities exist to move away from the use of organic
solvents through pollution preventative approaches.
The mission of Federal facilities often requires the use of processes which lead to waste
generation. The fabrication, maintenance and repair of mechanical and electrical equipment are
routine processes at Federal sites. These processes typically include cleaning and degreasing and
parinting and depainting steps that can produce air emissions that must be managed under the
Clean Air Act. This report profiles how the Clean Air Act regulates these operations, and more
importantly, how pollution preventative approaches to complying with Clean Air Act
requirements can lead to reduced costs and material consumption rates, improved workplace
environments, and potentially eliminate the applicability of Clean Air Act requirements altogether.
Investing in alternatives that reduce or eliminate waste generation can make life more tolerable
under the Clean Air Act.
EPA has defined pollution prevention as "source reduction" consistent with the Pollution
Prevention Act. Pollution preventative approaches are those activities which reduce the
generation of waste at the source. This includes changes in raw materials, operating practices and
processes which result in the reduced use or the reduced release of toxic materials. The Pollution
Prevention Act established a "waste management hierarchy" with a clear first preference for
pollution prevention or source reduction. Under this hierarchy, if source reduction options are
not available, then consideration should be given to environmentally sound recycling of waste. If
pollution prevention and recycling are not feasible, then treatment options followed by safe
disposal should be considered as the least desirable choice for waste management. This report
focuses on the opportunities for the preferred option, source reduction.
In many instances cleaning and degreasing and painting and depainting processes depend
on the use of organic solvents, many of which are receiving considerable attention by
environmental programs, including those of the Clean Air Act. Volatile Organic Compounds
(VOCs), Hazardous Air Pollutants (HAPS), and Ozone Depleting Compounds (ODCs) are
regulatory terms for chemicals whose use is limited by the Clean Air Act. In many settings,
facilities are taking steps to get out from under the regulatory burdens associated with these
substances through the implementation of pollution preventative alternatives. These alternatives
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allow process operators to achieve the same endpoint, but without the use of these targeted
compounds. By eliminating the use of these regulated materials, the need to consider the use of
control systems and to continually demonstrate compliance with applicable requirements are also
eliminated. Significant savings of time and resources can be achieved by reducing permitting,
monitoring, recordkeeping, and reporting compliance burdens associated with Clean Air Act
limitations.
There are no "cookbook" approaches to implementing pollution prevention. Every
operation has unique needs; careful consideration is required. For degreasing and cleaning,
consideration must be given to the nature of the substrate to be cleaned, potential contaminants,
and the degree of cleanliness required for the next processing step. In some instances, the need to
clean altogether can be eliminated using no-clean production technologies. For painting and
depainting, consideration must be given to the properties of the specific substrate and the
requirements for the coating used. This report provides information sources to assist Federal
facilities in their investigation of preventative alternatives to meet Clean Air Act requirements.
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Part I Cleaning and Degreasing
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CHAPTER 1
CLEANING- AND DEGREASING- SPECIFIC
ENVIRONMENTAL FACTORS
CLEANING AND DEGREASING PROCESS
Cleaning and degreasing processes remove from surfaces undesirable materials which
might interfere with the further processing or appearance of a substrate or part. Common
contaminants include oil, grease, dirt, dusts, and processing aids. Processing aids include cutting
fluids, fluxes, and polishing compounds. Solvents are typically used to clean these surfaces in
combination with a variety of cleaning technologies. The choice of solvent and cleaning
technology is a function of the characteristics of the substrate to be cleaned, the contaminant to be
removed, and the performance or cleanliness expectations.
Cleaning and degreasing processes are generally characterized by whether the solvent
cleans as a liquid or as a vapor, and by the type of process: spot or wipe cleaning, batch
operation, or a continuous, in-line, process.
The term "cold cleaning" refers to processes where solvent, as a liquid, contacts the part's
surface to clean. Cold cleaning can be spot, batch, or continuous. Cold cleaners operate below
the solvent's boiling point temperature, typically slightly above room temperature. Cold cleaners
range from simple dip tanks to automated washing machines operating much like a household
dishwasher. The solvent in cold cleaners dissolves and/or mechanically removes the impurities.
"Vapor degreasing", on the other hand, relies on vapor contact with the surface to be
cleaned. The liquid solvent is heated above its boiling point to generate a vapor phase. The parts
are suspended in this vapor phase. The vapor condenses on the part's surface and drips back into
the boiling liquid carrying the impurities with it. Vapor degrcasers operate as batch processes, in
heated, open tanks, such as an open top vapor degreaser, or as a continuous process, such as a
conveyorized cleaning unit.
Cleaning solvents are chosen based on consideration of available cleaning equipment,
compatibility of solvents to the substrate for cleaning, the effectiveness of the solvent in attacking
the impurities of concern, and the degree of cleaning required. The integrity of the substrate must
not be altered by the cleaning solvent. Environmental considerations such as the Clean Air Act
requirements are also impacting the selection of cleaning technologies and solvents.
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ENVIRONMENTAL FACTORS
Emissions from cleaning operations are a concern to workers operating the equipment and
to the ambient air in the community. Some cleaning solvents are flammable, potentially explosive
and their use requires special precautions to protect the health and safety of workers. Many
solvents used in cleaning and degreasing processes are also regulated by the Occupational Safety
and Health Administration to limit exposure to workers. Their use also leads to the generation of
hazardous wastes.
Solvent vapors can escape cleaning units as a fugitive release into the workplace and out
building vents into the environment. To protect workers in cleaning and degreasing activities,
engineering controls such as local exhaust ventilation systems can be necessary to reduce solvent
concentration levels. Personal protective equipment, such as gloves and respirators, may also be
necessary for some chemicals and cleaning technologies. The use of personal protective
equipment necessitates proper training of workers on how to use the equipment, such as proper
fitting of respirators or selection of glove material, and maintenance of the equipment Pollution
preventative approaches can eliminate the use of solvents of concern and lessen the need for these
added controls and requirements to protect workers.
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CHAPTER 2
CLEANING AND DEGREASING SOLVENTS
AND THE CLEAN AIR ACT
A variety of solvents have been used in cleaning and degreasing: halogenated solvents,
aromatic compounds, alcohols, etc. Solvents in each of these categories have been the subject of
regulations under the Clean Air Act - as VOCs, HAPs, and ODCs. The requirements under Clean
Air Act programs which control the use of these solvents continue to evolve. The development of
pollution preventative techniques for these processes is in part driven by the opportunity to meet
the same process needs but without dependence on compounds regulated under the Clean Air
Act. Using regulated compounds not only brings the burden of controlling their use, but also the
need to obtain permits, pay emission fees and continually demonstrate compliance through
monitoring, testing, reporting and recordkeeping. This chapter describes how solvents in each of
these processes are regulated.
CLEAN AIR ACT PROGRAMS
Table 1 shows the primary solvent categories and some of the dominant solvents used in
each category. The specific Clean Air Act programs which limit the use of these solvents are also
identified by the chemical regulatory category. Many of these solvents are also subject to
reporting releases and waste generation to the Toxic Release Inventory (TRI) under the
Emergency Response and Community Right-to-Know Act (EPCRA). For Federal facilities, the
TRI will be the measure of progress in meeting the pollution prevention planning requirements of
Executive Order 128S6. Table 1 indicates the applicability of the TRI program to these solvents
as well.
Control of VOCs
VOCs are regulated under the Clean Air Act because they react in the atmosphere with
nitrogen oxides and produce ground level ozone. A VOC is considered any organic compound
that will react in the atmosphere. This includes all organic compounds except a list of "exempt"
solvents (methane, ethane and several halogenated solvents) with negligible reactivity in the
atmosphere. An ambient Air Quality Standard (NAAQS) for ozone was been established under
Title I of the Clean Air Act to protect public health. Emissions of VOCs and nitrogen oxides are
to be reduced in geographic areas not meeting this ambient standard, the so called "non-
attainment areas."
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TABLE1
APPLICABILITY OF THE CLEAN AIR ACT AND TOXIC RELEASE INVENTORY
REPORTING REQUIREMENTS TO CLEANING AND DEGREASING SOLVENTS
Solvent Cateeory/Example
Clean Air Act
Applicability
TRI
VOC
HAP
ODC
CHLOROFLUOROCARBONS (CFCs)
CFC-113
Class I
X
HYDROCHLOROFLUOROCARBONS (HCFCs)
HCFC-225
1 | Class n
X
HALOGENATED SOLVENTS
Methyl Chloroform
(1.1.1 Trichloroethane)
X
Class I
X
Carbon Tetrachloride
X
Class I
X
Methylene Chloride
X
X
Perchloroethvlene
X'
X
X
Trichloroethylene
X
X
KETONES
Methyl Ethyl Ketone
X
X
X
Methyl Isobutyl Ketone
X
X
X
Acetone2
1
ALCOH
OLS
Methanol
X
X
Ethanol
X
Isonrooanol
X
fferchkxioethylenc wu proposed for exclution from the definition of a VOC (1(1/26/92,57 FR 48490). No further action hM been taken on
this proposed change to dale.
'Acetone ww excluded bom the definition of a VOC (6/16/95, 60FR31633); Acetone was alio removed tan the TRI fat (6/16/95,
60PR31643).
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TABLE 1 — continued
Solvent Category/Example
Gean Air Ac
Applicability
t
TRI
VOC
HAP
ODC
AROMATIC HYDROCARBONS
Toluene
X
X
X
Xylene
X
X
X
ALD
'HATIC HYDROCARBO
NS
Mineral Spirits
X
Naptha
X
OTHER CATEGORIES AND COM]
POUNDS
N-Methyl Pyrrolidone
X
Glycol Ethers
X
X'
X2
Terpenes
X
VOC - Volatile Organic Compound, regulated under the non-attainment provisions of Title I of the Gean Air Act
HAP - Hazardous Air Pollutant, regulated under the air toxics provisions of Title in of the Gean Air Act
ODC - Ozone Depleting Compound, regulated under the stratospheric ozone protection provisions of Title VI of the
Clean Air Act
TRI - Toxic Release Inventory; annual reporting of releases to the environment required for TRI chemicals under the
Emergency Response and Community Right-to-Know Act (EPCRA).
k Ikxh the Hip and TRI lin identify Glycol Etben at a chemical category for thoae Olycol Ethen which ate derivttves of Mono-, Di-, or Tri-
Ethylene Glycol. Ethylene Olycol is alio lifted as an individual compound on both lira.
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States are required to develop air quality management plans or State Implementation Plans
(SIPs) to achieve the NAAQSs in these non-attainment areas. These SIPs include requirements
for the application of "reasonably available control technology" (RACT) to reduce emissions from
VOC sources in the non-attainment areas.
EPA provides guidance to States on RACT through "Control Technique Guidelines
(CTGs) CTGs identify control approaches for VOC processes which are considered technically
and economically feasible for facilities to implement States generally implement RACT through
rules which are State adopted and federally approved. These rules apply to industrial and
commercial processes which emit VOC emissions. Most states' RACT rules include requirements
for cleaning and degreasing processes.
The Clean Air Act also provides for the control of VOCs (and other pollutants) through
the development of New Source Performance Standards (NSPSs) for new or modified equipment.
These standards are developed for individual source categories, and reflect best available control
technology at the time the standard was set. An NSPS has been proposed for use of non-
halogenated solvents in immersion, cold cleaning machines to limit VOC emissions. (September 9,
1994,59FR46602).
Pnntral of HAPS
Title HI of the 1990 Amendment to the Clean Air Act lists 189 chemicals (some are
chemical categories) that are considered significant threats to public health. These chemicals and
chemical categories are known as the hazardous air pollutants or HAPS. EPA is required to
establish standards for categories of major sources emitting these chemicals which represent the
mayimiim achievable control technology (MACT) for that operation. Major sources have the
potential to emit 10 tons or more of an individual HAP or 25 tons or more of all HAPs in
aggregate. These requirements apply to both new and existing sources. Major source categories
have been identified and a ten year program through the year 2000 was initiated to develop
MACT standards for these sources. Smaller sources of these pollutants may also be regulated
through less stringent control requirements. If EPA fails to develop standards in accordance with
the 10 year plan, States must control sources in their jurisdiction using case-by-case determination
of MACT.
The Title m MACT standard program schedule will be difficult to meet; EPA's limited
resources have lead to delays in developing some of the early MACT standards. State programs
are likely to be required to develop MACT standards for some source categories in their
jurisdiction. Source categories identified which require the development of MACT standards
include cleaning and degreasing.
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Control of ODCs
The Montreal Protocol, an international agreement phasing out ozone depleting
substances, lead to the inclusion of Tide VI of the Clean Air Act in the 1990 Amendments. The
United States is committed to an accelerated phase out of the production and use of ozone
depleting chemicals (ODCs). Federal agencies, through Executive Order 12843 (issued April 21,
1993) are encouraged to accelerate replacement of ODCs with safe alternatives and abide by the
requirements of Title VI. Many US industries have established company goals to expedite the
elimination of their use of ODCs.
The CAA defines ODCs in two groups, Class I, and Class II. Class I substances have the
greatest ozone depleting potential. They include chlorofluorcarbons (CFCs), halons, methyl
chloroform and carbon tetrachloride. Class II substances are hydrochlorofluorocarbons (HCFCs).
For the U.S., the phaseout deadline for the production of Class I chemicals was set at January 1,
1996 (12/10/93,58 FR 65018). The phaseout of Class II chemicals is required by January 1,
2015. As shown on Table 1, ODCs are used in degreasing and cleaning processes.
Procedures to implement Title VI of the CAA include the Significant New Alternatives
Program (SNAP). The SNAP process reviews and lists acceptable and unacceptable substitutes
for Class I and Class II substances. Use of substitutes may be authorized with use limitations.
Rulemaking will be required when the use is restricted or unacceptable. EPA has prepared initial
lists for known potential substitutes. Manufacturers of new substitutes must file a SNAP notice
to EPA for approval and listing of new substitutes.
The listings are based on EPA's review of available information and determination whether
the use of the substitute may present adverse effects to human health or the environment. The
initial list of acceptable and unacceptable substitutes was published with the SNAP rule on March
18.1994 (59 FR 13044). These lists were updated on August 26,1994 (59 FR 44240), January
13.1995 (60FR3318), June 13,1995 (60FR31092), and July 28,1995 (60FR38729)! EPA
anticipates quarterly additions and annual updates of the entire list.
Reporting to TRI
Reporting to the Toxic Release Inventory (TRI) is required for many of the solvents
identified in Table 1. The TRI was created by the Emergency Planning and Community Right-to-
Know Act of 1986 (EPCRA, also referred to as Title m, Superfimd Amendments and Reauthor-
ization Act (SARA)). Regulations for the TRI are at 40 CFR 372. The TRI requires submittal of
annual reports on the releases and offsite transfers of over six hundred listed chemicals and
chemical categories. The thresholds for reporting are 25,000 pounds manufactured and/or
processed and 10,000 pounds otherwise used for each chemical listed. The 1990 Pollution
Prevention Act (PPA) expanded the TRI reporting requirements to include information on waste
generation and the use of source reduction and recycling to limit waste generation. A "Form R" is
used for reporting. For 1987 through 1993 reporting was required for over three hundred
chemicals and chemical categories. EPA then added 32 chemicals and 2 chemical categories to
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the list of TRI substances, requiring reporting for the first time for calendar year 1994 (12/1/93,
58FR63496 and 58FR63500). An additional 286 chemicals were added for the 1995 calendar
year reporting requirements (11/30/94,59FR61432), bringing the number of listed chemicals to
over 600.
Federal facilities must file TRI reports. Executive Order 12856 (dated August 3,1993)
established a pollution prevention planning process for Federal facilities, requiring all Federal
facilities to comply with EPCRA. Initial reporting was required for the 1994 calendar year. The
TRI reports will serve as the accounting system for demonstrating compliance with the pollution
prevention goals established in EO 12856. With the 1994 reports, each federal facility defined
their baseline release levels. They now must develop their pollution prevention strategy or facility
plan to reduce these reported levels. The initial 1994 reports were due to EPA by July 1,1995.
Subsequent reports must be filed by the following July 1. The facility plans are due on December
31,1995. The EO requires each Agency to achieve a 50 percent reduction in reported TRI
releases in aggregate for all of their facilities by 1999. Implementation of individual facility plans
are expected to collectively provide the necessary reductions in waste generation to achieve each
agency's goals.
For many facilities, the chemicals in Table 1 will be major contributors to their baseline
levels. Therefore, identifying preventative approaches to meeting Clean Air Act requirements will
also benefit the development of pollution prevention plans and meeting their Agency's goals.
REQUIREMENTS FOR SOLVENT CLEANING AND DEGREASING
VOC Limitations
Many of the solvents used for cleaning and degreasing are VOCs (see Table 1) targeted
for control. An estimated 33 States have regulated VOC solvent use in cleaning and degreasing.
Many of the State regulations are patterned after an EPA CTG, "Control of Volatile Organic
Emissions from Solvent Metal Cleaning" (EPA-450/2-77-022, November 1977), which recom-
mended limits for VOC emissions.
State regulations generally apply to cold cleaning, vapor degreasing and conveyorized
degreasing processes. The provisions are based on design and operating requirements, rather than
emission limits, because of the difficulty in measuring emissions. The specific requirements in
each State's regulation will have some different features. They may include applicability criteria
based on minimum surface area of the cleaning unit (such as 10 square feet for cold cleaning
units) or the physical/chemical property of the cleaning solvent (such as vapor pressure of 0.3 psi
at 100°F). The tbrust of these State regulations are summarized below.
r"ltl The regulation of VOCs from cold cleaners is generally based on
design and operating requirements. Typical provisions require the use of a cover
for the coldcleaning unit during periods of non-use, and facilities to prpvide for
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draining parts prior to removal from unit. The addition of control equipment (for
example, a carbon adsorption system) may be required if the solvent is heated.
Vapor Decreasing. Design and operating requirements include covers which
open only for parts entry or exit from the unit to limit the spread of vapors; "free-
board" minimum, that is the height above the vapor to the lip of the unit must
equal or exceed, for example, 0.75 times the width of the unit; refrigerated
condenser coils in the unit lid to recover vapors; or control systems to collect
vapors such as a carbon adsorption system.
Convevorized Degreasers. Facilities to minimize carry-out of solvent with parts
by rotating parts in baskets and allowing sufficient time for drainage; vapor
recovery through the use of chilled coils or capture and collection with a carbon
adsorption system; and covers for the exit and entrance of the unit when not in use.
The purpose of these provisions is to limit the generation of solvent vapors, thereby controlling
emissions. Add-on controls can be applied if the same degree of control can be demonstrated.
Examples of pollution preventative approaches which eliminate the use of VOCs for many
cleaning and degreasing requirements will be presented in Chapter 5.
HAP Rules
Several halogenated solvents used in cleaning processes and are listed have HAPs in the
CAA (see Table 1). "Halogenated Solvent Cleaning" was listed as a category targeted for
development of control limitations as required by the CAA (7/16/92,57 FR 31592). On
December 2,1994 a MACT standard applicable to halogenated solvent cleaning was published by
EPA (59FR 61805). A correction to this standard was published on June 5,1995 (60FR29484).
"Aerospace Manufacturing and Rework Facilities" was also listed as a major source
category. A MACT standard was published for this category on September 1,1995
(60FR45948), which includes requirements for solvent cleaning and degreasing.
Halogenated Solvent Cleaning
The MACT standard controls the use of halogenated solvents in cleaning machines which
are batch vapor phase units (such as open top vapor cleaners), and in-line (continuous) units
based on cold or vapor phase cleaning. A separate standard was set for batch cold cleaners which
requires covers and a water layer over the solvent The majority of batch cold cleaning units do
not use halogenated solvents. Halogenated solvent use in cold cleaners is believed to be limited to
the use of methylene chloride in carburetor cleaning units.
The halogenated solvent MACT standard provides three options for the control of batch
vapor and in-line cleaning units. Compliance with the standard can be demonstrated by meeting
one of three sets of requirements:
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a. Stringent equipment design and operating practices with monitoring,
recordkeeping and worker training to substantiate their use; or,
b. Minimum equipment design and operating requirements and an emission limitation
based on the surface area of the cleaning unit determined by a proposed reference
test method; or,
c. A three month rolling average limitation on solvent loss per unit surface area of the
cleaning unit based on material balance through record keeping for quantities
solvent added and removed from unit and specified calculation procedures.
The standard offers an array of options for the equipment design and operating require-
ments, each with a related set of monitoring requirements. These include consideration of
freeboard ratio, cover designs, and freeboard refrigeration. Existing facilities must comply with
this standard by December 2,1997. New or modified facilities must meet this standard upon
startup. For more detailed information on this MAC standard the reader is referred to the report
"Guidance Document for the Halogenated Solvent Cleaner NESHAP" (EPA-453/R-94-081) and
the published rule.
Aerospace Manufacturing and Rewnrk Facilities
The MACT standard for the aerospace industry applies to new and existing commercial,
civil and military manufacturing and rework facilities. The standard addresses a number of
aerospace processes which may use HAPs including surface coating, depainting, and cleaning
activities.
Cleaning activities covered by the standard include HAP solvent use in hand wipe, spray
gun and flush cleaning operations. The standard establishes housekeeping requirements intended
to limit HAP emissions from the storage of solvents and solvent laden cleaning materials including
the use of containers which are designed to close and contain vapors. Solvent handling and
transfer procedures designed to limit the potential for spills are also required.
Solvents used in hand-wipe cleaning must meet certain criteria. They either must be an
aqueous formulation (at least 80 percent water), a hydrocarbon formulation containing no HAPs
or ODCs with a vapor pressure of less than 7 mm Hg at 20°C, or any cleaning formulation with a
vapor pressure less than 45 mm Hg at 20°C. Determination and recordkeeping of the cleaning
solvents' constituents and their vapor pressures is required.
For spray gun cleaning, several options are provided to contain vapors during cleaning
including the use of closeable cleaning units and cleaning solvent receiving vessels. Work
practices are included for flush cleaning of parts and coating unit components. The standard
exempts a number of specific cleaning operations from the hand-wipe criteria such as cleaning
electronic components or surfaces prior to adhesive bonding. For more detailed information on
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this rule, the reader is referred to the Final Rule and the Background Information Document
(EPA-453/R-94-036a).
Control of ODCs
CFC-113 and methyl chloroform are two Class I substances which have been widely used
in cleaning and degreasing activities. Federal facilities should be in a process to identify and begin
the use of suitable substitutes prior to the January 1,1996 phaseout deadline.
Several Class II chemicals, and particularly HCFC-225, are being pursued as alternatives
to serve in many of the same functions and applications as CFC-113 and methyl chloroform. The
use of HCFC-225 has been proposed as an acceptable substitute, subject to use limitations, for
CFC-113 and methyl chloroform (9/26/94,59FR49108). Appendix B includes a composite listing
of the approved alternatives for degreasing and cleaning from the SNAP publications.
LIVING WITH THE CLEAN AIR ACT
Regulatory programs created by the Clean Air Act impact directly on the use of solvents
in cleaning and degreasing activities. Once control requirements are established, permitting and
compliance demonstration requirements follow. Given the scope of the Clean Air Act mandate
and its direction and focus on chemical substances, research and development in the area will
continue to evolve. Greater pressure for reductions in VOCs is expected in geographic areas
having difficulty achieving the ozone non-attainment standards (Los Angeles, Northeast
Corridor). The use of HAPS will be increasingly regulated in the coming years. The termination
of production of Class I substances is on the near horizon with Class II substances following in
the not too distant future. It is reasonable to expect a continuing tightening down on the use of
chemical solvents.
For Federal facilities, environmental performance will be more visible as a result of
Executive Order 128S6. The required reporting on chemical releases to the Toxic Release
Inventory and the development of facility plans for reducing these releases will be open to public
scrutiny.
The use of organic solvents in cleaning and degreasing processes has been the target of
activities by government, industry and environmental organizations to identify and encourage the
use of pollution prevention alternatives. Pollution preventative approaches have been developed
and implemented in many industrial scenarios. They can serve as models for Federal facilities,
helping them not only to meet or exceed potential Clean Air Act requirements, but to reduce costs
for materials, waste disposal, reporting, and recordkeeping. In addition, implementation of
pollution preventative approaches help in reducing potential liabilities from waste generation and
exposure to workers.
15
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The remainder of this report presents information on pollution prevention alternatives for
the processes under review. A large part of the pollution prevention effort has been in the pursuit
of the "safer substitute." Given the emphasis on safer substitutes, this report focuses on potential
substitute materials and processes for current processes using HAPs, ODCs and VOCs. Safer can
mean different things to different decision makers. Generally it means the use of less regulated
and less hazardous compounds, providing benefits such as reduced solvent losses and exposure to
workers, and lessened concern for worker safety, flammability, and waste management require-
ments.
16
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CHAPTER 3
POLLUTION PREVENTION OPPORTUNITIES
IN CLEANING AND DEGREASING
INFORMATION SOURCES
The search for alternatives to the use of ODCs, HAPs, and VOCs for cleaning and
degreasing has lead to the development of several reports on alternatives to these chemicals. A
listing of many of these reports and who to contact to obtain them is presented in Appendix A.
Included in Appendix A are the contact points for key EPA information sources including:
• Enviro$ense - is an electronic bullentin board providing access to a wide array of
environmental and pollution prevention information as well as professionals active
in the environmental management area. Enviro$ense is accessible by modem and
the World Wide Web on the Internet.
• Technology Transfer Network - TTN is a bulletin board system on Clean Air Act
programs operated by the Office of Air Quality Planning and Standards (OAQPS).
TTN provides access to the latest documents on supporting policy, technical and
rulemaking activities and is accessible by modem.
• Pollution Prevention Information Clearinghouse - PPIC provides access to
materials developed by EPA and State pollution prevention program activities.
• Stratospheric Ozone Hotline - provides policy, technical, and rulemaking
information on the phase out of ozone depleting compounds.
These sources provide useful information on all technical and regulatory activities related
to the Clean Air Act and pollution prevention.
Some recent reports which are particularly useful in the investigation of cleaning and
degreasing alternatives include:
• Solvents - The Alternatives - provides a summary of key factors to consider
when investigating solvent substitutes including a lists of suppliers of aqueous and
semi-aqueous cleaners and equipment suppliers (prepared by Bob Carter of the
Waste Reduction Resource Center for the Southeast (800-476-8686), P.O. Box
27687,3825 Barrett Drive Raleigh, NC 27611-7687).
Guide to Cleaner Technologies: Alternatives to Chlorinated Solvents for
Cleaning and Degreasing (2/94, EPA/625/R-93/016) - outlines the different
17
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cleaning and degreasing requirements, identifies current and emerging cleaning
alternatives (prepared by EPA's National Risk Management Research Laboratory
(fonnerly The Risk Reduction Engineering Laboratory), Cincinnati, Ohio 45268).
irHwwingHnp ryryi 13 «nd Mpthvl Chloroform in Aircraft Maintenance
(10/93, EPA/430/B-93/006) - identifies alternatives and suppliers of
substitutes and alternative cleaning equipment (prepared by EPA and the Industry
Cooperative of Ozone Layer Protection (ICOLP).
The investigation of alternative solvents can be facilitated by comparative data on
solvents. Several data systems have been developed to provide assistance in the selection of
alternative solvents. To use these systems, the user must know the characteristics about the
substrate and soil to be cleaned. Systems identified include:
• SAGE - "Solvent Alternatives Guide" - Developed by EPA's Office of Research
and Development as an on-line tool to assist in making educated decisions on
alternative solvents providing information on costs, secondary impacts and use
requirements (Contact Mr. Charles Darvin (919-541-7633), National Risk
Management Research Laboratory (MD-61), ORD, EPA, RTP, NC 27711). Also
accessible through Enviro$ense.
• Hsspfi. "Hazardous Solvent Substitution Data System" - developed by the
Department of Energy's Idaho National Engineering Laboratory; on-line system
that provides a full array of technical data on individual solvents (Contact Kevin
Twitchell (208-526-6956), Idaho National Engineering Laboratory, P.O. Box
1625, Mailstop 1604, Idaho Falls, ID 83415-1604).
. NCMS SflYfllt Tl«tabase - developed by the National Center for Manufacturing
Sciences to provide information on alternatives to ozone depleting solvents
(contact Mike Wixom (313-995-4910), National Center for Manufacturing
Sciences, 3025 Boardwalk, Ann Arbor, MI 48108-3266)
More information on each of these data systems is presented in Appendix C.
POLLUTION PREVENTION ALTERNATIVES IN CLEANING
AND DEGREASING
Investigating alternatives to replace the use of a CFC, HAP or VOC requires information
on the substrate, soil, and cleanliness needs and expectations. Generic fixes are not generally
available but rather case specific information must be considered in the context of available
alternatives. A number of prevention technologies are available for cleaning and degreasing which
eliminate the need for HAPS, ODCs, and VOCs in many situations. Table 2 identifies several
technologies and their reported applications as alternatives to organic solvent systems.
18
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comparison purposes, similar information is presented on controlling a solvent-based, vapor
degreaser. Information on the benefits and limitations to each of these alternatives is presented in
Table 3. Much of the information in Table 2, and 3 was adapted from the EPA report described
above, Guide to Cleaner Technologies; Alternatives to Chlorinated Solvent* for rimming
and Degreasing (2/94, EPA/625/R-93/016). The reader is referred to this report for more
information on each of these alternatives.
Clean Air Act emission requirements can be achieved by controlling organic solvent based
systems, such as enclosing a vapor degreaser, as shown in Table 3. However, the choice of a
preventative technologies, i.e., aqueous cleaner, eliminates use of organic solvents and
applicability of the Clean Air Act requirements altogether. Demonstrating compliance on a
continuous basis through monitoring, reporting and recordkeeping will no longer be necessary for
these technologies.
Several examples of alternative technologies implemented to meet Clean Air Act require-
ments are shown in Table 4. More information on these examples can be found in the listed
references. These examples illustrate some of the benefits that have been realized through the
implementation of pollution preventative approaches as a result of individual facilities efforts to
move away from the use of regulated compounds. In many of these cases, these facilities could
have been faced with significant expenses to control VOC or HAP emissions. However, in these
examples they found solutions to their cleaning and degreasing needs which resulted in cost
savings and elimination of the burden of demonstrating compliance with Clean Air Act
requirements.
19
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TABLE2
PREVENTION TECHNOLOGIES FOR CLEANING AND DEGREASING
TechmloKr
Reported Application
Waste Products
and Emissions
Example Capital Costs
Automated Aqueous
Cleaning
Cleaning of small parts.
Spent cleaning solution.
$180,000 approximately for a unit with 1,000 lb/hr
processing speed for steel parts.
Aqueous Power Washing
Cleaning of large and small parts.
Spent cleaning solution.
$12,000 approximately for 1,000 lb capacity,
4* x 4'chamber.
Ultrasonic Cleaning
Cleaning of ceramic, aluminum, plastic, and
metal parts, electronics, glassware, wire,
cable, rods.
Spent cleaning solution.
Approximately $10,000 for console w/ 25" x 18" x
15" chamber.
Low-Solids Fluxes
Soldering in the electronic industry.
No waste products.
No additional capital cost
Inert Atmosphere Soldering
Soldering in the electronics industry.
No waste products.
Varies widely.
Conqjfetely Enclosed Vapor
Cleaner
Same as conventional open-top vapor
degreasers.
Solvent air losses.
Spent solvent.
Water in water separator.
Approximately $200,000 for a unit with 560 lb/hr
processing speed for steel parts.
Adapted from; Guide to Cleaner Technologies: Cleaning and Dcgrcasing Process Changes (2/94; EPA/625/R-93-017).
20
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TABLE3
PREVENTION TECHNOLOGIES FOR CLEANING AND DEGREASING: BENEFITS AND LIMITATIONS
TecfanoiocT
Pollution Prevention
Benefits
Other Benefits
Limitations
Automated Aqueous
Cleaning
Eliminates solvent use by using
water-based cleaners.
Eliminates use of ODCs, HAPs, and VOCs.
Eliminates solvent hazards.
Reduces water consumption.
Cleaning chemicals are reused.
Easy to install and operate.
Eliminates emission fees and compliance demonstration
requirements for monitoring, recordkeeping, and
reporting.
May not be able to replace vapor de-
greasing for some delicate parts.
Requires more space than vapor de-
greasing.
Wastewater treatment required.
Relatively higher energy requirement.
Aqueous Power
Washing
Eliminates solvent use by using
water-based cleaners.
Eliminates use of ODCs, HAPs, and VOCs.
Eliminates solvent hazards.
Reduces cleaning time.
Eliminates emission fees and compliance demonstration
requirements for monitoring, recordkeeping, and
repotting.
Pressure and temperature may be too great for
some parts.
Wastewater treatment required.
Ultrasonic Cleaning
Eliminates solvent use by
making aqueous cleaners more
effective.
Eliminates use of ODCs, HAPs, and VOCs.
Eliminates solvent hazards.
Can clean in small crevices.
Cost effective.
Faster than conventional methods.
Inorganics are removed.
Neutral or biodegradable detergents can often be
employed.
Eliminates emission fees and compliance demonstration
requirements for monitoring, recordkeeping, and
rcooftins.
Part must be immersible.
Testing must be done to obtain optimum
solution and cavitation levels for each
operation.
Thick oils and grease may absorb ultra-sonic
energy.
Energy required usually limits parts sizes.
Wastewater treatment required if aqueous
cleaners are used.
21
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TABLE 3 - continued
Tcdmoioey
Pollution Prevention
Benefits
Other Benefits
Limitations
Low-Solids Fluxes
Eliminates need for cleaning and,
therefore, eliminates solvent use.
Eliminates use of ODCs, HAPs, and VOCs.
Eliminates solvent hazards.
Little or no residue remains after soldering.
Closed system prevents alcohol evaporation and water
absorption.
Eliminates emission fees and compliance demonstration
requirements for monitoring, recordkeeping, and
reporting.
Conventional fluxes are more tolerant of
minor variations in process parameters.
Possible startup or conversion
difficulties.
Even minimal residues are unacceptable in
many military specifications.
Inert Atmosphere
Soldering
Eliminates need for flux and,
therefore, eliminates solvent
cleaning.
Eliminates use of ODCs, HAPs, and VOCs.
Eliminates solvent hazards.
Economic benefits from elimination of flux.
Eliminates emission fees and compliance demonstration
requirements for monitoring, recordkeeping, and
reporting.
Requires greater control of operating pa-
rameters.
Temperature profile for teflow expected to
play more important role in final results.
Completely Enclosed
Vapor Cleaner
Reduces solvent air emissions.
Can provide for compliance with VOC and HAP
regulations.
Virtually eliminates air emissions and workplace hazards.
Cleaning principle remains the same; user does not have
to switch to aqueous cleaning.
Significant recovery of solvent
Reduced operating costs.
High initial capital cost
Slower processing time.
Relatively higher energy requirement.
Monitoring, recordkeeping and reporting
required to demonstrate continuous compli-
ance.
Operating permit may be required.
Residual emissions subject to emission
fees.
Adapted from: Guide to Qeaner Technologies: Cleaning and Degreasing Process Changes (2/94; EPA/625/R-93-017)
22
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TABLE4
EXAMPLES OF POLLUTION PREVENTION OPPORTUNITIES FOR
CLEANING/DEGREASING FOR CLEAN AIR ACT COMPLIANCE
Process
(Ref#)
Pollution Prevention Opportunities
Cost
Benefit
Compliance1
Benefits
Other Issues
Automated
Aqueous
Parts
Washing
(Ref 1)
Quality Rolling and Deburring Company, Inc.,
metal finishing company, added an automated
aqueous washer to provide cleaning needs for
plant expansion. Also replaced some plant
' cleaning done by vapor degreasing, alkaline
tumbling, and hand aqueous cleaning. Chemical
costs for the automated washer were 40% lower
compared to alkaline tumbling and 95% lower
compared to hand-aqueous washing.
$60,000
annual sav-
ings
Allowed for plant
growth in VOC
non-attainment
area
Reduced quantity
of cleaning chemi-
cals required
Reduced waste-
water generated
High initial investment,
$200,000 was quickly
offset by annual
savings
Vapor degreaser still
used for delicate parts
Hand washing still used
for difficult cleaning
jobs
Batch
Aqueous
Power
Washer
(Ref 1)
The Seattle Metro Garage in Seattle, Washington
uses an aqueous power washer to clean parts
removed during overhaul and maintenance. The
unit eliminates the need for solvent to clean parts.
Discharges from the unit pass through an
oil/water separator and then to the sanitary sewer
system.
Eliminated
cost of
solvent
Eliminated organic
solvent use
Eliminated hazard-
ous waste genera-
tion
Investigating smaller
system for car and
truck parts
23
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TABLE 4 — continued
Process
(Ref#)
Pollution Prevention Opportunities
Cost
Benefit
Compliance1
Benefits
Other Issues
Aqueous
Ultrasonic
Cleaning
Process
(Ref 2)
The Ross Gear Division of TRW in Greenville,
Tennessee replaced trichloroethylene (TCE)
vapor degreaser for removing lapping oils from
parts with three stage aqueous (alkaline) process
utilizing an ultrasonic cleaning step. Reduced
overall plant hazardous waste by 50% and
decreased disposal costs. TRW replaced a vapor
degreasing system on one of their processes with
a three-stage aqueous/ultrasonic system washer.
Prior to the washer, the process, which removes
oil-based lapping compound from parts, generated
14,090 lb of TCE still bottoms, 3,740 lb of
filtration powder, and 50,300 lb of fugitive and
stack emissions in one year. In addition, the plant
recently switched to a water-based lapping
solution.
Eliminated
cost of TCE
Eliminated use of
TCE
Eliminated genera-
tion of hazardous
waste from clean-
ing process
Installed ultrafiltration
system to separate
nonhazardous oil from
wastewater sent to
sanitary sewer
No-Clean
Technology
.
(Ref 2)
AT&T Bell Labs in Columbus, Ohio converted to
a low-solids flux cleaning system in 1988. With
this system, the plant has eliminated post-solder
cleaning and the use of 30,000 gallons of
perchloroethylene (PERC) annually.
$145,000
annual sav-
ings
Eliminated use of
PERC
Eliminated genera-
tion of hazardous
waste from process
24
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TABLE 4 — continued
Process
(Ref#)
Pollution Prevention Opportunities
Cost
Benefit
Compliance1
Benefits
Other Issues
Semi-Aqu-
eous
Batch
Cleaning
Process
(Ref 2)
Four Star Tool, Inc. of Rosemont, Illinois
replaced a manual cold cleaning process using
trichloroethylene (TCE) by installing a four step
semi-aqueous process using d-limonene. The
switch allows the plant to eliminate use of 20
drums of TCE and save $5,805 per year in solvent
costs.
$5,805
annual sav-
ings
Eliminated use of
TCE
Oily material is
skimmed from spent
cleaner which is dis-
charged to sanitary
sewer
Semi-A-
queous
Batch
Cleaning
System
(Ref 3)
APS Materials, Inc. of Dayton, Ohio cleans
specialty cobalt/molybdenum and titanium parts
prior to application of a plasma coating. APS
replaced 1,1,1 .trichloroethane and methanol in
their heated, batch ultrasonic degreasing operation
with a terpene-based cleaner, limonene. A re-
quired capital cost of $1,793, with pay back of 4.5
months and annual savings of $4,800.
$4,800
Eliminated use of
1,1,1, and meth-
anol
Eliminated haz-
ardous waste from
cleaning process
Bonding strengths of
coatings slightly im-
proved with new
cleaning formulation
LowVOC
Wipe
Solvent
(Ref 4)
The Lockheed Fort Worth Company developed a
low vapor pressure organic solvent for CFC-113
based cleaning solvent used in surface wiping of
aircraft parts, components, and assemblies. As a
result, the plant reduced CFC emissions by 100%,
VOC emissions by 75%, and solvent costs by
87%
Reduced
costs by 87%
Eliminated use of
CFCs in wipe
cleaning
Significant reduc-
tion in VOC
generation
Effective at removing a
variety of soils
including inks, oils
greases, waxes, and un-
cured resins
Reported as having low
toxicity and non-
flammable
25
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TABLE 4 - continued
Process
(Ref#)
Pollution Prevention Opportunities
Cost
Benefit
Compliance1
Benefits
Other Issues
Aqueous
Degreasing
System
(Ref 5)
Font Motor Company's Climate Control Division
is replacing their current trichloroethylene (TCE)
vapor degreasing system with an aqueous
degreasing system. Their pilot system resulted in
a superior process, lower costs, improved plant
environment, and reduced environmental impact
Eliminated
cost of TCE
Elimination of use
of TCE
Reduced hazardous
waste generation
Used Total Quality
Management approach
to investigate alter-
natives
Process will be used
Division wide
Automated
Aqueous
Cleaning
System
(Ref 6)
The Naval Undersea Warfare Station in
Keyport, Washington is replacing their Agitene
(mineral spirits and lanolin) dip tanks for cleaning
parts and fuel tanks with automatic parts washers
which using biodegradable cleaners: water/dete-
rgent in an agitator washer system or an ultrasonic
cleaner. Initial equipment costs would be recov-
ered quickly due to decreased costs of labor, haz-
ardous waste disposal, and purchase of cleaning
solvents.
Reduced use of
Agitene and VOC
generation
1 Elimination of regulated compound also provides reduced compliance demonstration expenses for monitoring, recordkeeping and reporting.
Regulatory liabilities are also reduced.
26
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TABLE 4 - continued
REFERENCES FOR POLLUTION PREVENTION EXAMPLES
1. United States Environmental Protection Agency, Office of Research and Development.
"Guide to Cleaner Technologies, Cleaning and Degreasing Process Changes." Publication
No. EPA/625/R-93/017, Washington, DC. February 1994.
2. United States Environmental Protection Agency, Office of Research and Development.
"Achievements in Source Reduction and Recycling for Ten Industries in the United
States." Publication No. EPA/600/2-91/051, Washington, DC. September 1991.
3. United States Environmental Protection Agency, Office of Research and Development.
"Pollution Prevention Case Studies Compendium." Publication No. EPA/600/R-92/046,
Washington, DC. April 1992.
4. United States Environmental Protection Agency, Office of Air and Radiation. "Eliminat-
ing CFC-113 and Methyl Chloroform in Aircraft Maintenance Procedures." Publication
No. EPA/430/B-93/006, Washington, DC. October 1993.
5. President's Commission on Environmental Quality, Quality Environmental Management
Subcommittee. "Total Quality Management, A Framework for Pollution Prevention."
Washington, DC. January 1993 (report available through US Council on Environmental
Quality).
6. United States Environmental Protection Agency, Office of Research and Development.
"Waste Minimization Opportunity Assessment, Naval Undersea Warfare Engineering
, Station, Keyport, Washington." NTIS Publication No. PB91-216457, Cincinnati, OH.
July 1991.
27
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Part II Painting and Depainting
-------
CHAPTER 4
PAINTING- AND DEPAINTING-SPECIFIC ENVIRONMENTAL FACTORS
PAINTING
Painting or surface coating involves the use of a full array of coatings and coating application
technologies for application on a variety of shapes and surfaces. Coatings are applied to enhance
corrosion resistance, improve appearance, or provide both these benefits. Surface shapes may be flat,
cylindrical, round or multifaceted. Surface materials may be wood, metal, ceramic, fabric, plastic or a
variety of composite materials. The coatings may be Applied by hand or by machine using a variety of
application techniques: brush, roller, dip, flow, and spray techniques.
Several spray application techniques exist including conventional air spray, airless, air-assisted
airless, electrostatic, and high-volume low-pressure (HVLP) spray. The effectiveness of a spray system
in applying coating to a particular surface is characterized by its "transfer efficiency." The greater the
transfer efficiency, the greater the portion of the coating that is sprayed ends up on the surface.
Overspray represents the coating that is sprayed, but does not reach or adhere to the intended surface.
Coating formulations contain a number of components including resins (body of the coating),
pigments (for color), application additives (flow control), drying additives (curing and film control
agents) and solvents. Solvents serve as vehicles or carriers for the coating ingredients. Some coatings
dry on their own, like latex house paint, or require the assistance of heat (drying ovens) or energy
(radiation-cured coatings). Multiple coating layers may be applied to meet the end objective. Coatings
are characterized as conventional solvent-based, waterborne, high solids, radiation-cured, and powder
coatings.
Environmental Factors
Toxic or hazardous concerns can be associated with materials used in any of the coating
components. Solvents, however, have received the most attention under the Gean Air Act. They are
released from the coating during application, drying and curing. Solvents can make up a few percent to
over 90 percent of the coating formulation. Once the coating is diy, all of the solvent in the coating
formulation has been released to the air.
Workers must be protected from the coating solvent vapors; many are regulated compounds
under the Occupational Safety and Health Act. The released solvent vapors can be captured using
exhaust ventilation systems on both the application process (paint booth) and the drying process (drying
oven). The exhaust air can be released to the ambient air or sent to an air pollution control device.
Air releases of coating components other than solvents occur only with spray application
technologies. The sprayed coating which ends up as overspray can become suspended in air. Spray
31
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operations typically control overspray with exhaust ventilation systems to protect workers and limit
contamination of the work area. These systems collect and filter the air carrying the overspray particles.
Particle filters will collect the overspray but not the solvent vapors.
Pollution prevention technologies can reduce or eliminate the use of solvents in coatings. For
spray applications, they can improve the transfer efficiency. These techniques can lead to improved
worker protection and Clean Air Act compliance.
DEPAINTING
Depainting or paint stripping is required in many painting, maintenance and repair operations.
Paint application equipment must be cleaned to remove paint buildup which might interfere with its
operation. Equipment with defective or worn coatings may require coating removal prior to application
of a new coating. Repair and inspection activities may also require coating removal.
Several approaches to depainting are available. They rely on chemical, mechanical and/or fhrrmq]
processes to remove the coating. The most common approaches utilize a chemical solvent stripper, such
as those based on methylene chloride, or a blasting agent like sand or plastic media to mechanically
remove the coating.
Chemical solvent strippers either dissolve the coating or penetrate and swell it to separate it from
the surface. The stripper is spread on the coated surface and given time to work. The weakened coating
is then removed with the residual stripper by scraping or flushing with water. The spent paint stripper
and paint sludge must be collected and disposed of. The chemical solvent stripper must be effective in
removing the coating, but must not impact the integrity of the surface being stripped.
Blasting techniques spray a blasting agent repeatedly onto the coated surface, cracking and
abrading the surface of the coating. The blasting agents can be separated from the coating fragments and
recycled until they deteriorate and become ineffective. The blasting continues until there are no remnants
of the coating. Care must be taken in selecting the blasting agent. The blastipg agent must be abrasive to
the coating but not the underlying substrate.
Environmental Factors
The use of chemical solvent strippers produces solvent vapors and a waste stream containing
spent stripper, dissolved coating, water and possibly metals. The vapors and waste stream are generally
considered hazardous. The solvency requirements for a chemical stripper maka about any solvent
selected hazardous for workers to handle in stripping operations. Methylene chloride, for example the
most popular ingredient in chemical strippers, has significant toxicity concerns requiring great care in
handling. It is listed as a Hazardous Air Pollutant (HAP) and its use is regulated in the workplace under
the Occupational Safety and Health Act. Many other stripping formulations have chemical ingredients
which require equal care in their use. The waste sludge from chemical stripping operations can require
32
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handling as a hazardous waste. Chemical strippers tend to be very effective. However, the degree of
caution required to safely use them is one of the reasons alternative approaches are sought for depainting.
The use of blasting technologies can generate dust from coating fragments and deteriorating
blasting media. Workers must be protected from this dust, particularly if the coating itself contains
hazardous constituents, such as medalized pigments. Although spent blasting media is typically not
considered hazardous, the collected paint fragments may require treatment as a hazardous waste.
33
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CHAPTER 5
PAINTING AND DEPAINTING: SOLVENTS AND THE CLEAN AIR ACT
A variety of solvents have been used for painting and depainting: halogenated solvents, aromatic
compounds, alcohols, etc. Solvents in each of these categories have been the subject of regulations under
the Clean Air Act - as VOCs, HAPs, and/or ODCs. The requirements under Clean Air Act programs
which control the use of these solvents continue to evolve. The development of pollution preventative
techniques for these processes is in part driven by the opportunity to meet the same needs but without
depending on compounds regulated under the Clean Air Act. Using regulated compounds not only brings
the burden of controlling their use, but also the need to obtain permits, pay emission fees and continually
demonstrate compliance through monitoring, testing, reporting and recordkeeping. This chapter
describes how solvents in each of these processes are currently regulated.
CLEAN AIR ACT PROGRAMS
Table 5 shows the primary solvent categories and some of the dominant solvents used in each
category. The specific Clean Air Act programs which limit the use of these solvents are also identified by
the chemical regulatory category. Many of these solvents are also subject to reporting releases and waste
generation to the Toxic Release Inventory (TRI) under the Emergency Response and Community Right-
to-Know Act (EPCRA). For Federal facilities, the TRI will be the measure of progress in meeting the
pollution prevention planning requirements of Executive Order 12856. Table 5 indicates the applicability
of the TRI program to these solvents as well.
Control nf VOCs
VOCs are regulated under the Clean Air Act because they react in the atmosphere with nitrogen
oxides to produce ground level ozone. A VOC is considered any organic compound that will react in the
atmosphere. This includes all organic compounds except for certain "exempt" solvents (methane, ethane
and several halogenated solvents) with negligible reactivity in the atmosphere. A list of these exempt
solvents is located in 40 CFR Part 51.1. An ambient Air Quality Standani (NAAQS) for ozone was been
established under Title I of the Clean Air Act to protect public health. Emissions of VOCs and nitrogen
oxides are to be reduced in geographic areas not meeting this ambient standard, the so called "nonattain- •
ment areas." States are required to develop air quality management plans, or State Implementation Plans
(SIPs) to achieve the NAAQSs in non-attainment areas.
35
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TABLE5
APPLICABILITY OF THE CLEAN AIR ACT AND TOXIC RELEASE INVENTORY REPORTING REQUIREMENTS TO
PAINTING AND DEPAINTING SOLVENTS
Solvent Catetonr/Ewnpie
Process Area
Clean Air Act
Applicability
TRI
Palatine
Depalntins
VOC
HAP
ODC
HALOGENATED SOLVENTS
Methyl Chloroform
(1,1,1 Trichlorocthane)
X
X
Class I
X
Methylene Chloride
X
X
X
X
KETONES
Methyl Ethyl Ketone
X
X
X
X
X
Methyl Isobutyl Ketone
X
X
X
X
Acetone1
X
X
ALCOHOLS
Methanol
X
X
X
X
Ethanol
X
X
Isopropanol
X
X
AROMATIC HYDROCARBONS
Toluene
X
X
X
X
X
1 Acetoae m roMwl from te defioUiuu of a VOC {6l\6/95.60FR31633); Acetone was «bo removed bom the TR1 list 60FR31643)
36
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TABLE 5 — continued
Solvent Category/Example
Process Area
Clean Air Act
ADDHcabQtty
TRI
Paintint
Depalnting
VOC
HAP
ODC
Xylene
X
X
X
X
X
ALIPHATIC HYDROCARBONS
Mineral Spirits
X
X
X
Naptha
X
X
X
OTHER CATEGORIES AND COMPOUNDS
N-Methyl Pyrrolidone
X
X
Glycol Ethers
X
X
X
X
X1
Terpenes
X
X
VOC- Volatile Organic Compound, regulated under the non-attainment provisions of Title I of the Clean Air Act
HAP - Hazardous Air Pollutant, regulated under die air toxics provisions of Title in of die Clean Air Act
ODC - Ozone Depleting Compound, regulated under the stratospheric ozone protection provisions of Title VI of the Clean Air Act
TRI - Toxic Release Inventory; annual reporting of releases to the environment required for TRI chemicals under die Emergency Response and Community Right-to-Know
Act(EFCRA).
1 Bodi the HAP and TRI Hstx identify Glycol Ethers as ¦ t hemic «l category for those Glycol Ethen which are derivirtues of Mono-, Di-, or Tri-Ethylene Glycol. Ethylene Glycol is also listed as an
*• • -• — -
MMBWOMH COropOUM OB POOI BHf.
37
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iw SIPs in-'"'" requirements for the application of "reasonably available control technology-
(RACT)torcduce emissions from VOC sources in the non-attanment areas.
EPA provides guidance to States on RACT through "Control Technique GuideliMS (CTGs)
^ f/flrvnr nrocesses control approaches that are considered technically and economically
S^tefedBties to implement. States generally implement RACT through rules which are State
md Meratty approved. These rules apply to industrial and commercial processes which emu
V^ri"t1LS' RACT ru.es .nclude rcquircments forpamtag presses.
The Clean Air Act also provides for the control of VOCs (and other poButants) through the
J , Source Performance Standards (NSPSs) for new or modified sources. These
developed for individual source categories, such as metal furniture coating and reflect ben
Insectology at «he toe the standard was set Several NSPSs have been developed for
surface coating operations which limit VOC emissions.
fnntral of HAPS
Title rn of the Clean Air Act lists 189 chemicals (some are chemical categories) that are
rnn-:J . threats to public health. These chemicals and chemical categories are know as
considered sigmn an reauired to establish standards for categories of major sources
™Ston Major sources have the potential to emit 10 tons or more of an individual HAP or 25 tons or
HA* rugate. These requirements apply to both new and existing sourcesLMajor
"°"°frnf-^ S identified and a ten year program extending through the year 2000 w»
ta^tKopMACT standards for these sources. Smaller sources of these polluttnts may also be
»^dttoS«saringent control requirements. If EPA fails to develop standards in accordance
wm loT^ pto. States must control sources in their jurisdiction usmg case-by-case determmttions
of MACT.
The Title m MACT standard program schedule will be difficult to meet; EPA's limited rraojuws
h»ve leadto dSavsindeveloping some of the early MACT standards. State programs Me likely to be
have lead to delay sundards for jo™- source categories in their jurisdiction. Source categories
wS£|^ the development of MACT standards include punting and depainting.
flfffltfftl "f flDCS
The Montreal Protocol, an international agreement phasing out ozone depleting substances, lead
u ¦ V VI of the Clean Air Act. The United States is committed to an accelerated phase
«0 te.nclus.on Of Tide VI of (ODCs). Federal agencies, through
? . 12843 (issued April 21,1993) are encouraged to accelerate replacement of ODCs with
abide by the requte^uof Title VL M-ar US industries have estabUsbed
company goals to expedite the eltminatica of their use of ODCs.
38
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The CAA defines ODCs in two groups, Class I, and Class n. Class I substances have the greatest
ozone depleting potential. They include chlorofluorcarbons (CFCs), halons, methyl chloroform and
carbon tetrachloride. Class II substances are hydrochlorofluorocarbons (HCFCs). For the U.S., the
phaseout deadline for the production of Class I chemicals was set for January 1,1996 (12/10/93,58 FR
6S018). The phaseout of Class II chemicals is required by January 1,201S. As shown in Table 5, ODCs
are not typically used in painting and depainting. However, methyl chloroform has been found in some
paint formulations.
Reporting tn TRI
Reporting to the Toxic Release Inventoiy (TRI) is required for many of the solvents identified in
Table 5. The TRI was created by the Emergency Planning and Community Right-to-Know Act of 1986
(EPCRA, also referred to as Title m, Superfund Amendments and Reauthorization Act (SARA)).
Regulations for the TRI can be found in 40 CFR Part 372. The TRI requires submittal of annual reports
on the releases and offsite transfers of over six hundred chemicals and chemical categories. The thresh-
olds for reporting are 25,000 pounds manufactured and/or processed and 10,000 pounds otherwise used
for each chemical listed. The 1990 Pollution Prevention Act (PPA) expanded the TRI reporting
requirements to include information on waste generation and the use of source reduction and recycling to
limit waste generation. A "Form Rn is used for reporting. For 1987 through 1993, reporting was
required for over three hundred chemicals and chemical categories. EPA then added 32 chemicals and 2
chemical categories to the list of TRI substances, requiring first time reporting for calendar year 1994
(12/1/93,58FR63496 and 58FR63500). An additional 286 chemicals were added for the 1995 calendar
year reporting requirements (11/30/94,59FR61432), bringing the number of listed chemicals to over 600.
Federal facilities must file TRI reports. Executive Order 12856 (dated August 3,1993)
established a pollution prevention planning process for Federal facilities, requiring all Federal facilities to
comply with EPCRA. Initial reporting was required for the 1994 calendar year. The TRI reports will
serve as the accounting system for demonstrating compliance with the pollution prevention goals
established in EO 12856. With the 1994 reports, each federal facility defined their baseline release levels.
They now must develop their pollution prevention strategy to reduce these reported levels. The initial
1994 reports were due to EPA by July 1,1995. Subsequent reports must be filed by the following July 1.
The facility plans are due on December 31,1995. The EO requires each Agency to achieve a 50 per cent
reduction in reported TRI releases in aggregate for all of their facilities by 1999. Implementation of
individual facility plans are expected to collectively provide the necessary reductions in waste generation
to achieve each agency's goals.
For many facilities, the chemicals in Table 5 will be major contributors to their baseline levels.
Therefore, identifying preventative approaches to meeting Clean Air Act requirements will also benefit
the development of pollution prevention plans and meeting their Agency's goals.
39
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REQUIREMENTS FOR PAINTING OPERATIONS
VOr T-imitations
Painting operations use a wide array of solvents which are VOCs. VOCs have been regulated
through RACT requirements for existing sources in SIPs and for new sources through New Source
Performance Standards (NSPS).
RACE
Many states have established VOC limits for surface coating operations. These requirements are
based on the RACT guidance in CTGs published by EPA. These CTGs addressed surface coating of
cans, coils, paper, fabric, motor vehicles, metal furniture, magnet wire insulation, large appliances, flat
wood paneling, and metal parts and products. The development of MACT standards has resulted in the
initiation of new CTGs addressing VOC controls for several MACT source categories including coating
operations in the aerospace, plastic parts, shipbuilding and wood furniture manufacturing industries.
State RACT W'tntinns for VOCs from surface coating operations are generally expressed in
terms of mass of VOC per unit volume of coating. The unit volume of the coating is adjusted to account
for the use of non-VOC diluents by subtracting the volume of water or exempt solvents (i.e., halogenated
solvents which are not considered VOCs, see Table 5). Coatings which meet these limits are termed
"compliant coatings." Compliance can also be achieved through the use of add-on control technologies
and improvements in transfer efficiency provided the equivalent degree of control can be demonstrated.
RACT limits may also be expressed in terms mass of VOC per unit of surface area coated (pounds of
VOC per square foot of paneling coated) or mass of VOC per volume of coating solids applied. Applied
generally solids reaching the substrate. The reader is referred to the appropriate State rules to
determine the VOC limits applicable to specific coating operations. Examples of VOC limits are present-
ed in Appendix D (taken from p«cnrdkeeping Guidance Document for Surface Coating Operations ^
th* printing Industry 7/89, EPA 340/1-88-003).
Demonstrating compliance with VOC limits can require recordkeeping on the amount of specific
mating formulations and any solvent diluents used on a daily basis. Eliminating the use of VOCs in
surfy coating operations would also eliminate this recordkeeping burden.
NSPSs
New source performance standards (NSPSs) have also been published for a number of surface
coating operations. These requirements apply to new or modified coating operations only, those
constructed after the effective date of the applicable rule. NSPS are published in Part 60 of Title 40 of
the Code of Federal Regulations. Surface coating NSPS's apply to new coating lines for
• Metal Furniture - Subpart EE (47 FR 49287,10/29/82)
• Automobile and Light Duty Truck - Subpart MM (45 FR 85415,12/24/80)
40
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MACT Mqjor Source Categories
for Surface Coating Operations
Scheduled Publication
Date
Aerospace Industry
September 1,1995
Final Rule Published
Auto and Light Duty Truck
November, 2000
Flatwood Paneling
November, 2000
Large Appliance
November, 2000
Magnetic Tape
December 15,1995
Final Rule Published
Metal Can
November, 2000
Metal Coil
November, 2000
Metal Furniture
November, 2000
Misc. Metal Parts and Products
November, 2000
Paper and Other Webs
November, 2000
Plastic Parts and Products
November, 2000
Fabrics
November, 2000
Shipbuilding and Repair
December 6,1994
Proposed Rule Published
Wood Furniture
December 6,1994
Proposed Rule Published
The aerospace, shipbuilding and wood furniture standards have potential applicability to Federal facilities
and will be described below.
42
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Aerospace Manufacturing and Rework Facilities
The MACT standard for the aerospace industry applies to commercial, civil and military
manufacturing and rework facilities which are major sources. The regulation addresses a number of
aerospace processes including surface coating, depainting, and cleaning activities.
For surface coating, the MACT standard limits organic HAP emissions and VOC emissions on a
pound per gallon of coating, as applied, basis. For the HAP limits, the volume of coating is adjusted by
subtracting any water; for VOCs, the volume is adjusted by subtracting water and any exempt (non-
VOC) solvents. The specific limits are shown below.
Pollutant Limits
Primer
Topcoat
HAPs
lbs/gal
(less water)
2.9
3.5
VOCs
lbs/gal
(less water,
exempt solvents)
2.9
3.5
Sources can comply with these limits by using compliant coatings, or several different coatings which on
a daily, volume-weighted average basis, meet the limit. Rather than compling with these coating limits,
sources can choose to control emissions. The combination of the effectiveness of the capture (source
enclosure) and collection systems (treatment device) must limit HAP or VOC emissions by 81 percent.
Sources cannot average between primer and topcoat limits, nor between compliant coatings and the
control equipment option.
The MACT standard also includes equipment standards for application technologies. The use of
the following is required: flow coat, roll coat, brush coat, dip coat, electrostatic attraction, or high
volume low pressure (HVLP) spray guns. Alternative application techniques could be used if equivalent
control of emissions is demonstrated in comparison to electrostatic or HVLP.
To demonstrate compliance with the standard, records must be maintained on the VOC and HAP
content of each coating used. Using coatings which individually meet the proposed limits would require
records be kept of VOC and HAP determinations for each coating and monthly use volumes. However,
if the source chooses to average VOC and HAP content across several coatings which are both compliant
and non-compliant, then records of daily volume-weighted average determinations would be necessary.
The use of control devices would trigger monitoring requirements. Preventative approaches based on use
43
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of compliant coatings would limit these compliance burdens. Using coatings void of HAPs and VOCs
would eliminate the applicability of the MACT standard altogether.
Ship Building and Ship Repair
The proposed MACT will limit the use of volatile organic HAPs, termed VOHAPS, at facilities
that build, repair, paint and repaint, convert or alter ships. The standard applies to work performed on all
military and commercial cargo and passenger ships including cruise ships, fenies, barges, tankers,
container ships, patrol and pilot boats, buoys, and dredges. Facilities with potential VOHAP amicci^
meeting the major source criteria of 10 tons for an individual VOHAP or 25 tons for all VOHAPs will be
subject to the standard. The standard does not address HAP emissions from non-volatile coating
materials such as metal compounds in pigments.
The proposed standard provides two alternatives to meet as applied VOHAP coating content
limits. The basic standard includes limits on the pounds of VOHAP per gallon of coating, less the portion
of coating volume which is water, non-HAP, or VOC "exempt" solvents (not a VOC or a HAP).
Acetone, for example, is now a non-HAP "exempt" solvent. The alternative standard is based on pounds
of VOHAP per gallon of coating solids. Limits were proposed for general coating use and 22 specialty
coatings. These limits are summarized below. The reader is referred to the proposed rule for the
individual specialty coatings and limits set by the proposed rule.
VOHAP Standard
Alternate VOHAP
Standard
Units
lbs/gallon (minus water
and non-HAP, VOC
exempt solvents)
lbs/gallon coating solids
General Use Coatings
2.83
4.76
Specialty Coatings
2.83 to 6.5
4.76 to 92.46
The rule requires that compliance be demonstrated on a monthly basis. Sources can also petition
for approval of an alternative approach for using non-compliant coatings such as through the use of a
control system. Good housekeeping practices and training are also required as part of the proposed rule.
The preamble to the proposed rule provides more information on the requirements of this standard.
Wood Furniture Manufacturing
Facilities which manufacture wood furniture and have potential emissions meeting the major
source criteria would be subject to this proposed MACT standard. The proposed standard limits volatile
HAPs (called VHAPs in this proposal) in finishing materials, adhesives, and strippable spray coatings
used in the production of wood furniture. Included with the standard are requirements for work pra^^
for finishing and cleaning operations and training.
44
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The standard proposes separate limits for new and existing manufacturing facilities based on
pounds of VHAP per pound of coating solid. The standard proposes overall limits for each facility and
specific limits for individual finishing materials, cleaning operations, and adhesives. Equivalent limits for
alternative control approaches are also proposed. The reader is referred to the proposed rule for the
specific coatings and VHAP limits in the rule. A summary of the limits is provided below.
Existing Facilities
lbs VHAP/lb Solid
New Facilities
lbs VHAP/lb Solid
Overall Coating
average as applied
1.0
0.8
equivalent control alternative
1.0
0.8
Individual Finishing Materials
Stains
Thinners
Other Coating Materials
1.0
10.0
0.8
1.0
10.0
0.8
Strippable Booth Coatings
0.8
0.8
Contact Adhesives
Foam Adhesives for flammability
requirements
All other Adhesives
00 O
0.2
0.2
equivalent control alternative
1.0
0.2
The rule requires compliance be demonstrated on a monthly basis and the maintenance of records
on VHAP content and material use. The preamble to the proposed rule provides more information on the
requirements of this proposed MACT rule.
REQUIREMENTS FOR DEPA1N17NG OPERATION
Chemical-based depainting operations have traditionally relied almost exclusively on methylene
chloride-based stripper formulations. Methylene chloride is an exempt solvent and is not considered a
VOC. Solvent emissions from depainting operations have not been the target of State RACT rules.
Methylene chloride is a HAP, however, and "paint stripper users" is listed as a source category for the
development of MACT standards. The MACTT standard for paint stripper users is scheduled for
publication by November, 2000. The aerospace MACT standard published on September 1,1995
includes provisions for the control of HAP emissions from depainting operations in the aerospace
industry.
45
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Aerospace Manufacturing and Rework Facilities
The aerospace MACT standard limits HAP emissions from stripping the outer surface of wings,
stabilizers and entire aerospace vehicles. The use of HAPs in these depainting activities is prohibited.
The standard does not apply to stripping parts. Exceptions are provided for spot stripping and «1real
removal. For these activities, annual use limits per aircraft for HAP containing stripper are provided.
These limits allow for up to 26 gallons for commercial aircraft and up to SO gallons for military aircraft
The rule also requires non-chemical based equipment (such as media blasting technology) be operand in
accordance with manufacturers' recommendations. If the equipment fails, up to 14 days per year of HAP
containing stripper can be used.
The standard requires records be maintained on the volume and HAP content of any nhwrifrai
based formulation used. Records must also be keep for any time periods of malfunction for the non-
chemical based equipment.
LIVING WITH THE CLEAN AIR ACT
Regulatory programs resulting from the Clean Air Act impact directly on the use of solvents in
painting and depainting activities. Once control requirements are established, permitting and compliance
demonstration requirements follow. Given the scope of the Clean Air Act mandate and its direction and
focus on chemical substances, research and development in this area will continue to evolve. Greater
pressure for reductions in VOCs is expected in geographic areas having difficulty achieving the ozone
non-attainment standards (Los Angeles, Northeast Corridor). The use of HAPS will be increasingly
regulated in the coming years. The termination of the production of Class I substances is on the near
horizon with Class n substances following in the not too distant future. It is reasonable to expect a
continuing tightening down on the use of chemical solvents.
For Federal facilities, environmental performance will be more visible as a result of Executive
Order 12856. The required reporting on chemical releases to the Toxic Release Inventory and the
development of facility plans for reducing these releases will be open to public scrutiny.
The use of organic solvents in painting and depainting processes has been the target of activities
by government, industry and environmental organizations to identify and encourage the use of pollution
prevention alternatives. Pollution preventative approaches have been developed and implemented jn
many industrial scenarios. They can serve as models for Federal facilities, helping them not only to meet
or exceed potential Clean Air Act requirements, but to reduce costs for materials, waste disposal,
reporting, and recordkeeping. In addition, implementation of pollution preventative approaches help in
reducing potential liabilities from waste generation and exposure to workers.
The remainder of this report presents information on pollution prevention alternatives for the
processes under review. A large part of the pollution prevention effort has been in the pursuit of the
"safer substitute." Given the emphasis on safer substitutes, this report focuses on potential substitute
materials and processes for current processes using HAPs, ODCs and VOCs. Safer can mean different
46
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things to different decision makers. Generally it means the use of less regulated and less hazardous
compounds, providing benefits such as reduced solvent losses and exposure to workers, and lessened
concern for worker safety, flammability, and waste management requirements.
47
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CHAPTERS
POLLUTION PREVENTION OPPORTUNITIES
IN PAINTING
INFORMATION SOURCES
The search for alternatives to ODCs, HAPs, and VOCs for painting has lead to the development
of several reports on alternatives to these chemicals. A listing of many of these reports and who to
contact to obtain them is presented in Appendix A. Included in Appendix A are contact points with key
EPA information sources including:
• Enviro$ense - is an electronic bullentin board providing access to a wide array of
environmental and pollution prevention information as well as professionals active in the
environmental management area. Enviro$ense is accessible by modem and the World
Wide Web on the Internet.
• Technology Transfer Network - TTN is a bulletin board system on Clean Air Act
programs operated by the Office of Air Quality Planning and Standards (OAQPS). TTN
provides access to the latest documents on supporting policy, technical and rulemaking
activities and is accessible by modem.
• Pollution Prevention Information Clearinghouse - PPIC provides access to materials
developed by EPA and State pollution prevention program activities.
• Stratospheric Ozone Hotline - provides policy, technical, and rulemaking information on
the phase out of ozone depleting compounds.
These sources provide useful information on all technical and regulatory activities related to the
Clean Air Act and pollution prevention.
Information on alternative coating technologies is available in a report titled "National Emission
Standard for Hazardous Air Pollutants for the Aerospace Industry - Background Information for the
Proposed Standards" (April, 1994, EPA-453/R-94-036a, also available through TTN). This document .
outlines the technologies considered by EPA's Office of Air Quality Planning and Standards in developing
the MACT standards for the aerospace industry. Appendix A identifies additional reports with
information on surface coating alternatives.
POLLUTION PREVENTION ALTERNATIVES IN PAINTING
Pollution preventative approaches to complying with the Clean Air Act requires consideration of
both the coating technology and the coating formulation. A variety of coating application technologies
49
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are available, from brash to spray application as identified on Table 6. Pollution prevention
be achieved through improvements in transfer efficiency, particularly with spray application t«^hnjgtlrti
Moving from 20 to 40 percent transfer efficiency with a conventional spray gun system to the 90 to 95*
transfer efficiencies achievable with electrostatic spray guns can result in significant savings in p*""t ••-nirr
and solvent loss from paint application.
Changes in the application technique alone are not likely to bring compliance with VOC and HAP
limitations. Developing coating techniques using "compliant" coatings will eliminate the need for add-on
control equipment. The use of coatings which are HAP and VOC free will eliminate the applicability of
Clean Air Act requirements altogether. Table 7 identifies the types of coating formulations available
The use of conventional coatings, typically with high solvent content, will usually require the application
of a treatment system. Wateiborae and high solids coatings can be potential compliant coatings. Their
use can result in reduced solvent emissions, particularly when used with high efficiency application
methods. Powder
Several examples of pollution prevention achievements in coating operations are shown in Table
8. These examples show the benefits of investigating alternative coating formulations (powder coatings)
and application systems (HVLP). Benefits achieved include reduced material costs and reduced
hazardous waste generation. Solvent free coatings, like solvent free cleaning agents, eliminate the
compliance demonstration burdens as well.coatings and radiation-cured coatings essentially eliminate
solvent emissions.
50
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TABLE6
AVAILABLE APPLICATION TECHNOLOGIES FOR PAINTING
Technoiocy
Transfer
Efficiency
(%)
Benefits
Limitations
Conventional Application Methods
Conventional Airspray
20-40
Versatile.
High energy requirements. High air pressures
required. High coating use with low transfer
efficiency.
Airless Spraying
35-50
Improved transfer efficiency over conventional
airspray.
High hydrostatic pressure required.
Air-assisted Airless Spfay
System
30-60
More manageable than airless spray alone, uses
lower pressures, lower air and fluid rates.
Dip Coating
High
Higji transfer efficiency.
Limited to parts that can fit into the dip tank.
Roll Coating
High
High transfer efficiency with high rates of
application and automation.
Surfaces must be flat
Brash Coating
High
Useful for touch-up and detail painting oper-
ations that cannot tolerate spray gun over-spray.
High labor costs, increased production time, and
poor coating thickness control are typical.
Row Coating
High
High transfer efficiency.
Typically limited to flat sheets and non-critical
parts. Coating thickness is difficult to control.
High EfOdncr Appiication Methods
High Volume Low Pressure
Spray Gtms (HVLP)
High
Low air pressures allow for well controlled
spray patterns with less overspray and bounce
back from substrate.
High solids coatings may require turbine to
reduce to viscosity of the coating. Cannot be
used with extension nozzles and may slow pro-
duction rates due to low fluid delivery rates.
51
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TABLE 6 — continued
Technotoer
Transfer
Efficiency
(%)
Benefits
Limitations
Electrostatic Spray Guns
90-95
Very high transfer efficiencies. Electrostatic
effect can be utilized in conjunction with
aiispray, airless, air-assisted airless, and HVLP
systems to enhance their transfer efficiencies.
Primarily used for metal parts or substrates prc-
trealed with conductive coatings.
52
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TABLE7
AVAILABLE PAINT COATING FORMULATIONS
CmUbc Formulations
% Organic
Solvent (by wt)
Benefits
Limitations
Conventional Coatings
70-80
Knowledge and experience with coating
systems.
Uses VOCs and/or HAPs which require add-on
controls.
Waterborne Coatings
5-40
Less overspray and improved spray transfer
efficiency may be achieved. Less toxic, reduced
fire hazard.
Potential compliant coatings.
Require spray guns of specific materials,
protection from freezing, better temperature and
humidity control. Have longer drying times,
shorter shelf life.
Higher Solids Coatings
35-50
Greater surface area coverage meaning less
coating required. Reduced solvent emissions.
Potential compliant coatings.
Have longer drying times than conventional
coatings, higher viscosities which may require
heating prior to spray application.
Powder Coatings
-0-
Greatly reduced solvent emissions, reduced fire
hazard, toxicity, and make-up air requires of the
spray booth.
Eliminates useof HAPsand VOCs.
Eliminates emission fees and compliance
demonstration rerquircments for recordkeeping,
reporting and monitoring.
Powder coatings must be applied electrostati-
cally, so they cannot be used on non-conductive
parts such as composites. Production must be
shut down forcolor changes; powder must
remain dry; high curing temps required.
Radiation-cured coatings
-0-
Eliminates use of HAPs or VOC.
Requires no solvents.
Eliminates emission fees and compliance
demonstration requirements for record-
keeping, reporting and monitoring.
Requires energy source to cure coating (ultra-
violet or electron-beam).
Limited to surfaces reachable by energy source;
3-dimensional surfaces difficult to cure.
53
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TABLE8
EXAMPLES OF POLLUTION PREVENTION OPPORTUNITIES FOR
PAINTING FOR CLEAN AIR ACT COMPLIANCE
Process
(Ref#)
Pollution Prevention Opportunities
Cost
Benefit
Compliance1
Benefits
Other Issues
Spray Paint
Line
(Ref 1)
Justrite Manufacturing replaced their solvent-
based spray paint line with a powder coating
system. This reduced paint-associated waste and
volatile organic compound emissions by 100%.
They also achieved a higher quality paint finish
and improved worker safety.
Reduced
Coating
Usage
100% VOC reduc-
tion
Disposal, operating,
energy, and clean-up
costs have all been
reduced by switching
to powder coatings.
Alternative
Coatings
(Ref 2)
An autobody shop that switched from lacquer to
enamel-based coatings reduced its VOC emis-
sions. Lacquer paints typically contain 70 to 90%
volume solvent while enamels contain 55 to 75%
volume solvent
Reduced
coating
usage
Reduced VOC
emissions
Enamels are less prone
to react with
polyester/fiberglass
filler to discolor or
yellow.
High Vol-
ume Low
Pressure
Spray Guns
(Ref 3)
A medium sized commercial/rework aircraft
company reduced coating purchases by 22-30%
by switching from conventional coating applica-
tion methods to High Volume Low Pressure
(HVLP) spray guns.
22-30%
reduction in
coating
usage
VOC emissions
were reduced by
20-40%
HVLP is the preferred
technology in the
aerospace industry at
this time.
54
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TABLE 8 — continued
Process
(Ref#)
Pollution Prevention Opportunities
Cost
Benefit
Compliance1
Benefits
Other Issues
Powder
Paint
Technology
(Ref 4)
By switching to powdered paint technology,
Garden Way, Inc. accomplished a 95% reduction
in their hazardous waste streams and has
experienced sizable treatment savings.
$25,000
annual sav-
ings
100% VOC reduc-
tion, 95% hazard-
ous waste reduc-
tion
System will pay for
itself in 5-10 years.
Automated
Painting
(Ref 5)
General Dynamics replaced manual mixing and
hand-spraying of metal parts with computer-
controlled robots (a GR OM 500 unit), a pro-
portional paint mixer, electrostatic spray guns,
automatic waste cleaning solvent systems which
allow for recycle and reuse of waste paint, and
solvent stills. Due to these changes, paint waste
was reduced by 60%, new paint purchases by
20%, and solvent purchases by nearly 60% in just
two years.
$40,000
annual sav-
ings not
including
savings from
new paint
purchases
Not known
Though the initial
capital investment of
$1.4 million may be too
much for small
companies, parts of the
system such as the
electrostatic sprays and
solvent stills are
inexpensive and very
effective.
'Elimination of regulated compoun also provides reduced compliance demonstration expenses for monitoring, recordkeeping and
reporting. Regulatory liabilities are also reduced.
55
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TABLE 8 - continued
REFERENCES FOR POLLUTION PREVENTION EXAMPLES
1. Illinois Hazardous Waste Research and Information Center. "Pollution Prevention: Illinois
Industry Success Stories." Champaign, IL. May 1994.
2. United States Environmental Protection Agency, Office of Research and Development. "Guides
to Pollution Prevention - The Automotive Refinishing Industry." Publication No. EPA/625/7-
91/016, Washington, DC. October 1991.
3. United States Environmental Protection Agency, Office of Air Quality Planning and Standards.
"National Emission Standard for Hazardous Air Pollutants (NESHAP) for the Aerospace Industry
- Background Information for Proposed Standards." Preliminary Draft, Research Triangle Park.
NC. April 1994.
4. United States Environmental Protection Agency, Office of Research and Development.
"Achievements in Source Reduction and Recycling for Ten Industries in the United States."
Publication No. EPA/600/2-91/051, Washington, DC. September 1991.
5. United States Environmental Protection Agency, Office of Research and Development.
"Evaluation of Five Waste Minimization Technologies at the General Dynamics Ponoma Division
Plant." Publication No. EPA/600/2-91/067, Cincinnati, OH. January 1992.
56
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CHAPTER 7
POLLUTION PREVENTION OPPORTUNITIES IN DEPAINTING
INFORMATION SOURCES
Appendix A also identifies the information sources and reports available on depainting. Recent
reports which provide useful information on depainting alternatives are:
Guide to Cleaner Technologies: Organic Coating Removal (2/94, EPA/625/R-
93/015) - identifies current and emerging alternative coating removal technologies with
emphasis on non-chemical based alternatives (prepared by EPA's National Risk
Management Research Laboratory, Cincinnati, Ohio 45268).
• Paint Removal. An Assessment of Emission Control Options (3/92, Center for
Emissions Control) - a review of alternative approaches to paint stripping with emphasis
on chemical alternatives. (Prepared by Center for Emission Control, an industry trade
organization).
Although several alternative chemical formulations are available to replace methylene chloride based
formulations, the identification of non-chemical based techniques is the focus of this report Changing
from methylene chloride, a HAP, to another solvent, likely a VOC will not foreclose the need to consider
further controls. As described below, a wide array of non-chemical based alternatives are available.
Federal facilities are encouraged to focus their investigation of depainting alternatives on non-chemical
alternatives.
POLLUTION PREVENTION ALTERNATIVES IN DEPAINTING
A variety of technologies are available which can be used to remove coatings. Several blasting
techniques exist as well as approaches which thermally destroy (burn) the coating. Table 9 identifies
several of the alternative removal techniques available and repotted applications. Table 6 summarizes the
benefits and limitations associated with die use of these technologies. This information was adapted from
the report, Guide to Cleaner Technologies: Organic floating Rrmnval previously identified. Additional
information on each of these alternatives is available in this report
Successfully applying one of these techniques as an alternative to a HAP-based formulation, such
as one using methylene chloride, will eliminate future compliance concerns under the Clean Air Act,
whether to the MACT standard published for the aerospace industry, or future standards for depainting.
The future use of methylene chloride paint stripping formulations has the potential to be severely limited
under the Clean Air Act because the availability of these alternative techniques.
57
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Some examples are available which document the potential benefits achieved in operations which
have replaced methylene chloride formulations with blasting technologies. These examples are presented
on Table 7. Significant savings were achieved in each example. In each case, workers no longer r'-^j
to be protected from dermal contact or inhalation of vapors from use of chemical strippers. Future
compliance burdens with Clean Air Act requirements are also eliminated.
Investing time and effort to identify and implement pollution prevention techniques has the
potential to offers benefits that will be realized now and in the future. Federal facilities are encourage
look hard at preventative techniques, particularly in the development of their Clean Air Act compliance
strategies.
58
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TABLE9
PREVENTION TECHNOLOGIES FOR COATING REMOVAL
Tecfenoluev
Reported Application
Waste Products
iuid Emissions
Energy Use
Operations Needed
Alter Stripping
Plastic Media
Blasting
Removes paint from a variety of
metal and non-metal substrates.
Strips aircraft components and
ground support equipment.
Cleans/strips commercial and
industrial parts.
Removes powder coatings from
sensitive substrates.
Solid coating residue and
spent media waste.
Airborne particles.
Noise.
Compresses air to propel
blasting media.
Energy for media recovery and
recycle, dust collection, and
ventilation.
Continuous separation of
media from stripped coating
particles and spent media
during stripping.
Remove masking.
Dispose of spent media and
contained coating residue
waste.
Some spent thermoplastic
media (even with coating
residue) can be reused to
make plastic parts.
Wheat Starch
Blasting
Gentile stripping action suitable for
abrasion sensitive fillers and
composite materials.
Gaining acceptance for thin, soft
aluminum in commercial aircraft
skins.
Solid coating residue and
spent media waste.
Airborne particles.
Noise.
Compressed air to propel
blasting media.
Energy for media recovery and
recycle, dust collection, and
ventilation.
Continuous collection and
reuse of spent media during
stripping.
Remove masking.
Dispose of spent media and
contained coating residue
waste.
Spent media can be treated by
biodegradation.
Banting Cutoff
Removes thick coatings from a
variety of coating line fixtures and
tools.
Ash.
Offgas.
Electricity or gas supply for
heating.
Cool down.
Ash removal and collection.
59
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TABLE 9 - continued
Tedmolonr
Reported Application
Waste Products
and Emissions
Enemy Use
Operations Needed
After Stripping
Molten Salt
Removes thick coatings from a
variety of coating line fixtures and
tools.
Salt/coating by-product
sludge.
Off gas.
Rinse water.
Electricity or gas supply
heating.
Cool down.
Water rinse.
Sodium
Bicarbonate
Wet Blasting
Removes paints from a variety of
metal substrates.
Depaints wood without damaging
the substrate.
Cleans and depaints brick walls.
Removes heavy accumulations of
grease and dirt from mechanical
equipment
Liquid waste containing
coating residue and spent
media.
Some airborne particulates.
Noise.
Compressed air and water
supply to propel blasting media.
Ventilation to control particu-
late.
Remove masking.
Dispose of sodium bicarbon-
ate solution and coating
residue waste.
Carbon Dioxide
Pellet
Cryogenic
Blasting
Strips surfaces needing high degree
of final cleanliness.
Useful for equipment where it is
desirable to avoid disassembly.
Useful when volume of residue must
be minimized such as with
radioactive-contaminated compo-
nents or coatings containing haz-
ardous metals (e.g., cadmium or
lead).
Solid coating residue
waste.
Airborne particulates.
Cojgas.
Noise.
Liquid caibon dioxide supply.
Compressed air supply to
propel blasting media.
Remove masking.
Dispose of coating residue
waste.
60
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TABLE 9 — continued
Ttduokn
Reported Application
Waste Products
and Emissions
Energy Use
Operations Needed
After Strfpplne
High-Pressure
Waster Blasting
Robotic systems for rapid coating
removal.
Sludge waste containing
paint residue.
Wastewater.
Some airborne particu-
lates.
Noise.
Electricity to drive water pump.
Remove masking.
Dispose of coating residue
sludge and wastewater.
Medium Pressure
Water Blasting
Rapid coating removal.
Sludge waste containing
paint residue (and in some
systems solvent or abrasive
additives).
Wastewater.
Some airborne particulates.
Noise.
Electricity to drive water pump.
Remove masking.
Dispose of coating residue
sludge and wastewater.
If used, dispose of abrasive or
sorbent or other treatment
medium carrying solvent.
Liquid Nitrogen
Cryogenic
Blasting
Removes thick coatings of coating
from a variety of coating line fixtures
and tools.
Solid coating reskhie and
spent media waste.
Inert nitrogen gas.
Liquid nitrogen supply,
Vent nitrogen gas from the
stripping cabinet.
Allow parts to warm for 5
minutes.
Dispose of coating residue
waste.
Adapted from: Guide to Cleaner Technologies: Organic Coating Removal {2/94; EPA/625/R-93-015).
61
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TABLE 10
PREVENTION TECHNOLOGIES FOR COATING REMOVAL: BENEFITS AND LIMITATIONS
Technology
Pollution Prevention Benefits
Other Benefits1
Limitations
Plastic
Media
Blasting
Eliminates VOCs and HAPs.
Uses nontoxic media.
Uses a dry process.
Spent media are cleaned and
reused several times for paint
stripping.
Some spent thermoplastic
media are recyclable to make
plastic products.
Provides high-throughput-
controlled coating removal.
Can selectively remove
individual coating layers.
Eliminates water use.
When stripping is done with
thermoplastic media, the waste
may be recyclable.
Spent plastic media contain paint chips and so may be
hazardous waste.
Requires workers to wear respiratory and eye protection
equipment
Blasting generates high noise levels.
May cause metal substrate damage.
More aggressive media types damage fiberglass or
composite materials.
Contaminants in media can stress substrate.
Uses flammable media.
Wheat Star
Blasting
Eliminates VOCs and HAPs.
Spent media are cleaned and
reused several times for paint
stripping.
Uses a nontoxic, biodegradable
medium.
Uses a dry process.
Provides controlled coating
removal.
Can selectively remove
individual coating layers.
Fltmtnsitee water nc«
Uses inexpensive media.
Media are nontoxic and
biodeeradable.
Spent starch media contain paint chips and so may be
hazardous waste.
Contaminants in recycled media may damage substrate.
Stripping rate is generally slow to moderate.
Requires workers to wear respiratory and eye protection
equipment.
Blasting generates high noise levels.
Media are moisture sensitive.
62
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TABLE 10 - continued
Technology
Pollution Prevention Benefits
Other Benefits1
Limitations
Bumoff
F.fiminatpc VOCs and HAPs
Provides rapid removal of thick
coatings.
Can process complex shapes.
Bumoff ovens can remove
uncured coating.
Generate coating ash residue that may be hazardous
waste.
Will damage heat-sensitive materials such as heat-
treated aluminum or magnets.
Coatings containing halogens (PVC or PIPE) and/or
nitrogen will produce corrosive offgas.
Must not be used for low-melting metals or alloys.
Must not be used with pyrophoric metals.
May require offgas treatment, depending on local air
permitting regulations.
Potential foe generation of products of incomplete
combustion.
Presents possibility of fire.
Molten Salt
Eliminates VOCs and HAPs
Provides rapid removal of thick
coatings.
Can process complex shapes.
Salt bath ensures even heating.
Rinsewater waste is compatible
with conventional water
treatment systems.
Generates by-product sludge that may be hazardous
waste.
Will damage heat-sensitive materials such as heat-
treated aluminum or magnets.
Must not be used for low-melting alloys.
Must not be used with pyrophoric metals.
May require offgas treatment depending on local air
permitting regulations.
Potential for generation of products of incomplete
combustion.
63
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TABLE 10 - continued
Technology
Pollution Prevention Benefits
Other Benefits1
Limitations
Sodium
Bicarbonate
Wet
Blasting
Eliminates VOCs and HAPs.
Uses nontoxic media.
Provides a controllable process
for coating removal.
Can selectively remove
individual coating layers.
Uses inexpensive stripping
media.
In some cases, liquid waste
may be discharged to a
conventional wastewater
treatment plant.
Use of water dissipates heat
generated by the abrasion.
Eliminates need to prewash
surface.
Sodium bicarbonate
wastestreams. are generally
compatible with existing water
treatment systems.
Uses nonrecyclable stripping media.
Generates wet sodium bicarbonate sludge containing
coating debris, which may be a hazardous waste.
Must collect and treat wastewater containing sodium
bicaibonate and paint chips.
May require exhaust ventilation system to control
particulate.
Requires workers to wear respiratory and eye protection
equipment
Blasting generates high noise levels.
Media can be aggressive so potential for substrate
damage exists.
64
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TABLE 10 — continued
Technology
Pollution Prevention Benefits
Other Benefits1
Limitations
Carbon
Dioxide
Pellet
Oyogenic
Blasting
Eliminates VOCs and HAPs.
Uses a dry process so no
wastewater is generated.
Coating chips collected dry.
Generates low volume or dry
waste (none from the media).
Eliminates water use.
Provides well-defined coating
removal pattern.
Can selectively remove
individual coating layers.
Requires limited pre- or
poststripping cleanup.
No masking needed except for
delicate materials such as soft
clear plastics.
Equipment can be stripped
without disassembly.
No media separation/recycling
system needed
No media disposal cost.
Pellets driven into interstitial
spaces vaporize, leaving no
residue.
Generates coating debris which may be a hazardous.
Requires ventilation to avoid potentially dangerous C02
concentrations.
Generates airborne particulates that may contain metal
from the coatings.
Requires workers to wear respiratory and eye protection
equipment.
Requires workers to wear hearing protection.
Possible worker exposure to extreme cold.
Potential for worker injury from high-velocity C02 pellet
impact.
Nonautomated system fatigues workers quickly.
Possible static electricity buildup on substrate if no
grounding provided.
Some coating debris may redeposit on substrate.
Low temperatures can cause condensation on substrate.
Large local temperature drops can occur in substrate but
confined mainly to the surface layer.
May damage thermoset composite materials.
Difficult to control coating removal on graphite-epoxy
composites.
Slow coating removal rate.
Equipment bulkv and caoital intensive.
65
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TABLE 10 — continued
Technoloev
Pollution Prevention Benefits
Other Benefits1
Limitations
High
Pressure
Water
Blasting
Eliminates HAPs and VOCs.
Water can be processed and
recycled during stripping,
reducing waste water volume.
High stripping rate.
Stripping water can be
recycled.
Wastewater stream is
compatible with existing water
treatment systems.
Coating debris sludge may be hazardous waste.
System is needed to collect and recycle stripping water.
Ultrahi gh-pressure systems (>15,000 psi) require
expensive robotic operation.
Misapplied water jet will damage substrate.
Blasting generates high noise levels.
Water can enter cavities.
Water can penetrate and/or damage joints, seals, and
bonded areas.
Medium
Pressure
Water
Blasting
Eliminates HAPs; some
systems use VOCs containing
softeners.
Water can be processed and
recycled during stripping
reducing wastewater volume.
High stripping rate.
Stripping water can be
recycled.
Wastewater stream is
compatible with existing water
treatment systems.
Coating debris sludge may be hazardous waste.
System is needed to collect and recycle stripping water.
Requires workers to wear respiratory and eye protection
equipment.
Blasting generates high noise levels.
Mechanized applications typical due to high reaction
forces.
Misapplied water jet will damage substrate.
Water can enter cavities.
Water can penetrate and/or damage joints, seals, and
bonded areas.
66
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TABLE 10 - continued
Technology
Pollution Prevention Benefits
Other Benefits1
Limitations
Liquid
Nitrogen
Qyogenic
Blasting
Eliminates HAPs and VOCs.
Environmentally clean.
No ash residue.
Low waste volume.
Eliminates water rinse.
Very fast cycle times 5 to 15
min. give high throughput rate.
Works well on thick coating
buildups.
Generates some solid waste containing coating chips and
spent plastic media, which may be a hazardous waste.
May require ventilation system to prevent nitrogen
buildup in confined spaces.
Requires worker protection from low temperatures
during unloading.
Not effective on thin coating films.
Less effective on epoxies and urethanes.
Existing technology limits part size to less than 5 ft tall
and 38 in. diameter, weight less than 400 lb. per
stripping cycle.
Uses a dry process.
No dust, fumes, or chemicals
released.
Coating chips collected dry
with small volume erf media.
Adapted from: Guide to Cleaner Technologies: Organic Coating Removal (2/94; EPA/625/R-93-015).
1 Technologies which eliminate use of VOCs or HAPs, eliminate emission fees and compliance demonstration requirements for monitoring,
recordkeeping andrepotting.
67
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TABLE 11
EXAMPLES OF POLLUTION PREVENTION OPPORTUNITIES FOR
PAINT REMOVAL FOR CLEAN AIR ACT COMPLIANCE
Process
(Ref#)
Pollution Prevention Opportunities
Cost
Benefit
Compliance1
Benefits
Other Issues
Plastic
Media
Blasting
(Ref 1)
A study of Plastic Media Blasting (PMB) strip-
ping of C-5 aircraft at Air Force installation
concluded that PMB offers significant economic
and environmental advantages over solvent
stripping. The PMB process at this facility is
expected to eliminate 72,000 gallons/year of
methylene chloride stripper.
$4,800,000
annual sav-
ings
Eliminated use of
HAP.
Reduce hazardous
waste generation.
PMB eliminate water
use.
Reduced labor re-
quirements over che-
mical stripping.
Must manage dust
generated.
Must protect workers
from dust, but not
vapors and skin contact
with chemicals.
Sodium
Bicarbonate
Wet
Blasting
(Ref 1)
The NASA Johnson Space Center (JSC) Aircraft
Operation Division has used sodium bicarbonate
to strip the surface of aircraft wheels prior to
inspecting for structural defects. NASA has
eliminated the high costs of disposing of solid and
liquid wastes generated from their prior use of
methylene chloride and other organic solvent
strippers.
100% waste
reduction
Eliminated use of
HAP and VOCs.
Eliminated hazard-
ous waste.
Must protect workers
from dust, but not
vapors and skin contact
with chemicals.
68
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TABLE 11 - continued
Process
(Ref#)
Pollution Prevention Opportunities
Cost
Benefit
Compliance1
Benefits
Other Issues
Bead-Blast
Paint
Stripper
(Ref 2)
As a result of replacing methylene chloride
stripping with a bead-blast paint stripper in its
paint shop, General Dynamics has reduced paint-
related waste by 50%. The mechanical stripper,
which cost $18,000, will be paid for in just 3.6
years.
$5,000
annual dis-
posal savings
50% hazardous
waste reduction.
Eliminated use of
HAP.
Some fugitive emis-
sions occur around the
unit
Must protect workers
from dust, but not
vapors and skin contact
with chemicals.
1 Elimination of regulated compound also provides reduced compliance demonstration expenses for monitoring, recordkeeping and
reporting. Regulatory liabilities also reduced.
69
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TABLE 11 — continued
REFERENCES FOR POLLUTION PREVENTION EXAMPLES
1. United States Environmental Protection Agency, Office of Research and Development. "Guide to
Cleaner Technologies - Organic Coating Removal." Publication No. EPA/625/R-93/015,
Washington, DC. February 1994.
2. United States Environmental Protection Agency, Office of Research and Development.
"Evaluation of Five Waste Minimization Technologies at the General Dynamics Ponoma Division
Plant." Publication No. EPA/600/2-91/067, Cincinnati, OH. January 1992.
70
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APPENDIX A
INFORMATION SOURCES ON POLLUTION PREVENTION
-------
CONTACTS FOR OBTAINING POLLUTION PREVENTION DOCUMENTS
For EPA Documents:
National Technical Information Service (NTIS)
(703) 487-4650
For ETA Office of Research and Development (ORD) Documents:
Center for Environmental Research Information
26 West Martin Luther King Drive
Cincinnati, Ohio 45268
(513) 569-7562
For Information on ORD Projects:
National Risk Management Research Laboratory
U.S. Environmental Protection Agency
26 West Martin Luther King Drive
Cincinnati, Ohio 45268
(513)569-7215
For Information and Documents on the Clean Air Act:
Technology Transfer Network (TTNI Bulletin Board System
Operated by the EPA's Office of Air Quality Planning & Standards (OAQPS), the system can
be accessed with a computer by calling (919) 541-1447 for 9600 & 19200 bps modems or
(919) 541-5742 for 1200 & 2400 bps modems (Databits=8, parity=N, and stop bits=l). Help
Line: (919) 541-5384
For Information on the Significant New Alternatives Policy (SNAP) Program:
Stratospheric Ozone Information Hotline: 1-800-296-1996
For Pollution Prevention Information:
EPA's Pollution Prevention Information Clearinghouse
(202)260-1023
-------
For Access to Information and Professionals concerning Pollution Prevention and
Environmental Compliance:
ENVIRQSfiNSF,
Operated by EPA's Office of Research and Development and Office of Enforcement and
Compliance Assurance, the system can be accessed by computer modem by calling 703-908-2092
(2,400 to 14,400 bps modems, bits =8, parity =n, stop bits =1, emulation =ANSI or VT-100); or by
the World Wide Web via the Internet: bttp://wastenot.inel.gov/envirosense/
For Information on State, Local and Academic Pollution Prevention Programs:
The National Roundtable of State Pollution Prevention Programs
218 D Street, SE
Washington, DC 20003
Phone: 202-543-7272
FAX: 202-543-3844
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SOURCES OF INFORMATION ON CLEANING AND DEGREASING
Control of Volatile Organic Emissions from Solvent Metal Cleaning, EPA/450/2-77-022,
Research Triangle Park, NC, November 1977. NTIS No. PB-274 557.
United States Environmental Protection Agency, Office of Research and Development. "Guide to
Cleaner Technologies, Cleaning and Degrcasing Process Changes." Publication No.
EPA/625/R-93/017, Washington, DC. February 1994.
United States Environmental Protection Agency, Office of Research and Development "Guide to
Cleaner Technologies, Alternatives to Chlorinated Solvents for Cleaning and Degrcasing."
Publication No. EPA/625/R-93/016, Washington, DC. February 1994.
United States Environmental Protection Agency, Office of Air and Radiation. "Manual of
Practices to Reduce and Eliminate CFC-113 Use in the Electronics Industry." Publication
No. EPA/400/3-90/003, Washington, DC, March 1990.
United States Environmental Protection Agency, Office of Air and Radiation. "Eliminating CFC-
113 and Methyl Chloroform in Precision Cleaning Operations." Publication No.
EPA/400/1-91/018, Washington, DC, June 1991.
United States Environmental Protection Agency, Office of Air and Radiation. "Conservation and
Recycling Practices for CFC-113 and Methyl Chloroform." Publication No. EPA/400/1-
91/017, Washington, DC, June 1991.
United States Environmental Protection Agency, Office of Air and Radiation. "Alternatives for
CFC-113 and Methyl Chloroform in Metal Cleaning." Publication No. EPA/400/1-91/019,
Washington, DC, June 1991.
United States Environmental Protection Agency, Office of Air and Radiation. "Aqueous and
Semi-Aqueous Alternatives for CFC-113 and Methyl Chloroform Cleaning of Printed
Circuit Board Assemblies." Publication No. EPA/400/1-91/016, Washington, DC, June
1991.
United States Environmental Protection Agency, Office of Air and Radiation. "Eliminating CFC-
113 and Methyl Chloroform in Aircraft Maintenance Procedures." Publication No.
EPA/430/B-93/006, Washington, DC. October 1993.
Pojasek, Robert B. Pollution Prevention Review. "Practical Pollution Prevention - Is Your Quest
for Substitute Solvents Preventing You from Evaluating Other Options?" Winter 1991-
92. (Available through Pollution Prevention Information Clearinghouse.)
United States Environmental Protection Agency, Office of Research and Development. "Waste
Minimization Opportunity Assessment, Naval Undersea Warfare Engineering Station,
Keyport, Washington." NTIS Publication No. PB91-216457, Cincinnati, OH. July 1991.
-------
President's Commission on Environmental Quality, Quality Environmental Management
Subcommittee. "Total Quality Management, A Framework for Pollution Prevention."
Washington, DC. January 1993. (Report available through US Council on Environmental
Quality.)
United States Environmental Protection Agency, Office of Air Quality Planning and Standards.
"National Emission Standards for Hazardous Air Pollutants: Halogenated Solvent
Cleaning Background Information Document." Publication No. EPA/453/R-93/054,
Research Triangle Park, NC. November 1993.
United States Environmental Protection Agency, Office of Air Quality Planning and Standards.
"Alternative Control Techniques Document-Industrial Cleaning Solvents." Publication
No. EPA/453/R-94/015, Research Triangle Park, NC. February 1994.
United States Environmental Protection Agency, Office of Research and Development.
"Pollution Prevention Case Studies Compendium." Publication No. EPA/600/R-92/046,
Washington, DC. April 1992.
United States Environmental Protection Agency, Office of Research and Development.
"Industrial Pollution Prevention Opportunities for the 1990s." Publication No. EPA/600/8-
91/052, Washington, DC. August 1991.
United States Environmental Protection Agency, Office of Research and Development. "Guides
to Pollution Prevention - The Marine Maintenance and Repair Industry." Publication No
EPA/625/7-91/015, Washington, DC. October 1991.
United States Environmental Protection Agency, Office of Research and Development. "Project
Summary - Waste Minimization Opportunity Assessment: Scott Air Force Base."
Publication No. EPA/600/S2-91/054, Cincinnati, OH. December 1991.
United States Environmental Protection Agency, Office of Research and Development.
"Environmental Research Brief: Waste Minimization Assessment for a Manufacturer of
Sheet Metal Cabinets and Precision Metal Parts." Publication No. EPA/60Q/S-92/021,
Cincinnati, OH. May 1992.
United States Environmental Protection Agency, Office of Research and Development.
"Environmental Research Brief: Waste Minimization Assessment for a Manufacturer of
Military Furniture." Publication No. EPA/600/S-92/017, Cincinnati, OH. June 1992,
United States Environmental Protection Agency, Office of Research and Development.
"Environmental Research Brief: Waste Reduction Activities and Options for an Autobody
Repair Facility." Publication No. EPA/600/s-92/043, Cincinnati, OH. October 1992.
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United States Environmental Protection Agency, Office of Research and Development
"Opportunities for Pollution Prevention Research to Support the 33/50 Program."
Publication No. EPA/600/R-92/175, Washington, DC. October 1992.
United States Environmental Protection Agency, Office of Research and Development
"Achievements in Source Reduction and Recycling for Ten Industries in the United
States." Publication No. EPA/600/2-91/051, Washington, DC. September 1991.
United States Environmental Protection Agency, Office of Research and Development.
"Pollution Prevention Research Within the federal Community." Cincinnati, OH.
(Summary paper of pollution prevention opportunity assessments at Federal facilities,
available through EPA's Risk Reduction Engineering Laboratory, Cincinnati, Ohio.)
Illinois Hazardous Waste Research and Information Center, "Pollution Prevention: Illinois
Industry Success Stories", Publication No. TN94-039, Champaign, Illinois, May, 1994.
(Available through Illinois Hazardous Waste Research and Information Center, One East
Hazelwood Drive, Champaign, Illinois 61820,217-333-8940.)
Industrial Pollution Prevention Handbook hy Harry Preaman, fhapt^r ?«; Mnfimw Hill, 1995.
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SOURCES OF INFORMATION ON PAINTING AND DEPAINTTNG
Control of Volatile Organic Emissions from Existing Stationary Sources, Volume I: Control
Methods for Surface Coating Operations, EPA-45Q/2-76-028, Research Triangle Park,
NC, November 1976. NTIS No. PB-260 386.
Control of Volatile Organic Emissions from Existing Stationary Sources, Volume II: Surface
Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks, EPA-450/2-
77-008, Research Triangle Park, NC, May 1977.
Control of Volatile Organic Emissions from Existing Stationary Sources, Volume HI: Surface
Coating of Metal Furniture, EPA-450/2-77-032, Research Triangle Park, NC, December
1977. NTIS No. PB-278 257.
Control of Volatile Organic Emissions from Existing Stationary Sources, Volume IV: Surface
Coating of Insulation of Magnet Wire, EPA-45(V2-77-033, Research Triangle Park, NC,
December 1977. NTIS No. PB-278 258.
Control of Volatile Organic Emissions from Existing Stationary Sources, Volume V: Surface
Coating of Large Appliances, EPA-450/2-77-034, Research Triangle Park, NC, December
1977. NTIS No. PB-278 259.
Control of Volatile Organic Emissions from Existing Stationary Sources, Volume VI: Surface
Coating of Miscellaneous Metal Parts and Products, EPA-450/2-78-015, Research
Triangle Park, NC, June 1978. NTIS No. PB-286 157.
Control of Volatile Organic Emissions from Existing Stationary Sources,'Volume VII: Factory
Surface Coating of Flat Wood Paneling, EPA-450/2-78-032, Research Triangle Park, NC,
June 1978. NTIS No. PB-292 490.
United States Environmental Protection Agency, Office of Research and Development
"Pollution Prevention Case Studies Compendium." Publication No. EPA/625/R-93/015,
Washington, DC. February 1994.
Center for Emissions Control. "Paint Removal, An Assessment of Emission Control Options."
Washington, DC. March 1992.
United States Environmental Protection Agency, Office of Research and Development "Guides
to Pollution Prevention: The Automotive Refinishing Industry." Publication No.
EPA/625/7-91/016, Washington, DC. October 1991.
United States Environmental Protection Agency , Office of Air Quality Planning and Standards.
"National Emission Standard fen- Hazardous Air Pollutants (NESHAP) for die Aerospace
Industry - Background Information for the Proposed Standards." Publication No.
EPA/453/R-94-036a. Preliminary Draft, Research Triangle Park, NC. April 1994.
-------
United States Environmental Protection Agency, Office of Research and Development.
"Evaluation of Five Waste Minimization Technologies at the General Dynamic Ponoma
Division Plant." Publication No. EPA/600/2-91/067, Cincinnati, OH. January 1992.
United States Environmental Protection Agency, Office of Research and Development.
"Achievements in Source Reduction and Recycling for Ten Industries in the United
States." Publication No. EPA/600/2-91/051, Washington, DC. September 1991.
United States Environmental Protection Agency, Office of Research and Development.
"Industrial Pollution Prevention for the 1990s." Publication No. EPA/600/8-91/052,
Washington, DC. August 1991.
Hazardous Waste Research and Information Center. "Pollution Prevention: Illinois Industiy
Success Stories." Publication No. TN94-039, Champaign, IL. May 1994.
United States Environmental Protection Agency, Pollution Prevention Research Branch
"Pollution Prevention Research Within the Federal Community." Cincinnati, OH.
United States Environmental Protection Agency, Office of Research and Development.
"Pollution Prevention Case Studies Compendium." Publication No. EPA/600/R-92/046
Washington, DC. April 1992.
Industrial Pollution Prevention Handbook bny Hany Freeman; Chapter 29; McGraw-Hill, 1995.
-------
APPENDIX B
COMPOSITE SNAP PROGRAM ALTERNATIVES LISTINGS
FOR CLEANING AND DEGREASING
-------
• Pressure Sensitive Tape and Label Surface Coating - Subpart RR (48 FR 4837S,
10/18/83)
• Large Appliance - Subpart SS (47 FR 47785,10/27/82)
Metal Coil - Subpart TT (47 FR 49612,11/1/82)
Beverage Can - Subpart WW (48 FR 38737 8/25/83)
• Flexible Vinyl and Urethane Coating (49 FR 26892,6/29/84)
• Magnetic Tape - Subpart SSS (53 FR 38914,10/3/88)
• Plastic Parts for Business Machines - Subpart TTT (53 FR 2676,1/29/88)
• Polymeric Coating of Supporting Substrates - Subpart VW (54 FR 37551,9/11/89)
VOC limits in NSPSs are generally expressed in terms of mass of VOC per unit volume of applied solids
in the coating. Appendix D lists many of the NSPS coating limits. The reader is referred to these specific
rules for more information on the NSPSs.
HAP Rules
Several surface coating operations have been identified as major sources of HAPs. These source
categories have been targeted for the development of MACT standards. The specific source categories
and the date scheduled under the Clean Air Act for completing the MACT standards are shown below. A
MACT standard applicable to the aerospace manufacturing and rework industry was published on
September 1,1995 (60FR45948). A MACT standard was also published for magnetic tape production
on December 15,1994 (59FR64580). In addition, MACT standards were proposed on December 6,
1994 addressing surface coating in the shipbuilding and ship repair industry (59FR62681), and in the
wood furniture manufacturing industry (59FR62652). There proposed rules should be made final in the
1996 fiscal year.
41
-------
T*-
INTEGRATE) LISTS FROM FEDERAL REGISTER NOTIFICATIONS OP :
DETERMINATIONS OF ACCEPTABILITY OF ALTERNATIVES FOR
CLASS I OZONE DEPLETING CHEMICALS
UNDER THE SIGNIFICANT NEW ALTERNATIVES POLICY (SNAP) PROGRAM
(Comprehensive as of August 1996)
Section 612 of the Clean Air Act (CAA) requires EPA to review alternatives to ozone depleting substances and to publish Rsts of acceptable and
unacceptab'e substitutes. It is Megal to replace an ozone depMngchamfcal with a substitute which has been listed *s unacceptable. In
eddWon, jiy parson who produces a substitute must notify B>A at least 90 days before new or existing alternatives are introduced into
interstate coit«nen a for significant new use as substitutes.
For farther dotal on the attached decisions refer to: the foflowfy Federal Register Notices: 69 FR 13044 (March 16* 1994); and 59 FR 44240
(August 20,1994); 60 FR 3318 (January 13.1996);*00 FR 3f092 (June 13.19961; end 60 FR 38729 (July 28,19961.
FOR MORE INFORMATION ON FEDERAL REGULATIONS UNDER THE STRATOSPHS3C OZONE PROTECTION PROGRAM. PLEASE CALL THE
STRATOSPHERIC OZONE PROTECTION HOTLINE AT1-80Q-296?1996 (OUTSIDE THE U.S. CALL (202) 775-6677).'
-------
bqlvht crjifcHm *
juxsrasu 80BSTIT0TCS
Qjpdafcad Angnifc 1999
BHD USB
nMiiiuii
DBCX8ZQH
Natal*
cleaning «/
CFC-113,
KF
Aqueoua deanara
Acceptable
SPA expecta to iaaua effluent guidallnea
for thla lnduatry under the Clean Hater
Act by aa early aa 1994.
lail-aqaaou cleaner*
A&eptable
IMameta to iaaua of fluent guidallnea
for thla lnduatry under the Clean Water
Hot fay u early aa 1994.
Stzaight organic aolvant
cleaning (with fcupaiM, Cl-
C30 pateelm hydtooriwM.
oxygenated organic eolveafca
na u katooait aatara,
atteif aleoliolii ate.)
Aenptabl*
OSHA atandarda nust be wet, if applicable.
>
Trichloroethylena,
parchloroethylane , Methylene
chloride
Accaptabla
otsBA and MSA atandarda mat be net. EPA
expecta* to iaaue Maxinun Achievable
Coritrol Technology requirements under the
CleanAir Act for thia application by
1994. .
Tttllhiag oila
Acceptable
Depending on geographic region, nay be
auM act to TOC controla.
faptfecitieal fluid*
liMptabla
Volatile aatlqrl a Ooxaaaa
Acceptable
Approval la granted for the whole claaa of
ooh9oiibAp •
-
Trane-l,2-dlchloroethylene
loeqptabli
-------
I-SHD TOE 1 8QMTXT0R
DftCXSXM
—
I llMtraica I kspwou dtaasn
I classing v/-1
10641), I
1NCV I
Acceptable
• i»
BVA'expects to'laiot affluent guidelines
for this Industry Imderthe Clean Water
Act byae early aa 1994.
I I fleai-eqpeous eluntra
IflMptablt
SPA expects to issue effluent guidelines
for this industry under .the Clean Mater
Act by 1994.
1 I Straight organic aolmt
I I eltnlag (with t«ep«M« CI-
I I C20 pttnlrai Iqfdroeazbaoi,
1 1 oxygenated etfule aolwlic
I I nela es teteoM, Mttn. :
1 I athtn, ileoholi, «ke.)
Accepteble
OSBA standards wist be net, if applicable.
I I XklddoiMtl7lMW«
I 1 parchloroethylnns, aethylene
I 1 chloride
Jkoceptable
08HA and BCRA standards wist be met. BM
expects to issue Maxinua Achievable
Control Technology requirements under the
Clean Air Act for this application by
1994.
I I Ko-elMB lltKUtiTU
Acceptable
Substitutes found acceptable include low
solids fluxes and inert gas soldering.
I I Supercritical fluids, plana
I I cleaning, UV/Osone cleaning
Acceptable
OSBA standards for ozone wist be net.
I 1 Volatile Mtlqrl lilosaBM ,
Acceptable
Jlpprfrral is granted for the whole class of
cospounds.
1 J Tran«-l,2-dichloroethylene
Acceptable
-------
no oss
rasvznm
raczflzov
— '
Precision
cleaning w/
CFC-113,
ttBwna elauuri
Acceptable
SPA expecta to iaaue effluent guideline*
for this industry under the Clean Water
Act by aa early aa 1994.
MOT
flMl*>4Mou elanara
Acceptable
EPA expects to iasue effluent guidelines
for this industry under the Clean Water
Act by as early as 1994.
Straight organic solvent
cleaning (with tatpann. Cl-
C20 pttcolm hydrocarbon*,
oxygenated organic lolTanti
jMb as katoMi, aafcara*
ethers, alcohols# ate.)
Acceptable
OSHA atandarda mist be net, if applicable.
Trichloroethylene,
perchloroethylene. methylene
chlorida •
Acceptable
OSHA arid ion standards wist be met. SPA
expects to issue Maximum Achievable
Control Technology requirements for this
application by 1994.
Supercritical fluids, plana
elaniaff VT/Oiom cleaning
Xeo«tabl«
OSHA standards for ozone must be met.
scv?-ias
.'.cceptable
M nAn'tf 3Qppm.
¦
Trans-l,2-dlchloroetbyl«e
Acceptable
volatile aathfl siloxanes
Acceptabla
Approval is granted for the whole class of
compounds.
-------
SOLVENT CLSJUVUVQ
SUBSTITUTES ACCEPTABLE SUBJECT TO
KUtROKED QSB LIMITS
I BD 081 I BUMTll'VTB
DKXSXfP
I ttMteoalea 1 Mrflwio-
1 cleaning w/ 1 carbons
I c?c-ii3. I testis, cms,
|"C* Icitu. C7fi«,
I 1 ctvit.
I 1 csnimo,
I 1 cfiriaso,
I I C7F15IO. and
1 Icsric)
leeeptablt Cor
hlgh-perfwnMBO,
precision-/
engineered
applications only
where reasonable
efforts, have been
made to ascertain
that other
alternatives are
not¦technically
feasibly due 'to
performance or
safety reqpi* reaents
The principal environmental'chsracteriatic of
concern Cor PPCs is that they have long etmospheric
. lifetimes and high global warning potentials.
Although actual contributions:to global warning
dsperi upon the quantities of PPCs emitted, the
effects ere for practical purposes irreversible.
User must observe this limitation on PFC
acceptability by conducting a reasonable evaluation
of other substitutes to determine that WC use is
necessary to eieet performance.or safety
requirements. Documentation ofthis evaluation oust
be kept on file.
For additional guidance regarding applications in
which i>FCs nay be anpropriete, users should consult
the Freaable for this rulemaking.
I Vcaolalw 1 Nrflnoco*
1 cleaning v/ 1 eerbona
ICFC-113, 1 (C5F12, at 11.
I Her I c«ri«, cific,
I I cmi,
I 1 csfiito,
I I CCF13H0,
1 I C7F15KO, and
I 1 carici
Acoepteble Cos
high-performance(
precision-
engineered
applications only
where reasonable
efforts have been
nade to ascertain
that other
alternatives ere
not technically
feasible due to
performance or
I safety requirements
I i.i lii mi. ii u i i ' i
The principal environmental characteristic of
cone, rn for PKs is that they have long atmospheric
lifatiswe and high global warming potentials.
Although actual contributions to global warming
depend upon the quantities of PPCs 'emitted, the
effecte are Coir practical purposes irreversible.
Users aust observe this limitation on PFC
acceptability by conducting-a reasonable evaluation
of other substitutes to determine.that PFC use is
necesssry to meet performance' or eafety
requirMMts. Documentation of this evaluation must
be kept on file.
j For additional guidance regarding applications in
which PFCs maw be appropriate, users should consult
1 the Pmiwills for this rulemaking.
-------
NLVBT CLKMTZM
SUBSTITUTES ACCftPTABLK. 8UBJ1CT TO
USE RESTRICTIONS
BHD US*
SUBSTITUTE
DSCI8I0B
CONDITIONS
CONNORS
Electronics
elMalag w/
CTC-113,
ncr
KCFC-225ca/cb
Acceptable
Subj ect to the company-
set exposure Unit o£ 25
ppm far the -ca.isomer
HCPC-225ca/cb is offered
as an isomeric blend.
The cotqpany-set workplace
standard for the cb-
isomer is higherr-250ppm.
The use of the less taacic
cb-isomer in the blend
suggests that the 25 ppm
standard for the ca-
isomer can be readily
met.
Vrscision
cleaning w/
CTC-113,
ua
¦CVC-225ca/cb
'
Acceptable
Subject to the company-
set exposure limit of 25
ppm Cor the -ea isomer
HCFC-225ca/b is offered
as an isomeric blend
The company-set workplace
standard for the cb-
isomer is higher--2S0ppm.
The use of the lees toxic
cb-lsomer in the blend
suggests that, the 25 ppm
standard for' the- ca-
isomer can be readily
met.
-------
tnsiaion
cleaning •/'
CFC-113
¦CVC 141b and
lta blends
Unacceptable
High 00V) other ilttttitiTM exist. Effective date: As of
30 day* after final.xvla for usaa in new equipment
(including ratrofittf;«ada after the effective date)> aa of
January l, i»9S for uaee in axiating equipment. BPA will
Scant, if neceaaary, narrowed una acceptability liatinga
for CTC-113 paat the.off active date of the prohibition.
IXWlllM,
elknlag *»/
iicr
SCVC 141b and
its blends
Unacceptable
High OOP) other alternative! exist. Effective date: Aa of
30 daya after final rule for usee in new equipment
(including ratcofita «ada aftar the effective date)i aa of
January 1, 199S Cor taaea in axiating equipment.
-------
GLKNRVO'
iiiuxm maammm
BB USE
80B8T1TUTI
COHOSH
Ha tali cleaning
w/ arc-113,
ncr, and «cpc-
141b
acrc-122
Agency la still reviewing ODP. .'HUB HCPCis a new.
dia^cal aid mst also complete ?reaanufacture notice
requirements under the Toacic Substances Control Act.:
HFC-4310a«e
SNAP/Prenanufacture Notice review under the Toxic
Substances Control Act nrsrly completed.'
Klectronica
claming «/
arc-113, ncp
and MFC-141b
Parfluoropolyethars
Agency evaluating global warning concerns.
llMtnaiea
cleaning w/
ncni-14ib
Ferflnorocaxbena (CSVU,
cms, c«ri4, cmr, emi,
cspiuo, ccri3vo, crnsao, and
canc)
Agency in process of evaluating global warning
concerns.
Precision
cleaning*/
CFC-113, ncr
BCPC-122
Agency it still reviewing OOP. This ttCFC is a new
cbenical and nust also complete Prenanufacturd notice
requir—ants under the Toxic Substances Cpfctrol Act.
¦rc-4310nse
<8W and Pr—anufacture Notice review under the Toodc
Substances Control Act is nearly completed.
ChloBflbmoMtbaM
BPA is ooapleting a nore detailed analysis on the
range of OOP for this substitute and is reviewing
updated intonation on the toxicity of this
substitute.
Precision
elaanlag »/
SCPC-141b
Perfleoroearbons (CSV13,
cms, ciri4, cTfii, cma.
csniiio, ccpi3vo, cmsm, and
CtPlC)
Agency in process of evaluating global warning
concerns.
-------
APPENDIX C
SOLVENT INFORMATION DATA SYSTEMS
-------
Hazardous Solvent Substitution Data System
EG&G Idaho, Inc. a management and operations contractor at the U.S. Department of
Energy's Idaho National Engineering Laboratory, has been charged with developing a list of
products that may be used as substitutes for hazardous solvents.
Because of the dynamic nature of regulatory agency requirements with respect to the risks
that chemicals pose to human health and the environment, risk assessments must be conducted
before any process changes can be made or any new processes can be initiated. The risk
assessment process requires interaction and cooperation between a variety of disciplines. A brief
description of the process follows.
To use a particular solvent, the user needs to know the types of soils the product will
remove, its base material compatibility and application capability, and any history of use of the
product by industry. The industrial hygienist must review the Material Safety Data Sheets
(MSDSs) to assess whether the chemical element or compound is on any of the hazardous
constituents lists prepared by regulatory agencies and to assess the toxicity, exposure criteria,
ecology, and methodology with respect to the proposed use of the product The process engineer
must know if existing equipment can be used or modified, or if the proposed use requires
additional capital investment The process engineer must also know if the product is recyclable
and if the spent product is biodegradable. The process manager must be assured that the user's
safety will not be at risk, that the process complies with regulatory requirements, and that the life
cycle costs are within the budget estimates.
To meet the information needs of the various disciplines, the Hazardous Solvent
Substitution Program has developed an unstructured data system. The system allows of
die technical product data sheets provided by manufacturers. These are processed by optical
character recognition technology, which enables the use of full text retrieval technology. The
technology allows the user to query the data system using word and topic searches in conjunction
with boolean and context operators. The system also provides a link to vendor-supplied MSDSs
for each product. The chemical compound or elements of the product can be compared against
the hazardous constituents lists. This capability includes a feature that highlights those products
that appear on the lists. Toxicity and biodegradability data may be linked to the product or to the
compound or chemical elements of the product. Performance Hatn test and product use
references may also be linked to each product. The solid line shows data linkage to product that
presently exists, the dotted line shows data that will be linked in the near future.
-------
The following is a description of each type of document available on the Hazardous
Solvent Substitution Data System:
Product Hatfl - The product data is the base document. It lists the product name and the
name, address, and phone number of the manufacturer. The technical data addresses the
types of soils that can be cleaned, the applications (immersion, spraying, etc.) and the
mnh»rjjak with which the product is compatible or incompatible. In most cases, data
required in the MSDS is also listed in the technical data. The text is scanned as American
Standard Code for Information Interchange (ASCII) code; it is also scanned as an image
because some of the product information sheets con-tain graphics, tables, or charts that
are not available in text-only retrieval.
Material safety data sheets - The MSDSs are scanned as images only because of the poor
print quality of many MSDSs. This prevents the processing of undetected errors and
f iiminflfrs the liability associated with changing an MSDS. The MSDS is linked to the
product, making it available for immediate review when a user views the technical data.
ry-mical clgirvnts list - The chemical elements list is derived from the list of chemical
elements and/or compounds in the MSDS. This feature allows a user to query the system
on the types of chemicals that make up the product. A comparison can also be made to
the chemical elements or compounds contained in the regulatory lists of hazardous
constituents.
Hazardous constituents list - This feature lists the chemical elements designated as hazard-
ous under the various worker and environmental protection laws.
EPA and other toxicity reports/data - This feature provides information on toxicology
tests and reports that have been generated on various chemical elements, chemical
compounds, and chemical families or groups. These reports are also linked to products.
An industrial hygienist can immediately review test data for chemicals on which toxicology
reports are available.
Usage reference - The usage data describes how the product is used in industry: the
application, the process parameters, and any sources of additional information.
-------
Contact:
Kevin E. Twitchell
Idaho National Engineering Laboratory
P.O. Box 1625
Mailstop 1604
Idaho Falls, ID 83415-1604
(208)526-6956 voice
(208) 526-8480 fax
-------
Solvent Alternatives Guide (SAGE)
In 1982, AEERL initiated a program to assist in the selection of nonpolluting industrial
surface cleaning alternatives. The objective of the program was to make the identification of
cleaning options simple yet based on the latest technical and economic feasibility information
available. This objective could be most easily accomplished through the use of electronic
equipment and a logic tree format The resulting system called SAGE for Solvent Alternatives
Guide incorporates the speed and ability of the computer to evaluate a large number of operating
parameters and conditions to identify the most viable surface cleaning option. The first BETA
test version 1.0, of SAGE was released in May of 1993 and placed on the control Technology
Center Bulletin for down loading and review. Version 1.0 included only metal surface solvent
cleaning and was designed to test the SAGE concept for selecting surface cleaning alternatives.
Since its release there have been over 100 down loading of SAGE from the GTC bulletin board
and another 100 copies of the system disk was mailed to requestors. Many of the responses from
users of the BETA test version indicate that the system in a few minutes confirmed their prior
conclusions derived from many hours of study and analysis. The report also gave many users
greater insight into the technical considerations and requirements for use of die various options
which were previously unknown. The results of the responses have validated the concept used in
the SAGE system. The system has been featured in a number of trade magazines including
"Product Finishing," and "The Journal of the American Electroplaters and Surface Finishers
Society."
SAGE is not a database rather a PC based logic tree system that evaluates the users
present operating scenario and then identifies possible surface cleaning alternative solvent
chemistries and processes that best suits the defined operating and material requirements. The
system asks a series of questions concerning the users existing operation such as: part size,
present processing chemistry, part cost, production rate, and contaminants. Based on the answers
provided a number of recommended options is provided which represent the most probable
alternate cleaning chemistry and/or process. The report generated by SAGE presents the
recommended options and important technical parameters. It also provides information on
environmental considerations that must be taken into account, regulations that must be addressed
when using the alternative, safety requirements, economic considerations, and equipment
requirements, and other information that must be considered when implementing the
recommended alternative. Finally, the repeat will include examples of case studies with a similar
operating scenario and requirements.
SAGE is designed for use by individuals ranging from shop foremen to regulatory agency
personnel, both technical and nontechnical personnel. It requires only a 286 level wMrfiiiw and a
printer if a complete report is required. The SAGE system is scheduled for continued upgrade
through FY 95 with quarterly release of new versions during this period. Subsequent versions
will incorporate into the system additional surface cleaning requirements such as paint stripping,
electronic manufacturing, machinery, and printing equipment cleaning. In addition a process and
frcility design capability, economic and cost projection capability, and a regulation summation by
gtate will be incorporated into the system.
-------
While the final selection of a process alternative must ultimately be made by the
SAGE will provide the user with the information needed to make that choice.
Contact:
Charles H. Darvin
National Risk Management Research Laboratory (MD-61)
Office of Research and Development
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
(919) 541-7633
-------
NCMS Solvent Database
The NCMS Solvent Database is an electronic database providing access to information on
environmental fate, health and safety data, regulatory status, chemical/physical properties, and
suppliers. The database includes over 320 pure solvents and trade name mixtures. Each record
includes 15 fields of environmental fate, 31 fields of health and safety, 21 fields of regulatory
status, 36 fields of chemical/physical properties, and 19 fields of descriptive and supplier data. A
relational search capability will enable users to identify potential alternative solvents or mixtures
which meet preselected criteria. For example, one can request a list of alcohols exceeding a flash
point of 4S*C and not regulated under SARA 313. Users can also display and print customized
data tables by choosing solvents and properties from pick.
The NCMS Solvent Database is a stand-alone application running undo- Paradox
Runtime. The database is distributed on floppy disks. System requirements are a 100% IBM-PC
compatible computer with a 386 or later processor and a hard drive with 6MB of available disk
space. You will also need 2MB RAM configured as extended memory, DOS 3.0 or later, and
CGA, EGA, VGA, or compatible monitor. The Solvent Database supports the use of a mouse
and IBM, HP and Epson-compatible printers.
Contact:
Mike Wixom
Project Manager
Environmentally Conscious Manufacturing
National Center for Manufacturing Sciences
3025 Boardwalk
Ann Arbor, MI 48108-3266
313/995-4910 (voice)
313/995-1150 (fax)
mike.wixom@ncms.org (internet)
-------
APPENDIX D
EXAMPLE LIMITS FOR VOCs FROM SURFACE COATING OPERATIONS
(from EPA Report: Recordkeeping Guidance
Document for Surface Coating Operations and
the Printing Industry 7/89, EPA 340/1-88-003).
-------
ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
Operation
Pounds VOC per gal coating
nlnus water4
1. CAN COATING
CTG Limits
a) Sheet basecoat (exterior and
Interior) and over varnish;
tvo piece can exterior base
coat and over varnish
2.8
Established based on 25 volume
percent solids and 80:20 voluae nix
of water and VOC
b) Two and three piece can
Interior body spray* two
piece can exterior and
(spray and roll coat)
4.2
Establish based on 18 voluae percent
sol Ids and 70:30 nix of water and
VOC
c) Three piece can side-sen
spray
5.5
d) End sealing compound
3.7
CTG Reference:
EPA 450/2-77-008, Vol. II.
Hay 1977
NSPS Limits
From two piece beverage can
surface coating operations:
Each exterior base coating
except clear base coating
operation
2.4 lb/gal of coating solids
Each over varnish coating
andeach clear base coating
operation
3.8 lb/gal of coating solids
-------
ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Each Inside spray coating
operation
NSPS Reference:
40 CFR 60 WW; 1983
NSPS BID:
EPA 450/3-80-036a & b
CaHfomia Limits
Sheet base coat (exterior and
interior) and over varnish
Two piece can exterior base
eaat and over varnish
Pounds VOC per gal coating
minus water*
7.4 lb/gal of coating solIds
2. PAPER COATING
CT6 Limit!
Coating line (consists of the
coatings put on paper, pressure|
sensitive tapes regardless of
substrate (Including paper,
fabric, or plastic f1l«) and
related web coating processes
on plastic film such as type-
writer ribbons, photographic
film and oagnetlc tape.
Alto Included 1n paper coating
category are decorative
coatings on aetal foil such as
gift wrap and packaging.
2.9 (1.0 California)
CT6 Reference:
I tea 1
The sane as for
-------
ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water1
a) Prime application, flashoff
area, and oven
1.9 (1.2 Delaware Holt)
Prime coat (15.1 lb/gal
solids applied—later
gu1dance)
1.2
Guide coat (15.1 lb/gal
solids applied—later
guidance)
2.8 at baseline TE • 30 percent,
Established based on the use of
water-borne coatings
b) Topcoat application,
flashoff area, and oven
2.8 At baseline TE - 30 percent.
Established based on the use of
water-borne coatings
e) Final repair application,
flashoff area, and oven
4.8
CTG Reference: The sen as for
Iten 1
NSPS Limits
Prime coat
Guide coat
Top eoat
I.3 lb/gal solids applied
II.7 lb/gal sol ids applied at
baseline TE • 39 percent
12.2 lb/gal solids applied at
baseline TE • 37 pereent
A requlreomit of the NSPS 1s
that the operator oust conduct
a perfornance tost each calen-
dar aonth and report the
results to EPA within 10 d«ys.
The calculation of the vol use
weighted average mass of VOC
per volume of applied coating
-------
ALLOWABLE YOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water9
solids during each month con-
stitutes a performance test.
While RM 24 1s the reference
method for use in this perfor-
mance test to determine data
used 1n the calculation of the
volatile content of coatings,
provisions have been made to
allow the use of coatings manu-
facturers 1 formulation data to
determine the volume fraction
of solIds. Zf an Incinerator
is used, owner must submit a
quarterly report on incinerator]
performance.
USPS Reference:
40 CFR 60 MM; 1980
NSPS BID: 450/3-79-030aib
California Limits
SCAQMD Rule 1115
a) Prime application, flashoff
area and oven:
for electrophoretic primer
for primer surfaeer
for spray primer
b) Topcoat application, flash-
off area, and oven
(1.2 at baseline TE
(2.8 at baseline TE
(2.3 at baseline TE
Massachusetts has separate
Halts for primer application
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ALLOWABLE VOC UNITS FOR SURFACE CQATXR6 OPEXATZONS
(Continued)
Ooeratlon
Pounds VOC per gal coating
minus water4
Exemptions 1n Virginia: Wheel
enamels* ant1 -rust coatings and
sealers not associated with
prime or top coat application
to the vehicle body.
Exemption in Delaware: Coating
lines emitting less than 40
lbs/ day per facility
7. SURFACE COATING OF LARGE
APPLIANCES
CTS Limits
2.8 at baseline TE ¦ 60 percent
CTS Reference: Vol V
NSPS Limits
7.5 lbs/gal of applied coating
solids
Established based on 62 vol use
percent solids applied at a TE
of 60 percent
NSPS Reference:
40 CFR SS, 1982
NSPS BID: 450/3-80-007alb
C*Hfa»n
Air dried or forced air dried
coatings
(2.8)
Baited coatings
(2.3)
Industrial machinery:
ExtraM performance coatings
If dried at >90°C
(2.8)
(2.3)
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