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Industrial

Painting &
Coating

Regulatory
Requirements
and
Pollution
Prevention
Ideas

Prepared by the Kansas Small Business Environmental Assistance Program


What Is SBEAP?
The Small Business Environmental uct design, substitution of materials,
Assistance Program, SBEAP, was ini- process optimization, waste mini-
tiated as a result of the Clean Air Act mization, and recycling—all of
Amendments of 1990. SBEAP helps which can help diminish the burden
small businesses comply with envi- of compliance and protect the envi-
ronmental regulations by providing ronment.
technical assistance, introducing
businesses to pollution prevention SBEAP operates independently of
practices, and offering compliance the Kansas Department of Health
assistance to help with environmen- and Environment, KDHE, but coordi-
tal permitting and reporting require- nates with the agency to ensure that
ments. In Kansas, the Pollution SBEAP’s interpretation of Kansas
Prevention Institute at Kansas State regulations is consistent with
University is the technical assistance KDHE's intent.
provider for SBEAP. All SBEAP serv-
ices are completely confidential, To obtain technical assistance or
non-regulatory, and free. request an on-site assessment, call
800-578-8898. SBEAP also operates
Because services are free, SBEAP a Web page at www.sbeap.org. It
provides guidance in compliance and contains SBEAP publications, includ-
technical matters to businesses that ing our quarterly newsletter, Kansas
otherwise would not have access to AIRlines. It also has industry-specific
such help because of financial con- information and a calendar of
straints. Its staff can introduce you events.
to such practices as changes in prod-

1
Table of Contents
Introduction .....................................................................................................................3
Substrate Surface Preparation..............................................................................4
Coating Application ..............................................................................................6
Drying and Curing ................................................................................................8

Coating Application Types and Technologies ..................................................................9


Low-Volume High-Pressure Spray (LVHP) Systems ...........................................10
High-Volume Low-Pressure (HVLP) Systems ....................................................11
Powder Coatings .................................................................................................13
Electrostatic Paint Systems ................................................................................14
Airless and Air-Assisted Airless Systems............................................................15
Other Technologies.............................................................................................16

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


High-Solids Coatings...........................................................................................20
Water-Based Coatings .........................................................................................21
Powder Coating...................................................................................................22
Ultraviolet (UV) Radiation-Cured Coatings........................................................23

Pollution Prevention for the Coating Industry...............................................................24


Hierarchy of Pollution Prevention Strategies .....................................................26
Priority 1: Source Reduction..............................................................................27
Priority 2: Recycle and Reuse ............................................................................33

Coating Operator Techniques ........................................................................................35

Regulatory Issues............................................................................................................37
Waste Disposal Regulations ................................................................................38
Air Regulations ...................................................................................................49
Wastewater Regulations......................................................................................57
Water Regulations...............................................................................................59
Community Right-to-Know Regulations.............................................................60
Health and Safety ...............................................................................................63

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

2
Introduction
Paint usage has environmental Why paint? Paints and other surface
impacts at all stages of its life cycle, coatings provide protection to a
including manufacturing, applica- product, as well as being decorative
tion, and eventual disposal. The pur- and eye-catching. Generally, paint
pose of this manual is to provide type and means of application are
general background information on dependent upon what function the
environmental compliance require- coating must perform. General steps
ments for painting application opera- for painting and coating applications
tions, with specific emphasis on typically include the following:
minimizing wastes through pollution
prevention. The manual reviews var- ■ substrate surface preparation
ious coating applications, coating ■ application of the coating
types, pollution prevention opportu- ■ drying of the coating
nities, and environmental regula-
tions. If you have questions or Preparatory, application, and drying
would like further information on processes chosen depend on many
materials presented here, you can factors, including your clients’
contact an SBEAP specialist by call- demands and anticipated rate at
ing 800-578-8898, or view any of our which you have to get products fin-
publications by visiting our Web site ished and delivered.
at www.sbeap.org.

3
Surface Preparation
Surface preparation of the material bond between the coating material
(substrate) to be painted is very and the surface, and ensures the
important. As high as 80% or more of coating is applied and adheres in a
all coating adhesion failures can be uniform manner. Examine your
directly attributed to improper sur- operations and see if there is a way
face preparation.1 A substrate must to minimize the amount of cleaning
be clean before a coating is applied. required by keeping your substrate
Improper preparation can lead to a from getting dirty during storage or
lower quality or defective product, processing.
or one that is not visually appealing.
The most common forms of surface Mechanical Cleaning
debris are oils or greases that origi-
nated from mechanical processing, The first step in your preparation
or are deliberately applied for pur- process should be mechanical clean-
poses of corrosion prevention during ing. Wiping loose dust and dirt off
temporary storage or shipping. Other your parts with a rag is an easy
surface contaminants commonly example. More vigorous action may
include oxidation, rust, corrosion, be needed to remove rust or other
heat scale, tarnish, and in some contaminants strongly attached to
cases, old paint. Dirt, grease, or the part. For wood surfaces, sanding
other similar materials will block the followed by wiping with a lint-free
bonding surface and create an cloth is effective. For metal sub-
imperfection on the finished part. strates, metal scale and rust can be
Proper preparation improves the removed by brushing the part with a
wire brush, a sand or grit blaster, or
plastic “wool” pads.

1
North Carolina Division of Pollution Prevention
and Environmental Assistance, April 1998,
Pollution Prevention in Metal Painting and
Coating Operations

4
Chemical-assisted Cleaning
Another option for preparing your solutions are used to clean and
parts for painting includes chemical- remove rust and scale from metal
assisted cleaning. Traditionally, sol- substrates because no hydrogen
vents have been used to remove oily- embrittlement results. Elevated tem-
type contaminants through wiping, perature solutions are more effective
spraying, dipping, or vapor degreas- for removing greases and oils, but
ing. But there are problems associat- the energy consumption needs to be
ed with solvent cleaning. Spraying considered.
can be wasteful, dip tanks can lead
to large quantities of hazardous Conversion Coatings
waste being generated, and vapor
degreasers are regulated under envi- For those working with metal sub-
ronmental laws and pose a potential strates, a conversion coating may be
health hazard. Also, solvent-contam- applied to metal prior to painting to
inated rags may need to be disposed improve adhesion, corrosion resist-
of as hazardous waste. ance, and thermal compatibility.
Conversion coatings chemically
With such issues in mind, some have react with the metal surface to build
switched from solvent to aqueous a more complex physical surface
cleaning, which is generally more that improves the bonding of the
environmentally friendly. Acidic coating. Iron and zinc phosphate
solutions effectively remove rust, coatings are usually used for steel.
scale, and oxides from metal sur- Iron, zinc, and chromium phosphate
faces, but can cause hydrogen are all used when it comes to coat-
embrittlement as hydrogen gas ings for aluminum, with the choice
formed penetrates the metal and of solution largely depending on the
reduces its strength. Mild alkaline volume of aluminum being
processed.

5
Coating Applications
Which paint or coating application Coatings consist of resins, pigments,
process you choose will depend on solvents, and additives. Particular
your particular operations. What is types of coatings you’re applying will
the material you are coating? What have varying amounts of each of
are the chemical and physical char- these constituents. Resins or binders
acteristics the coating must have? hold all paint constituents together
What is the shape and size of the and enable them to cure into a thin
product—does it have a unique plastic film. Resins are made up of
shape that might make uniform polymers, which are chosen based
application more difficult? How on physical and chemical properties
many products must you paint each desired in the finished product.
shift? Acrylics produce a shiny, hard finish
with good chemical and weather
Several factors affect how good the resistance. Alkyds are relatively low
paint coverage is on the piece, as in cost and because of their versatili-
well as the transfer efficiency of the ty are considered a “general pur-
application. Transfer efficiency is the pose” paint. Epoxies provide excel-
relationship between the amount of lent water resistance and superior
paint you apply and the amount of chemical resistance, but do lose
paint actually adhering to the part their gloss from ultraviolet light.
being coated. The higher the transfer Urethanes combine high gloss and
efficiency of your process, the more flexibility with chemical stain resist-
paint you are getting on your part ance, and demonstrate excellent
and the less overspray you have. water resistance.
Your equipment and booth setup,
the type of paint you’re applying, the
particular product you’re coating,
and your painting operators’ skill all
factor into how efficiently you’re
using your paint.

6
Pigments are tiny particles insoluble Many of these same chemicals may
in paint incorporated to improve the cause any solid wastes generated as
physical appearance of the coating. part of your painting operations to
Additives are also used to impart become hazardous wastes.
specific physical or chemical proper- Additionally, any discarded products
ties to the coating. Some pigments may fall under the Resource
or additives may contain metals Conservation and Recovery Act
which may classify any resulting (RCRA), or hazardous waste regula-
solid wastes as hazardous. Paint per- tions.
formance may be improved by
adding curing agents, defoamers, The next chapter goes into detail
gloss modifiers, or other agents. about different coating application
types and technologies currently
Solvents are used to carry the coat- being used.
ing solids to the part being painted.
They are also added to paint to aid
in its application by reducing viscos-
ity so the coating may be easily
applied. Solvents are a major source
of environmental concern in coating
applications because as curing
occurs, hazardous air pollutants
(HAPs) and volatile organic com-
pounds (VOCs) are released.

7
Drying and Curing
Getting the paint or coating to your If the resin or binder is said to be
product’s surface is only half of the convertible, then it undergoes some
process—the other half being how form of chemical reaction to trans-
the coating will be transformed into form it to the solid film. If the resin
the hard, protective, decorative fin- is non-convertible, then it is only the
ish that your clients will desire. Will evaporation of the solvents in the
your paint dry by evaporation? Will paint that causes drying and results
drying outside your booth be neces- in the desired film. Some coatings
sary due to your choice of coatings are cured by a process that can be
or to your product schedule? controlled, such as baking, providing
an opportunity for overspray to be
collected and recycled.

8
Coating Application Types
and Technologies
Besides the “conventional” method even how much room you have in
of applying coatings, many choices your business. The following are
exist for someone who is involved in summaries of some available tech-
painting or coating operations. The nologies. If you have specific ques-
right choice for you depends on your tions, call SBEAP at 800-578-8898,
particular business operations—the and we can work with you and your
type of pieces you coat; the finished vendor to determine if these systems
appearance requested by customers; will work for you.
money available for equipment,
training, and maintenance costs; and

9
LVHP
Low-volume high-pressure spray overspray, increased booth cleanup
(LVHP) is considered the conven- costs, and increased filter use and
tional method of applying coatings. related costs. Additionally, if a high-
It depends on air-atomizing the paint er coating thickness is necessary,
at pressures of 40–70 pounds per more operator passes may be neces-
square inch (psi). Air is supplied sary to get the desired mil thickness,
from an air compressor or turbine. and hence application time is
While these spray systems create increased.
high quality finishes at high produc-
tion rates, they do have several dis-
advantages, including extensive

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HVLP
The principle of high-volume low- HVLP guns allow operators to finish
pressure (HVLP) has been applied to intricate parts with comparable qual-
“conventional” spray guns to apply ity to conventional sprayers. This
paint with a high volume of dispers- makes them a good choice for small
ing air at low pressures. HVLP guns shops that finish smaller, more intri-
have nozzles with larger diameter cate parts which demand a higher
openings for atomizing air, can be level of gun control. Other advan-
bleeder or non-bleeder types, and tages of the HVLP system include
require air volumes of 10–30 cubic the following:
feet per minute. Air and fluid deliv-
■ transfer efficiencies, from 50 to
ery to the spray gun affect the effi-
90 percent reported, depending
ciency, ease of use, cost, and versa-
on the air-delivery system used
tility of HVLP sprayers.
■ reduced amount of overspray,
and hence material use
In a siphon-fed HVLP system, air
■ reduced VOC and HAP emis-
pressure to the sprayer is used to
sions
pull paint from the cup located
■ reduced paint booth filter use
below the gun, producing a fully
and cleanup costs
atomized pattern for even surface
■ reduced worker exposure due to
coverage. Gravity-fed HVLP systems
high-pressure “blowback” from
are well adapted for higher viscosity
the spray
paints, such as clears, water-based
■ good coverage of intricate parts
paints, high-solids paints, and epoxy
■ finish quality comparable to con-
primers, given the paint cup loca-
ventional air sprayers
tion. The cup, located at the top of
the gun, allows paint to completely
drain, minimizing paint waste.

11
■ comparable transfer efficiencies HVLP systems, however, do have
to air-assisted airless sprayers at some disadvantages, including diffi-
low-fluid delivery rates, with low culty in obtaining higher fluid deliv-
to medium viscosity fluids ery rates with high viscosity materi-
■ more efficient air atomization als, and a lack of sufficient atomiza-
■ air-spray coating adaptable to tion required for some fine finishes.
any size coating operation and
application rate
■ equipment fittings allow for fast
color changes and application of
very different fluid viscosities

12
Powder Coating
Powder constituents are very similar of gun chosen for a given coating
to wet paint with resins, pigments, line can be matched to the perform-
and additives, but lack a solvent car- ance characteristics needed for the
rier. When powder coating, powder products being coated.
is supplied to the spray gun by the
powder delivery system. This deliv- Powder coating became a major fac-
ery system consists of a powder stor- tor in the metal finishing industry
age container, or feed hopper, and a when the electrostatic spray process
pumping device that transports a (see next section) was introduced in
stream of powder into hoses or feed the 1960s. Electrostatic spraying
tubes. Compressed air is often used made it possible to apply thin layers
as a “pump” because it aids in sepa- of coating for higher quality decora-
rating the powder into individual tive finishes, and allowed powders to
particles for easier transport. Powder be used on parts not suitable for dip-
spray guns impart an electrostatic ping in a fluidized bed. As the pow-
charge to the powder being sprayed der coating technology continues to
via a charging electrode located at develop, advances have been made
the front of the spray gun. Managing in powder formulations to offer a
the electrostatic field can direct the wider range of colors, glosses, and
powder’s flow and control pattern textures.
size and shape, and powder density
as it is released from the gun. The higher transfer efficiencies asso-
ciated with powder coating are par-
All spray guns can be classified as tially due to the recycling and reuse
either manual or automatic. of powder overspray.
Although basic operating principles
of most guns are the same, an almost
limitless variety in style, size, and
shape of spray guns exists. The type

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Electrostatic Paint Systems
Electrostatic paint systems deliver Electrostatic systems must be prop-
paint that has been atomized by var- erly grounded at all stages of paint
ious methods, such as air-atomizing, delivery to reduce injuries and fire
airless, or rotary. The atomized fluid hazards that can result from shorting
droplets are given a negative charge or sparking. Compounds or compo-
as they leave the spray gun. The nents that conduct electricity,
charge causes the paint particles to diverting electrons from the paint
be “attracted” to the part, and if circuit, decrease system efficiency.
high enough, can cause the paint Humidity also reduces transfer effi-
particles to actually reverse direc- ciency.
tion as they pass, coating the edges
and back of the part (an effect called
wrap-around), increasing transfer
efficiency. In some cases, even
water-based paints can be applied.
An advantage of these systems is the
uniform coating thickness produced.

14
Airless and Air-Assisted Airless Systems
A method of atomizing paint is to Air-assisted airless sprayers look
increase the spray gun’s fluid pres- very much like air-atomizing guns.
sure to 500–6500 psi and redesign Paint is delivered to the guns at
the fluid nozzle so paint is atomized pressures of 150 to 800 psi. Air is
without pressurized air flow. Airless used to shape the pattern of the fluid
guns are effective for applying high- spray leaving the gun nozzle. The
viscosity coatings with relative ease major difference between airless and
since there is only one hose attached air-assisted spray guns is the atomiz-
to the gun. The airless system pro- ing tip—an air nozzle allows jets of
vides high delivery rates (useful for atomized air to exit from ports in
fast-moving production lines), with small projections on each side of the
the size of the nozzle determining tip. The air jets hit the paint stream,
quantity and thickness of the paint breaking up larger droplets of paint
applied to the part. This system also and atomizing it to a finer degree.
has higher transfer efficiencies than While having a high capital cost, air-
conventional spraying. These sys- assisted airless spray systems have
tems do have some disadvantages, good atomization and high transfer
including expensive nozzles and efficiencies, are capable of reaching
increased maintenance, a tendency high production rates, can handle a
for tip plugging, increased operator wide range of fluid viscosities, have
training and skill due to skin-injec- improved finish appearances as com-
tion danger, reduced fan pattern pared to airless technology, and have
control, and limited coating types. lower equipment maintenance due
to lower operating pressures.

15
Other Technologies
Rotary Atomizers Dip Coating
Paint is fed to the center of a spin- Parts are coated by being dipped
ning disk or bell, and use centrifugal into vats of paint. Dip coating
force to break the paint into requires paint viscosity to remain
droplets. These devices use electro- constant to assure acceptable film
static charge to guide the paint to quality and is not suitable for items
the part being coated. Electrostatic with cavities. This process works
charging also plays a key role in well on parts that are always the
atomizing the paint at low speeds. same color and have minimum deco-
Rotary atomizers are well suited for rative finish requirements, such as
covering large, broad surfaces; have agricultural equipment.
high transfer efficiencies; and have
high solid, waterborne versatility.
Other advantages include the cre-
ation of a spray without use of thin-
ner and higher transfer efficiencies.
These systems do have some draw-
backs, including increased equip-
ment maintenance needs and safety
hazards.

16
Flow Coating Autodeposition
These systems use 10 to 80 separate This process relies on a chemical
streams of paint that coat all the reaction to deposit an organic coat-
part’s surfaces. Like dip coating, this ing onto iron, steel, zinc, and zinc-
process is best suited for standard- alloy plated materials. The part is
ized color needs with low decorative immersed into a solution containing
finish requirements. Paint viscosity the coating compounds. When the
controls coating thickness, and an part is submerged, the paint com-
area must be provided for the part to pound precipitates out of the solu-
hang while dripping excess paint. tion and coats the part. The part is
then removed from the tank, rinsed,
and cured. This process does not use
organic solvents, so no VOCs are
emitted.

17
Electrodeposition
This system, like the autodeposition paint resin, which deposits onto
system, requires the part to be parts, creating a uniform coating.
immersed in a waterborne coating. Although the coating contains some
The cosolvent is typically an organic solvent, this process has low VOC
solvent. The process is very much emissions. Electrodeposition does
like electroplating in that the reac- have a high initial investment cost
tion is driven by electricity. Direct and intensive maintenance require-
current is passed through the solu- ments. Separate tanks and rinse
tion and causes a reaction with the lines are needed for each color.

18
A Comparison of Coatings
Traditionally, paint has been consid- The following provides a comparison
ered a liquid made up of several of four different coating technologies
components that when applied and —high-solids coatings (where the
cured impart a thin plastic film. paint was modified to produce a
Paints have traditionally been organ- coating with higher solids concentra-
ic solvent-based, with the solvents tion and a lower VOC concentra-
aiding in the application process. tion), waterborne coatings (which
While being versatile, it has many mainly use water to disperse the
environmental issues associated with paint resin, although some solvent is
its use, including air emissions and still present), powder coatings
hazardous waste disposal. High- (which have become a viable alter-
solids paints have a higher percent- native for decorative and functional
age of paint solids and contain less coatings, although still predominate-
solvent, and while air emissions may ly a metal-finishing process), and
be less, they are still present. Water- UV-cured coatings (coatings requir-
based paints, which utilize water as ing UV radiation to initiate crosslink-
the solvent, also have reduced VOC ing of the resin).
emissions, as well as a reduced fire
hazard. “Solid paints,” such as pow-
der coatings and paints containing
no solvents (and hence have reduced
HAP and VOC emissions), are widely
available. These materials have given
rise to the term “coatings” instead of
paints. With catalyzed or two-com-
ponent coating systems, reactive
resins and catalysts are mixed just
before entering the application
equipment. This type of coating sys-
tem can also reduce solvent use.

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High-Solids Coatings
Pollution prevention benefits: Applications:
■ reduces solvent in coatings ■ zinc-coated steel doors

■ less overspray compared to con- ■ miscellaneous metal parts

ventional coatings ■ same as conventional coatings

■ higher transfer efficiencies

Limitations:
Operational benefits: ■ solvent use not completely elimi-

■ can apply thick or thin coat nated


■ easy color blending or ■ shorter pot life than convention-

changing al coatings
■ compatible with conventional

and electrostatic application


equipment

Energy savings:
■ reduced air flow in work spaces

and curing ovens (low VOC)


■ reduced energy needed for heat-

ing makeup air

20
Water-Based Coatings
Pollution prevention benefits: Applications:
■ eliminates or reduces solvent in ■ wide range

coatings ■ architectural trade finishers

■ reduced VOC emissions and fire ■ wood furniture

hazards ■ damp concrete

■ reduced hazardous waste

disposal Limitations:
■ water used for cleanup ■ coating flow properties and dry-

ing rates can change with


Operational benefits: humidity, affecting coating appli-
■ can apply thick or thin coat cation
■ easy color blending or changing ■ sensitive to humidity, workplace

■ compatible with conventional humidity control required


and electrostatic application ■ may have poor flow characteris-

equipment tics due to high surface tension


of water
Energy savings: ■ special equipment needed for

■ reduced air flow in work spaces electrostatic application


(little or no VOC) ■ water in paint can cause corro-

■ reduced energy needed for heat- sion of storage tanks and trans-
ing makeup air fer piping, and “flash rusting” of
metal substrates

21
Powder Coatings
Pollution prevention benefits: Applications:
■ eliminates solvent in coatings ■ steel

■ little or no VOC emissions ■ aluminum

■ easier to recycle and reuse over- ■ zinc and brass castings

spray
■ reduces solvents for cleaning Limitations:
■ reduces need for solid paint ■ requires handling of heated parts

waste disposal ■ part must be electrically conduc-

tive, complex shapes difficult to


Operational benefits: coat
■ can apply thick coat in one ■ difficult to apply thinner coat-

application ings
■ no mixing or stirring ■ need special equipment or extra

■ efficient material use, possible to effort to make color changes


achieve nearly 100% transfer ■ difficult to incorporate metal

efficiency if a reclaim system is flake pigments


used

Energy savings:
■ little air flow needed for worker

protection (no VOC)


■ little energy needed for heating

makeup air

22
Ultraviolet (UV) Radiation-Cured Coatings
Pollution prevention benefits: Applications:
■ eliminates solvent in coating ■ some metal applications

■ allows for increased production ■ filler for chipboard

rates ■ wood

■ 100% reactive liquid ■ “wet look” finishes

Operational benefits: Limitations:


■ can apply thin coats ■ styrene volatility

■ easy color blending or changing ■ typically best applied to flat

■ efficient material use, nearly materials


100% transfer efficiency ■ limited to thin coatings

■ high capital cost of equipment

Energy savings: ■ yellow color

■ little air flow in work spaces (no

VOC)
■ cure with UV instead of an oven

■ little energy needed for heating

makeup air

23
Pollution Prevention for the
Coating Industry
What is Pollution Prevention? more sensible to prevent wastes than
implement expensive treatment and
Pollution prevention, or P2, means control technologies to ensure waste
preventing wastes rather than using does not threaten human health and
expensive treatment and control the environment.
technologies on end-of-pipe wastes.
P2 can decrease environmental lia- P2 and the Coating Industry
bilities, reduce waste disposal costs,
and improve working conditions. It Paint application wastes include left-
may be as simple as preventing spills over paints, dirty thinner from
and leaks through better housekeep- cleaning spray guns and paint cups,
ing and maintenance, or as complex air emissions of volatile organic com-
as switching solvent-cleaning sys- pounds (VOCs) and hazardous air
tems. pollutants (HAPs), dirty spray booth
filters, dirty rags, and disposal of
Development of Pollution out-dated supplies. Ways to reduce
Prevention Concepts these wastes include rigid inventory
control, better housekeeping prac-
In 1990, beginning with the tices, mixing paint according to
Pollution Prevention Act, EPA shift- need, better operator training, prop-
ed focus from “end-of-pipe” pollution er cleaning methods, using alterna-
treatment and cleanup to policies, tive coatings, using styrofoam filters,
technologies, and processes that pre- recycling solvents on and off site,
vent and minimize the generation of and using waste exchanges.
pollution. The underlying theory
behind P2 is that it is economically

24
Better operating practices, or “good Waste assessments help identify the
housekeeping” applies to all waste amounts and types of wastes gener-
streams and requires minimal capital ated at your facility. Knowing this
investment, yet can be very effective makes it easier to know how waste
in reducing the amount of wastes can be reduced and where to con-
generated. Good housekeeping centrate your efforts. Any waste
includes management initiatives to management program is an organ-
increase employee awareness of the ized and continuous effort to sys-
need for and benefits of pollution tematically reduce waste generation,
prevention, and preventive mainte- and should reflect the goals and poli-
nance to reduce the number of leaks cies of management. An effective
and spills. program also includes the involve-
ment and enthusiasm of employees,
especially those who have an under-
standing of the processes being
examined.

25
Hierarchy of Pollution Prevention Strategies
for Coating Operations

Inventory control
Priority 1: Source Reduction Better housekeeping practices
Operator training
High-transfer efficiency equipment
Alternative coatings
Better cleaning methods

On-site solvent recycling


Priority 2: Recycling & Reuse Off-site solvent recycling
Waste exchanges

Proper
disposal

26
Priority 1: Source Reduction
Source reduction techniques are Look at standardizing the paint
designed to reduce the amount of types and colors you offer your cus-
waste initially generated. Simple tomers. This can help minimize the
housekeeping changes and conduct- number of different paint products
ing periodic inspections of all equip- you keep in inventory, again lessen-
ment can be less expensive than fix- ing the chance for paint product to
ing malfunctions when they appear, go bad. Standardizing your paint
or cleaning up a preventable spill. types and colors also provides you
with another benefit—it minimizes
Inventory Control the chance that a client’s particular
paint selection will provide you with
Inventory control is an effective and a surprise and cause what may have
efficient way of reducing indiscrimi- previously been a non-hazardous
nate use of raw materials. By reduc- waste to become a new hazardous
ing the amount of paint that waste for you to handle. If justified
becomes unusable, you not only save by volume demand, purchase your
costs associated with waste disposal, chief coating colors in 15-, 30-, or
but you also save costs associated 55-gallon reusable drums rather than
with initial product purchase. Mark 5-gallon pails. Just be sure that prod-
receiving dates on your incoming uct won't sit around too long.
paint products, and use a “first in,
first out” procedure to use older
paint materials first.

27
If you have paint material that for ■ Keep paint and solvent contain-
one reason or another will not meet ers tightly closed to reduce evap-
your clients’ specifications or expec- oration, emissions, and material
tations as a finished coat, use it as dry-out.
an undercoat or primer; or see if you ■ Reduce leaks and spills by plac-
can find a business that can use the ing drums at points of highest
paint and sell it, even at reduced use.
cost. ■ Use spigots or pumps when
transferring materials from stor-
Monitor the amount of paint used by age containers to smaller con-
different workers to get the same tainers.
jobs done. Shop owners may moni- ■ Control evaporation by using
tor employee operations and make tight-fitting lids and spigots.
verbal or written comments on prod- ■ Use drip pans.
uct usage. Limit employee access to ■ Use secondary containment in
material storage areas, or develop bulk storage areas.
some kind of accounting system to ■ Move drums carefully to prevent
track material use. damage or punctures, which
could lead to leaks or ruptures
Better Housekeeping during future use.
Practices
Material Preparation
Basic housekeeping techniques can be
very effective in reducing pollution. Look for ways to reduce the amount
Many methods are available to control of solvent used in product pre-clean-
and minimize material losses, which ing. Examine substituting chemical
can be implemented easily and at lit- cleaning for physical or mechanical
tle or no cost to the operator. Specific cleaning when preparing the product
approaches to bulk material drum
location, material transfer methods,
evaporation, and drum transport can
effectively limit material loss.

28
surface for painting application. Paint Mixing
Sand or particle blasting are some
examples, although they have their For small jobs, the amount of paint
own environmental issues. Plastic prepared will often exceed the
media has been substituted for sand amount of paint actually applied.
in some blasting operations for both Track usage rates for different paint
environmental and worker health types. Have various sizes of paint-
issues. The plastic media can be mixing and sprayer cups available to
reused once separated from the limit over-mixing of paint for a spe-
stripped-paint waste, reducing both cific project, and to reduce the
purchasing and waste disposal costs. amount of solvent needed for equip-
Dry ice is another alternative mate- ment cleanup.
rial for blasting processes. If solvent
cleaning is used, reduce solvent loss Better Operator Training
due to evaporation by installing and Employee Participation
cleaning tank lids or increasing free-
board space in vapor degreasers. Operators may be very skilled at
producing high quality finishes, but
Conversion Coatings poorly trained in minimizing paint
usage. Key points for operators
Avoid dirtying or soiling the sub- include the following:
strate prior to the beginning of the
cleaning process. Analyze water for ■ Do not arc the spray gun and
hardness and dissolved solids. Use blow paint into the air.
alkaline cleaners or phosphate com- ■ Maintain a fixed distance from
pounds with hard water stabilizers the painted surface while trigger-
where necessary. Use low-tempera- ing the gun.
ture, energy-conserving alkaline ■ Too much or too little overlap
cleaners or phosphate compounds. leads to wasted paint and heavy
or lightly coated areas. A 50%
overlap pattern is typically rec-
ommended.

29
■ Air pressure should be kept Maintenance and Use of
low—this can increase transfer High-Transfer Efficiency
efficiency from 30 to 60 percent.
Equipment
■ Keep the gun perpendicular to
the surface being painted. Less overspray means fewer air
Angling the gun leads to some of emissions. You can reduce the
the spray being too far from your amount of waste you generate by
product surface and a decrease increasing the transfer efficiency of
in transfer efficiency. your coating process. Remember,
transfer efficiency is a measure of
Ask your operators where they see how much paint goes on the part,
improvements could be made—after compared to how much is sprayed.
all they work with the equipment Typical transfer efficiency from con-
daily and may have suggestions not ventional air guns ranges from 20 to
previously thought about. Provide 40 percent, thus 60 to 80 percent of
incentives to increase employee par- the paint is overspray. Overspray is
ticipation in whatever waste reduc- a function of the design and opera-
tion or recycling program you have. tion of the system used and your
One business tracked the savings in operator application techniques.
material purchases and money made Talk to your equipment vendor
from recycling activities and put this about higher transfer efficiency
into a general employee account to equipment, and examine the pay-
be used by the workers to improve back period by switching to such
their working stations and lunch- equipment. It may be that the
room. amount of material saved will justify
upgrading your equipment.

Even if you've examined upgrading


your equipment and have decided to
continue with your current process
equipment, make sure it is in good
working order—your painters' per-

30
formance depends on the condition Proper Cleaning Methods
of their tools. Poorly maintained
equipment may result in products Wastes resulting from cleaning of the
that don’t meet customer demand application equipment can be
and can reduce the transfer efficien- reduced by more efficient cleaning
cy of your operations. methods. Reduce solvent use in
equipment cleaning by scraping
Alternative Coatings paint cups or tanks into a separate
container before rinsing the equip-
VOC emissions are related to the ment with solvent. Make use of
type of coating used and the number Teflon-lined metal paint containers,
of coats necessary for a high quality which are easier to clean. Use an
finish. Acrylic lacquers are typically enclosed gun-cleaning station. Spray
thinned with solvent by 125 to 150 solvent through the gun into the
percent. With synthetic enamels, cleaning station where it is captured
solvent thinning amounts to 15 to 33 for recovery and reuse. Schedule
percent. Minimize or eliminate VOC jobs so that large batches of items of
emissions by substituting solvent- similar color are painted, instead of
based paint with waterborne paint, small batches of custom items, to
high-solids paint, or with medium- reduce the amount of dirty cleaning
or low-solvent paint. Consider, how- solvent and waste paint generated
ever, the desired final product speci- during change-out.
fications and the type of product
being coated when choosing substi-
tute materials.

31
Filters booth), as this could cause the filters
to become a listed waste (and this
Suppliers or recyclers of thinners act is considered illegal disposal).
may replace and dispose of dirty Because the filters are in a solid
spray booth filters for a generator. It state rather than a liquid, they are
is the responsibility of the generator, not considered a hazardous waste in
however, to determine if these filters Kansas due to ignitability (D001). It
are hazardous. Filters may be char- is important to remember, however,
acteristic hazardous waste (toxicity) that paint filters have been known to
if they contain enough metals or cause trash fires and that some local
volatiles. The volatiles could come trash haulers and transfer stations
from the paint thinners used or from will not allow them to be disposed in
the paint itself. The metals typically the regular trash. In this case, the
are found in paint pigments. When filters should be segregated from the
cleaning paint equipment (including regular trash and disposed under a
gun tips and hoses), solvent and/or Special Waste Disposal Authorization
thinners should not be sprayed on from KDHE.
filters (or into the air in the paint

32
Priority 2: Recycling and Reuse
Reusing and recycling can help to on-site distillation may provide a
reduce waste disposal costs. Wastes more cost-effective alternative.
may potentially be used as raw Batch distillation of all high-grade
materials for a process, or materials solvent wastes can virtually elimi-
may be able to be recovered before nate the need for purchasing lower
being disposed. Recovery technolo- quality solvents for use in prelimi-
gies can either remove desired mate- nary painting operations and
rials from a waste stream before dis- cleanup. An operator may reclaim
posal or can directly use waste from four and one-half gallons of thinner,
one process as raw material in with one-half gallon left as sludge
another. from five gallons of paint and thin-
ner wastes. This ratio varies depend-
On-Site Solvent Recycling ing on the operations.

Several alternatives are available for When determining the amount of


recycling solvent on site. Gravity hazardous waste your company gen-
separation is inexpensive and rela- erates each month (done to deter-
tively easy to implement by allowing mine which hazardous waste genera-
the solvent/sludge mixture to sepa- tor category you fall under), remem-
rate under inactive conditions. The ber to count any solvent that enters
clear solvent can then be decanted your distillation/solvent recycling
with a drum pump and used for unit, each time it is placed in the
equipment cleaning, reducing the unit. So while on-site solvent recy-
amount of wash solvent purchased. cling may help you reduce your
Reclaimed solvent can be used for waste disposal and solvent purchas-
formulating primers and base coats, ing costs, it will not reduce your
but might create problems if not suf- hazardous waste generation rate.
ficiently pure. Read more about properly counting
your wastes in the hazardous waste
For those facilities that generate regulatory section of this manual.
larger quantities of waste solvent,

33
Off-Site Solvent Recycling Waste Exchanges and
Donations
Low-volume solvent users, or those
who find it uneconomical to recycle Find a business that can use your
contaminated solvents on site, usual- old or off-spec coating material, or
ly send their waste to commercial contact a waste exchange program.
recyclers for recovery. Commercial Waste exchanges are organizations
recyclers have versatile distillation that manage or arrange the transfer
processes and can handle large vol- of materials between industries,
umes and varieties of solvents. where one producer’s waste becomes
Generally, solvent recyclers recover another industry’s feed stock.
70 to 80 percent of the incoming Remember, if your by-products are
spent solvents into reusable prod- determined to have value as raw
ucts. Recyclers often sell reclaimed material to another industry, then
solvents back to the user. they are not considered waste and
are exempt from RCRA (hazardous
In general, suppliers who offer recy- waste) regulations. Most exchanges
cling services include the cost of exist as information clearinghouses,
waste collection and recycling in the which provide information on mate-
price of their solvent. This increases rials available for reuse.
the thinner cost, but effectively Opportunities exist for these
eliminates separate hauling and dis- exchanges to oversee direct transfer
posal or recycling costs. It also of used solvent from industries
reduces the administrative burden requiring ultra-high-purity solvents
on the owner. to industries that do not have such
stringent requirements.

If you can’t find a business that can


use your unwanted coating material,
check around to see if local organi-
zations and community groups may
be able to use it.

34
Proper Coating Techniques
for Operators
The following text was taken from Since the flow of coating from the
EPA pollution prevention publica- gun is consistent, the speed of the
tions.2 You can see a copy of the gun as it is moved across the part
complete publication at www.epa. should be consistent as well. Steady
state.oh.us/opp/paints/fact23.html. gun speed will help obtain a uniform
thickness of coating. A gun speed
Techniques spray painters use dur- higher than manufacturer specifica-
ing application have a definite effect tions can distort the spray pattern
on transfer efficiency and offer waste and not permit the maximum
reduction potential. Fundamentals of amount of material to reach the sur-
good spray techniques consist of the face.
following:
The distance of the gun from the
■ proper overlap of the spray part must be consistent, since, again,
pattern the flow of material from the gun is
■ proper gun speed consistent. Generally, this will be six
■ proper distance of the gun from to eight inches for non-electrostatic
the part systems. Spray losses increase with
■ holding the gun perpendicular to the distance, as does solvent loss.
the surface of the part This solvent loss is often corrected
■ triggering the gun at the begin- by the addition of more solvent. This
ning and end of each stroke does not correct the spray loss, and
overspray still ends up in the spray
Proper overlap of spray patterns will booth.
be determined by the coating.
Proper overlap may range from 50
percent to 80 percent. Greater over-
lap may result in wasted strokes, and 2
Ohio Environmental Protection Agency, Office
less overlap may result in streaks. of Pollution Prevention, September 1994,
Pollution Prevention in Painting and Coating
Operations

35
Except for special conditions, the All manufacturer specifications
gun should be held perpendicular to should be checked to ensure that
the surface of the part. Arcing the operators are using the proper tech-
gun for hard-to-reach areas wastes nique for their equipment. Operator
material by applying an uneven coat. training and experience will provide
This also may result in streaks. operators with knowledge of various
These areas should be compensated painting techniques needed to paint
for by changing the positioning of parts of different configurations.
the gun or operator. Different techniques are helpful
when painting inside corners, out-
If the trigger of the gun is not side corners, slender parts, round
released at the end of a stroke, the parts, flat parts, large parts, or small
material continues to flow and when parts.
the gun changes direction, momen-
tary stopping of the gun results in an Standard operating techniques will
accumulation of coating material. To not be fully successful if other prob-
avoid this piling, the operator may lems exist, such as room tempera-
spray past the edge of the surface, ture changing throughout the day
spraying material into the spray (which changes the viscosity of the
booth and wasting coating. paint) or if equipment needs repair.
Operators cannot be expected to
compensate for broken gauges, worn
fluid tips, or other equipment prob-
lems.

36
Regulatory Issues
Pollution generated from industrial The potentially significant amount of
coating applications can come from pollution generated from these and
a variety of sources, including spent other painting processes causes
paint, paint sludge, and paint filters. industrial coaters to fall under four
Dirty thinner from the cleaning of major categories of environmental
spray guns and paint cups, rags con- regulations affecting their opera-
taminated with cleaning or paint tions: hazardous waste, air, water,
materials, and unused coating prod- and right-to-know reporting.
ucts are other wastes. Inefficient Workplace safety must always be
coating transfer operations and considered as well. This section con-
equipment cleaning are major tains brief summaries of these regu-
sources of waste generation, and loss lations. A list of who to contact for
of hazardous air pollutants (HAPs) more information can be found at
and volatile organic compounds the end of this publication.
(VOCs) during the application and
drying processes may even cause
small businesses to be classified as
major sources of air pollution.

37
Waste Disposal Regulations
Businesses that paint or coat use Definitions of Hazardous Waste
many materials in their work that
typically are hazardous waste when Tracking the movement of hazardous
they are no longer usable, and hence wastes has become a “cradle-to-
the businesses are generators of haz- grave” effort. The first step in proper
ardous waste. Solvents in paints, waste handling is to determine if the
thinners, and cleanup solvents, as waste is considered hazardous. EPA
well as metals in paints, may be has defined a waste as hazardous if it
sources of hazardous waste. has certain properties that could
pose danger to human health or the
Paint cans and used filters may be environment. Waste is classified as
classified as hazardous waste if the hazardous in one of two ways, char-
paint is hazardous. Wet materials acteristic or listed. First, a waste is
may be classified as hazardous waste considered hazardous if it exhibits
because of their solvent content. one of the characteristics of a haz-
ardous waste; if it is corrosive,
You, therefore, should become famil- ignitable, reactive, or toxic.
iar with statutes and regulations that Corrosive:
apply to the handling and disposal of The pH of the substance is less
hazardous wastes. It is your respon- than or equal to 2, or greater
than or equal to 12.5.
sibility to determine which of your
wastes are hazardous, and to ensure Ignitable:
that they are transported and dis- The substance has a flashpoint
posed according to the law. You may less than 140ºF.
want to read the Hazardous Waste
Reactive:
Generator Handbook published by The material vigorously reacts with
KDHE for more information. You air or water, has a tendency to
may receive a free copy of the hand- explode, or produces toxic gases.
book by calling the SBEAP Resource
Center at 800-578-8898. Toxic:
It is deemed toxic according to
approved toxicity tests.

38
Paint and related solvent wastes Categories of Hazardous Waste
often display ignitable or toxic char- Generators
acteristics. While oil- or solvent-
based paint wastes are usually What generator class you are in is
ignitable, some water-based paints dependent upon how much waste is
can also be ignitable because of the generated at your facility. In Kansas,
drying agents they contain.3 These three classes exist—small quantity,
wastes may also contain a regulated Kansas, and EPA. You must deter-
metal pigment such as chromium or mine your generator category to
lead. determine which regulations apply
to you. Your facility may change its
Waste material can also be consid- status from one category to another,
ered hazardous if it is on EPA’s list of depending on how much waste it
hazardous wastes (F-list, K-list, P- generates in a given period.
list, and U-list), found on pages 24
through 45 of the Hazardous Waste In determining your status as a haz-
Generator Handbook. Check your ardous waste generator, count all
material safety data sheets to see if quantities of hazardous waste that
your paints, paint thinners, or clean- you generate in a given month.
ers contain any of these wastes.
Common solvents in painting opera- Reduce your quantity of hazardous
tions are classified as hazardous and waste by separating hazardous waste
are found in the F001 to F005 waste and non-hazardous waste. A mixture
number categories (page 24). of these two types of wastes must be
Examples of such solvents include treated as hazardous.
xylene, acetone, methanol, methyl
isobutyl ketone, toluene, methyl
ethyl ketone, and benzene, among
others.

3
Minnesota Pollution Control Agency, September
1997, Evaluating Paint and Ink Wastes

39
Do not count wastes that
■ are specifically exempt (page 3 of the Hazardous Waste Generator
Handbook)
■ may be left in the bottom of containers that have been completely emp-
tied by conventional means such as pouring and pumping.
Containers are considered empty if no more than one inch of residue
remains on the bottom, or no more than three percent by weight of
the contents remain inside a container that is 110 gallons or less, or
no more than 0.3 percent by weight of the contents remains inside a
container than is larger than 110 gallons. If the container contained a
P-listed waste, it must be triple-rinsed before being considered empty.
■ are managed in an elementary neutralizing unit, a totally enclosed treat-
ment unit, or a permitted wastewater treatment unit
■ are legally allowed to be discharged directly to a publicly owned treat-
ment works (POTW)

40
Small Quantity Generator
If the following criteria is met, the SQG's are required to handle haz-
state of Kansas considers you a small ardous waste they generate in an
quantity generator (SQG): environmentally sound manner and
are not subject to any notification or
reporting requirements. Small quan-
■ The facility generates no tity generators may use any of the
more than 55 lbs of haz- following alternatives to handle their
ardous waste, or no more hazardous wastes when disposed of
than 2.2 lbs of acutely haz- in quantities less than 55 pounds:
ardous (P-listed) waste in a recycling, reuse, reclamation, dispos-
calendar month. al at a permitted sanitary landfill,
neutralization and discharge to the
■ The facility accumulates no sanitary sewer only with permission
more than 2,200 lbs of haz- of the city and in conformance to
ardous waste or no more any applicable EPA pretreatment
than 2.2 lbs of acutely haz- requirements, and disposal at a per-
ardous waste, or no more mitted hazardous waste disposal
than 55 lbs of debris and con- facility.
taminated materials from the
cleanup of spillage of acutely
hazardous waste.

41
However, when, as a small quantity Small quantities of hazardous waste
generator, you accumulate more may NOT be disposed of by dumping
than 55 pounds, you must do the on the surface of the ground or into
following: surface waters, burying in the
ground at an unpermitted site, or by
using wastes such as solvents for
■ Package, label, mark, and killing weeds.
placard all shipments of haz-
ardous waste. All containers
of hazardous waste must be
marked with the words
“Hazardous Waste.”
■ Follow the dating and mark-
ing requirements for contain-
ers and tanks.
■ Document weekly inspections
of hazardous waste storage
sites.

40
Kansas Generator
Each of the following criteria must Kansas generators must comply with
be met to be considered a Kansas the following regulatory require-
generator: ments:

a) Determine which wastes gener-


■ The facility generates 55 lbs ated by the facility are haz-
or more of hazardous waste ardous
but less than 2,200 lbs in a
calendar month, and the b) Obtain an EPA identification
facility does not generate 2.2 number by submitting a haz-
lbs or more of acutely haz- ardous waste notification form
ardous waste or 55 lbs or to the Kansas Department of
more of debris and contami- Health and Environment. (This
nated materials from the form is available in Appendix B
cleanup of spillage of acutely of the Hazardous Waste
hazardous waste. Generator Handbook.)

■ The facility accumulates no c) Prepare a manifest for all ship-


more than 2,200 lbs of haz- ments of hazardous waste.
ardous waste or 2.2 lbs of Package, label, mark, and plac-
acutely hazardous waste, and ard all shipments of hazardous
no more than 55 lbs of debris waste in accordance with pre-
and contaminated materials transportation requirements.
from the cleanup of spillage (This form is can be found in
of acutely hazardous waste. Appendix C of the Hazardous
Waste Generator Handbook.)

43
d) Prepare and maintain the fol- The above list is an abbreviated ver-
lowing records for three years: sion of compliance requirements.
1) a signed copy of all manifests For a complete listing of require-
initiated ments associated with hazardous
2) manifest exception report(s) waste, please consult the Hazardous
3) hazardous waste analyses Waste Generator Handbook, the
4) weekly inspection reports Kansas Statutes Annotated, Chapter
65—Article 34, and the
e) Meet all storage requirements Administrative Regulations, Article
for containers and/or tanks. 31.

f) Meet emergency preparedness


requirements.

g) Report all international ship-


ments of hazardous waste to the
Kansas Department of Health
and Environment and the
Environmental Protection
Agency.

44
EPA Generator
An EPA generator is one who fulfills EPA generators are subject to all reg-
any one of the following: ulations for Kansas generators,
except for the emergency prepared-
ness requirements, as well as the fol-
lowing additional requirements:
■ The facility generates in any
single month or accumulates
a) Provide a personnel training
at any time 2,200 lbs or more
program to ensure that facility
of hazardous waste, or gener-
personnel are able to respond
ates in any single month or
effectively to a hazardous waste
accumulates at any time 2.2
emergency. The program must
lbs of acutely hazardous
include the following:
waste.
1) a director trained in haz-
■ The facility generates or ardous waste procedures
accumulates at any time 2) instruction which teaches
more than 55 lbs of debris facility personnel about the
and contaminated materials location of emergency
from the cleanup of spillage response and monitoring
of acutely hazardous waste. equipment; maintenance and
operation of such equipment;
communications procedures
and response procedures for
fires, explosions, and con-
tamination incidents (train-
ing must be completed with-
in six months after the date
an employee enters a posi-
tion)
3) an annual review of the ini-
tial training

45
4) development of job titles and 5) make arrangements with the
descriptions, a description of local hospital, police depart-
training to be given each job ment, fire department, and
title, and a record of all train- emergency response team to
ing which occurs familiarize them with the
plant layout and hazards
b) Adequately provide for pre- involved with the wastes gen-
paredness and prevention with erated (such arrangements
the following precautions: should be documented)
1) proper maintenance of facili-
ties to minimize releases of c) Prepare a contingency plan and
hazardous waste implement emergency proce-
2) where appropriate for the dures to ensure that releases of
type of waste generated, pro- hazardous waste are properly
vide an internal communica- handled. The contingency plan
tions or alarm system, a tele- must provide for:
phone or two-way radio, and 1) a description of actions facili-
fire extinguishing and control ty personnel must take to
equipment (all required respond to a release
equipment must be tested 2) a description of arrange-
and maintained to ensure ments made with local
proper operation) authorities for emergency
3) provide personnel working services
directly with hazardous 3) designation of primary and
waste with immediate access secondary emergency coor-
to communications and dinators and listing of their
alarm equipment addresses and phone num-
4) maintain aisle space suffi- bers
cient to allow passage of per- 4) a list of all emergency equip-
sonnel and fire, spill control, ment on site, including capa-
and decontamination equip- bilities and locations
ment

46
5) an evacuation plan where The above list is an abbreviated ver-
potential need for evacuation sion of compliance requirements.
exists For a complete listing of require-
6) copies of the contingency ments associated with hazardous
plan to be maintained at the waste, please consult the Hazardous
facility and submitted to the Waste Generator Handbook, the
local police department, fire Kansas Statutes Annotated, Chapter
department, hospital, and 65 —Article 34, and the
emergency response team Administrative Regulations, Article
7) a contingency plan that is to 31.
be periodically reviewed and
current

47
Shipping Wastes Off Site
The three most important things to You must ensure that your trans-
remember when shipping hazardous porter and waste facility meet appli-
wastes off site are cable state and federal regulations.
Disposal facilities must have permits
issued by EPA or the state in which
the facility is located. Under state
■ Choosing a reputable hauler
and federal law, you may only use
and facility with EPA ID num-
authorized hazardous waste trans-
bers. If you have questions
porters and disposal facilities that
about who to call to deter-
have been assigned EPA identifica-
mine if they are “reputable,”
tion numbers.
contact SBEAP at 800-578-
8898.
The hauler you choose will transport
■ Packaging and labeling all
your waste, and the waste manage-
wastes appropriately. ment facility will be its final destina-
■ Preparing hazardous waste tion. But remember, you are still
manifest. responsible for the wastes you pro-
duce.

48
Air Regulations
With the enactment of the Clean Air facility has the potential to emit
Act Amendments (CAAA) in 1990, more than the above stated amount
the way air emissions are regulated of HAPs or VOCs, or if it falls under
was reorganized. One change was specific air regulations or national
regulated hazardous air pollutants emission standards for hazardous air
(HAPs). The current list of HAPs pollutants (NESHAPs).
contains 187 chemicals and can be
found on the internet at Major Sources
www.epa.gov/ttn/atw/orig189.html.
Painters and coaters are subject to
Many paints contain significant limits on their VOC and HAP emis-
quantities of HAPs such as toluene, sions from solvents used in paints,
xylene, methyl ethyl ketone (MEK), paint stripping, or cleaning. Your
or methyl isobutyl ketone (MIBK). facility is defined as a major source
The amount of HAPs or volatile of air pollution if it has the potential
organic compounds (VOCs) your to emit:
facility has the potential to release
or emit will determine if your busi- ■ 10 tons of any single HAP
ness is required to obtain an operat- ■ 25 tons of any combination
ing permit and/or comply with other of HAPs
regulatory requirements. ■ 100 tons or more of any
other regulated air pollutant
Air Operating Permits in a single year. Such pollu-
tants include nitrous oxides,
In January 1995, the Kansas Depart- sulfur oxides, particulate
ment of Health and Environment, matter less than 10 microns,
KDHE, adopted regulations to imple- or VOCs.
ment provisions of the CAAA of
1990. The new clean air rules speci-
fy three different types of air operat-
ing permits, depending on whether a

49
There are other regulated pollutants Your potential to emit, or PTE, is
that typically don’t apply to coating based on the maximum amount of
processes but may affect your facili- air pollution your facility would emit
ty if painting is only one part of your if
total operation.
■ each process unit is operated
Class I Permits at 100 percent of its physical
and operational design capac-
The Class I operating permit is a sin- ity
gle document that contains all air ■ materials that emit the most
quality requirements your facility air pollutants are used 100
has to meet. If your facility is percent of the time
defined as a major source, then it ■ all of the equipment is oper-
will need a Class I permit. As stated
ating 24 hours per day, 365
above, Class I status is based on
days per year
your business’ potential to emit vari-
■ no pollution control equip-
ous air pollutants.
ment is used

The Class I permit application


process can be very involved, time
consuming, and expensive. Once
KDHE receives your application, it
has 60 days to determine whether it
is complete. Both the public and the
U.S. Environmental Protection
Agency can participate in the appli-
cation review process. Once issued,
your permit is good for five years,
and you will need to submit a renew-
al application at least six months
before it expires.

50
Class II Permits Class III Permits
If your facility’s actual emissions are The Class III permit is primarily a
less than the major source thresholds, registration form that needs to be
but the potential emissions still completed if you are not required to
exceed them, then your facility may obtain a Class I or Class II permit,
qualify for a Class II permit, which is but are subject to a National
less expensive and time consuming to Emission Standard Hazardous Air
complete than the Class I permit. The Pollutants (NESHAP), are located in
Class II permit allows you to specify Johnson or Wyandotte counties and
how you will limit your potential are subject to VOC regulations, have
emissions to below the major source an incinerator, or are subject to a
threshold and thus avoid the need for new source performance standard
a Class I permit. (NSPS). New sources required to
obtain a Class III permit have one
The Class II permit application asks year from start-up to submit their
for information KDHE needs to deter- application.
mine your facility’s potential-to-emit,
such as material safety data sheets Other Restrictions
and chemical usage rates, and how
you will limit your potential to emit. Certain counties have additional
Both the public and EPA can review restrictions. In Kansas, facilities in
the permits, in addition to KDHE. Johnson and Wyandotte counties are
Once issued, the permit remains valid restricted to using coatings with low
with no required renewal unless it is VOC content. Current regulations
revoked or you are unable to limit mainly affect surface coating of mis-
your potential emissions to below the cellaneous metal parts and products
major source thresholds. Air emission and metal furniture, at facilities with
limits and material tracking require- have potential VOC emissions
ments may be part of a Class II per- greater than three tons per year. For
mit. By June 1 of each year, you will example, regulations limit the VOC
need to submit operating information, content to 3.5 pounds per gallon for
such as material usage rates and coatings.
MSDSs for the previous year, so KDHE
can recalculate your air emissions.
51
Air Construction Permits
and Approvals
cations at existing facilities can meet
So you are putting in a new paint applicable Kansas and federal air
booth. Do you need a permit before quality requirements.
you begin construction? Will you
need a permit to operate your You need a construction permit if
booths now? During a pre-construc- your potential to emit, or your
tion review, the Kansas Department increase in potential to emit,
of Health and Environment (KDHE) exceeds the levels shown below, or if
ensures that proposed construction the construction activity includes an
projects at new facilities and modifi- incinerator.

Pollutant Construction permit PTE threshold


Lead 0.6 tons per year
PM10 15 tons per year
PM 25 tons per year
SOx 40 tons per year
VOC 40 tons per year
NOx 40 tons per year
CO 100 tons per year
HAPs (individual) 10 tons per year
HAPs (any combination) 25 tons per year

If you are not required to obtain a ogy (MACT) standard or a


construction permit, you may need a national emission standard for
construction approval if you will be a hazardous air pollutants
new or modified source and (NESHAP)
■ your potential to emit (or your
■ you are subject to a New Source
increase in potential-to-emit)
Performance Standard (NSPS)
equals or exceeds the following
■ your facility is subject to a maxi-
thresholds
mum achievable control technol-
52
Pollutant Construction approval PTE threshold
Lead or lead compounds 0.1 pounds per hour
SO2 or SO3 2 pounds per hour
PM10 2 pounds per hour
PM 5 pounds per hour
NOx 50 pounds per 24 hours
CO 50 pounds per 24 hours

(In Wyandotte and Johnson counties)


VOCs 3 pounds per hour
15 pounds per 24 hours

(Areas Except for Wyandotte and Johnson counties)


VOCs 50 pounds per 24 hours

The primary difference between a If you need to obtain an operating per-


construction permit and a construc- mit or construction permit/approval
tion approval is that the permit form, visit the KDHE Bureau of Air
requires an application fee while the and Radiation’s Web site at
approval does not. The fee is equiva- www.kdhe.state.ks.us/bar/index.html,
lent to 0.05% of the capital cost of or call SBEAP at 800-578-8898.
the proposed activity.

53
Do I Need an Air Permit for My Oven/Incinerator?
First you need to decide whether the If the incinerator has been approved
device you're using is classified as an to burn non-hazardous paint filters,
incinerator. If it uses a direct flame you may use it for that purpose. If it
and burns anything in addition to hasn't been approved, you need to
paint hooks, it is an incinerator. If it request a modification to your per-
is an oven type, it still may be classi- mit. Please note that hazardous
fied as an incinerator. If the device is waste paint filters can't be incinerat-
classified as an incinerator, you need ed without a hazardous waste treat-
a permit. Otherwise, an individual ment, storage, and disposal facility
evaluation must be done to deter- permit. If the paints used in your
mine the types of air emissions, and business contain metals, there are
a potential-to-emit calculation must hazardous waste considerations as
be performed to determine whether well. Always review the material
the oven exceeds any permitting safety data sheets (MSDSs) for the
threshold. products you use. If you are baking
off paint hooks and have been using
a paint containing chromium, for
example, evaluate the residue metals
content.

54
Sample Calculation for Your Potential to Emit (PTE)
A facility should conduct an emis- total quantity of product used annu-
sions inventory to know what kind ally, density of the product, and
of permit is needed. Information on weight percent of HAPs or VOCs.
calculating potential solvent emis- This information will allow you to
sions, including solvent emissions calculate the amount of HAPs and
from painting and cleaning, follow. VOCs in the product.

Air emissions that result from evapo- The quantity of product used can be
ration of solvents—such as those in taken from purchasing records, pro-
paints - can be calculated using a vided you maintain an essentially
material balance approach. What constant inventory. If you are dis-
comes in to the facility is considered posing of waste materials and have
to be emitted into the air. The records to show the amount of HAPs
amount of volatile organic com- or VOCs in the waste, that amount
pounds (VOCs) and hazardous air can be subtracted from the total
pollutants (HAPs) in each product used since it was not emitted into
(such as coatings and solvents) can the air.
be calculated and totaled for an
entire year. The potential to emit Typically, total density of the prod-
(PTE)—what would be emitted if the uct can be found on the MSDS sheet.
facility operated at maximum design Either the density will be specifically
capacity, 24 hours a day, 365 days listed as pounds per gallon, or it will
per year, or 8760 hours per year - be given as specific gravity. If specif-
can be calculated by multiplying ic gravity is given, multiplying the
actual emissions of HAPs and VOCs reported number by 8.3 pounds per
by the ratio: gallon will give the density of the
product.
(8760 hours) ÷ (actual operating hours)
density = (specific gravity) x (8.3 lbs/gal)
Actual emissions of HAPs and VOCs
can be determined if you know the

55
Often times, the weight percent of Acetone is an example of a VOC
HAPs or VOCs are also given on the which is exempt. Now that you have
MSDS. If your MSDS happens to give all your information, you can calcu-
you volume percents rather than late your actual and potential emis-
weight percents, you will have to do sions for your pollutants of concern.
a quick calculation to get the weight
percent of the particular pollutant.
Actual emissions = (product volume used annually)
x (product density) x (wt% of pollutant)
HAP wt% = (HAP density) x (product volume) x
(HAP volume%) ÷ 100 Potential emissions = (actual emissions) x (8760
hours) ÷ (actual operating hours)

Determining your VOC weight per-


cent is a little different, because The Kansas Small Business
VOCs are contributed to by many Environmental Assistance Program,
chemicals in your product. The easi- SBEAP, has several publications to
est way to calculate your VOC help you understand the air regula-
weight percent is by the following: tions and can assist you in determin-
ing your potential air emissions.
SBEAP’s toll free number is 800-578-
Wt% VOC = 100 – (wt% of solids) – (wt% of water) 8898, and you can visit our Web site
– (wt% of any exempt VOCs) at www.sbeap.org.

56
Wastewater Regulations
The primary objective of the Clean NPDES permit. Treatment of the
Water Act (CWA) is to restore and wastewater is generally necessary.
maintain the chemical, physical and Wastewater generated from coating
biological integrity of the nation’s applications might be regulated
surface waters. Pollutants regulated because of the presence of organic
under the CWA are classified as “pri- solvents or heavy metals.
ority” pollutants. These include vari-
ous toxic pollutants; “conventional” Use of wastewater treatment systems
pollutants, such as biochemical oxy- which do not discharge or direct
gen demand (BOD), total suspended waste to a POTW are also regulated
solids (TSS), fecal chloroform, oil by KDHE. Wastewater ponds which
and grease, and pH; and “non-con- do not discharge are not regulated
ventional” pollutants, including any under the NPDES program but will
pollutant not identified as either still require a Kansas water pollution
conventional or priority. control permit. Wastewater ponds
which receive industrial waste have
Under the Clean Water Act, point special requirements regarding their
sources of wastewater (discharge construction and permitting. KDHE
pipes or sewers) discharging to should be consulted.
waterways require a National
Pollutant Discharge Elimination
System (NPDES) permit. Permits,
issued by the Kansas Department of
Health and Environment—Bureau of
Water, specify levels of toxicity and
other characteristics that must be
achieved prior to discharge. Some
businesses discharge wastewaters
from phosphating processes or
waterfall paint booth units via their

57
Another type of discharge regulated Reduced water use is the primary
by the Clean Water Act is one that waste reduction option for phospha-
goes to a publicly owned treatment tizing. Water needed to maintain the
works (POTW). The national pre- bath solution can be reduced by
treatment program controls the indi- monitoring temperature, chemical
rect discharge of pollutants to concentration, and the pH level. Re-
POTWs by industrial users. use solution or rinse water from one
Facilities regulated under this pro- bath to others when possible. What
gram must meet certain pretreat- is your source of water? Is it deion-
ment standards. Recent rules require ized or tap water? City water can
facilities that utilize the phosphating bring in considerable amounts of dis-
process and discharge to a POTW be solved solids, and these contaminants
permitted due specifically to this can vary seasonally. Properly match-
type of discharge. If discharging to a ing the phosphating chemicals with
POTW, contact KDHE to determine the metal substrate is another key
the applicability of pretreatment issue in minimizing waste from phos-
requirements and permitting phating operations. This can signifi-
requirements. cantly minimize sludge generation.4

The goal of the pretreatment pro-


gram is
■ to protect municipal wastewater
treatment plants from damage
that can occur when hazardous,
toxic, or other wastes are dis-
charged into a sewer system
■ to protect the quality of sludge
generated by these plants
4
N.C. Division of Pollution Prevention and
Directing industrial waste to a septic Environmental Assistance. Pollution Prevention
tank is prohibited. Contact KDHE or in Metal Painting and Coating Operations—A
Manual for Pollution Prevention Technical
SBEAP if you have questions. Assistance Providers. April 1998

58
Water Regulations
If the facility is served by a munici- potable consumption, and serves 25
pal or rural water discrict line, there people more than 60 days per year,
are no public water supply program the facility is considered a public
issues to address. If the facility uti- water supply and needs to be per-
lizes its own source of water or mitted by KDHE.

59
Community Right-to-Know Regulations
The Comprehensive Environmental Reporting Spills
Response, Compensation, and
Liability Act (CERCLA), generally Spills of hazardous substances must
known as the “Superfund” law, be reported to the appropriate
requires businesses to report spills of authority if “reportable quantities”
hazardous materials; requires are spilled. These quantities range
reports and notification of local from 1 to 5,000 pounds of sub-
authorities on the use, storage, and stances spilled within a 24-hour
release of hazardous materials; and period. Reportable quantities are
requires reports on the release of often found on the MSDS provided
certain toxic substances. These with the material. In many cases,
requirements combine those in the local authorities require facilities to
original CERCLA law and those report smaller spills. The number for
added through the Emergency the U.S. EPA National Response
Planning and Community Right-to- Center is 800-424-8802. The 24-
Know Act (EPCRA). Following is a hour spill response number for the
short summary of the primary Kansas Department of Health and
requirements. Environment (KDHE) is 785-296-
0614.

60
Reporting Use, Storage, and Disposal of Hazardous Materials
EPCRA Section 302 requires a facili- In Section 311 of EPCRA, facilities
ty to notify the state emergency are required to submit material safe-
response commission (SERC) if the ty data sheets (MSDSs) or a list of
company exceeds the threshold MSDSs for each extremely hazardous
planning quantity for any extremely substance or OSHA hazardous mate-
hazardous substance. Section 304 rial that exceeds a certain threshold.
requires a facility to report any This information is to be submitted
potentially dangerous release of any to the USEPA (they prefer a list), the
hazardous substance to the SERC SERC, the local emergency response
and local emergency response com- committee, and the local fire depart-
mittee, in addition to reporting such ment.
a release to the federal authorities.

Kansas Tier II
Section 312 of EPCRA requires facil- mittee, and your local fire depart-
ities to submit an inventory of the ment. These forms contain more
hazardous chemicals stored on site, detailed information on the chemi-
if threshold quantities are met. cals stored onsite and the locations
Facilities required to submit MSDSs of those chemicals at the facility.
under Section 311 are required to The Tier II form is an annual form
comply with this section for the due March 1.
chemicals they report under 311.
The inventory must be submitted on
Tier II reporting forms. The Kansas
Department of Health and
Environment (KDHE) has the form
on its Web site at
www.kdhe.state.ks.us. This infor-
mation is to be submitted to KDHE,
your local emergency response com-

61
You must file a Kansas Tier II form if
is smaller, of an extremely haz-
ardous substance (EHS). Some
■ you have at your facility more common EHS include nitric
than 10,000 lbs of any chemi- acid, sulfuric acid, and ammo-
cal OSHA requires you to have nia.
a MSDS for; or
■ you have either 500 lbs or the
threshold quantity, whichever A complete EHS list can be obtained
by calling SBEAP at 800-578-8898.

Form R
The aspect of EPCRA that has gotten
the most publicity is the require- ■ have ten or more full time
ment under Section 313 whereby employees;
facilities that “routinely” and/or and
accidentally release a defined set of
chemicals must report annually on ■ use any of the designated
those releases. Compilation of this chemicals at a rate of 10,000
information is called the toxics lbs or more a year;
release inventory, or TRI. Reports or
are due to the EPA, with copies sent
to KDHE, by July 1 of each year. ■ manufacture and process any
Facilities required to report have the of the designated chemicals at
following characteristics: a rate of 25,000 lbs or more a
year.

■ be classified in SIC codes 10


(except 1011, 1081, 1094), 12 Because the list of chemicals to
(except 1241), 20-39, 4911, which the TRI requirements apply is
4931, 4939, 4953, 5169, 5171, revised periodically, it is important
or 7389; to get an approved list from KDHE or
by calling SBEAP at 800-578-8898.
62
Health and Safety
The Occupational Safety and Health Further information on OSHA regu-
Administration (OSHA) regulates all lations may be obtained from one of
aspects of workplace safety, includ- the following contacts:
ing personal protective equipment,
paint booth design, fire and explo- ■ If you are located in Kansas, an
sion precautions, emergency excellent resource for businesses
response, and worker protection. with OSHA-related questions is
the Kansas Department of
Human Resources—Industrial
Safety Division. They will con-
duct free, voluntary OSHA audits
if requested by the facility
owner. Businesses participating
in this program are required to
correct any serious violations
found. They can be reached at
785-296-4386.

■ The regional office for OSHA (for


Kansas, Nebraska, Missouri, and
Iowa) can be reached at 816-
426-5861.

■ In Kansas, the Wichita OSHA


office can be reached at 316-
269-6644.

63
Where to Find Help
Remember, the Small Business Environmental Assistance Program can help
your business with all environmental regulatory or pollution prevention issues.
Our services are free and confidential.

General Information
SBEAP (Small Business Environmental Assistance Program): 800-578-8898
KDHE: 785-296-1500
Public advocate 800-357-6087

Air
Air Permits and Emission Calculations
KDHE: 785-296-1593
Technical Assistance with Air Emissions
SBEAP: 800-578-8898

Waste
Waste Management Requirements
KDHE: 785-296-1600

Wastewater
Wastewater Requirements
KDHE: For cities: 785-296-5525
KDHE: For industry: 785-296-5547
KDHE: Pretreatment requirements: 785-296-5551
KDHE: Industrial waste to septic tanks: 785-296-5560

Water
Water Requirements
KDHE: Public water supply: 785-296-5503

64
Storage Tanks
KDHE: 785-296-1660
Fire Marshal: 785-296-3401

Right-to-Know
KDHE: 785-296-1689
Pollution Prevention
Technical Assistance—Free and Non-regulatory
SBEAP: 800-578-8898

OSHA-Related Questions
OSHA regional office 816-426-5861
Wichita OSHA office 316-269-6644
Kansas Department of Human Resources 785-296-4386

This publication was created by Kansas State University’s Pollution Prevention Institute through the Small Business Environmental Assistance Program (SBEAP).
SBEAP’s mission is to help Kansas small businesses comply with environmental regulations and identify pollution prevention opportunities. SBEAP is funded through
a contract with the Kansas Department of Health and Environment. SBEAP services are free and confidential. For more information, call 800-578-8898, send an e-
mail to SBEAP@ksu.edu, or visit our web site at http://www.sbeap.org. Kansas State University is an EEO/AA provider.
6/02–25

65
Kansas Small Business Environmental Assistance Program