The painting and depainting of vehicles beyond a touch up of a scratch.
Summary of Federal Requirements
Painting operations may be performed at vehicle care facilities within federal facilities. Many paints, as well as paint strippers and varnish removers contain organic solvents that are hazardous to human health and the environment and are regulated by RCRA as a hazardous waste. A few of these hazardous chemicals are: acetone, benzene, methanol, methylene chloride, petroleum distillates, toluene, trichloroethane, and xylene.
Also potentially regulated by RCRA are cleaning solvents and thinners used to clean brushes. Traditional solvents often contain toxic chemical compounds that may qualify the waste product as hazardous waste.
Hazardous Material Storage
The storage of hazardous materials such as paints, stains, thinners, and lacquers before they become a waste is regulated by OSHA and not EPA. But, depending on the amount of hazardous materials stored and/or used at the facility, EPA reporting requirements may apply. The regulatory impacts of hazardous materials being stored and/or used at facilities are outlined in the Laboratories -> Hazardous Materials Storage section of the Facility Regulatory Tour.
Managers may be required to perform compliance related activities when disposing of waste paints, varnishes, paint strippers, varnish removers, degreasers, or cleaning solvents. The amount of waste generated at a site is a major factor that determines the extent to which regulations may apply. Visit the Hazardous Waste Storage section to find out how to determine if your waste is considered hazardous according to RCRA and what generator classification your facility falls within.
Used or spent rags containing listed hazardous wastes or exhibiting hazardous characteristics, are common to many paint shops. Improper management of recyclable or disposable spent rags can result in RCRA penalties for any violator, including federal facilities. A spent rag is one that has been used and is no longer fit for use without being regenerated, reclaimed, or otherwise reprocessed. Perhaps the most important factor in identifying spent rags as hazardous waste is that the sole responsibility lies with the generator or user of the rag. Whether the rags are shipped off-site for disposal or to an industrial laundry, any accumulation of hazardous rags on-site prior to shipment must be done in compliance with the requirements for the accumulation of hazardous waste rules.
Depending on the size of the paint booth, and the paints used the emissions may need to be considered for permit applications. If it is a wet-wall paint booth there may be wastewater pre-treatment standards. If the facility uses kraft paper (or other type of paper) when ready for discard the paper may be considered a hazardous waste depending on the paint and saturation.
This may be done in a large, vehicle sized booth, or a small booth for a hand held object. There are booths that use sand, plastic beads, walnut shells, and a variety of other products to remove the paint. Regardless of what is used, the paint waste must be disposed of as hazardous waste. Depending on the size of the booth, there may be applicable air emissions standards.
Summary of State Requirements
Depending on the classification of the facility, states may also require the facility to consider the emissions from paints and cleaners in their calculations as part of a CAA Title V permit submission.
Laws and Statutes
The Clean Air Act
Resource Conservation and Recovery Act, Subtitle C