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RE: alternatives to lead in autobody work







Alice -

Thanks for the additional information about halogenated organic
compounds.

Are all halogenated organic compounds persistent by definition, or is
there some additional test for persistence?


>>> Ironically, these can legally vent up the stack of the paint booth
in our area, as long as the booth is registered with the local air
agency.>>>

I don't find this unusual or surprising.   Only a small percentage of
all spray booths across all industries have their exhaust sent through a
VOC control device.

In auto refinishing the percentage is much smaller since the large
majority of the sources are very small and their painting is
intermittent.  There are some auto refinish spray booths that do have
VOC control devices.  One system used at some auto refinish facilities,
which I believe was developed by DeVilbiss and is now sold/known as
Envirocure, uses an inorganic sorbent to catch VOC during the spraying
cycle and desorbs them at low temperature (150 to 200 F) to a small
catalytic oxidizer during the baking/curing cycle.  You can find more
information about this at <www.envirocure.com>  .

We have an area source HAP project for auto refinishing in our group.
This summer someone is going to visit some auto refinish facilities
including some that have spray booth exhaust VOC contorls.

PCBTF is not a VOC.  It is a negligibly photochemically reactive
(exempt) compound.  The presence of PCBTF, perhaps along with other
exempt solvents, in place of solvents that are VOC reduces the VOC
content of the coating.   PCBTF is also not a HAP.

Does your state or county have an auto refinishing VOC rule?  I could
not find it on either web site.

Dave

Dave Salman
Coatings and Consumer Products Group
US EPA OAQPS
Mail Code C539-03
RTP NC 27711
tel (919) 541-0859
fax (919) 541-5689
e-mail salman.dave@epa.gov








|---------+---------------------------->
|         |           "Chapman, Alice" |
|         |           <Alice.Chapman@ME|
|         |           TROKC.GOV>       |
|         |                            |
|         |           05/28/2004 02:03 |
|         |           AM               |
|         |                            |
|---------+---------------------------->
  >--------------------------------------------------------------------------------------------------------------|
  |                                                                                                              |
  |       To:       Dave Salman/RTP/USEPA/US@EPA, "Chapman, Alice" <Alice.Chapman@METROKC.GOV>                   |
  |       cc:       "Hickok, Dave" <Dave.Hickok@METROKC.GOV>, "Tomchick, Laurel" <Laurel.Tomchick@METROKC.GOV>,  |
  |        owner-p2tech@great-lakes.net, p2tech@great-lakes.net                                                  |
  |       Subject:  RE: alternatives to lead in autobody work                                                    |
  >--------------------------------------------------------------------------------------------------------------|




Thanks for the feedback Dave!


We haven't identified any new sources of halogenated compounds since the
study.  The ones that did come up (from product MSDSs) are:


- parachlorobenzotrifluoride (PCBTF), CAS 98-56-6, solvent used in
low-VOC paints; however this compound is not expected to remain in a
paint filter (all the ones we tested were quite dry & dusty, no
significant solvent residues).  Ironically, these can legally vent up
the stack of the paint booth in our area, as long as the booth is
registered with the local air agency.


- binder resin used in paint booth filter, "synthetic anoinic colloidal
emulsion of vinyl chloride copolymer in water" with residual vinyl
chloride monomer


- binder used in paint booth filter, "halogenated polymer, incorpoating
Spo-Ax, an antimicrobial additive"... "burning characteristics:  flame
retarded, self-extinguishing"


- paint pigments:  diarylide or phthalocyanine pigments, for example,
hexadecachlorophthalocyanine, Pigment Green 7, Pigment Green 36, Pigment
Yellow 12 and tetrachlorisonsolinone yellow


Washington regulates HOCs due to their environmental persistence.  It's
a very broad definition and captures lots of compounds not typically
regulated in other states.  Here are a couple of snips from Washington's
Dangerous Waste Regulations


WAC 173-303-040, Definitions
        "Persistence" means the quality of a material that retains more
than half of its initial activity after one year (365 days) in either a
dark anaerobic or dark aerobic environment at ambient conditions.
Persistent compounds are either halogenated organic compounds (HOC) or
polycyclic aromatic hydrocarbons (PAH) as defined in this section.


         "Halogenated organic compounds" (HOC) means any organic
compounds which, as part of their composition, include one or more atoms
of fluorine, chlorine, bromine, or iodine which is/are bonded directly
to a carbon atom. This definition does not apply to the federal land
disposal restrictions of 40 CFR Part 268 which are incorporated by
reference at WAC 173-303-140 (2)(a). Note: Additional information on
HOCs may be found in Chemical Testing Methods for Designating Dangerous
Waste, Ecology Publication #97-407.


WAC 173-303-100, scroll down to section (6) for concentrations at which
they are designated dangerous waste.
http://www.leg.wa.gov/WAC/index.cfm?section=173-303-100&fuseaction=section






Alice I. Chapman, PE
Local Hazardous Waste Management Program in King County
130 Nickerson St, Suite 100
Seattle, WA  98109-1658
http://www.govlink.org/hazwaste/


206-263-3058, phone
206-263-3070, fax





-----Original Message-----
From: Salman.Dave@epamail.epa.gov [mailto:Salman.Dave@epamail.epa.gov]
Sent: Thursday, May 27, 2004 5:41 AM
To: Chapman, Alice
Cc: Hickok, Dave; Tomchick, Laurel; owner-p2tech@great-lakes.net;
p2tech@great-lakes.net
Subject: RE: alternatives to lead in autobody work








Alice -


Thank you for sharing this very informative study.


I have two questions.


1]  In the few months since the report was published, have you found any
more specific infomration about the use of halogenated compounds in dry
paint filters?  (e.g., chlorinated or brominatred flame retardant


chemicals)


2]  Can you explain to me what the environemtnal concerns are for the
halogenated compounds in general and as they appear in used dry paint
filters?  I am not sure if it has to do with the potential for them
leaching into groundwater, the hazards of potential reaction or
combustion by-products, etc.,  and whether these concerns differs for
liquid waste (e.g., waste halogenated solvent) verus a flame retardant
coating that contains halogens.


As I started looking through the report, I was trying to guess what the
source of the halogenated compounds could be.  I never would have
thought of flame retardant chemicals before I saw it in the report.


Dave Salman


Dave Salman
Coatings and Consumer Products Group
US EPA OAQPS
Mail Code C539-03
RTP NC 27711
tel (919) 541-0859
fax (919) 541-5689
e-mail salman.dave@epa.gov










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