Metal Painting and Coating Operations

Table of Contents  Background  Regulatory Overview  Planning P2 Programs  Overview of P2  Surface Preparation
Alternatives to Solvent-Borne Coatings  Application Techniques  Curing Methods  Equipment Cleaning

Planning Pollution Prevention Programs at Coating Facilities

How can assistance providers and regulatory compliance staff sell pollution prevention options to a facility? The most important point that an assistance provider can make is that pollution prevention can help the facility achieve regulatory compliance while saving money. The savings associated with recapturing and reclaiming materials is obvious; but the value of reducing the regulatory burden and the expense from wasted raw materials, can, in many cases, exceed the cost of pollution prevention projects. Overall, the benefits associated with pollution prevention include:

• Reduced Operating Costs/Overhead
  These savings can result in reduced utility charges, water/sewer fees, wastewater treatment costs, waste disposal expenses, permit discharge fees, analytical monitoring, and reporting costs.
• Reduced Manufacturing Costs
  Facilities can save money on reduced material costs (paint and solvent purchases), water costs, and energy costs.
• Product Quality Improvements
  Pollution prevention techniques often increase the quality of the coating process. Improving process controls makes coating operations more efficient and allows them to run within tighter operating parameters, often resulting in decreased reject rates.
• Environmental Risk Reduction <> Pollution prevention projects can result in reduced noncompliance enforcement actions; reduced environmental and worker health liability; and reduced risk of on-site contamination via spills, releases, and leaks.

Potentially, a facility can realize other benefits from the implementation of a comprehensive pollution prevention program. Source reduction can lower insurance costs, protect property values, and improve relationships with financial institutions. Even though pollution prevention has clear economic advantages and the techniques can be simple, inexpensive, and time proven, many facilities still do not have significant source reduction programs (Haveman, 1995).

This chapter provides information on how to conduct an assessment of a facility that has a coating process. It provides information on a general facility assessment as well as specific information on assessing the coating process. Technical assistance providers should be aware that while a facility may have one process or chemical that is of major concern, assessing the entire facility is critical. In this way they can identify processes that are impacting the coating process and that might be increasing pollution generation.

Characterizing a Facility

Numerous factors can influence whether a facility adopts and implements pollution prevention techniques. Understanding what motivates a facility can help a technical assistance provider develop a message for the facility that will influence their decision to implement pollution prevention. The following list divides firms into categories and describes some characteristics of firms and their motivating factors:

• Environmentally proactive firms that actively pursue and invest in strategic environmental management projects: Most often these firms are in compliance with environmental regulations. They actively pursue and invest capital in continuous improvement projects that go beyond compliance in order to maintain their places as environmental leaders in their sector. These firms are often driven by public recognition, and pride in industry performance. They understand the economic payoffs of strategic environmental investments and believe that flexibility in compliance would promote innovative approaches and increase their willingness to help other firms.
  
• Firms that are in compliance but do not or cannot seek opportunities to improve environmental performance because they lack the necessary resources: Regulatory compliance is what drives this potentially large middle tier. Barriers to proactive performance include a lack of capital and information, and a lack of positive reinforcement.

The barriers that generally apply to some or all of these facilities are:

• Regulatory compliance and/or enforcement actions: Many shops lack the personnel and capital resources to move beyond compliance. Liability may be a barrier to obtaining loans for capital improvements. Existing liability can overwhelm their ability to pay for remediation or new, cleaner technologies.
  
• Development of safer products: In some cases, suppliers might be reluctant to suggest environmentally proactive processes or product changes because these could result in lower product sales.
  
• Uncertainty about future regulatory activity: Inconsistency in existing regulatory requirements and enforcement actions at the federal, state, and local level creates uncertainty and, at worst, competitive imbalances throughout the industry. This climate generates distrust of EPA and state programs and can inhibit meaningful communication.
  
• Lack of awareness of changes in product/process technology: Facilities may not have the time or resources to research new technologies and the benefits these technologies could provide them (Haveman, 1995). In some cases, facilities may be aware of the new technologies but are unwilling to implement them because they cannot field test the new systems at their facility.

Planning

The key to developing a successful pollution prevention program is planning. Assistance providers can work with facilities to implement planning programs, assist in establishing baseline measures, and identify potential pollution prevention projects. The key steps to starting a pollution prevention program include:

• Obtaining management support and involvement
• Establishing an in-house pollution prevention team
• Attracting company wide involvement

The following pages outline an ideal planning process. Often, there are issues and limitations that inhibit a company's ability to carry out all of the outlined activities. Therefore, this process should be viewed as a flexible model.

Management Support

The support of company management is essential for developing a lasting and successful pollution prevention program. The level of success that a facility can achieve in reducing waste generation appears to depend more on management interest and commitment than on technical and economic feasibility, particularly for source reduction technologies that require process modifications or housekeeping improvements. In some states, the technical assistance programs will not work with a facility until top management has shown that it is willing to support a long-term pollution prevention program.

At the outset of the P2 planning program, management endorsement is needed to help identify the pollution prevention team and give credence to the planning effort. Throughout the program, company management can support the team by endorsing goals and implementation efforts, communicating the importance of pollution prevention, and encouraging and rewarding employee commitment and participation in the effort (Dennison, p. 61).

At some companies, technical assistance providers may find that employees see only the barriers face in implementing a project, which they use as excuses to not implement pollution prevention. At other firms, motivated employees are empowered to find solutions to overcome obstacles, and the companies can reap the benefits of successful pollution prevention projects. Technical assistance providers should stress to management that a successful program has a wide range of benefits. These benefits include cost savings, reduced liability, and enhanced company image as described earlier.

Assistance providers should inform management that some initial labor costs will be incurred as a result of organizing and implementing a pollution prevention program. Usually, however, companies find this up-front investment is repaid several times over. Case studies often highlight the benefits that other companies have realized from implementing such programs.

Technical assistance providers can help facilitate management support by developing a plan that sells pollution prevention to a company's executives. Successful management initiatives that have promoted pollution prevention include: developing a corporate policy that makes pollution prevention a mandate; incorporating pollution prevention success into performance evaluations; and offering financial incentives for meeting pollution prevention goals or for finding pollution prevention opportunities.

Obviously, each firm is different. The assistance provider's approach to each company's leadership should attempt to address their specific interests and priorities as manifested by the corporate culture. Identifying these interests and priorities is a challenge for any assistance team. On these visits the teams discuss their priorities and pollution prevention in relation to those priorities. Technical assistance providers should also stress to management that planning is an ongoing task. Once the initial plan is completed, the facility should continue to reevaluate their operations to identify areas that can be improved (CAMF, 1995).

Establishing the Team

A successful pollution prevention program requires not only support from management, but also input and participation from all levels of the organization. To champion the effort, every pollution prevention program needs an effective pollution prevention coordinator. Assistance providers can help identify the team leader, work with the leader on developing their team, and suggest ways for the facility to implement its pollution prevention program.

A team approach allows tasks to be distributed among several employees and enables staff from different parts of the company to have input into the planning process. Members of the team are typically responsible for:

• Working with upper management to set preliminary and long-term goals
• Gathering and analyzing information relevant to the design and implementation of the program
• Promoting the program to employees and educating them on how they can participate in the effort
• Monitoring and reporting to management on the progress of the program (Dennison, p. 61)

The pollution prevention team should include employees who are responsible for planning, designing, implementing, and maintaining the program. The ideal size of the team depends on the size of the organization. In small companies, the team can consist of one person who wears many hats, or the company manager and a technical person. In larger companies, the team might include environmental managers, building supervisors, technical staff, maintenance staff, marketing staff, purchasing staff, and other interested employees (Dennison, p. 63).

External personnel, such as technical assistance providers or consultants, can complement the team by providing technical or managerial expertise. Often these people can offer auditing expertise as well as knowledge of pollution prevention, and environmental laws and regulations. However, external contributors will be unfamiliar with the facility's operation. Once the team is established, assistance providers and regulatory staff should encourage the facility to take the following steps to properly evaluate the options for reducing pollution:

• Define and Identify the Facility's Objectives: Clearly identify, quantify, and rank the facility's objectives. For example, at some facilities compliance with air quality standards is a primary concern while optimized worker efficiency and cost are secondary concerns.
  
• Define Criteria for Evaluating Pollution Prevention Options: Clearly define what constitutes a feasible option. Items to consider in addition to technical feasibility include economic feasibility, quality standards, and the effect of the option on the overall process.

The following pages provide an overview of the typical steps involved in assessing a facility and coatings processes in particular. These steps include:

• Characterizing the facility
• Gathering baseline facility data
• Analyzing workplace practices
• Developing process flow diagrams
• Identifying pollution prevention options
• Analyzing and selecting options for further investigation
• Pilot testing preferred options
• Implementing the new system
• Evaluating and maintaining the pollution prevention program

While the facility may have brought in a technical assistance provider to suggest methods for a single process or problem, the entire facility must be evaluated because the coating process will be affected by outside issues. Consider the case of a facility that wants to change from solvent cleaning to aqueous cleaning but has problems with removing cutting fluids. The machining process would need to be examined to see if the facility could use alternative cutting fluids that are easily removed using aqueous cleaning.

Assess the Facility

Once the team has defined its objectives and criteria for a pollution prevention program, the next step is to assess the facility. Beyond the facility tour, useful information for the assessment can be obtained from sources such as:

• Engineering interviews and records
• Accounting interviews and records
• Manifest documents
• Vendor data
• Regulatory documents
• Sampling data

Map the Facility

Locate or prepare drawings of the layout of the process and storage areas. These drawings should be to scale, showing the location of all relevant equipment and tanks, and identifying:

• Floor space of the facility
• Coating and other process lines
• Gutters, sumps, and sewer lines
• Water lines, control valves, and flow regulators
• Ventilation/exhaust systems

Gather Baseline Information

The first step in P2 assessments of coatings processes is to collect as much information as possible about the coating process from company personnel. Background information should establish the sources and nature of wastes generated, and can include:

• Specific information about emissions (e.g., current releases, desired reductions) and other wastes generated from coatings operations (e.g., wastewaters and paint wastes)
• Details about the type of coating used and application techniques
• Information about the types of parts to be coated and performance specifications of the finish
• Details about the surface preparation and equipment cleaning processes (e.g., equipment and methods used)

Technical assistance providers should also review all operations of the facility that relate to chemical, energy, or water use. Some of the information that technical assistance providers should request includes:

• Estimates of production units, such as square meters coated and number of parts that pass through a line sequence, or production rates (i.e., square feet processed per hour)
• Material purchases
• Material inventory
• Material use rates (where each material is used and how much is used in each process)
• Waste management costs
• Raw material costs
• Compliance problems
• Control processes
• Sampling and analysis information
• Process line design and condition
• Actual operating procedures
• Operating parameters

The information listed above should be used in conjunction with the information obtained in the walk-through of the facility to determine what pollution prevention options are technically and economically feasible. This information should also provide the technical assistance provider with information to determine which processes in a facility need to be addressed to reduce pollution generation.

Analyze Workplace Practices

A great deal of data should be accumulated so that assistance providers can determine the best pollution prevention approaches for a facility. The first pieces of information gathered should be material/resource use, general operating procedures, and facility information. This information usually can be gathered prior to a facility tour and used to start a facility map that will be valuable during the site visit. Table 5 provides an overview of the basic operational information that technical assistance providers should obtain from the company prior to the technical assistance visit.

Table 5. Overview of Assessment Information (BCDNRP)

Additional information is gathered during the facility tour. When touring the coatings operations at a facility, technical assistance providers should observe or ask employees about workplace operating practices. Often, employees can provide valuable insight both into why waste is being generated and into some of the obstacles a plant may face in implementing new projects or methods. The following lists present some of the questions technical assistance providers might want to ask (KSBEAP, p.33):

Personnel

• Do employees view overspray as lost product?
• Are paint and solvent records maintained for each spray gun operator?
• Are gun operators or paint crews rewarded for high quality work using less paint?
• Are there written guidelines on how much paint should be prepared and used for frequent jobs?
• Are employees provided with proper devices to measure the correct amount of paint?
• Are operators given spray gun training?
• Is technique training routinely provided?
• Are performance monitors in place?

Housekeeping/Maintenance

• Is spray equipment maintained according to manufacturer or vendor instructions?
• Are paint containers tightly closed when not in use?
• Are there regular inspections and repairs for paint and solvent leaks?
• Are tight-fitting spigots used?
• Are spigots or pumps used to transfer paint from storage containers to smaller containers?

Inventory Control

• Are good records kept on paint inventory and use?
• Are paint purchase expenses allocated to the painting department?
• Are paint containers adequately labeled?
• Are paints stored on the floor according to manufacturer's instructions?
• Are paints used on a first-in, first-out basis?
• Is access to the paint room controlled?
• Is access to solvents controlled?
• Are unused or expired paints returned to vendors or manufacturers?
• Is a computerized paint-mixing system used?

Scheduling

• Are certain production runs scheduled around the same time each month?
• Are jobs scheduled so that jobs using the same color are scheduled together?
• Are production runs scheduled to go from lighter to darker colors?

Equipment and Materials

• Are efficient spray guns being used (e.g., HVLP, electrostatic)?
• Are paints maintained at proper viscosity?
• Is the correct gun setup being used for the paint and the workpiece?
• Is it possible to reduce gun pressure and achieve an acceptable finish?
• Are gun operators keeping the spray pattern over the workpiece?
• Are gun operators holding the gun perpendicular to the work surface?
• When part size allows, are operators making a pass over the full length of the work surface?
• Are paints with less or no hazardous ingredients being used?
• Are high-solids or powder coatings used?

Rework

• Is touch up done only on the imperfection or reworks?
• If paint is stripped, are mechanical methods being used instead of chemical ones?
• If using chemical stripping, are less toxic strippers being used?

Cleanup and Disposal

• Are waste paint handling and solvent handling charges allocated to the production units or departments that incur them?
• Are guns, nozzles, and lines cleaned immediately after use?
• Are enclosed paint gun cleaners used?
• Is compressed air used to clean lines instead of solvent?
• Are spatulas or scrapers used to clean equipment and paint containers prior to using solvents?
• Are polystyrene filters used?
• Is unused paint stored properly so that it can be used again?
• If waste paint cannot be used onsite, are there potential employee or local uses?
• Is solvent recycled onsite?
• Is solvent gravity separated from waste sludge?

If the technical assistance provider uses the team approach described above, many individuals from all areas of the company will have a chance to share their perspective on pollution problems and solutions. Working with this information, technical assistance providers can develop a process map, including data information. Using these tools, the P2 team can go onto the plant floor to discuss the process with those directly involved (e.g., supervisors and front-line production workers) to determine appropriate P2 projects and develop a baseline to measure all future efforts.

Develop a Process Flow Diagram

Once all the information has been gathered and a map of the facility is drawn, technical assistance providers can develop a process-flow diagram. Process-flow diagrams break the facility down into functional units, each of which can be portrayed in terms of material inputs, outputs, and losses. Developing a process map helps the facility understand how the production process is organized, thereby providing a focal point for identifying and prioritizing sources of emissions and waste (EPAp, 1996).

The process map should cover the main operations of the facility and any ancillary operations (e.g., shipping and receiving, chemical mixing areas, and maintenance operations). Separate maps can be generated for these ancillary operations. Another important area to cover is "intermittent operations" or operations that do not occur on a regular basis. The most common intermittent operations are cleaning and

Assistance providers should also help the facility to include operations that are upstream and downstream of the coating operation. For example, machining operations could have a major impact on cleaning operations. Pollution and waste issues often cross process boundaries. An understanding of the origins of the pollution can assist the facility in identifying opportunities for pollution prevention.

Identify Pollution Prevention Opportunities

Using the information obtained in the facility assessment, the team should compile a list of P2 options that are technically feasible. Brainstorming sessions with the P2 team can provide innovative ideas. Researching case studies of other companies also can provide valuable information. Other potential sources of ideas include suppliers and consultants. At this point, all ideas should be taken seriously, and none should be rejected automatically for reasons such as "that's already been tried," or "it will never work," or "it's too expensive."

After all options have been identified, the team should screen the options based on the objectives and criteria that were established in the assessment phase. Each option should fit into one of the following categories:

• Ideas that are impractical
• Ideas that need more detailed information and study
• Ideas that can be implemented with a minimum of effort and cost

This initial evaluation will assist the company in identifying a subset of options that deserve further investigation. Generally, the number of options requiring detailed information and study should be pared to a minimum (Ferrari, 1994).

When screening ideas, assistance providers should keep in mind that an important principle of excellence in manufacturing is maximizing the productivity of the coating process. Some pollution prevention options can increase productivity while others can decrease productivity, sometimes substantially. Technical assistance providers should be aware of how their suggestions can affect the productivity of the coatings process when screening options. By gaining information on these types of issues, technical assistance providers can provide better suggestions on pollution prevention options when assessing a facility.

Analyze and Select Options

Once a short list of options has been identified, the team should begin the process of deciding which options are appropriate for the facility. During this phase, the team should be clear on the company's objectives and criteria. Depending on the goals of the company, cost effectiveness might not be the overriding goal. The following questions should be asked when screening options:

• Which options will best achieve the companies waste/emissions reduction goals?
• What are the main benefits to be gained by implementing this option?
• Does the technology exist to implement the option?
• How much does it cost?
• Can the option be implemented without major disruptions in production?
• Does the option have a good track record?
• Does the option require additional space?
• What are other areas that might be affected by implementation of the option?

In addition, a company that believes cost effectiveness is critical should consider the long-term costs associated with a particular option. For instance, the team might be inclined to disregard an option because the initial capital outlay is high; however, upon examining the total cost associated with the project, the team might find that the measure could yield impressive savings in several years (Dennison, p. 75). In order to identify the total costs associated with both existing and new processes, the facility could consider costs that traditionally have not been incorporated into capital acquisitions. For more information on identifying these costs, assistance providers can refer to Improving Your Competitive Position: Strategic and Financial Assessment of Pollution Prevention Projects, a training manual developed by NEWMOA for conducting financial assessments of pollution prevention projects.

Pilot Test or Validate Preferred Options

Once the facility has determined its preferred option(s), the facility can pilot test the program prior to full facility implementation. A pilot test can highlight any installation or implementation issues. At this point, the technical assistance provider has completed most of his or her job. However, if issues arise in the pilot test phase, he or she can be called in to troubleshoot and suggest other alternatives. The technical assistance provider could brief the facility's P2 team on how to anticipate and prevent problems and issues during implementation of the new system. This could be useful because the cost to correct a failed system can greatly exceed the cost of proper initial implementation.

Procure and Implement New System

Once the new system is installed, the company's employees should be informed about the project and the importance of their cooperation and involvement. Operators should be trained on how to properly operate the system. Companies should update employees on the expected benefits of and the progress made in achieving the goals of the new system.

Frequent updates on the progress of the overall P2 program can increase a staff's stake in the program. In order to sustain employee interest in P2, facilities should encourage staff to submit new ideas for increasing the effectiveness of the program.

A few critical rules should be kept in mind when helping a company consider new projects:

• No single system or process is right for all applications. A vast range of variables can affect the coatings process which, in turn, affects the selection and performance of a pollution prevention system. Specific variables include work type, work loading rate, workpiece geometry, substrate materials, and finish requirements.
  
• Prior to investing in any new system, the team should take the time to evaluate and understand the process, preferably including a rigorous pilot test in the facility.
  
• The team should recognize that the provider of any new system (including the designer and sales staff) is a new partner at the facility (Ferrari, 1994).

Evaluate and Keep the Program Going

Assistance providers can suggest that the facility develop a mechanism for soliciting input from all employees in the future. Communicating the success of the program also can keep employees involved. The facility can use the baseline information developed from the facility assessment phase to communicate any progress that has been made. Technical assistance programs can follow up with a facility (usually within 6 months to one year from their final visit) to report on the successes and failures of the company's P2 program and learn of new projects that the facility may have implemented.