Ask the Expert Question-and-Answer Archive

by Ron Joseph

September, 2006

Solvent Limitations in Ship Building NESHAP

Q: We are a shipyard in the tropics. I recall reading an EPA –NESHAPS statement that addressed paint thinning allowances for shipyards. I specifically recall seeing a statement addressing “No Thinning Allowances” for shipyards in the tropics. The only allowance for the use of solvent was 1000 liters annually for cleaning purposes only.

Are you aware of this regulation and can you expand upon it?

A: The EPA has written National Emission Standards for Hazardous Air Pollutants (NESHAPs) for various industries that emit large quantities of hazardous air pollutants (HAP). A list of HAPs can be found at EPAs web site.  Please note that only a few solvents are considered to be HAPs!   To be covered by a NESHAP your company must have the "Potential to Emit" (PTE) more than 10 tons/year of a single HAP or more than 25 tons/year of a combination of HAPs. Other conditions also apply and you should therefore familiarize yourself with the qualification requirements.  The definition of "Potential to Emit" can be found in the NESHAP that covers general conditions, which you can also access on the EPA web site.  

Therefore IF your company is subject to the ship building NESHAP, you are required to limit your use of solvents. However, if your company does not qualify, then you are not required to follow this directive.   Unfortunately, I cannot go into more detail now as this topic is extensive.  You can take classes in the US that deal with NESHAPs, or you can retain the services of an American environmental consulting firm that can calculate your "potential to emit" and advise you on how to proceed. The following URL will get you started on the topic, but you might need to access more documents to get fully educated on this extensive and important subject.  http://www.epa.gov/ttn/atw/shipb/shipbpg.html  

Good luck.

Best wishes,

Ron Joseph