Transcript Document

Tennessee Small Business
Environmental Assistance Program
(SBEAP)
9 Metal Fabrication & Finishing
for Small Businesses
SBEAP offers free, non-regulatory and confidential assistance
National Emissions Standards for
Hazardous Air Pollutants:
Area Source Rule for:
9 Metal Fabrication & Finishing
Final Rule Effective Date: July 23, 2008
Course Overview
Background and Control of MFHAPs
Requirements
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•
Equipment
Management Practices
Exemptions
Compliance
Notification, Recordkeeping & Reporting
Q & A - Contact Information
Background: Why Did EPA
Create This Regulation?

The Clean Air Act (CAA) required EPA to
develop air emission standards for a list of
187 hazardous air pollutants (HAPs)
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The standards are to reduce exposure to
HAPs because the chemicals are known, or
suspected, to cause cancer or other serious
health effects, such as birth defects
Metal Finishing Hazardous Air Pollutants
MFHAPs - materials that contain:
Cadmium
Lead
Chromium
Nickel
in amounts greater than or equal to 0.1
percent by weight (as the metal), and
Manganese in amounts greater than or
equal to 1.0 percent by weight
Background: What’s this rules about?
Affected Operations for 9 Metal Sources:
1.
2.
3.
4.
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7.
8.
9.
Electrical and Electronic Equipment Finishing
Fabricated Metal Products
Fabricated Plate Work (Boiler Shops)
Fabricated Structural Metal Manufacturing
Heating Equipment, except Electric
Industrial Machinery and Equipment Finishing
Iron and Steel Forging
Primary Metal Products Manufacturing
Valves and Pipe Fittings
Background: What’s this rules about?
8 Processes covered by 9 Metal Rule:

Dry Abrasive blasting (3)
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Non-vented i.e. “Glove Box” type
Vented w/ filters
Objects greater than 8 feet
Dry grinding and Dry polishing w/ machines
 Machining
 Spray Painting (2)
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Spray Booth
Non Spay Booth
Welding
National Emissions Standards for
Hazardous Air Pollutants:
Area Source Rule for:
9 Metal Fabrication & Finishing
Dry Abrasive Blasting Activity
Final Rule Effective Date: July 23, 2008
Dry Abrasive Blasting Activity
All equipment and activities necessary
to perform dry abrasive blasting
operations which use materials that
contain MFHAP or that have the
potential to emit MFHAP
Dry Abrasive Blasting Requirements
Dry Abrasive Blasting for “glove box” type
operation must have enclosed &
unvented blast chamber
Management & P2 Practices:
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Minimize dust generation during emptying
of the enclosure; and
Operate all equipment used in the blasting
operation according to manufacturer’s
instructions.
Dry Abrasive Blasting Requirements
Vented enclosure:

Must use a control system with a capture
device, and a cartridge, fabric, or HEPA
filter to reduce (PM) emissions
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Enclosure must have a roof and at least
two complete walls, with side curtains and
ventilation
Dry Abrasive Blasting Requirements
Vented enclosure - Management and
pollution prevention practices:
 Take
measures to minimize excess dust in
the surrounding area to reduce MFHAP
emissions
 Enclose
abrasive material storage areas and
holding bins, seal chutes and conveyors
transporting abrasive materials
 Operate
all equipment according to
manufacturer’s instructions
Dry Abrasive Blasting Requirements
Objects greater than 8 Feet:
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Management and P2 Practices
Must use low PM-emitting blast media (e.g.,
crushed glass, hematite, steel shot or
aluminum oxide
Do not re-use blast media unless
contaminants have been removed by
filtration or material screened to original size
Dry Abrasive Blasting Requirements
Objects greater than 8 Feet:
Management and P2 Practices Cont.
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Enclose abrasive material storage areas,
holding bins, seal chutes and conveyors
Operate all equipment used in the blasting
operation according to manufacturer’s
instructions
Perform visible emissions monitoring
Dry Abrasive Blasting Requirements
Objects greater than 8 Feet:
Visible Emissions Testing
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Conduct visible emissions testing to
demonstrate continuous compliance with
management and pollution prevention
practices
Perform visual determinations of fugitive
emissions using EPA Method 22 at the
fence line nearest operation
Dry Abrasive Blasting Requirements
Objects greater than 8 Feet:
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Graduated Testing
Affected source must be tested daily for
visible emissions with Method 22 for 10
consecutive days during operation
If no visible emissions are observed, test
once every 5 consecutive days of operation
If no visible emissions are observed during
4 consecutive weekly Method 22 tests, test
once per consecutive 21 days (month)
Dry Abrasive Blasting Requirements
Objects greater than 8 Feet:
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Graduated Testing Cont.
If no visible emissions are observed during 3
consecutive monthly Method 22 tests, test
once every three months of operation
If any visible emissions are observed during
the weekly, monthly, or quarterly testing, the
source must resume VE testing more
frequently
National Emissions Standards for
Hazardous Air Pollutants:
Area Source Rule for:
9 Metal Fabrication & Finishing
Dry grinding and Dry polishing
with Machines Activity
Final Rule Effective Date: July 23, 2008
Dry grinding and Dry polishing with
machines - Requirements
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Operations often emit significant PM, which
is a surrogate for MFHAP
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Must capture PM emissions (MFHAPs) and
vent the exhaust to a cartridge, fabric, or
HEPA filter
Dry grinding and Dry polishing with
machines - Requirements
Management and pollution prevention practices:
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Minimize excess dust in the surrounding
work areas to reduce PM emissions;
Operate all equipment according to
manufacturer’s instructions
Dry grinding and Dry polishing with
machines - Exemptions
Operations do not include those
performed with hand-held or benchscale devices
National Emissions Standards for
Hazardous Air Pollutants:
Area Source Rule for:
9 Metal Fabrication & Finishing
Machining Activity
Final Rule Effective Date: July 23, 2008
Machining Requirements
Machining is typically enclosed and/or uses
lubricants or liquid coolants that prevent
escape of small particles
Management and pollution prevention
practices:
Minimize excess dust in the surrounding area
to reduce PM emissions;
 Operate equipment used in machining
operations according to manufacturer’s
instructions.
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National Emissions Standards for
Hazardous Air Pollutants:
Area Source Rule for:
9 Metal Fabrication
& Finishing
Welding Activity
Final Rule Effective Date: July 23, 2008
Welding Requirements
Minimize emissions of MFHAP
by implementing one or more
management practices:
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Use welding processes with
reduced fume generation
capabilities (e.g., gas metal arc
welding (GMAW); aka metal
inert gas welding(MIG));
Use welding process variations
(e.g., pulsed GMAW), which
can reduce fume generation
Welding Requirements cont.
Additional Management Practices:
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Use welding filler metals, shielding gases,
carrier gases, or other process materials
capable of reduced welding fume generation
Optimize welding process variables (e.g.,
electrode diameter, voltage, amperage,
welding angle, shield gas flow rate, travel
speed) to reduce the amount of welding fume
generated
Welding Requirements cont.
Additional Management Practices:
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Use a welding fume capture and control
system and operate according to
manufacturer’s specifications.
Welding Requirements cont.
Visual Emissions Testing:
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Welding operations using 2,000 pounds of
welding rod per year must perform visible
emissions testing from a vent, stack, exit, or
opening from the building
Welding metal fabrication and finishing
operations must demonstrate continuous
compliance via management practices and
equipment standards
Testing has a 3 tier compliance structure
Welding Requirements cont.
Visual Emissions Testing: Tier I
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Welding compliance requires visual
determinations of fugitive emissions using
EPA Method 22 and allows the graduated
testing schedule
If visible emissions are present during any
Method 22 test - corrective action is required
For graduated schedule source resumes
visible emissions testing in the previous,
more frequent schedule
Welding Requirements cont.
Visual Emissions Testing: Tier II
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2nd tier welding compliance must be
implemented if visible emissions are
detected for the 2nd time in any consecutive
12-month period
2nd tier requires corrective action and
documentation of the detection of visible
emissions and the corrective action taken
Must perform a visual determination of
emissions opacity using EPA Method 9
Welding Requirements cont.
Visual Emissions Testing: Tier III
3rd tier welding compliance includes the
development and implementation of a Sitespecific Welding Emissions Management
Plan (SWMP)
 SWMP must be kept at the facility in a readily
accessible location for inspector review
 Facility must report any exceedence of the
20 percent opacity limit on an annual basis
along with their annual certification and
compliance report
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Initial
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Compliance Requirements
Must certify that they have implemented all
required management and pollution
prevention practices
Spray painting operations must certify
compliance with use of PM filters in spray
booths or spray rooms; use of approved
spray delivery and cleaning systems; and
proper training of workers in spray painting
application techniques
Continuous Compliance
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Requirements
Demonstrate by adhering to management
practices and maintaining appropriate
records
For specific processes or groups of
processes visual emissions testing for dry
abrasive lasting of objects greater than 8 feet
PM control efficiency rating of filters used in
spray booths/ rooms for MFHAPs
Visual emissions testing for welding at
facilities that use 2,000 pounds of welding rod
National Emissions Standards for
Hazardous Air Pollutants:
Area Source Rule for:
9 Metal Fabrication & Finishing
Spray Painting Activity
Final Rule Effective Date: July 23, 2008
Spray Painting Activity
All equipment and activities
needed for spray-applied
painting operations using
paints which contain MFHAP
All equipment used to apply
cleaning materials in
preparation for painting, to
remove dried paint; to apply
paint and to dry or cure after
application; or to clean paint
operation equipment
Spray Painting Requirements
Background: What’s this about?
Spray Painting Requirements
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Spray painting of objects in general
Spray painting of objects greater than 15 feet
in any dimension
Spray painting operations in the Fabricated
Structural Metal Manufacturing source
category
Control of MFHAP from Spray Painting
Facilities must control MFHAPs with the
use of Equipment:
 Spray
Booths or Rooms w/ Particulate
Matter (PM) filters
 Low
–emitting and pollution preventing
Spray Gun Technology
Management Practices
Control of MFHAP without a Spray Booth
Used for objects greater than 15’
For objects greater than 15 feet in any
dimension and Spray Painting at
Fabricated Structural Metal
Manufacturing Facilities Not Performed in
Spray Booths
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Comply with equipment standard of Spray
Gun Technology
If spray guns are used, no PM filters
required
Paint Spray Booth or Room
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Must have a full roof, and
four walls, of which can
include up to 2 side
curtains
Must be ventilated so that
air is drawn into the booth
and leaves only though the
PM filter
PM filters with at least 98%
control efficiency
Water-wash Spray Booth or Room
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As an alternative option, spray
booths or spray rooms may be
equipped with a water curtain
that achieves at least 98%
control and capture efficiency
of MFHAP
Must be operated and
maintained according to
manufacturer’s specifications
Spray Gun Technology
Facilities that apply spray coatings are
required to use efficient spray guns
including high-volume - low-pressure
(HVLP) spray gun, electrostatic
application, airless spray gun, airassisted airless spray gun, or an
equivalent technology that is
demonstrated to achieve comparable
transfer efficiency
Spray Painting Training
Requirements
Ensure painters are trained in spray painting
techniques to help reduce and control
MFHAPs
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Training should be provided to all workers
that perform spray painting
Painters must be certified as having
completed classroom or hands-on training
in the proper selection, mixing, and
application of paints
Refresher training to occur every 5 years
Spray Painting Training
Requirements Cont.
Initial and refresher training must address
topics to reduce paint overspray &
emissions:
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Spray gun equipment selection, setup, and
operation, including measuring paint viscosity
Selecting the proper fluid tip or nozzle, and
achieving the proper spray pattern, air
pressure and volume, and fluid delivery rate
Spray Painting Training
Requirements Cont.
 Spray
technique for different types of paints to
improve transfer efficiency and minimize paint
usage and overspray
 Maintaining
correct spray gun distance and
angle to the part, using proper banding and
overlap
 Reducing
lead and lag spraying at the
beginning and end of each stroke
 Routine
spray booth and filter maintenance,
including filter selection and installation
Spray Painting Training
- by When?
Spray painters at existing sources must be
trained by July 25, 2011, or 180 days after
hiring
Spray painters at new sources must be
trained and certified no later than January
20, 2009, 180 days after startup, or 180
days after hiring
Management Practices
Control MFHAP in spray painting:
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Must regularly inspect and replace filters in all
Spray Booths or Spray Rooms per
manufacturer’s instructions, and document
these activities
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All spray painting must be done with efficient
Spray Gun Technology and alternate spray
guns must be EPA approved
Management Practices Cont.
Spray Gun Cleaning
 All cleaning operations must be done with
non-HAP gun cleaning solvents, or
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In a way that an atomized mist of spray of
gun cleaning solvent and paint residue is not
created outside of a container that collects
the used cleaning solvent
Management Practices Cont.
Spray Gun Cleaning may be done by:
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Hand cleaning parts of disassembled gun in
a container of solvent, or
Flushing solvent through the gun without
atomizing the solvent and paint residue, or
Using a fully enclosed spray gun washer, or
Any combination of these non-atomizing
methods above may be used
Management Practices Cont.
Spray painting worker certification
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All painters must be certified and trained
in spray application of paints, setup and
maintenance of spray equipment
Meet minimum requirements for training
and certification
Spray application of paint by non-certified
persons is prohibited
Management Practices Cont.
Spray painting training program content
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Provide a description of the methods to be
used at the completion of initial or
refresher training to demonstrate,
document, and provide certification of
successful completion of training
Facilities that document a painter’s work
experience and/or training as equivalent
to meet initial training requirements –
need not provide training to these painters
Management Practices Cont.
Spray painting training program content
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List of all current personnel by name and
job description who are required to be
trained
Management Practices Cont.
Spray System Recordkeeping
Facility must maintain documentation of the
HVLP or other high transfer efficiency spray
paint delivery methods
Records of spray painting training
Maintain records of employee training
certification for use of HVLP or other high
transfer efficiency spray paint delivery
methods
Spray Painting Exemptions
This rules does not apply to:
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Non-HAP spray paint
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Research or laboratory facilities
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Tool or equipment repair operations, facility
maintenance, or quality control activities
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Military operations or NASA
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Operations that produce military munitions
Spray Painting Exemptions
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Training requirements do not apply to
students under supervision of an
instructor who meets the requirements
Requirements do not apply to operators of
robotic or automated painting operations
Hand held devices with a paint cup
capacity that is less than 3.0 fluid ounces
(89 cubic centimeters);
Spray Painting Exemptions
 Powder
coating,
 Hand held non-refillable aerosol
containers, or
 Non-atomizing application technology,
paint brushes, rollers, hand wiping, flow
coating, dip coating, electro-deposition
coating, web or coil coating, touch-up
markers, or pens
Spray Painting Exemptions
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Painting that normally requires the use of an
airbrush or an extension on the spray gun to
properly reach limited access spaces
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Coatings that normally have a dried film
thickness of less than 0.0013 centimeter
Spray Painting Exemptions
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Application of paints that contain fillers that
adversely affect atomization with HVLP or
equivalent spray guns
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Thermal spray operations i.e. metalizing,
flame spray, plasma or electric arc spray, in
which solid metallic or non-metallic material
is heated to a molten state and applied to
the work piece, where a bond occurs upon
impact
How to Show Compliance

Must certify all required management and
pollution prevention has been
implemented

Certify facility use of PM filters in spray
booths or spray rooms; use of approved
spray delivery and cleaning systems; and
proper training of workers in spray
painting application techniques
How to Show Compliance Cont.
Continuous Requirements:
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Comply by operating capture and control
systems according to the manufacturer’s
specifications
Maintain records on site to document
conformity
Keep manufacturer’s instruction manual
available at the facility at all times
Test for Continuous Compliance
Continuous compliance in controlling Spray
Painting MFHAPs:
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All spray-applied paints with MFHAP are
applied with a HVLP spray gun, electrostatic
application, airless spray gun, or equivalent;
Emissions of MFHAP are minimized during
mixing, storage, and transfer of paints
Test for Continuous Compliance
Continuous compliance in controlling Spray
Painting MFHAPs:
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Paint and solvent lids are kept closed when
not in use
Facility must ensure / certify that paint spray
booths or spray rooms are fitted with PM
fiberglass or polyester fiber filters, water
spray technology or other comparable filter to
achieve at least 98% control efficiency of
MFHAPs
What are my Compliance dates?

Existing Sources must achieve
compliance with the applicable provisions
by July 25, 2011
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New Sources must achieve compliance
with the applicable provisions by
July 23, 2008, or upon startup, whichever
is later
Notification, Record keeping &
Reporting Requirements

New sources must submit an Initial
Notification no later than 120 days after
initial startup or November 20, 2008,
whichever is later

Existing sources must submit the Initial
Notification no later than July 25, 2011
(See SBEAP’s hand-out or EPA’s sample of initial
notification form for reporting details)
Notification, Record keeping, &
Reporting Requirements
Notification of Compliance (NOC) Status:
 NOC reports are to be submitted no later
than 120 days after the applicable
compliance date for new sources; Existing
sources must submit by November 22, 2011

Submit an annual certification and
compliance status report
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A facility with exceedences during the year,
must submit an annual certification and
compliance report with any exceedences
reported
Notification, Record keeping, &
Reporting Requirements
Notification of Compliance Status:

Reports must describe the circumstance of
the exceedence and the corrective action
taken
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See SBEAP’s sample Notification of
Compliance Status document
Notification, Record keeping,&
Reporting Requirements

Facilities are required to maintain all
records that demonstrate initial and
continuous compliance

Include records of all required notifications
and reports, with supporting
documentation; and records showing
compliance with management and pollution
prevention practices
Questions Anyone?
Resource Assistance Tools
are available on SBEAP’s
web Page:
http://tn.gov/environment/apc
/sbeap/sbeap_9metal.shtml
E-mail: [email protected]
Contact SBEAP staff about this
presentation, updated information
or assistance tools for 9 Metal
Fabrication & Finishing
Tennessee Small Business
Environmental Assistance Program
(SBEAP)
1-800-734-3619
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