Tennessee Small Business Environmental Assistance Program (SBEAP) 9 Metal Fabrication & Finishing for Small Businesses SBEAP offers free, non-regulatory.

Tennessee Small Business Environmental Assistance Program

(SBEAP)

9 Metal Fabrication & Finishing

for Small Businesses

SBEAP offers free, non-regulatory and confidential assistance

Area Source Rule for:

9 Metal Fabrication & Finishing

Final Rule Effective Date: July 23, 2008

National Emissions Standards for Hazardous Air Pollutants:

Course Overview

Background and Control of MFHAPsRequirements

• Equipment • Management Practices

ExemptionsComplianceNotification, Recordkeeping & ReportingQ & 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)

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 ChromiumLead Nickelin 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. Electrical and Electronic Equipment Finishing2. Fabricated Metal Products3. Fabricated Plate Work (Boiler Shops)4. Fabricated Structural Metal Manufacturing5. Heating Equipment, except Electric6. Industrial Machinery and Equipment

Finishing7. Iron and Steel Forging8. Primary Metal Products Manufacturing9. Valves and Pipe Fittings

8 Processes covered by 9 Metal Rule: Dry Abrasive blasting (3)

• 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)

• Spray Booth• Non Spay Booth

Welding

Background: What’s this rules about?


9 Metal Fabrication & Finishing Dry Abrasive Blasting Activity



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: Minimize dust generation during emptying

of the enclosure; and

Operate all equipment used in the blasting operation according to manufacturer’s instructions.


Vented enclosure: Must use a control system with a

capture device, and a cartridge, fabric, or HEPA filter to reduce (PM) emissions

Enclosure must have a roof and at least two complete walls, with side curtains and ventilation


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


Objects greater than 8 Feet: 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


Objects greater than 8 Feet: Management and P2 Practices

Cont.

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


Objects greater than 8 Feet: Visible Emissions Testing

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


Objects greater than 8 Feet: 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)


Objects greater than 8 Feet: 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


9 Metal Fabrication & Finishing Dry grinding and Dry polishingwith Machines Activity



Dry grinding and Dry polishing with machines - Requirements

Operations often emit significant PM, which is a surrogate for MFHAP

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:

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 bench-scale devices


9 Metal Fabrication & Finishing Machining Activity



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.


9 Metal Fabrication & Finishing Welding Activity



Welding Requirements

Minimize emissions of MFHAP by implementing one or more management practices: 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: 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


Additional Management Practices: Use a welding fume capture and

control system and operate according to manufacturer’s specifications.


Visual Emissions Testing: 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


Visual Emissions Testing: Tier I 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


Visual Emissions Testing: Tier II 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


Visual Emissions Testing: Tier III 3rd tier welding compliance includes the

development and implementation of a Site-specific 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

Initial 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 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


9 Metal Fabrication & Finishing Spray Painting Activity



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

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

Comply with equipment standard of Spray Gun Technology

If spray guns are used, no PM filters required

Paint Spray Booth or Room

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

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, air-assisted 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

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 TrainingRequirements Cont.

Initial and refresher training must address topics to reduce paint overspray & emissions:

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 TrainingRequirements 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: Must regularly inspect and replace

filters in all Spray Booths or Spray Rooms per manufacturer’s instructions, and document these activities

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

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


Spray Gun Cleaning may be done by:

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


Spray painting worker certification

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


Spray painting training program content

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


Spray painting training program content

List of all current personnel by name and job description who are required to be trained


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 trainingcertification for use of HVLP or other hightransfer efficiency spray paint deliverymethods

Spray Painting Exemptions

This rules does not apply to:

Non-HAP spray paint

Research or laboratory facilities

Tool or equipment repair operations, facility maintenance, or quality control activities

Military operations or NASA

Operations that produce military munitions


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);


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


Painting that normally requires the use of an airbrush or an extension on the spray gun to properly reach limited access spaces

Coatings that normally have a dried film thickness of less than 0.0013 centimeter


Application of paints that contain fillers that adversely affect atomization with HVLP or equivalent spray guns

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: 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:

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:

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

New Sources must achieve compliance with the applicable provisions byJuly 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

A facility with exceedences during the year, must submit an annual certification and compliance report with any exceedences reported

Reports must describe the circumstance of the exceedence and the corrective action taken

(See EPA’s sample Notification of Compliance Status document)

Notification, Record keeping, &Reporting Requirements

Notification of Compliance Status:

Reports must describe the circumstance of the exceedence and the corrective action taken

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)

CALL US IF YOU NEED US

1-800-734-3619

Tennessee Small Business Environmental Assistance Program (SBEAP) 9 Metal Fabrication & Finishing for Small Businesses SBEAP offers free, non-regulatory.

Documents

operation slide

mfhap slide

weight slide

abrasive materials

ventilation slide

visible emissions testing

metal rule

mfhap emissions