EPA Seeks Comments on Proposed HAP Area Source Standard

Nine Metal Fabrication and Finishing Source Categories Affected

The EPA is seeking comments by May 5 on its proposed national emission standards for control of hazardous air pollutants (HAPs) for nine metal fabrication and finishing area source categories. This proposed rule will apply only to facilities that are an area source of the compounds of cadmium, chromium, lead, manganese, and nickel, or an area source of volatile organic HAPs (VOHAPs) from spray painting operations, and which perform metal fabrication or finishing operations in one of these nine categories: (1) Electrical and Electronic Equipment Finishing Operations; (2) Fabricated Metal Products; (3) Fabricated Plate Work (Boiler Shops); (4) Fabricated Structural Metal Manufacturing; (5) Heating Equipment, except Electric; (6) Industrial Machinery and Equipment: Finishing Operations; (7) Iron and Steel Forging; (8) Primary Metal Products Manufacturing; and (9) Valves and Pipe Fittings.

This rule proposes emission standards in the form of management practices and equipment standards for new and existing operations of dry abrasive blasting, machining, dry grinding, and dry polishing with machines, spray painting and other spray coating, and welding operations. These proposed standards reflect EPA's determination regarding the generally achievable control technology (GACT) and/or management practices for the nine area source categories. All existing area source facilities subject to this proposed rule would be required to comply with the rule requirements no later than 2 years after the date of publication of the final rule in the Federal Register.

The nine processes addressed by this proposed rule are: (1) Dry abrasive blasting of objects less than or equal to 8 feet in any dimension, performed in completely enclosed and unvented blast chambers; (2) dry abrasive blasting of objects less than or equal to 8 feet in any dimension, performed in vented enclosures; (3) dry abrasive blasting of objects greater than 8 feet in any dimension; (4) dry grinding and dry polishing with machines; (6) control of VOHAPs from spray painting; (7) control of MFHAPs in spray painting of objects less than or equal to 15 feet in any dimension; (8) control of MFHAPs in the spray painting of objects greater than 15 feet in any dimension; and (9) welding.

In terms of surface preparation, the rule will require owners and operators dry abrasive blasting objects less than or equal to 8 feet in any dimension in completely enclosed and unvented blast chambers to minimize dust generation when emptying the enclosure and to operate all equipment used in the blasting operation according to manufacturer's instructions. The control system would have to include an enclosure as a capture device and a cartridge, fabric, or HEPA filter as a control device for the process. When dry abrasive blasting objects greater than 8 feet in any dimension, the rule would require keeping work areas free of excess dust by once-a-day sweeping or vacuuming; enclosing dusty material storage areas and holding bins, seal chutes, and conveyors; and operating all equipment according to the manufacturer's instructions.

Operations involving dry grinding and dry polishing with machines would be required to use capture devices and vent the exhaust to a cartridge, fabric, or HEPA filter with at least an 85% control efficiency. Owners and operators would also be required to keep work areas free of excess dust by once-a-day sweeping or vacuuming and to operate all equipment according to the manufacturer's instructions.

Under the proposed rule, owners or operators of spray painting operations from affected sources that have the potential to emit VOHAPs will be required to use paints containing no more than 3.0 pounds VOHAP per gallon paint solids on an annual (12-month) rolling average. These owners and operators would also have to minimize VOHAP emissions during mixing, storage, and transfer of paints and keep paint and solvent lids tightly closed when not in use. When spray painting objects greater than 15 feet in any dimension owners or operators would be required to comply with one equipment standard and use low-emitting and pollution preventing spray gun technology.

HVLP, electrostatic application, or airless spray application must be used unless an equivalent technology with comparable transfer efficiency is used. The transfer efficiency procedure for HVLP, for example, should be equivalent to the California South Coast Air Quality Management District's Spray Transfer Efficiency Test established in 1989 and Guidelines for Equivalency approved in 2002.

The proposed rule also includes management practices for spray gun cleaning and training for spray gun operators.

Comments identified by Docket ID No. EPA-HQ-OAR-2006-0306 may be sent directly to the EPA on or before May 5, 2008, by one of the following methods:

Web: http://www.regulations.gov
Follow the on-line instructions for submitting comments.
E-mail: a-and-r-docket@epa.gov
Fax: 1-202-566-9744
Mail:
National Emission Standards for Hazardous Air Pollutants,
Area Source Standards for Metal Fabrication and Finishing Operations Docket
Environmental Protection Agency,
Air and Radiation Docket and Information Center
Mailcode 2822T
1200 Pennsylvania Ave NW
Washington DC 20460

To add your voice to the joint AISC/SSPC comments, please submit your comments by April 28 to:

Heather Bayne
SSPC Protective Coatings Professional
Phone: 1-412-281-2331 x2224
Toll Free: 1-877-281-777 x2224
Fax: 1-412-281-9992
Email: bayne@sspc.org

For further information:
http://edocket.access.gpo.gov/2008/E8-6411.htm

Source: SSPC