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New Metal Finishing Rules Loom

Tuesday, May 3, 2011

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Metal fabricators and spray finishers, beware: After three years on deck, new federal emissions standards are set to take effect, with implications for training, cleaning, equipment and other operational factors.

July 25, 2011, is D-Day for all new and existing facilities affected by the Environmental Protection Agency’s lengthy National Emission Standards for Hazardous Air Pollutants (NESHAP) for Metal Fabrication and Finishing Source Categories (6X).

The new rules, issued in 2008, aim to reduce air pollution from compounds of cadmium, chromium, lead, manganese, nickel and other metals emitted by nine types of metal fabrication and finishing operations.

Affected facilities include those that fabricate iron, steel or other metal for structural purposes, such as bridges, buildings, and sections for ships, boats and barges.

 Spray painting
Paint & Coatings Resource Center
The new rules mandate management practices and equipment standards for operations involved in spray painting and other spray coating operations.

The rule establishes management practices and equipment standards for new and existing operations involved in dry abrasive blasting, machining, dry grinding and dry polishing with machines, spray painting and other spray coating, and welding operations.

The standards are based on what EPA considers “generally achievable control technology and/or management practices” for these establishments.

Facilities Affected, Excluded

The rule applies only to facilities whose “primary activity” is in one of these source 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
9. Valves and Pipe Fittings

Finishing and fabricating facilities are not subject to the rule unless they are “primarily engaged” in those operations.

However, they may still be subject to NESHAP Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources (6H), which primarily addresses paint removal operations that use methylene chloride (MeCl) paint strippers, motor vehicle and mobile equipment surface coating operations, and miscellaneous surface coating operations located at area sources.

The rule also does not apply to thermal spray operations, which are covered by Plating and Polishing Area Source NESHAP (6W).

Covered Operations

The new rule addresses three types of dry abrasive blasting operations:
  • Those performed in completely enclosed chambers;
  • Those performed in vented enclosures; and
  • Those performed not in vented enclosures on objects greater than eight feet in any dimension.
It applies to:
  • Spray painting of objects in general;
  • Spray painting of objects greater than 15 feet in any dimension; and
  • Spray painting operations in Fabricated Structural Metal Manufacturing.
Painting Equipment and Practices

The rule requires affected spray painting sources to comply with two equipment standards:
  • Use of spray booths or spray rooms equipped with particulate matter (PM) filters; and
  • Use of low-emitting and pollution preventing spray gun technology.
The PM filter requirement does not apply to spray painting of objects greater than 15 feet in any dimension or to non-spray-booth painting at Fabricated Structural Metal Manufacturing facilities.

Two management practices are also affected:
  • Spray painter training; and
  • Spray gun cleaning.
Training and Cleaning Requirements

The rule requires employers to certify that all workers who perform spray painting at affected facilities, including contract personnel, complete “classroom or hands-on training” in selecting, mixing and applying paints. Training must include:
  • Spray gun equipment selection, set up, and operation;
  • Spray technique for different types of paints; and
  • Routine spray booth and filter maintenance, including filter selection and installation.
Refresher training is required every five years. Facilities may also document that a painter’s work experience and/or other training has provided the required training.

In addition:
  • All spray-applied paints with metal finishing and fabrication hazardous air pollutants (MFHAP) must be applied with an HVLP spray gun, electrostatic application, airless spray gun or equivalent;
  • MFHAP emissions must be minimized during mixing, storage and transfer of paints;
  • Paint and solvent lids must be kept closed when not in use; and
  • All spray gun cleaning operations must be done with either non-HAP solvents, or performed in such a way as to contain emissions from solvents and paint residues.
More Information

For more information, visit EPA’s NESHAP Questions and Answers. Establishments are also advised to consult their local or state air resources agencies or departments for assistance.

   

Tagged categories: Air quality; EPA; Hazardous air pollutants; Health and safety; Protective coatings; Regulations; Structural steel; VOC emissions

Comment from paul mellon, (5/4/2011, 4:31 PM)

It is truly inexplicable how Paintsquare could miss the most amazing part of this new EPA rule! Abrasive Blasting is mentioned 89 times in the 35 page rule which is 2.5x PER PAGE! The EPA Office of Air has just made the most amazing statement that will immediately impact all these industries on July 25 2011! On 3 separate occasions the EPA makes the below statement about abrasive blasting: National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Nine Metal Fabrication and Finishing Source Categories Pages 6,17and 25 (a) If you own or operate an existing affected source, you must achieve compliance with the applicable provisions in this subpart by July 25,2011. (3) Standards for dry abrasive blasting of objects greater than 8 feet (2.4 meters) in any one dimension. Whenever practicable, you must switch from high particulate matter (PM)-emitting blast media (e.g., sand) to low PM-emitting blast media (e.g., crushed glass, specular hematite, steel shot, aluminum oxide), where PM is a surrogate for MFHAP. For anyone who missed it the Environmental Protection Agency just called for used Crushed Glass vs. Sand. Guess what? the EPA does not mention the number one abrasive in the United States one time, coal slag abrasives! No slags are mentioned because the EPA knows that slags emit Hazardous Air Pollutants and have the tests to prove it since 1994. The clock is ticking and the bell goes of July 25, 2011 if your company is in one these industries and you are using slag products. Guess what the chances are that coals slag will ever make it back into the EPA Beneficial Use Program!


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