November 2008: New Area Source Standards
On July 23, 2008, U.S. EPA finalized the new area source National Emission Standards for Hazardous Air Pollutants (NESHAP) regulation that affects emissions of Metal Fabrication and Finishing operations as well as Metal Plating and Polishing operations. This rule requires new management practices, pollution prevention strategies and equipment standards for metal fabrication/finishing operations and metal plating/polishing operations. The standards apply to operations that are an area source of the compounds of cadmium, chromium, lead, manganese, and nickel, or volatile organic HAP (VOHAP) and have the potential to emit less than 10 tons per year of any single Hazardous Air Pollutant (HAP) or less than 25 tons per year of a combination of HAPs.
Does This Apply to Me?
Metal Fabrication and Finishing
The regulation contains requirements for general production processes like dry abrasive blasting, dry grinding and dry polishing, machining, spray coating and welding. The following nine source categories of metal fabrication/finishing operations are affected:
- Electrical and Electronic Equipment Finishing Operations
- Fabricated Metal Products
- Fabricated Plate Work (Boiler Shops)
- Fabricated Structural Metal Manufacturing
- Heating Equipment, except Electric
- Industrial Machinery and Equipment Finishing Operations
- Iron and Steel Forging
- Primary Metal Products Manufacturing
- Valves and Pipe Fittings
Metal Plating and Polishing
The following activities engaged in by metal plating/polishing operations are affected:
- Nonchromium electroplating
- Electroless plating
- Chromate conversion coating
- Nickel acetate sealing
- Sodium dichromate sealing
- Manganese phosphate coating
- Thermal spraying
- Dry mechanical polishing of finished metals
- Formed products
- Electroforming
- Electro-polishing
How Do I Comply?
Metal Fabrication and Finishing
The new requirements for metal fabrication and finishing involve minimizing dust generated from abrasive blasting, grinding and polishing, operating all equipment in accordance with the manufacturer’s instructions, proper cleaning and storage of spray guns and painter training, and using welding processes with reduced fume generating capabilities. All affected sources must submit an Initial Notification, Notification of Compliance Status, and an annual Certification and Compliance Report. Existing sources have three years but new sources must submit no later than November 20, 2008 or 120 days after start-up.
Metal Plating and Polishing
The requirements for metal plating and polishing entail the use of wetting agents/fume suppressants while operating electroplating, electroforming, or electropolishing tanks. While plating, limit the "flash" or short term electroplating operations to one hour per day or three minutes per hour. Electroplating tanks that utilize a cyanide bath must ensure that the pH of the tank is maintained at 12 or greater. An emission control device will have to be operated on dry mechanical polishing or thermal spraying. All affected sources must submit an Initial Notification, Notification of Compliance Status, and an annual Certification and Compliance Report. Existing sources have two years and new sources must submit upon start-up.
Note: There is no specific form required for initial notification. U.S. EPA provides Initial Notification Examples.
For More Information...
To learn more about the National Emission Standards for Hazardous Air Pollutants: Area Source Standards you can access the Metal Finishing and Fabrication Final Rule and the Metal Plating and Polishing Final Rule. A quick breakdown of the rules and requirements can be found in the U.S. EPA Fact Sheets for Metal Fabrication and Finishing Categories and Metal Plating and Polishing Operations.
If you have questions and would like to speak with a CTAP staff member please contact (800) 988-7901 or, via email, ctap at idem.in.gov.
