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

2. Area Source Rule for: 9 Metal Fabrication & Finishing Final Rule Effective Date: July 23, 2008 National Emissions Standards for Hazardous Air Pollutants:

3. Course Overview Background and Control of MFHAPs Requirements Equipment Management Practices Exemptions Compliance Notification, Recordkeeping & Reporting Q & A - Contact Information

4. 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

5. Metal Finishing Hazardous Air Pollutants MFHAPs - materials that contain: CadmiumChromium LeadNickel 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

6. Background: Whats this rules about? Affected Operations for 9 Metal Sources: 1. Electrical and Electronic Equipment Finishing 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 7. Iron and Steel Forging 8. Primary Metal Products Manufacturing 9. Valves and Pipe Fittings

7. 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: Whats this rules about?

8. Area Source Rule for: 9 Metal Fabrication & Finishing Dry Abrasive Blasting Activity Final Rule Effective Date: July 23, 2008 National Emissions Standards for Hazardous Air Pollutants:

9. Dry Abrasive Blasting Activity Al l equipment and activities necessary to perform dry abrasive blasting operations which use materials that contain MFHAP or that have the potential to emit MFHAP

10. 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 manufacturers instructions.

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

12. 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 manufacturers instructions

13. Dry Abrasive Blasting Requirements 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

14. Dry Abrasive Blasting Requirements 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 manufacturers instructions Perform visible emissions monitoring

15. Dry Abrasive Blasting Requirements 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

16. Dry Abrasive Blasting Requirements 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)

17. Dry Abrasive Blasting Requirements 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

18. Area Source Rule for: 9 Metal Fabrication & Finishing Dry grinding and Dry polishing with Machines Activity Final Rule Effective Date: July 23, 2008 National Emissions Standards for Hazardous Air Pollutants:

19. 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

20. 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 manufacturers instructions

21. Dry grinding and Dry polishing with machines - Exemptions Operations do not include those performed with hand-held or bench- scale devices

22. Area Source Rule for: 9 Metal Fabrication & Finishing Machining Activity Final Rule Effective Date: July 23, 2008 National Emissions Standards for Hazardous Air Pollutants:

23. 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 manufacturers instructions.

24. Area Source Rule for: 9 Metal Fabrication & Finishing Welding Activity Final Rule Effective Date: July 23, 2008 National Emissions Standards for Hazardous Air Pollutants:

25. 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

26. 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

27. Welding Requirements cont. Additional Management Practices: Use a welding fume capture and control system and operate according to manufacturers specifications.

28. Welding Requirements cont. 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

29. Welding Requirements cont. 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

30. Welding Requirements cont. Visual Emissions Testing: Tier II 2 nd tier welding compliance must be implemented if visible emissions are detected for the 2 nd time in any consecutive 12-month period 2 nd 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

31. Welding Requirements cont. Visual Emissions Testing: Tier III 3 rd 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

32. 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

33. 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

34. Area Source Rule for: 9 Metal Fabrication & Finishing Spray Painting Activity Final Rule Effective Date: July 23, 2008 National Emissions Standards for Hazardous Air Pollutants:

35. Spray Painting Activity A ll 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

36. Spray Painting Requirements

37. Background: Whats 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

38. 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

39. 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

40. 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

41. 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 manufacturers specifications

42. 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

43. 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

44. Spray Painting Training Requirements 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

45. 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

46. 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

47. Management Practices Control MFHAP in spray painting: Must regularly inspect and replace filters in all Spray Booths or Spray Rooms per manufacturers instructions, and document these activities All spray painting must be done with efficient Spray Gun Technology and alternate spray guns must be EPA approved

48. 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

49. Management Practices Cont. 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

50. Management Practices Cont. 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

51. Management Practices Cont. 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 painters work experience and/or training as equivalent to meet initial training requirements – need not provide training to these painters

52. Management Practices Cont. Spray painting training program content List of all current personnel by name and job description who are required to be trained

53. 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

54. 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

55. Spray Painting Exemptions 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);

56. 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

57. Spray Painting Exemptions 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

58. Spray Painting Exemptions 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

59. 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

60. How to Show Compliance Cont. Continuous Requirements: Comply by operating capture and control systems according to the manufacturers specifications Maintain records on site to document conformity Keep manufacturers instruction manual available at the facility at all times

61. 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

62. 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

63. 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 by July 23, 2008, or upon startup, whichever is later

64. 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 SBEAPs hand-out or EPAs sample of initial notification form for reporting details)

65. 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 EPAs sample Notification of Compliance Status document)

66. Notification, Record keeping, & Reporting Requirements Notification of Compliance Status: Reports must describe the circumstance of the exceedence and the corrective action taken See SBEAPs sample Notification of Compliance Status document

67. 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

68. Questions Anyone? Resource Assistance Tools are available on SBEAPs web Page: http://tn.gov/environment/apc /sbeap/sbeap_9metal.shtml http://tn.gov/environment/apc /sbeap/sbeap_9metal.shtml E-mail: BGSBEAP@tn.govBGSBEAP@tn.gov Contact SBEAP staff about this presentation, updated information or assistance tools for 9 Metal Fabrication & Finishing

69. Tennessee Small Business Environmental Assistance Program (SBEAP) CALL US IF YOU NEED US 1-800-734-3619