Tennessee Small Business Environmental

Assistance Program (SBEAP)

9 Metal Fabrication & Finishing

for Small Businesses

SBEAP offers free, non-regulatory and confidential assistance

 National Emissions Standards for
Hazardous Air Pollutants:

Area Source Rule for:

9 Metal Fabrication & Finishing

Final Rule Effective Date: July 23, 2008

 Course Overview

Background and Control of MFHAPs

Requirements
• Equipment
• Management Practices
Exemptions
Compliance
Notification, Recordkeeping & Reporting
Q & 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

Chromium
Lead Nickel
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
 Background: What’s 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
 Background: What’s this rules about?

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
 National Emissions Standards for
Hazardous Air Pollutants:

Area Source Rule for:

9 Metal Fabrication & Finishing

Dry Abrasive Blasting Activity

Final Rule Effective Date: July 23, 2008

 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.
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
 Dry Abrasive Blasting Requirements

Vented enclosure - Management and pollution

prevention practices:
 Takemeasures 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 
 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
 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 manufacturer’s
instructions
 Perform visible emissions monitoring
 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
 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)
 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
 National Emissions Standards for
Hazardous Air Pollutants:

Area Source Rule for:

9 Metal Fabrication & Finishing

Dry grinding and Dry polishing

with Machines Activity

Final Rule Effective Date: July 23, 2008

 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
 National Emissions Standards for
Hazardous Air Pollutants:

Area Source Rule for:

9 Metal Fabrication & Finishing

Machining Activity

Final Rule Effective Date: July 23, 2008

 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.
 National Emissions Standards for
Hazardous Air Pollutants:

Area Source Rule for:

9 Metal Fabrication
& Finishing

Welding Activity

Final Rule Effective Date: July 23, 2008

 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
 Welding Requirements cont.

Additional Management Practices:

 Use a welding fume capture and control system
and operate according to manufacturer’s
specifications.
 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
 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
 Welding Requirements cont.

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
 Welding Requirements cont.

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
 National Emissions Standards for
Hazardous Air Pollutants:

Area Source Rule for:

9 Metal Fabrication & Finishing

Spray Painting Activity

Final Rule Effective Date: July 23, 2008

 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:
 SprayBooths 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 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
 Spray Painting Training
Requirements Cont.
 Spraytechnique 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
 Routinespray 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
 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
 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
 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 painter’s work

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

Spray painting training program content 

 List of all current personnel by name and job

description who are required to be trained
 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
 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

 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);
 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
 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
 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
 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 by
July 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/ea/s
beap/sbeap_9metal.shtml

E-mail: BGSBEAP@tn.gov

Contact SBEAP staff about this

presentation, updated information or
assistance tools for 9 Metal
Fabrication & Finishing
 Tennessee Small Business Environmental
Assistance Program (SBEAP)

1-800-734-3619
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