EPA Finalizes Area Source Standards for Metal Fabrication and Finishing Operations

In the July 23 Federal Register, EPA published its final Area Source Standards for nine Metal Fabrication and Finishing source categories. In general, it appears that EPA made most of NPCA’s suggested changes, which were submitted in May. The final rule narrows its applicability to only those facilities that use or have the potential to emit Metal Fabrication hazardous air pollutants (HAPs), such as cadmium, chromium, lead, manganese, and nickel. Further, EPA included the Occupational Safety and Health Administration’s de minimis limits: any material that does not contain cadmium, chromium, lead, or nickel in amounts greater than or equal to 0.1 percent by weight (as the metal), and does not contain manganese in amounts greater than or equal to 1.0 percent by weight (as the metal), is not considered to be a material containing metal HAP.

In response to comments, EPA extended the two year compliance period to three years. It also dropped the volatile organic HAP coating limit requirements; facilities are subject to spray painting management practices (high volume, low pressure paint guns, painter training/certification and spray gun cleaning requirements). Spray booth filters are needed on spray booths when spray painting objects less than 15 feet in any dimension.

EPA exempted:

  • small capacity hand-held spray devices;
  • surface coating application using powder coating, hand-held, non refillable aerosol containers and non-atomizing application equipment;
  • any painting with airbrush or spray gun extension to reach limited access spaces;
  • thermal spray operations.

The agency also exempted research and quality assurance operations; facility maintenance; and military operations. And while EPA did not exempt training facilities, it clarified in the preamble that the rule does not apply to trade schools, academic centers of learning and industrial training facilities.

Although EPA agreed with industry that trivalent chromium is relatively benign as compared to hexavalent chromium, unfortunately the agency decided to regulate all chromium compounds in this rule.

The final rule provides further clarification on potential overlaps with the Paint Stripping and Miscellaneous Surface Coating Operation at Area Sources rule. You may find the final rule at http://edocket.access.gpo.gov/2008/pdf/E8-16263.pdf.

 

Contact: NPCA’s David Darling or Alison Keane for more information.

Source: September 2008 Coatings, posted 8/5/08