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EPA Publishes HAP Area Source StandardSSPC Government Affairs Changes Included The EPA has published the national emission standards for control of hazardous air pollutants (HAPs) for nine metal fabrication and finishing area source categories in the Federal Register. This rule will apply only to facilities that are an area source of the compounds of cadmium, chromium, lead, manganese, and nickel, or an area source of volatile organic HAPs (VOHAPs) from spray painting operations, and which perform metal fabrication or finishing operations in one of these nine 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; and (9) Valves and Pipe Fittings.The rule lists emission standards in the form of management practices and equipment standards for new and existing operations of dry abrasive blasting, machining, dry grinding, and dry polishing with machines, spray painting and other spray coating, and welding operations. The standards reflect EPA's determination regarding the generally achievable control technology (GACT) and/or management practices for the nine area source categories. All existing area source facilities subject to this proposed rule are required to comply with the rule requirements no later than 2 years after the July 23, 2008, publication of the final rule in the Federal Register. A table included in the attached PDF of the final rule explains its impact on the covered categories. In the final rule, several comments submitted by SSPC's Government Affairs were addressed including the provision that while painting a structure the use of enclosures on the portion of paint work that is 15 feet or less in any dimensions is unlikely to have a significant positive impact on emissions for several reasons: 1) the paints we use do not contain high levels of metal HAPs; (2) we will be using spray guns meeting the standards of the proposed regulation; and (3) only a small percentage of our pieces are under 15 feet. The EPA agreed that the minor emission reduction does not justify the high cost of creating an alternate paint process to comply. To learn more about this rule or the SSPC Government Affairs Committee, contact:
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Laws & Regulations, CFR Title40 |
