HEADLINES
New EPA Regulations for Painting and Stripping of Metal Parts
New EPA Regulations for Flexible Polyurethane Foam Production
New EPA Rules Affecting Iron and Steel Foundries
Changes in Halogenated Degreaser MACT Standards
Hazardous Waste Manifest Changes
Metal Finishing Industry May Accumulate F006 Waste for 180 Days
New EPA Regulations for Painting and Stripping of Metal Parts
On January 9 and July 23, 2008 U.S. EPA passed two new rules that may impact your painting and paint stripping operations. These rules are part of EPA’s NESHAP standards in an effort to limit emissions of hazardous air pollutants and are known as 40 CFR Part 63 Subparts HHHHHH and XXXXXX. If you use any paints that contain cadmium, chromium, lead, manganese or nickel, there are significant new requirements that will be placed on your painting operation. These include:
1. Training of all painters in proper spray application techniques and set-up and maintenance of the spray equipment
2. Applying spray coatings in spray booths that meets the following:
• use dry filters that achieve minimum of 98% collection efficiency OR use a water wash booth
• plastic and/or metal parts must be contained within a booth having three sides and a roof, and openings for conveyors are allowed
3. Use of one of the allowed spray application technologies:
• high volume, low pressure (HVLP)
• electrostatic
• airless
• air-assisted airless
• any technology approved by EPA with equivalent transfer efficiency
4. Using spray gun cleaning operation that does not spray solvent and waste coatings outside collection container; suggested alternatives include
• hand cleaning
• flushing gun with solvent
• fully enclosed gun cleaner
Stripping operations must eliminate or reduce the use of methylene chloride (depending on the material being stripped). If you are subject to the rules, one or more notifications to EPA and/or your state agency are required. Notification requirements begin in January 2010. We recommend that you review your coatings to determine if they contain the listed pollutants and notify us if they do. We expect these requirements to expand to paints containing organic pollutants such as xylene and toluene so you may want to keep these requirements in mind if you are adding painting capacity. There are also new related rules affecting abrasive blasting, machining, grinding polishing and welding.
New EPA Regulations for Flexible Polyurethane Foam Production
EPA has new requirements (August 2008) to reduce air pollution, particularly to reduce emissions of methylene chloride, from flexible polyurethane foam production. Methylene chloride can be used at flexible polyurethane foam production facilities in many ways, including as an auxiliary blowing agent, an equipment cleaner and as a mold release agent. In general, this rule prohibits the use of methylene chloride for any reason at a foam production facility.EPA has new requirements to reduce air pollution, particularly to reduce emissions of methylene chloride, from flexible polyurethane foam production. Methylene chloride can be used at flexible polyurethane foam production facilities in many ways, including as an auxiliary blowing agent, an equipment cleaner and as a mold release agent. In general, this rule prohibits the use of methylene chloride for any reason at a foam production facility.
This is a short summary of the requirements of this regulation for molded foam production; the primary requirements are that the use of methylene chloride is prohibited for the following applications:
• Equipment cleaning
• Mixhead flushing
• Mold release agents
Other than the prohibition of the use of methylene chloride for these applications, the regulation contains only minor recordkeeping requirements. Each facility must keep records demonstrating that products containing methylene chloride are not being used for these purposes. The rules do not specify the form that these records must keep, but it can be assumed that MSDSs, purchasing records and emission calculations will be adequate. There are no associated reporting requirements. You can find a copy of the rule at this link (the foam rule begins on page 38910):
http://www.epa.gov/ttn/atw/area/fr16jy07.pdf
New EPA Rules Affecting Iron and Steel Foundries
The 1990 Clean Air Act requires EPA to regulate the emissions of hazardous air pollutants (HAPs) from major and non-major (i.e., area) sources in certain industry sectors including iron and steel foundries. The rule applicable to iron and steel foundries that were major sources (generally known as the iron and steel foundry MACT rule).was promulgated in 2004 Since then, EPA has been working on standards that would be applicable to non-major or area sources, that is all iron and steel foundries other than those subject to the MACT rule.
In January 2008, EPA published the final iron and steel foundry area source rule in the Federal Register. EPA issued the standard based on generally available control technology (GACT) for the control of the following (HAPs): chromium, lead, manganese and nickel. The final rule classifies foundries by size and sets requirements for both large and small area source foundries.
Summary of Final Rule
Definition of Large and Small Area Source Foundries In the rule EPA differentiates between small and large foundries and sets different standards for each. Under the new area source rule, EPA defined large and small area source foundries according to the following parameters:
-Small Foundry - Annual metal melt production of 20,000 tons or less;
-Large Foundry - Annual metal melt production of greater than 20,000 tons.
For existing area source foundries, the initial size classification is based on production data for calendar year 2008. This fact sheet will concentrate on “small” foundries.
Requirements for Small Area Source Foundries
Small area source foundries must comply with pollution prevention management practices, notification requirements and record keeping provisions. The compliance date is January 2, 2009. These requirements are summarized below:
1. Pollution Prevention Management Practices- The pollution prevention management practices include metallic scrap management, mercury switch removal and binder formulation provisions to remove HAP-generating materials prior to melting operations and in mold formations.
A. Compliance Options for Use of Metallic Scrap - All foundries must prepare and operate a written metallic scrap plan with specifications for one of the two equivalent compliance options. Either scrap management plan is expected to achieve similar HAP reductions.
1) Use of only metal ingots, pig iron, slitter, or other materials that do not include metallic scrap from motor vehicle bodies, engine blocks, oil filters, oily turnings, lead components, chlorinated plastics or free liquids;
2) Use of scrap that has been depleted of organics and HAP metals to the extent practicable. This requirement is not applicable to cupolas equipped with after burners.
B. Mercury Switch Removal - Foundries may purchase scrap from motor vehicles only from scrap providers participating in an EPA-approved program for mercury removal or operate a site-specific mercury switch removal program at the foundry. EPA indicated that it expects that most foundries will elect to purchase scrap from providers with approved mercury switch programs. EPA did make a few revisions to the proposed regulations in the final rule First, EPA defined motor vehicle scrap for purpose of this provision to include only motor vehicle scrap that is shredded. Other types of scrap from motor vehicles that would not contain mercury such as brake rotor or pump casings would not be subject to this limitation to address mercury switch removal. In addition, EPA also allowed an additional year (i.e., two years from the effective date) for compliance with this requirement for foundries to allow time for more scrap providers to participate in an EPA-approved mercury switch removal program.
C. Binder Formulations - Furfuryl alcohol warm box mold or core making must use a binder chemical formulation that does not use methanol as a specific ingredient of the catalyst formulation.
2. Notification Requirements
A. Initial notification of applicability within 120 days;
B. Initial notification that identifies the foundry as a large or small area source;
C. Subsequent notifications within 30 days of a change in process or operations that reclassifies the status of the foundry and its compliance obligations;
D. Notification of compliance status per the general provisions in 40 CFR § 63.9(h).
3. Record Keeping Requirements
A. Maintain records of monthly metal melt production;
B. Report any deviation from pollution prevention management practices in the semi-annual report required by 40 CFR 63.10 of the general provisions;
C. Record the annual quantity and composition of each HAP-containing chemical binder or coating material used to make molds and cores (to encourage foundries to consider the use of non-HAP binder and coating materials where feasible);
D. Maintain records for at least five years.
Developed with the assistance of the American Foundry Society
Changes in Halogenated Degreaser MACT Standards
On May 3, 2007 (72 FR 25138) EPA revised the limits imposed by the Halogenated Solvent Vapor Degreasing MACT standard found in 40 CFR Part 63, Subpart T. The new rules govern degreasers containing perchloroethylene, trichloroethylene and methylene chloride. The new rules place facility-wide limits on solvent emissions depending on the solvent used. This replaces the previous limit that was based on the square footage of the degreaser. These facility-wide limits also replace the option of using work and operational practices to demonstrate compliance. The new rule was deemed necessary due to new health effects data that has become available since the original rule was promulgated in 1994.
The following facility-wide emission limits are now imposed on facilities with degreasers using the listed solvents. The variation in limits is based on EPA’s estimation of each solvent’s respective health risk.
|
Solvents Emitted | Facility-wide Emission Limit (lbs)* 12 Month Rolling Total |
|---|---|
| Perchloroethylene only | 10,560 |
| Trichloroethylene only | 31,020 |
| Methylene Chloride only | 132,000 |
| Mixture of above solvents | See formula in rule |
*Alternate limits exist for military depot maintenance facilities. Degreasers used in the manufacture of aerospace products and “narrow tubing” are exempt.
Compliance must be demonstrated monthly on a 12 month rolling total basis using a log similar to that currently maintained by degreaser owners that previously chose that option. The log must include solvent additions and deletions for the previous month. From that data emissions must be calculated for the previous month and previous 12 months. If the calculated 12 month total exceeds the limit above, EPA must be notified of the exceedance.
An existing facility must be in compliance and notify EPA of its compliance status by May 3, 2010. New sources or source constructed after August 17, 2006 must be in compliance upon startup. If compliance cannot be achieved, additional control equipment or process changes must be implemented.
Hazardous Waste Manifest Changes
On March 4, 2005, the U.S. EPA completely revised the rules for shipping hazardous waste. They eliminated state-specific manifests and mandated the use of a NEW Federal Uniform Manifest Form. Effective September 5, 2006, generators, transporters, and TSDF's will need to use the new uniform manifest form. Forms must be obtained by approved authorities. If your transporter or disposal site supplies completed manifests, you must make sure that they will be approved or that they obtain their manifests from approved sources by September 2006.
If you prepare your own manifest, facility personnel will need training on the new requirements. Computers will need updating if they print or track manifest information.
The primary goal of the revisions is to standardize the hazardous waste manifest. Under the new rules, the same manifest will be used the same way in every state. All "optional" field designations have been removed. All of the fields on the revised manifest are now mandatory. Many of the previously optional state fields have been removed. The goals for all of the final revisions is to standardize the content and appearance of the manifest form and continuation sheet, make the forms available from a greater number of sources, and improve the use of the manifest as a tool for tracking certain types of waste shipments.
Additional revisions have been made in an attempt to make RCRA manifest requirements consistent with DOT hazardous materials regulations, including adding a field an emergency response phone number to comply with DOT shipping paper requirements. Other changes are being made to manifest tracking numbers, manifest printing, and obtaining manifests. One of the highest priorities related to the regulatory revisions is to ensure that each manifest has a unique tracking number. The ability to provide a unique tracking number on each manifest must be addressed by each registrant applying to produce manifests. Anyone may obtain manifests from any registered printer, or may register to print their own. Also, states can no longer print state-specific instructions on manifests. State agencies can print the revised manifest but will need approval from the EPA to do so. States cannot require generators to obtain manifests from the state.
In addition to the manifest changes a new section 40 CFR Part 262.27 Waste Minimization certification has been added to the regulations. The new rules also clarify whether generators may allow an "agent" to sign the manifest for them, how to handle rejected shipments returned to the generator, and more.
Metal Finishing Industry May Accumulate F006 Waste for 180 Days
EPA promulgated regulations that allow large quantity generators of F006 sludges (certain sludges from the treatment of electroplating wastewaters) up to 180 days (or up to 270 days, as applicable) to accumulate F006 waste without a hazardous waste storage permit or interim status. This is provided that these generators recycle the F006 waste through metals recovery and meet certain conditions. This was done as an incentive to choose metal recovery instead of treatment and land disposal as their final waste management option. This standard, proposed on February 1, 1999, was issued as a final rule with minor changes on March 8, 2000.
