May 25, 2011 at 5:30 PM

Area Source Standards for 9 Metal Fabrication and Finishing Source Categories (40 CFR 63, Subpart XXXXXX National Emission Standards for Hazardous Air Pollutants)

Applicable to companies producing metal products using one or more of the following operations: 

• Dry Abrasive Blasting
• Machining
• Dry Grinding and Polishing
• Spray Painting
• Welding

AND which have the potential to emit compounds of cadmium (0.1%), chromium (0.1%), lead (0.1%), manganese (1.0%), and nickel (0.1%), or any of these metals in the elemental form with the exception of lead (collectively termed MFHAP) in quantities greater than the listed weight percent threshold. 

 Exceptions:

• Tool or equipment repair operations, facility maintenance, or quality control activities (see  §63.11522 for exact definitions)
• Operations performed on-site at installations owned or operated by the US Armed Forces, NASA, or the National Nuclear Security Administration.
• Operations that produce military munitions (defined in §63.11522) manufactured by or for the Armed Forces of the United States, or equipment directly and exclusively used for transporting military munitions.

 Initial Notification Dates:

• November 20, 2008 – or no later than 120 days after initial startup for a new affected source.
• July 25, 2011 File an Initial Notification for existing affected source.

 Timeline For Existing Sources:

• July 25, 2011 – File an Initial Notification
• July 25, 2011 – Compliance Date  
• November 22, 2011 – Notification of Compliance Status due.
• January 31, 2012 and annually thereafter – Compliance Reporting Requirements due. 

Timeline For New Sources:

• New sources must achieve compliance with the applicable provisions in this subpart by July 23, 2008, or upon start-up.
• Notification of Compliance Status Report is due 120 days after the initial start-up.  

Note: Additional notifications and reports are required if the source exceeds certain applicable requirements.

Next Actions:

1. Using MSDS review all materials used in the metal fabrication and finishing operations for the presence of the MFHAP exceeding the weight percent thresholds.
2. If present, consider alternative materials if available as potential substitutes. 
3. Review and identify required actions.
4. Implement the applicable requirements prior to the compliance date, July 25, 2011 for existing sources.

Regulation Link:  http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=dcebea2edda2a634b3fcb2cff69e79a0&rgn=div6&view=text&node=40:14.0.1.1.1.36&idno=40

Disclaimer- The above EHS-Alert is a summary and is not intended to be used for compliance purposes, nor is it a substitute for reading the rule or obtaining professional advice.    

Please add a comment

Leave a Reply

Name:

Email:
(Your email will not be publicly displayed.)

Please type the letters and numbers shown in the image.