- Email: [email protected]
Environmental coating problems
Environmetdal Coating Problems by Ron Joseph
MACT Regulations
R
ecently, I met Jeff Twaddle and John Wellspring, environmen.tal engineers with SECOR International. I found them to be so knowledgeable on the subject of Maximum Achievable Control Technology (MACT) regulations that I asked them if they would like to write a Q&A column on the subject. They have kindly obliged, and this month their first such column on General MACT Requirements, Chrome Electroplating, and Halogenated Solvents is presented. In a future column they will address some Q&A issues concerning the Aerospace, Wood Furniture Finishing, and Ship Building MACT standards. I do want to thank John and Jeff for their voluntary efforts and their wealth of information.
MACT STANDARDS: Q&A Many standards are now being proposed and promulgated by the U.S. Environmental Protection Agency (EPA) for control of Hazardous Air Pollutants (HAPS). These standards are being established for source categories using the MACT for each industry type. As these standards are proposed and promulgated many questions come to mind. This article is composed of questions gathered from sources affected by these MACT standards. We have attempted to group the questions into a general section followed by sections addressing specific MACT standards that apply to sources in the metal-finishing industry.
GENERAL QUESTIONS What is MACT? MACT stands for Maximum Achievable Control Technology. Under Title III of the 1990 Clean Air Act Amendments, the EPA is required to METAL FINISHING
. JULY 1997
regulate emissions of HAPS by establishing standards for various emission source categories. These standards were to be based on the best-controlled facilities for each source category.
What is a HAP? Included in the Clean Air Act Amendments of 1990 was a list of 189 toxic chemicals that EPA/Congress determined posed a potential health threat. Most of the HAPS are specific chemicals; however, some are chemical compounds. The list of HAPS at the time this article was prepared are listed in Table I. This table also identifies if each HAP is a volatile organic compound (VOC) and if the HAP is also a Form R chemical.
To whom does a MACT standard apply? MACT standards apply to major sources and area sources of HAPS. A source of HAPS is major if it has the potential to emit more than 10 tons per year of a single HAP or more than 25 tons per year of total HAPS. Be careful when calculating potential emissions. If you do not have federally enforceable restrictions in emissions, EPA requires that you evaluate potential emissions based on maximum capacity at 24 hr per day and 365 days per year. Control equipment can only be taken into consideration when it is required to be used by EPA or federally approved regulations. Certain MACT standards will also apply to an “area source,” which individually may not have a great amount of emissions, but a number of these types of sources are considered by EPA to be a health concern. Area sources that are subject to MACT standards include chrome electroplating and halogenated solvent decreasing. 0 Copyright
Elsevier Science inc.
How is a MACT standard established? EPA is to review the HAP emissions from each source category and to establish a MACT standard for each. MACT for existing sources is to be based on the 12% of the facilities that are best controlled. In the case of source categories that contain only a few facilities, EPA can use less than 12%. New source MACT is to be based on the best-controlled source in the source category.
What sources at a metal finisher may be required to comply with a MACT standard? There are many sources that may be operated by a metal finisher that are in the source categories that will have MACT standards. Table II has a list of source categories that may be included at a metal finisher. The table also includes the status of each at the time this article was prepared. If a major source of HAPS is constructed or reconstructed prior to the MACT standard being proposed for that source category, the source must comply with 112(g), which requires that a site-specific MACT standard be developed and proposed by the source.
What is the compliance date for a MACT standard? Compliance dates can be classified into three different categories based on facility operating status. Existing sources are required to be in compliance with the MACT standard within three years of promulgation. New sources that begin operating prior to promulgation must be in compliance with the proposed standard at start-up. If the final rule is substantively different from the proposed rule, these sources will likely be given sufficient time for transition to the final rule requirements. New sources, which are 35
Table I. Hazardous Air Pollutants
Hazardous Air Pollutant (HAP) Name
continued
36
METAL FINISMING
. JULY 1997
Table I. Hazardous Air Pollutants (continued)
I I
CASRN Hazardous Air Pollutant (HAP) Name
00051796 Ethyl carbamate (urethane) 00075003 Ethyl chloride (chloroethane) 00106934 Ethylene dibromide (dibromoethane) 00107062 Ethvlene dichloride (1,Pdichloroethane) 00107211 Ethvlene qlvcol 00151 564 1 Ethvleneimine (aziridine) 00075218 Ethvlesne oxide 00096457 Ethvlene thiourea 00075343 Ethvlidene dichloride(1 ,l-dichloroethane) 1 00050000 ] Formaldehyde 00076448 1 Heptachlor I 00118741 1 Hexachlorobenzene JOJ 37683 ] Hexachorobutadiene 00058899 1,2,3,4,5,6-Hexachlorocvclohexane (all stereo isomers, includinq Lindane) 1 00077474 Hexachlorocvclopentadiene 00067721 Hexachloroeths 122060 1 Hexamethvlene-1,6-diisocvanate _oJE 0061
00101144 00075092 00101688 00101779 00091203 00098953 00092933 00100027 00079469 00684935 00062759 00059892 00056382 00082688 00087865 00108952 00106503 00075445 n7mv~- 12 40 49 __
4,4-Metnvlenebr: Methvlene chloriae pcmorometnane , 4-4 Methvlenedilphenvl diisocvanate (MDI) 4,4-Mlethvlenedianiline ., Naphtnatene Nitrobe nzene 1( 4-Nitrobiphenvl 4-Nrtrophenol 2-Nitropropane N-Nitroso-N-methylurea NNitrosodimethvlamine I N-Nitrosomorpholine l Paratnion ’ - ” ^... ,.. I Pemacnioronttrobenzene (qurmobenzene) Pentachlorophenol Phenol p Phenvlenediamine Phosgene ’ -. Phosphine Phosphorus Phthalic anhvdride 1 Polychlonnated biphenyls (aroclors)
L S S
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
L
Yes
L G s L L I
I
__
I I
I
s ;
S S
I I
! 1
: s S G
I
S
II
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes
I I
I I
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
H I
Yes Yes Yes Yes Yes
I
Yes
I Yes, as cateqory
I.” Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes
I Yes, as cateqoly Yes Yes ! Yes I Yes Yes Yes Yes Yes Yes 1 Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes 1 I I
I
continued
METAL FINISHING
. JULY 1997
37
Table I. Hazardous Air Pollutants (confinued)
HazardousAir Pollutant [HAP) Name
For all listings above that contain the word “compounds” and for glycol ethers, the following applies: unless otherwise specified, these listings are defined as including any unique chemical substance that contains the named chemical (i.e., antimony, arsenic, etc.) as part of that chemical’s infrastructure. %‘CN where X=H’ or any other group where a fonal dissociation may occur-for example, KCN or Ca(CN),. %cludes mono- and diethers of ethylene glycol, diethylene glycol, and tdethylene glycol R-(OCH,CH,)n-OR’ where n = 1, 2, or 3: R = alkyl or aryl groups; and R’ = R, H, or groups that, when removed, yield glycol ethers with the structure R-(OCH,CH,)n-OH. Polymers are excluded from the glycol category. Includes mineral fiber emissions from facilities manufacturfng or processing glass, rock, or slag fibers (or other mineral-derived fibers) of average diameter 1 micrometer or less. %mited to, or refers to, products from incomplete combustion of organic compounds (or material) and pyrolysis processes having more than one benzene ring and that have a boiling point greater than or equal to 1Oo’C. *A type of atom that spontaneously undergoes radioactive decay.
38
METAL FINISHING
??
JULY 1997
Table Il. Status of MACT Standards for Source Categories That Are Likely Operated by Metal Finishers Categories of Hazardous Air Pollutant Major Sources in Surface Coating/Metal Finishing (Area Sources Are So Noted) Aerospace
industries
1l/l 511994
surface coatinq
Auto and light duty truck surface coatinq Chromic acid anodizing, decorative chromium electroplating, and hard chromium electroplating (area sources) Flat wood panelinq surface coatinq Friction products manufacturinq Halogenated solvent cleaners (area sources) Large appliance Magnetic tapes
Scheduled Promulgation Date
1
Steel picklinq_HCI furniture
process
&ace
coatinq
60FR45948(F), 60FR55482(A)
GG
Rule Proposal/ Effective Date 05/25/94,
60FR04948(F), 60FR27958(C), 60FR33122(C)
11/15/1994
59FR61801(F), 59FR67750(C), 60FR29484iti)
11/15/2000 11/15/1994
09/01/95
N
12/l 6/93, 01/25/95
T
Not yet proposed Not vet proposed 11129193, 12/02/94
59FR64580(F)
1
EE
1
Not yet proposed 03/11/94, V/15/94 Not Not Not Not
1l/l 5/2000 1l/l 512000 1l/l 5/2000 1 l/l 5/2000
vet vet vet yet
09/01/98
I 01/25/96 (decor), 011 25/97 (hardlanod)
1 l/15/97
I V/15/96,
or 12/15/97 if controlled
proposed proposed proposed proposed
I
1111511994
I
60FR64330(F)
1
II
1
1UO6/94, 12/l 5/95
I I
11/15/1997
I I
60FR62930(F)
1
JJ
1
Not yet proposed 12/06/94, 12/07/95
11/15/1994
Existing Source Compliance Da&
Not yet proposed
1l/15/2000 1l/15/2000
Metal can surface coatinq Metal coil surface coatinq Metal furniture surface coatinq Miscellaneous metal parts and products
Wood
40 CFR Part 63 Subpafi:
1
11/15/1994
surface coatinq
production Shipbuilding and ship repair surface
11/15/2000
Federal Register Citation(s)”
12/l 6197
1 11/21/97, or 12/07/98 if emit <50
ton
aFederal Register Citation Markings: (A) Proposed amendment to a final rule, (C) Correction or clarification published subsequent to a proposed or final rule, (F) Final rule-making action, and (P) Proposed rule-making action bNew sources beginning operation after the final rule effective date must be in compliance with the final rule upon initial startup. New sources beginning operation after the proposed rule is published, but before the final rule effective date, must be in compliance with the proposed rule upon initial startup and will have a period of time with which to comply with the final rule, after the final rule is promulgated.
constructed following promulgation the standard, must be in compliance start-up.
of at
If my facility is subject to one MACT standard, is it automatically subject to another? If a facility (source) is major for HAPS then it is subject to MACT standards for each source category present at the facility, regardless of individual HAP emissions per source category. Area sources are not automatically subject to other source category standards at their facility if the source is not major for HAPS.
What notifications or submittals are required when you have a source subject to a MACT standard? There are multiple notifications required in association with MACT stanMETAL FINISHING
. JULY 1997
dards. First, a notification is required to identify that the facility has a source subject to a standard. There are then notifications required that state the intent to conduct source testing and that state the compliance status of a source. A new or reconstructed source must also give notification in advance of being constructed or reconstructed. There may also be requirements to submit periodic monitoring reports. Specific standards should be consulted to determine if notification is required.
I understand that I need to prepare a plan if I am subject to a MACT standard. What does this plan need to address? Each source subject to a MACT standard must have a Startup, Shutdown, and Malfunction Plan. This plan must address procedures required to
ensure the source is operated and maintained in a manner consistent with good air pollution control practices. The plan must also ensure that the owners are prepared to correct malfunctions and to address record keeping associated with startup, shutdown, and malfunctions. The requirement to have this plan is found in 40 CFR 63 Subpart A, General Provisions. There may be no reference in the specific MACT standard that this plan is required, so be sure that the plan is in place. Some of the MACT standards do address specific requirements for this plan.
How long do I need to keep records associated with a source subject to a MACT standard? All records associated with a source must be maintained for a period of five 39
years. The most recent two years of records must be maintained on site. Records that must be maintained include, but are not limited to, source startup, shut down, and malfunction records; control equipment malfunctions and maintenance; corrective actions; all information necessary to demonstrate conformance with the malfunction plan and compliance with the standard; results of all tests; calibrations and maintenance of monitoring systems; and documentation of all notifications. If new HAPS are added to the list of 789 do I need to consider them when determining compliance? Yes; however, some additional time will be allowed to comply. Is there a difference in the MACT standards for new and existing sources? Yes. Existing sources must match the emission rates achieved by the best-controlled 12% of sources in their source category. New sources must match the best-controlled source in their source category. Generally, new sources have more restrictive requirements. New sources are those that begin construction after the MACT staridard proposal date. This is a good time to discuss reconstructed sources. A reconstructed source must generally comply with new source requirements. A source is considered to be reconstructed if components of a source are replaced and the fixed capital cost of the new components exceeds 50% of that of a comparable new source. What is the Ear/y Reduction Program, and how can a source qualify? The early reduction provisions of 40 CFR Part 63, Subpart D allow affected sources to receive a six-year extension to the compliance date of an otherwise applicable MACT standard. To qualify a source must make an application and must commit to comply with an enforceable alternate emission standard that reduces HAP emissions by at least 90% (95% in the case of particulate emissions). The enforceable commitment must be made prior to the proposal of the applicable MACT standard. The required HAP emission reduction can be obtained by adjust40
ment for high-risk pollutant weighting factors, if applicable (that is,-extri credit can be gained for the reduction of high-risk HAPS).
in their area for modification requirements.
Is the VOC content of a material equivalent to its volatile organic HAP content? The VOC content of a/material usually contains constituents that are not VOHAPs, and in this case, the VOC content is greater than the VOHAP content of a material. There are three compounds, given in Table I, that are exempt from the definition of VOC that are included in the HAP list. If these constituents are present the VOHAP content of a material can be higher than its VOC content; therefore, to determine the specific VOHAP content of a material, you will have to consider each of its constituents. Where constituent content is unknown, test methods have been available to determine the VOHAP content of a material.
CHROME ELECTROPLATING
What MACT requirements apply to a Major Source that modifies its operations? Eventually, Federal Hazardous Air Pollutant regulations will require major existing sources of HAPS to apply existing source MACT to any actual increase in HAP emissions occurring as a result of a physical change or a change in the method of operation of the source. MACT will supposedly apply to such increases whenever such change results in a greater than a de minimis increase in actual HAP emissions. Sources will supposedly be allowed to offset increases in HAP emissions with equivalent relative-hazardadjusted decreases in HAP emissions in order to avoid having to apply MACT. Where no such MACT has been established, MACT will be determined on a case-by-case basis. These requirements will apply to modifications that are less than reconstruction of a source in jurisdictions where the Title V program is in effect. As previously mentioned source reconstruction is currently subject to new source MACT in jurisdictions where the Title V program is in effect. As a word of caution some states have already promulgated modification rules that are applicable to major sources of HAP emissions. Sources should check the applicable standards
What sources are included in the Chromium Electroplating MACT Standard? The Chromium Electroplating standard applies to all hard and decorative chromium electroplating operations and chromium anodizing tanks. Chromium conversion coating operations are specifically excluded from being subject to this standard, provided no electrical current is applied to the tank. What are my control options to comply with the chrome electroplating MACT standard? The standards for hard chrome electroplating are based on sources being controlled with a packed bed scrubber and mist eliminator. There are different configurations on the specific control equipment that will allow existing hard chrome plating sources to comply. Fume suppressants are generally used by decorative and anodizing to comply. There are other options, such as foam blankets, available to comply with this standard. If chrome plating is not my primary business do I still have to comply with the MACT standard? Yes. All chromium electroplating operations are subject to this standard whether or not they are located at a major source. Do I have to demonstrate compliance with a new test if I have tested my emissions previously? If a compliance test was previously conducted on a chromium electroplating source, a new source test would not be required, provided there is sufficient source operating data and corresponding monitoring values were determined. Testing for existing sources must be completed within six months of the compliance date or in this case by July 25, 1997. If you operate a hard chrome plating operation or a chromium anodizing tank and have not tested by this date, you are late. METAL FINISHING
. JULY 1997
If I have to monitor the pressure drop of a control device and velocity pressure to the control device, how often do I need to record it? Is the pressure drop an average or an instantaneous measurement ? The compliant pressure drop and velocity pressure are established by averaging the pressure drop and velocity pressures during the three test runs during the initial performance test. Future monitoring of the pressure drop must be within kl in. of water column. The compliant pressure-drop range can be increased by conducting additional performance tests over different pressure drops. The velocity pressure must be +lO% of the average velocity pressure during the initial performance test or the range established by multiple tests. The monitoring of the pressure drop and velocity pressure is required to be recorded once each day the source is operated; therefore, the pressure drop and velocity pressure measurements can be considered to be an instantaneous reading. Please note that if you are required to monitor the velocity pressure, you are required to back flush the Pitot tube with water quarterly and to maintain records that this was done.
HALOGENATED SOLVENT DEGREASERS
standards. These alternative standards are based on emissions per area of surface cleaned; however, these standards are extremely restrictive and may not be a viable alternative.
If my solvent only contains a small fraction of halogenated solvent do I still have to comply with the MACT standard?
Are wiping solvents subject to the halogenated solvent degreasing MACT standard?
The halogenated Solvent Cleaning MACT standard applies to any solvent cleaning machine that uses any solvent containing methylene chloride, percloroethylene, trichloroethylene, 1, l,ltrichloroethane, carbon tetrachloride, and chloroform, or any combination of these solvents that exceed a total of 5% by weight; therefore, if your solvent contains more than a total of 5% of these solvents, then you have to comply with this standard.
Wiping with a rag that contains a halogenated solvent is specifically excluded from this MACT standard. Spray cleaners containing halogenated solvents are also excluded.
Biographies John Wellspring is the Manager of Air Resources in SECOR International Inc. ‘s Indianapolis office. Wellspring has over 17 years of professional experience in industry and in consulting, and he is an expert with regards to air pollution requirements associated with metal-finishing operations. Jeffrey Twaddle, P.E., is a Principal Air Quality Engineer in SECOR’s Nashville, Tenn., office. Twaddle has over 10 years of experience as a consultant and former regulator and has assisted many metal finishers with complying with regulations.
Does the halogenated solvent degreaser standard apply to cold cleaners in a facility’s maintenance shop? Yes, but only if they use a solvent that contains more than 5% by weight of any of the solvents listed earlier here.
If my degreaser cannot be physically modified to comply with the equipment requirements do I have any options?
Ron Joseph is an independent coating MF consultant in Saratoga, Calif.
There are options available to comply with equipment and work-practice
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METAL FINISHING
. JULY 1997
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Emswotth, PA
??
Jackson, MS
41
MACT Regulations
R
ecently, I met Jeff Twaddle and John Wellspring, environmen.tal engineers with SECOR International. I found them to be so knowledgeable on the subject of Maximum Achievable Control Technology (MACT) regulations that I asked them if they would like to write a Q&A column on the subject. They have kindly obliged, and this month their first such column on General MACT Requirements, Chrome Electroplating, and Halogenated Solvents is presented. In a future column they will address some Q&A issues concerning the Aerospace, Wood Furniture Finishing, and Ship Building MACT standards. I do want to thank John and Jeff for their voluntary efforts and their wealth of information.
MACT STANDARDS: Q&A Many standards are now being proposed and promulgated by the U.S. Environmental Protection Agency (EPA) for control of Hazardous Air Pollutants (HAPS). These standards are being established for source categories using the MACT for each industry type. As these standards are proposed and promulgated many questions come to mind. This article is composed of questions gathered from sources affected by these MACT standards. We have attempted to group the questions into a general section followed by sections addressing specific MACT standards that apply to sources in the metal-finishing industry.
GENERAL QUESTIONS What is MACT? MACT stands for Maximum Achievable Control Technology. Under Title III of the 1990 Clean Air Act Amendments, the EPA is required to METAL FINISHING
. JULY 1997
regulate emissions of HAPS by establishing standards for various emission source categories. These standards were to be based on the best-controlled facilities for each source category.
What is a HAP? Included in the Clean Air Act Amendments of 1990 was a list of 189 toxic chemicals that EPA/Congress determined posed a potential health threat. Most of the HAPS are specific chemicals; however, some are chemical compounds. The list of HAPS at the time this article was prepared are listed in Table I. This table also identifies if each HAP is a volatile organic compound (VOC) and if the HAP is also a Form R chemical.
To whom does a MACT standard apply? MACT standards apply to major sources and area sources of HAPS. A source of HAPS is major if it has the potential to emit more than 10 tons per year of a single HAP or more than 25 tons per year of total HAPS. Be careful when calculating potential emissions. If you do not have federally enforceable restrictions in emissions, EPA requires that you evaluate potential emissions based on maximum capacity at 24 hr per day and 365 days per year. Control equipment can only be taken into consideration when it is required to be used by EPA or federally approved regulations. Certain MACT standards will also apply to an “area source,” which individually may not have a great amount of emissions, but a number of these types of sources are considered by EPA to be a health concern. Area sources that are subject to MACT standards include chrome electroplating and halogenated solvent decreasing. 0 Copyright
Elsevier Science inc.
How is a MACT standard established? EPA is to review the HAP emissions from each source category and to establish a MACT standard for each. MACT for existing sources is to be based on the 12% of the facilities that are best controlled. In the case of source categories that contain only a few facilities, EPA can use less than 12%. New source MACT is to be based on the best-controlled source in the source category.
What sources at a metal finisher may be required to comply with a MACT standard? There are many sources that may be operated by a metal finisher that are in the source categories that will have MACT standards. Table II has a list of source categories that may be included at a metal finisher. The table also includes the status of each at the time this article was prepared. If a major source of HAPS is constructed or reconstructed prior to the MACT standard being proposed for that source category, the source must comply with 112(g), which requires that a site-specific MACT standard be developed and proposed by the source.
What is the compliance date for a MACT standard? Compliance dates can be classified into three different categories based on facility operating status. Existing sources are required to be in compliance with the MACT standard within three years of promulgation. New sources that begin operating prior to promulgation must be in compliance with the proposed standard at start-up. If the final rule is substantively different from the proposed rule, these sources will likely be given sufficient time for transition to the final rule requirements. New sources, which are 35
Table I. Hazardous Air Pollutants
Hazardous Air Pollutant (HAP) Name
continued
36
METAL FINISMING
. JULY 1997
Table I. Hazardous Air Pollutants (continued)
I I
CASRN Hazardous Air Pollutant (HAP) Name
00051796 Ethyl carbamate (urethane) 00075003 Ethyl chloride (chloroethane) 00106934 Ethylene dibromide (dibromoethane) 00107062 Ethvlene dichloride (1,Pdichloroethane) 00107211 Ethvlene qlvcol 00151 564 1 Ethvleneimine (aziridine) 00075218 Ethvlesne oxide 00096457 Ethvlene thiourea 00075343 Ethvlidene dichloride(1 ,l-dichloroethane) 1 00050000 ] Formaldehyde 00076448 1 Heptachlor I 00118741 1 Hexachlorobenzene JOJ 37683 ] Hexachorobutadiene 00058899 1,2,3,4,5,6-Hexachlorocvclohexane (all stereo isomers, includinq Lindane) 1 00077474 Hexachlorocvclopentadiene 00067721 Hexachloroeths 122060 1 Hexamethvlene-1,6-diisocvanate _oJE 0061
00101144 00075092 00101688 00101779 00091203 00098953 00092933 00100027 00079469 00684935 00062759 00059892 00056382 00082688 00087865 00108952 00106503 00075445 n7mv~- 12 40 49 __
4,4-Metnvlenebr: Methvlene chloriae pcmorometnane , 4-4 Methvlenedilphenvl diisocvanate (MDI) 4,4-Mlethvlenedianiline ., Naphtnatene Nitrobe nzene 1( 4-Nitrobiphenvl 4-Nrtrophenol 2-Nitropropane N-Nitroso-N-methylurea NNitrosodimethvlamine I N-Nitrosomorpholine l Paratnion ’ - ” ^... ,.. I Pemacnioronttrobenzene (qurmobenzene) Pentachlorophenol Phenol p Phenvlenediamine Phosgene ’ -. Phosphine Phosphorus Phthalic anhvdride 1 Polychlonnated biphenyls (aroclors)
L S S
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
L
Yes
L G s L L I
I
__
I I
I
s ;
S S
I I
! 1
: s S G
I
S
II
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes
I I
I I
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
H I
Yes Yes Yes Yes Yes
I
Yes
I Yes, as cateqory
I.” Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes
I Yes, as cateqoly Yes Yes ! Yes I Yes Yes Yes Yes Yes Yes 1 Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes 1 I I
I
continued
METAL FINISHING
. JULY 1997
37
Table I. Hazardous Air Pollutants (confinued)
HazardousAir Pollutant [HAP) Name
For all listings above that contain the word “compounds” and for glycol ethers, the following applies: unless otherwise specified, these listings are defined as including any unique chemical substance that contains the named chemical (i.e., antimony, arsenic, etc.) as part of that chemical’s infrastructure. %‘CN where X=H’ or any other group where a fonal dissociation may occur-for example, KCN or Ca(CN),. %cludes mono- and diethers of ethylene glycol, diethylene glycol, and tdethylene glycol R-(OCH,CH,)n-OR’ where n = 1, 2, or 3: R = alkyl or aryl groups; and R’ = R, H, or groups that, when removed, yield glycol ethers with the structure R-(OCH,CH,)n-OH. Polymers are excluded from the glycol category. Includes mineral fiber emissions from facilities manufacturfng or processing glass, rock, or slag fibers (or other mineral-derived fibers) of average diameter 1 micrometer or less. %mited to, or refers to, products from incomplete combustion of organic compounds (or material) and pyrolysis processes having more than one benzene ring and that have a boiling point greater than or equal to 1Oo’C. *A type of atom that spontaneously undergoes radioactive decay.
38
METAL FINISHING
??
JULY 1997
Table Il. Status of MACT Standards for Source Categories That Are Likely Operated by Metal Finishers Categories of Hazardous Air Pollutant Major Sources in Surface Coating/Metal Finishing (Area Sources Are So Noted) Aerospace
industries
1l/l 511994
surface coatinq
Auto and light duty truck surface coatinq Chromic acid anodizing, decorative chromium electroplating, and hard chromium electroplating (area sources) Flat wood panelinq surface coatinq Friction products manufacturinq Halogenated solvent cleaners (area sources) Large appliance Magnetic tapes
Scheduled Promulgation Date
1
Steel picklinq_HCI furniture
process
&ace
coatinq
60FR45948(F), 60FR55482(A)
GG
Rule Proposal/ Effective Date 05/25/94,
60FR04948(F), 60FR27958(C), 60FR33122(C)
11/15/1994
59FR61801(F), 59FR67750(C), 60FR29484iti)
11/15/2000 11/15/1994
09/01/95
N
12/l 6/93, 01/25/95
T
Not yet proposed Not vet proposed 11129193, 12/02/94
59FR64580(F)
1
EE
1
Not yet proposed 03/11/94, V/15/94 Not Not Not Not
1l/l 5/2000 1l/l 512000 1l/l 5/2000 1 l/l 5/2000
vet vet vet yet
09/01/98
I 01/25/96 (decor), 011 25/97 (hardlanod)
1 l/15/97
I V/15/96,
or 12/15/97 if controlled
proposed proposed proposed proposed
I
1111511994
I
60FR64330(F)
1
II
1
1UO6/94, 12/l 5/95
I I
11/15/1997
I I
60FR62930(F)
1
JJ
1
Not yet proposed 12/06/94, 12/07/95
11/15/1994
Existing Source Compliance Da&
Not yet proposed
1l/15/2000 1l/15/2000
Metal can surface coatinq Metal coil surface coatinq Metal furniture surface coatinq Miscellaneous metal parts and products
Wood
40 CFR Part 63 Subpafi:
1
11/15/1994
surface coatinq
production Shipbuilding and ship repair surface
11/15/2000
Federal Register Citation(s)”
12/l 6197
1 11/21/97, or 12/07/98 if emit <50
ton
aFederal Register Citation Markings: (A) Proposed amendment to a final rule, (C) Correction or clarification published subsequent to a proposed or final rule, (F) Final rule-making action, and (P) Proposed rule-making action bNew sources beginning operation after the final rule effective date must be in compliance with the final rule upon initial startup. New sources beginning operation after the proposed rule is published, but before the final rule effective date, must be in compliance with the proposed rule upon initial startup and will have a period of time with which to comply with the final rule, after the final rule is promulgated.
constructed following promulgation the standard, must be in compliance start-up.
of at
If my facility is subject to one MACT standard, is it automatically subject to another? If a facility (source) is major for HAPS then it is subject to MACT standards for each source category present at the facility, regardless of individual HAP emissions per source category. Area sources are not automatically subject to other source category standards at their facility if the source is not major for HAPS.
What notifications or submittals are required when you have a source subject to a MACT standard? There are multiple notifications required in association with MACT stanMETAL FINISHING
. JULY 1997
dards. First, a notification is required to identify that the facility has a source subject to a standard. There are then notifications required that state the intent to conduct source testing and that state the compliance status of a source. A new or reconstructed source must also give notification in advance of being constructed or reconstructed. There may also be requirements to submit periodic monitoring reports. Specific standards should be consulted to determine if notification is required.
I understand that I need to prepare a plan if I am subject to a MACT standard. What does this plan need to address? Each source subject to a MACT standard must have a Startup, Shutdown, and Malfunction Plan. This plan must address procedures required to
ensure the source is operated and maintained in a manner consistent with good air pollution control practices. The plan must also ensure that the owners are prepared to correct malfunctions and to address record keeping associated with startup, shutdown, and malfunctions. The requirement to have this plan is found in 40 CFR 63 Subpart A, General Provisions. There may be no reference in the specific MACT standard that this plan is required, so be sure that the plan is in place. Some of the MACT standards do address specific requirements for this plan.
How long do I need to keep records associated with a source subject to a MACT standard? All records associated with a source must be maintained for a period of five 39
years. The most recent two years of records must be maintained on site. Records that must be maintained include, but are not limited to, source startup, shut down, and malfunction records; control equipment malfunctions and maintenance; corrective actions; all information necessary to demonstrate conformance with the malfunction plan and compliance with the standard; results of all tests; calibrations and maintenance of monitoring systems; and documentation of all notifications. If new HAPS are added to the list of 789 do I need to consider them when determining compliance? Yes; however, some additional time will be allowed to comply. Is there a difference in the MACT standards for new and existing sources? Yes. Existing sources must match the emission rates achieved by the best-controlled 12% of sources in their source category. New sources must match the best-controlled source in their source category. Generally, new sources have more restrictive requirements. New sources are those that begin construction after the MACT staridard proposal date. This is a good time to discuss reconstructed sources. A reconstructed source must generally comply with new source requirements. A source is considered to be reconstructed if components of a source are replaced and the fixed capital cost of the new components exceeds 50% of that of a comparable new source. What is the Ear/y Reduction Program, and how can a source qualify? The early reduction provisions of 40 CFR Part 63, Subpart D allow affected sources to receive a six-year extension to the compliance date of an otherwise applicable MACT standard. To qualify a source must make an application and must commit to comply with an enforceable alternate emission standard that reduces HAP emissions by at least 90% (95% in the case of particulate emissions). The enforceable commitment must be made prior to the proposal of the applicable MACT standard. The required HAP emission reduction can be obtained by adjust40
ment for high-risk pollutant weighting factors, if applicable (that is,-extri credit can be gained for the reduction of high-risk HAPS).
in their area for modification requirements.
Is the VOC content of a material equivalent to its volatile organic HAP content? The VOC content of a/material usually contains constituents that are not VOHAPs, and in this case, the VOC content is greater than the VOHAP content of a material. There are three compounds, given in Table I, that are exempt from the definition of VOC that are included in the HAP list. If these constituents are present the VOHAP content of a material can be higher than its VOC content; therefore, to determine the specific VOHAP content of a material, you will have to consider each of its constituents. Where constituent content is unknown, test methods have been available to determine the VOHAP content of a material.
CHROME ELECTROPLATING
What MACT requirements apply to a Major Source that modifies its operations? Eventually, Federal Hazardous Air Pollutant regulations will require major existing sources of HAPS to apply existing source MACT to any actual increase in HAP emissions occurring as a result of a physical change or a change in the method of operation of the source. MACT will supposedly apply to such increases whenever such change results in a greater than a de minimis increase in actual HAP emissions. Sources will supposedly be allowed to offset increases in HAP emissions with equivalent relative-hazardadjusted decreases in HAP emissions in order to avoid having to apply MACT. Where no such MACT has been established, MACT will be determined on a case-by-case basis. These requirements will apply to modifications that are less than reconstruction of a source in jurisdictions where the Title V program is in effect. As previously mentioned source reconstruction is currently subject to new source MACT in jurisdictions where the Title V program is in effect. As a word of caution some states have already promulgated modification rules that are applicable to major sources of HAP emissions. Sources should check the applicable standards
What sources are included in the Chromium Electroplating MACT Standard? The Chromium Electroplating standard applies to all hard and decorative chromium electroplating operations and chromium anodizing tanks. Chromium conversion coating operations are specifically excluded from being subject to this standard, provided no electrical current is applied to the tank. What are my control options to comply with the chrome electroplating MACT standard? The standards for hard chrome electroplating are based on sources being controlled with a packed bed scrubber and mist eliminator. There are different configurations on the specific control equipment that will allow existing hard chrome plating sources to comply. Fume suppressants are generally used by decorative and anodizing to comply. There are other options, such as foam blankets, available to comply with this standard. If chrome plating is not my primary business do I still have to comply with the MACT standard? Yes. All chromium electroplating operations are subject to this standard whether or not they are located at a major source. Do I have to demonstrate compliance with a new test if I have tested my emissions previously? If a compliance test was previously conducted on a chromium electroplating source, a new source test would not be required, provided there is sufficient source operating data and corresponding monitoring values were determined. Testing for existing sources must be completed within six months of the compliance date or in this case by July 25, 1997. If you operate a hard chrome plating operation or a chromium anodizing tank and have not tested by this date, you are late. METAL FINISHING
. JULY 1997
If I have to monitor the pressure drop of a control device and velocity pressure to the control device, how often do I need to record it? Is the pressure drop an average or an instantaneous measurement ? The compliant pressure drop and velocity pressure are established by averaging the pressure drop and velocity pressures during the three test runs during the initial performance test. Future monitoring of the pressure drop must be within kl in. of water column. The compliant pressure-drop range can be increased by conducting additional performance tests over different pressure drops. The velocity pressure must be +lO% of the average velocity pressure during the initial performance test or the range established by multiple tests. The monitoring of the pressure drop and velocity pressure is required to be recorded once each day the source is operated; therefore, the pressure drop and velocity pressure measurements can be considered to be an instantaneous reading. Please note that if you are required to monitor the velocity pressure, you are required to back flush the Pitot tube with water quarterly and to maintain records that this was done.
HALOGENATED SOLVENT DEGREASERS
standards. These alternative standards are based on emissions per area of surface cleaned; however, these standards are extremely restrictive and may not be a viable alternative.
If my solvent only contains a small fraction of halogenated solvent do I still have to comply with the MACT standard?
Are wiping solvents subject to the halogenated solvent degreasing MACT standard?
The halogenated Solvent Cleaning MACT standard applies to any solvent cleaning machine that uses any solvent containing methylene chloride, percloroethylene, trichloroethylene, 1, l,ltrichloroethane, carbon tetrachloride, and chloroform, or any combination of these solvents that exceed a total of 5% by weight; therefore, if your solvent contains more than a total of 5% of these solvents, then you have to comply with this standard.
Wiping with a rag that contains a halogenated solvent is specifically excluded from this MACT standard. Spray cleaners containing halogenated solvents are also excluded.
Biographies John Wellspring is the Manager of Air Resources in SECOR International Inc. ‘s Indianapolis office. Wellspring has over 17 years of professional experience in industry and in consulting, and he is an expert with regards to air pollution requirements associated with metal-finishing operations. Jeffrey Twaddle, P.E., is a Principal Air Quality Engineer in SECOR’s Nashville, Tenn., office. Twaddle has over 10 years of experience as a consultant and former regulator and has assisted many metal finishers with complying with regulations.
Does the halogenated solvent degreaser standard apply to cold cleaners in a facility’s maintenance shop? Yes, but only if they use a solvent that contains more than 5% by weight of any of the solvents listed earlier here.
If my degreaser cannot be physically modified to comply with the equipment requirements do I have any options?
Ron Joseph is an independent coating MF consultant in Saratoga, Calif.
There are options available to comply with equipment and work-practice
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