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EPA Self-Audit and Inspection Guide
Organic Finishing of Metals

Table of Contents

National Emission Standards For Hazardous Air Pollutants For Source Categories (40CFR63.01 -- 40CFR63.788)

The following is a summary of the referenced federal rules, as published in the Code of Federal Regulations (CFR). This information is provided as an aide to help understand the requirements of the federal regulations, as they pertain to specific industrial or manufacturing operations. This information is not provided nor intended to act as a substitute for legal or other professional services. CFR citation numbers for each subpart are indicated, while the full text of the CFR citations can be viewed by clicking HERE and following the directions.

Under the Clean Air Act Amendments of 1990, Congress greatly expanded the Air Toxics program, creating a list of 189 substances to be regulated as hazardous air pollutants. Rather than regulating individual pollutants by establishing health-based standards, the new Air Toxics program granted EPA the authority to regulate specific industrial major source categories with National Emission Standards For Hazardous Air Pollutants (NESHAP) based on maximum achievable control technology (MACT) for each source category. Thus, a number of NESHAPs have been established to regulate specific categories of stationary sources that emit (or have the potential to emit) one or more hazardous air pollutants.

The standards in 40 CFR Part 63 are independent of the NESHAPs contained in 40 CFR Part 61 which remain in effect until they are amended, if appropriate, and added to this part. More information on NESHAPs can be found at the EPA Unified Air Toxics Website.

NESHAPs may cover both major sources and area sources in a given source category. Major sources are defined as those facilities emitting, or having the potential to emit, 10 tons per year or more of one HAP or 25 tons per year or more of multiple HAPs. Major sources are required to comply with MACT standards. Area sources are defined as those facilities that are not major sources. Area sources must comply with either MACT or the less stringent, generally available control technology (GACT) standards.

Subpart A -- General Provisions (40CFR63.01 -- 40CFR63.15)

This subpart describes the general provisions that apply to NESHAPs for various source categories and each affected facility must comply with specific testing, monitoring, reporting, and recordkeeping requirements. Performance testing is required to determine whether a facility is in compliance with the emission standards and is to be done under the normal operating conditions of the facility, using only approved test methods. Monitoring systems, methods, procedures, and frequency, and other pertinent requirements for the regulated source(s) are specified for each source category. Facilities are also required to notify and report to applicable State authorities regarding their operations and emissions.

Currently, only three subparts are in effect that are pertinent to facilites that perform organic coating of metal parts: Subpart T covers halogenated solvent cleaning systems; Subpart GG is the source category for the aerospace industry, and Subpart II is the source category for the shipbuilding and ship repair industry. EPA is planning to promulgate several specific NESHAP regulation by the year 2000 which will impact facilities performing organic coating.

Subpart T -- National Emission Standards for Halogenated Solvent Cleaning (40CFR63.460 -- 40CFR63.469)

This subpart applies to all batch vapor, in-line vapor, in-line cold, and batch cold solvent cleaning operations using methylene chloride, perchloroethylene, trichloroethylene, 1,1,1-trichloroethane, carbon tetrachloride, or chloroform or any combination of these in total concentration of >5% by weight. The rule does not apply to wipe cleaning activities or small buckets with capacities of 2 gallons or less. Compliance requirements for this Subpart depend on the type of machine: batch cold solvent cleaning machine (immersion or remote reservoir); batch vapor; in-line vapor; or in-line cold.

Batch cold cleaning machine standards (40CFR63.462)
Some equipment and procedural requirements include: covering tanks with tight fitting lids, keeping a water layer above solvent solutions, increasing the freeboard space (i.e., the distance between the solvent and top of the tank), storing waste in closed containers, providing sufficient drain time for parts, rotating complex parts to release trapped solvent, and monitoring agitation systems and air currents around open machines.

Batch vapor and in-line cleaning machine standards (40CFR63.463)
Design requirements include covering tanks with tight fitting lids, restricting parts movement to less than 3.4 meters per minute, attaching carbon absorption systems on exhaust streams, or increasing the freeboard space. Compliance options for batch vapor and in-line cleaning machines include: 1) install a control combination; 2) meet an idling mode emission limit; or 3) meet an overall emission limit (alternative standard).

Alternative standards (40CFR63.464)
Overall emission limits are based on the type and size of cleaning machine. Machines using overall emission limits to comply must maintain a log of solvent additions and deletions for each machine. Every month this log must be used to determine solvent emissions. Equipment standards, work practice standards and monitoring requirements are not applicable for the overall emission limit option.

Test requirements (40CFR63.465)
Every halogenated solvent cleaning machine is subject to testing requirements. The 40 CFR 63.465 should be referred to for the specific methods to be used.

Monitoring requirements (40CFR63.466)
Monitoring is required for all batch vapor, in-line vapor and in-line cold solvent cleaning machines using control combinations or idling mode mission limits to comply. Along with monitoring, it must be determined if each control device meets specific requirements. Owners/operators of machines using an idling mode emission to comply and controls not listed in the rule, must establish the monitoring frequency and submit it in the initial test report.

Recordkeeping requirements (40CFR63.467)
Certain records must be kept for all batch vapor, in-line vapor and in-line cold solvent cleaning machines. Record keeping requirements vary depending on the compliance option selected for a machine. Records can be maintained in either written or electronic form.

Reporting requirements (40CFR63.468)
Every halogenated solvent cleaning machine is subject to reporting requirements. Submittal dates depend on when a machine was installed. Depending on the compliance option selected for a machine, owner/operators may be required to submit the following: 1) Initial Notification Report; 2) Annual Compliance Report; 3) Annual Solvent Emission Report; 4) Initial Statement of Compliance Report; 5) Notification of Planned Performance Test (idling emission only); 6) Idling Emission Test Report; and 7) Semi-Annual Exceedance Report.

Equivalent methods of control (40CFR63.469)
Owners/operators may request EPA to consider the use of alternative equipment and or procedures that can provide the same amount of control that is required by the NESHAP final rule. Equivalent methods of control requests for existing sources had to be submitted to EPA by June 3, 1996. Requests for new sources must be submitted and approved by EPA prior to startup.

Subpart GG -- National Emission Standards for Aerospace Manufacturing and Rework Facilities (40CFR63.741 -- 40CFR63.753)

This subpart applies to individual operations within facilities that perform manufacturing or rework of commercial, civil, or military aerospace vehicles and/or components. These operations include: each cleaning operation (all hand-wipe cleaning operations, each spray gun cleaning operation, and all flush cleaning operations); each primer application operation; each topcoat application operation; each depainting operation; each chemical milling maskant application operation; and each waste storage and handling operation.

Standards: General (40CFR63.741)
Includes specific compliance standards for individual operations in aerospace facilities that are in addition to the general provisions for NESHAPs, such as requests for extensions, proper notification of state and federal authorities, and information on air pollution control devices.

Standards: Cleaning operations (40CFR63.744)
Specifies approved solvents and housekeeping practices and procedures for hand-wipe cleaning, spray gun cleaning and flush cleaning for all solvents, unless classified as not containing organic hazardous air pollutants (HAPs) or volatile organic compounds (VOCs). For aqueous solutions, the cleaning solution must be at least 80% water as applied, must have a flash point greater than 93 (C (200 (F), and must be miscible with water. For hydrocarbon-based solvents, the maximum vapor pressure must not be greater than 7 mm Hg at 20 (C and must not contain any HAPs or ozone-depleting substances.

Proper housekeeping practices include: putting rags or other materials in bags or containers immediately after use and keeping the bags or containers closed at all times to contain solvent vapors; storing fresh and spent cleaning solvents in closed containers; and, handling and transferring cleaning solvents to and from storage containers and equipment tanks in a manner that minimizes spills.

Hand-wipe cleaning operations: the facility must show that the cleaning solvent used is an approved solvent, as described above, or has a vapor pressure of 45 mm Hg or less at 20 C; or, must demonstrate that the volume of solvent used has been reduced by 60% from a baseline level, as adjusted for changes in production.
Spray gun cleaning requirements: when spray gun cleaning procedures involve forcing cleaning solvents through spray guns (with or without atomizing air), the facility must ensure that cleaning solvents are directed into containers (e.g., vat, drum, etc.) and that those containers are properly sealed when not in use; when cleaning procedures involve disassembling the gun and soaking the parts, the facility must ensure that the container remains closed at all times when not in use.
Flush cleaning requirements: each time an aerospace part, assembly or component is flush cleaned, the facility must empty the used solvent cleaning solution into an enclosed container or a collection system that remains closed when not in use.
Standards: Primer and topcoat application operations (40CFR63.745)
Compliance requirements for limiting or controlling HAP and VOC emissions to the atmosphere include:
(1) Reducing HAP or VOC concentrations in the coating materials -- Without emissions control devices, HAP concentrations must be limited to no more than 2.9 lb/gal (less water and exempt solvents) as applied for primers, while both HAP and VOC concentrations must be less than 3.5 lb/gal (less water) as applied for topcoats. For self-priming topcoats and other topcoat applications, both HAP and VOC concentrations must not exceed 3.5 b/gal.
(2) Emissions control devices -- The devices must reduce the organic HAP and VOC emissions from the individual operation to the atmosphere by 81% or greater.
(3) Different application methods or equipment -- Application methods or equipment that have demonstrated reduced HAP/VOC emissions are restricted to flow/curtain coating, dip coating, roll coating, brush coating, electrocoating, high-volume low-pressure (HVLP) spraying, electrostatic spraying or other spraying methods that achieve emissions reductions equivalent to the two spraying methods.
(4) Managing airflow in the application area -- Inorganic HAP emissions can be limited by controlling the air flow in areas where coating operations occur. The use of waterwash or dry filter booths is required and may necessitate the use of high efficiency particulate air filters.
Standards: Depainting operations (40CFR63.746)
Addresses depainting operations for the outer surface areas of completed aerospace vehicles, but the provisions do not apply to parts removed from the vehicle for depainting. HAP emissions from both non-HAP chemical strippers and technologies and organic HAP-containing chemical strippers are regulated. If non-chemical based operations are used (e.g., dry media blasting), additional precautions must be taken to reduce the presence of airborne inorganic HAP emissions. Such precautions include performing operations in enclosed areas and passing air streams through filtration systems before exhausting to the atmosphere. For HAP emissions from HAP-containing chemical strippers, HAP emissions must be reduced by the use of a control system.

Standards: Chemical milling maskant application operations (40CFR63.747)
Specifies compliance requirements for chemical milling maskant application operations: For operations without control devices, the organic HAP content, as well as the VOC content, of the maskant must be limited to no more than 1.3 lb/gal as applied. For operations with control devices, the control system must reduce both the organic HAP and VOC emissions by 81% or greater.

Standards: Handling and storage of waste (40CFR63.748)
Requires that handling, transfer, and storage of waste shall be conducted in such a manner that minimizes spills.

Compliance dates and determinations (40CFR63.749)
Affected facilities must make all efforts to comply with these standards within three years after the effective date of the regulations. Specific guidance and information is provided that addresses cleaning operations, HAP and VOC content level standards, and performance tests.

Test methods and procedures (40CFR63.750)
Specifies acceptable test methods to calculate composition, vapor pressure, HAP and VOC content of coating materials and chemical milling maskants, and efficiencies for emissions control devices.

Monitoring requirements (40CFR63.751)
Addressses monitoring and inspection processes for various operations for affected facilities. Provides information about suggested programs, such as visual leak inspection procedures, recording operating parameters of control devices, and the addition of continuous emission monitoring devices. Each affected facility must demonstrate initial compliance with the requirements contained in this subpart.

Recordkeeping requirements (40CFR63.752)
Facilities must maintain adequate records to support their compliance pattern. Records include information on the type and amount of solvents used; the HAP and VOC content of solvents, coatings, and maskants; maintenance logs for equipment; calculations and test results used to gather final information; etc.

Reporting requirements (40CFR63.753)
Outlines reporting requirements for facilities, including subpart applicability, permit applications, and information on equipment and operating conditions.

Subpart II -- National Emission Standards for Shipbuilding and Ship Repair (Surface Coating) (40CFR63.780 -- 40CFR63.788)

This subpart applies to any shipbuilding and/or ship repair facility that is considered to be a major source. However, the provisions of this subpart do not apply to coatings used in volumes less than 52.8 gallons per year, provided that the total coating volume does not exceed 264 gallons per year at any facility. Additionally, facilities that apply coatings through hand-held, non-refillable, aerosol containers or coatings applied to unsaturated polyester resin are not covered by this subpart. Startups, malfunctions, and shutdowns are not subject to these provisions unless an add-on control system is used to comply with this subpart.

Standards (40CFR63.783)
Shipbuilding and ship repair facilities must comply with the following standards on operations and alternative means of reducing emissions of volatile organic hazardous air pollutants (VOHAPs). The VOHAP content of coatings materials, as applied, is limited according to the end-use of the coating. For general use coatings, the limit is 2.83 lb/gal; higher limits are allowed for coatings requiring special characteristics. The maximum allowable content is 6.5 lb/gal for pretreatment wash primers. Also, the facility must handle and transfer VOHAP-containing materials in a manner that minimizes spills and keep materials in closed containers that are regularly inspected for leaks. To use alternative means of reducing emissions, the facility must provide engineering data to support the efficiency of systems and keep detailed records of operation.

Compliance dates (40CFR63.784)
Existing facilities subject to this subpart are to make all efforts to comply with these standards within two years after the effective date. New or reconstructed facilities are to comply with these standards as part of startup operations. Any unaffected facility that increases emissions so that they become affected by this subpart has one year to comply with the subpart standards.

Compliance procedures (40CFR63.785)
Compliance procedures include cerifying VOC content of coating materials, designating the type and amount of thinners to be used, and maintaining accurate records of the thinners used.

Test methods and procedures (40CFR63.786)
Discusses acceptable test methods for determining VOC content of coatings, based on methods in included in Part 60, including such additional topics as sensitivity, repeatability, and reproducibility of the tests and procedures.

Notification requirements (40CFR63.787)
In addition to notification requirements in the general provisions, facilities must provide implementation plans for achieving compliance.

Recordkeeping and reporting requirements (40CFR63.788)
Records must be maintained on a regular basis and include information on volumes of coatings used, the VOC content of coatings, maintenance records, and procedures and calculations for adding thinners to coatings. Reports with this information must be submitted to state and federal authorities for review and notification.

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