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NOW WHAT!!!!!!!

NOW WHAT!!!!!!! . MFASC MOORE COMPLIANCE & TRAINING. N E S H A P. NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS: AREA SOURCE STANDARDS FOR PLATING AND POLISHING OPERATIONS. 40 CFR PART 63 SUBPART WWWWWW. WHO ME?. You are subject to this subpart if:

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NOW WHAT!!!!!!!

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  1. NOW WHAT!!!!!!! MFASC MOORE COMPLIANCE & TRAINING

  2. N E S H A P • NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS: • AREA SOURCE STANDARDS FOR PLATING AND POLISHING OPERATIONS. • 40 CFR PART 63 • SUBPART WWWWWW

  3. WHO ME? • You are subject to this subpart if: • You own or operate a plating or polishing facility that is an area source of Hazardous Air Pollutants. • HAPs • CADMIUM • CHROMIUM • LEAD • MANGANESE • NICKEL

  4. AM I AN AREA SOURCE? • You are an area source if: • Electroplating other than chromium electroplating; • Electroless or non-electrolytic plating; • Other non-electrolytic metal coating processes: • Chromate conversion coating. • Nickel acetate sealing. • Sodium dichromate sealing, and/or. • Manganese phosphate coating. • Thermal spraying. • And/or

  5. AREA SOURCE An area source of HAP emissions is any source that DOES NOT have the potential to emit any single HAP at a rate of 10 tons a year or more and any combination of HAP at a rate of 25 tons or more a year.

  6. AM I AN AREA SOURCE? Dry mechanical polishing of finished metals and formed products after plating. Electroforming. Electropolishing.

  7. HAP • CADMIUM • CHROMIUM • LEAD • MANGANESE • NICKEL

  8. ON MORE TIME • DOES NOT APPLY TO ELECTRODEPOSITED CHROMIUM. Decorative, Hard or Chromic Acid Anodize. • (CHROME HAS ITS OWN RULE).

  9. EXEMPTION ??? To be exempt the HAP concentration must be less that 0.1% by weight. Dry mechanical polishing conducted to restore the original finish to a surface to apply a restoring the original finish.

  10. COMPLIANCE DATES Initial Notification due October 29, 2008. Compliance to the regulation must be achieved by July 1, 2010.

  11. COMPLIANCE REQUIREMENTSNON-CYANIDE - ELECTROLYTIC • Option 1 – Wetting Agent/Fume Suppressant • Option 2 – Capture and Control Device • Mesh Pads, packed bed scrubber, etc. • Option 3 – Tank Covers • Used for 95% of the time of the electroplating operation. • Continuous Plating – 75% of the tank surface.

  12. FLASH / SHORT TERM / STRIKES Used no more that 1 hour a day and no more that 3 minutes in any one hour. Tank covers must be used.

  13. CYANIDE PLATING BATHS ELECTROLYTIC • Cyanide plating operated at a pH of 12 or greater: • Measure and record the pH at start up. • Only done once. • Implement applicable Management Practices.

  14. POLISHING OPERATIONS • Must operate a capture system that captures particulate matter emissions and transport the emissions to a cartridge, fabric, or HEPA filter. • Maintain system in accordance with manufacture’s recommendations.

  15. THERMAL SPRAYING OPERATION READ THE REGULATION.

  16. NON-ELECTROLYTIC COATING PROCESSES Applicable Management Practices must be used.

  17. MANAGEMENT PRACTICES Applicable Management Practices must be implemented by July 1, 2010.

  18. MANAGEMENT PRACTICES 1. Minimize bath agitation when removing any parts processed in the tank, as practicable except when necessary to meet quality requirements.

  19. MANAGEMENT PRACTICES 2. Maximize the draining of bath solution back into the tank, as practicable , extending drip times when removing parts from the tank; using drain boards; or withdrawing parts slowly from the tank, as practicable.

  20. MANAGEMENT PRACTICES 3. Optimize the design of barrels, racks, and parts to minimize dragout of bath solution, as practicable.

  21. MANAGEMENT PRACTICES 4. Use tank covers, if already owned and available at the facility, whenever practicable.

  22. MANAGEMENT PRACTICES 5. Minimize or reduce heating of process tanks, as practicable (when doing so would not interrupt production or adversely affect part quality).

  23. MANAGEMENT PRACTICES 6. Perform regular repair, maintenance, and preventive maintenance of racks, barrel, and other equipment associated with affected sources, as practicable.

  24. MANAGEMENT PRACTICES 7. Minimize bath contamination, such as through the prevention or quick recovery of dropped parts, use of distilled/de-ionized water, water filtration, pre-cleaning of parts to be plated, and thorough rinsing of pre-treated parts to be plated, as practicable.

  25. MANAGEMENT PRACTICES 8. Maintain quality control of chemicals, and chemical and other bath ingredient concentrations in the tank, as practicable.

  26. MANAGEMENT PRACTICES 9. Perform general good housekeeping, such as regular sweeping or vacuuming, if needed, and periodic washdowns, as practicable.

  27. MANAGEMENT PRACTICES 10. Minimize spills and overflow of tanks, as practicable.

  28. MANAGEMENT PRACTICES 11. Use squeegee rolls in continuous or reel-to- reel plating tanks, as practicable.

  29. MANAGEMENT PRACTICES 12. Perform regular inspections to identify leaks and other opportunities for pollution prevention.

  30. COMPLIANCE REQUIREMENTS • Be in compliance with the applicable management practices and equipment standards of the regulation at all times.

  31. COMPLIANCE REQUIREMENTS If using a wetting agent/fume suppressant --- certify that you are using it and using it correctly. Implement applicable management practices.

  32. COMPLIANCE REQUIREMENTS If using a control system it must be designed to capture the HAP. Must be installed correctly and certified by you. Implement applicable management practices. Operate the system in accordance manufacture’s specification and instructions.

  33. COMPLIANCE REQUIREMENTS If using Tank Covers, they must be installed and used. Implement applicable management practices. Certify that they cover the required 95%.

  34. COMPLIANCE REQUIREMENTS If using Tank Covers for continuous or reel-to-reel, they must be installed and used. Implement applicable management practices. Certify that they cover the required 75%.

  35. COMPLIANCE REQUIREMENTS • For flash or short term plating tanks: • Certify that the tank is not used for more that 1 hour per day or 3 minutes in one hour. • Implement applicable management practices. • Use tank covers for at least 95% of the time. • Certify all the of the above.

  36. COMPLIANCE REQUIREMENTS Prepare an annual Compliance Certification and keep it in a readily-accessible location for inspector review.

  37. DOCUMENTATION REQUIREMENTS Document the use and additions of fume suppressant. OR Record the results of all control system inspections, corrective action for malfunctions, etc.

  38. DOCUMENTATION REQUIREMENTS • Short-term or Flash Plating • Record the times that the affected tank is operated each day.

  39. DOCUMENTATION REQUIREMENTS • If using Tank Covers • You must record the time the tank is operated and the times the tank is covered on a daily basis.

  40. DOCUMENTATION REQUIREMENTS Implementation of applicable management practices. Which ones are used, etc.

  41. Just a reminder ……. Forms and records need to be filled out and available for inspectors from the EPA, CARB, and/or AQMD. Handing them a 3 ring binder with nothing filled out in --- it is not good. Asking them to wait or return when the boss is here or your consultant ---- not a good idea either.

  42. NOTIFICATION REQUIREMENTS • INITIAL NOTIFICATION • (SEE FORM) • DUE OCTOBER 29, 2008 • Send to: • Federal EPA – Region 9 • CARB • Local AQMD • Don’t Forget the Return Receipt

  43. NOTIFICATION REQUIREMENTS • NOTIFICATION OF COMPLIANCE STATUS • Who, What, Where, and How you are in compliance. • Certify to it. • Due July 1, 2010.

  44. NOTIFICATION REQUIREMENTS • ANNUAL CERTIFICATION OF COMPLIANCE • The Who, What, Where and How you are in compliance. • Does not get mailed in unless a deviation for the requirements has occurred during the reporting year. • Annual Certification of Compliance is mailed along with the Deviation Report. • Due by January 31 of the year immediately following the reporting year. If submitting a Deviation Report, it too is due by January 31.

  45. RECORDKEEPING REQUIREMENTS A copy of the Initial Notification and Notification of Compliance Status. Records of continuous compliance to applicable management practices. All supporting documentation. Annual Certification of Compliance. Deviation Report, etc. Maintained for 5 years (forever + a week).

  46. INITIAL NOTIFICATION 1. Name and address of owner/operator. 2. Physical location of the affected source. 3. An identification of the applicable standard. 4.A brief description of the nature, size, design, and method of operation of the source, an identification of the emissions points, and the HAP emitted.

  47. INITIAL NOTIFICATION 5. A statement of whether the affected source is a major source or an area source. 6. A description of the compliance method (e.g., wetting agent, etc) for each affected source. REMEMBER IT’S DUE 10/29/08 THAT’S THE END OF THIS MONTH !!!!!!

  48. SUBMIT IT TO • (1) EPA, REGION 9 - AIR DIVISION • 75 HAWTHORNE STREET • SAN FRANCISCO, CA 84105 • (2) CALIFORNIA AIR RESOURCES BOARD • 1001 “I” STREET • P.O. BOX 2815 • SACRAMENTO, CA 95812 • (3) YOUR LOCAL AQMD • BY OCTOBER 29, 2008 • Return Receipt Requested

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