The NESHAP applies only to area sources where the primary activity of the facility is in one of the following nine source categories:
(1) Electrical and Electronic Equipment Finishing Operations (including motor and generator manufacture, and electrical machinery, equipment, and supplies, not elsewhere classified);
(2) Fabricated Metal Products;
(3) Fabricated Plate Work (Boiler Shops);
(4) Fabricated Structural Metal Manufacturing;
(5) Heating Equipment, except Electric;
(6) Industrial Machinery and Equipment Finishing Operations (including construction machinery manufacturing; oil and gas field machinery manufacturing; and pumps and pumping equipment manufacturing);
(7) Iron and Steel Forging;
(8) Primary Metal Products Manufacturing; and
(9) Valves and Pipe Fittings.
The regulation contains requirements for five specific processes, listed below. The requirements only apply when a process uses materials that contain specified metal compounds. Low level use of these metals in the processes may be exempt.
• Dry Abrasive Blasting
• Dry Grinding and Dry Polishing with Machines
• Dry Machining
• Spray Painting
• Welding
The regulation requires periodic emissions monitoring for some operations. There also are reports that facilities must submit.
• Initial Notification – due by July 25, 2011
• Notification of Compliance Status report – due by November 22, 2011 and,
• Annual certification and compliance reports.
Caltha LLP provides specialized expertise to clients, including the Metal Fabrication Sector, nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.
For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website
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