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  • Writer's pictureTom Petersen

NESHAP For Area Sources

Updated: Aug 29, 2023

Due to the large number of Area Source National Emission Standards for Hazardous Air Pollutants (Area Source NESHAP) being promulgated at this time, EES will devote several posts to the subject. Area Source regulations regulate Hazardous Air Pollutants (HAP) from facilities that are NOT majors source of HAP.

Last month we provided a summary of Area Source NESHAP for Iron & Steel Foundries. This month we will report on three additional Area Source regulations: Paint Stripping & Surface Coating, Plating and Polishing Operations and 9 Metal Fabrication and Finishing Source Categories. It is possible that your facility is subject to more than one of these regulations.

Below is are brief summaries of each regulation. There are links providing further details. You may also contact EES at 215-881-9401 if you have further questions:

NESHAP: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources

  • Status: Finalized January 9, 2008. Compliance deadline January 10, 2011. Some reporting required in early 2010.

  • Regulatory Citation: 40 CFR 63.11169-11180 Subpart HHHHHH

  • Does this apply to me? Requirements apply to the following:

  • Paint Stripping: Paint stripping utilizing MeCl for removal of dried paint from various substrates.

  • Spray application of coatings: Spray application of coatings (specific definition) to motor vehicles or mobile equipment.

  • Miscellaneous Surface Coatings: Ones that contain the following “target HAPs” are subject: Chromium, lead, manganese, nickel or cadmium.

  • What are the Basic Requirements?

  • Stripping: Maintain records of annual MeCl usage. Implement management practices to minimize emissions. A written plan is required for facilities using more than 1 ton/year of MeCl

  • Surface Coating: Paint booths with filters, HVLP spray guns (or equivalent), painter training, spray gun cleaning requirements & numerous recordkeeping & reporting requirements. You could also have a policy to not use coatings with target HAP metals and avoid the regulation’s requirements.

NESHAP: Area Source Standards for Plating and Polishing Operations

  • Status: Proposed March 14, 2008. Under a court ordered June 15, 2008 promulgation deadline. Compliance deadline for existing sources is two years from promulgation with some reporting required before that date.

  • Regulatory Citation: 40 CFR 63.11475-11513 Subpart WWWWWW

  • Does this apply to me? If your facility performs one of the following activities AND uses or has emissions of compounds of cadmium, chromium, lead, manganese and nickel.

  • Non-chromium Electroplating (chromium electroplating is subject to another area source regulation)

  • Electroless Plating

  • Other non-electrolytic metal coating processes such as chromate conversion coating & thermal spraying

  • Dry mechanical polishing of finished metals and formed products

  • Electroforming

  • Electropolishing

  • What are the proposed basic requirements? Depending on the process(es) you use, some or all of these requirements apply:

  • Use of Wetting agents and fume suppression

  • Use of Covered tanks

  • Time limits for certain activities

  • Minimizing tank agitation and maximizing drippings back into tanks

  • Control devices might be required to capture particulates and fumes.

  • Recordkeeping and reporting

NESHAP: Area Source Standards for 9 Metal Fabrication & Finishing Source Categories

  • Status: Proposed April 3, 2008. Under a court ordered June 15, 2008 promulgation deadline. Compliance deadline for existing sources is two years from promulgation with some reporting required before that date.

  • Regulatory Citation: 40 CFR 63.11514-11523 Subpart XXXXXX

  • Am I subject to this? Regulation is very specific on the source categories subject to the regulation. Table 1 of the proposal gives specific definitions for each of these categories. If you are in one of these categories and you are a source of emissions of compounds of cadmium, chromium, lead, manganese, nickel or volatile organic HAPs, then you are subject.

  • Electrical and Electronic Equipment Finishing Operations

  • Fabricated Metal Products

  • Fabricated Plate Work (Boiler Shops)

  • Fabricated Structural Metal Manufacturing

  • Heating Equipment, except Electric

  • Industrial Machinery and Equipment Finishing Operations

  • Iron and Steel Forging

  • Primary Metals Products Manufacturing

  • Valves and Pipe Fittings

  • Does this apply to me & what are the proposed requirements? If you are in one of the categories above and you do the activities below, then the regulation applies. Please note, it does not apply to tool or equipment repair or other facility maintenance. The Visual Fugitive Emission monitoring requirements are quite specific and any observations trigger increased monitoring, recordkeeping and reporting.

  • Dry abrasive blasting: Requirements vary based on the size of object and where the blasting occurs. The general goal is to minimize fugitive dust emissions. This can be done through the use of enclosures, venting to control devices, visual fugitive emission monitoring, and housekeeping. Machining metal fabrication: Requirements include general housekeeping and visual fugitive emission monitoring. Dry grinding and dry polishing: Requires that you capture emissions and vent to a filtration control device and conduct visual fugitive emission monitoring. Spray painting and other spray coating:

  • For coatings containing the metal HAPs, requirements include a spray booth (for objects less than 15 feet in all dimensions) which vents to a filtration device, application with HVLP spray guns (or equivalent), training requirements and spray gun cleaning requirements. Volatile Organic HAP (VO HAP) content limitations of 3 lbs VO HAP/gal solids

  • Welding: Minimize emissions by using low fume welding processes (numerous practices are listed) or a fume control system. In addition, visual fugitive emission monitoring is required.

Related Links:

Link to Area Source Standard for Paint Stripping and Miscellaneous Surface Coating:

EPA Brochure: This brochure is easy to read and provides a good overview of the requirements


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