PRODUCTS FINISHING — PFonline.com
13
THE VOICE OF FINISHING
80
YEARS
See us in
Booth
#C51026
at Fabtech
NASF Webcast for Manufactured Metal
Compounds and TRI Reporting
In response to recent EPA enforcement actions, NASF will present
a webcast on December 14, 2016 regarding calculating manufac-
tured metal compounds for threshold reporting limits pursuant
to Section 313 of the Emergency Planning and Community Right-
to-Know Act of 1986 (EPCRA). Although the EPA's enforcement
position is not new, it is of particular concern to surface finishing
operations that must calculate and document threshold deter-
minations of certain manufactured metal compounds on Form R
of the Toxics Release Inventory (TRI).
Joelie Zak of Scientific Controls Laboratories will summarize
the requirements for manufactured metal compounds for TRI
reporting and provide critical technical information to make
accurate calculations for threshold determinations. For more
information on the webcast, please contact Matt Martz or Jeff
Hannapel with NASF at mmartz@nasf.org or
jhannapel@thepolicygroup.com.
NASF Works with EPA and States on Plating and
Polishing Area Source Rule Compliance Efforts
Based on recent enforcement actions, EPA Region V Office of
Enforcement has identified multiple problems with compli-
ance regarding the plating and polishing NESHAP rule for area
sources (40 CFR Part 63,subpart WWWWWW). Before doing
further inspections and initiating any additional enforcement,
EPA asked the state Small Business Environmental Assistance
Programs (SBEAPs) in Region 5 (IL, IN, MI, MN, OH, WI) if they can
work with the industry to facilitate compliance.
The SBEAPs offers free and confidential compliance assis-
tance to small businesses in the region. Although most SBEAPs
are located in a regulatory agency, they are entirely separate
from the sections that enforce the rules.
Some of the compliance issues include:
• Electroplating – record keeping violations, failure to use
wetting agents or fume suppressants, failure to use a control
device (mesh pad, packed bed scrubber or mesh pad mist
eliminator) failure to cover tanks, failure to monitor pH;
• Electroless nickel plating and manganese phosphate
coating – record keeping violations, failure to perform work
management practices; and
• Thermal spraying – record keeping violations, failure to
perform work management practices.
The SBEAP representatives invited NASF to brainstorm the
best approach to facilitate further compliance with the plating
and polishing area source rule. During the September 28, 2016
call, the NASF representatives indicated the industry's willing-
ness to assist in the guidance to ensure continued compliance
with the requirements of the plating and polishing rule.
For more information regarding the plating polishing area
source rule and the industry's efforts to promote compliance
with EPA and the states, please contact Jeff Hannapel with
NASF at jhannapel@thepolicygroup.com.
BECOME A MEMBER AT NASF.ORG