1 May 4, 2004 Sacramento Thermal Spraying ATCM Public Workshop.

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May 4, 2004Sacramento

Thermal Spraying Thermal Spraying ATCM Public ATCM Public WorkshopWorkshop

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• Introductions

• ARB’s Toxics Program

• Thermal Spraying Project– Background

– Project Goals

– Completed & Ongoing Activities

– Regulatory Concepts

– Schedule

Agenda

Thermal Spraying Public Workshop - May 2004

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Identification of Toxic Air Contaminants

Airborne Toxic Control Measures

Air Toxics “Hot Spots” (AB2588)

Neighborhood Air Monitoring

Risk Reduction Guidelines

ARB’s Toxics Program


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Background:What is thermal spraying?

Metals are sprayed onto a surface in a molten (or nearly molten) condition to form a coating.

Includes: - Flame Spraying - Plasma Spraying - Twin-Wire Electric Arc - HVOF - Detonation Gun

ARB’s Thermal Spraying Project


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Spray Gun

Feed Material

Oxygen & Fuel Gas orElectric Arc

Molten Metal

Background:

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Background:• Materials may contain chromium,

nickel, and other toxic air contaminants

• Can generate air emissions of hexavalent chromium & nickel

• Used in a wide variety of industries, particularly aerospace



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Control Devices:• Most common is dry filter cartridge• Others include: HEPA Filter, Water

Curtain, Wet Scrubber, and Baghouse• Control Efficiency ratings can be

assigned, based on standardized tests:

HEPA Filter - 99.97% @ 0.3 umDry Filter - 99.999% @ 0.5 um



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Project Goals: • Characterize thermal spray

industry

• Quantify toxic air emissions

• Determine extent of health risks

• Implement risk reduction measures



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Why ? • Board request• Potential use as replacement for hard

chromium electroplating• Hexavalent chromium is very toxic • Nickel can cause cancer & other health

effects• Community Health/Environmental Justice


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Completed Activities• 2003 Survey of Thermal Spraying

Material Manufacturers

• 2004 Survey of Thermal Spraying Facilities

• Air Dispersion Modeling



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Key Findings from Surveys:• 103 tons of thermal spraying materials sold in CA in

2002

• Materials contained 18 tons of chromium and 34 tons of nickel

• The aerospace industry uses more than 1/3 of the materials

• CA has 47 active thermal spraying facilities

• Most facilities have control devices

• More than 1/2 of facilities use chromium-containing materials



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Key Findings from Surveys:



47 Total Active Facilities = 30 Permitted

17 Unpermitted

41 Have Control Devices

64 %

36 %

87 %

16 Have HEPA Filters 34 %

24 Use Products w/Chromium

51 %

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Ongoing Activities• Statewide Emission Inventory

• Health Risk Assessment

• Cost Analysis

• Initial Statement of Reasons

• Draft Regulatory Language



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Emission Estimates• Working with districts to

develop emission estimation methodology

• Based on stack tests, scientific research, and industry data



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Current Requirements• Air Permits

• Toxics New Source Review

• AB 2588



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Regulatory Concepts• New Facilities - 99.97% @ 0.3 um

• Existing Facilities - Control efficiency requirements would vary, depending on health risk & cost

• Permitting & Recordkeeping



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Regulatory ConceptsExisting Facilities - Point Sources:



90%Low Threshold

99.999% @ 0.5 umMedium Threshold

Required Control Efficiency

Annual Toxic Emissions

(lbs/yr)

99.97% @ 0.3 umHigh Threshold

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Regulatory ConceptsExisting Facilities - Volume Sources:



99%Low Threshold

99.999% @ 0.5 umMedium Threshold

Required Control Efficiency

Annual Toxic Emissions

(lbs/yr)

99.97% @ 0.3 umHigh Threshold

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Regulatory ConceptsNew Facilities:

Required Control Efficiency: 99.97% @ 0.3 um

All Facilities:

Permitting & Recordkeeping Future Compliance Date



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Summary•Thermal spraying generates toxic air

emissions.

•ARB is working on an ATCM regulation to control toxic emissions & protect public health.

•The ATCM would be based on the use of BACT in consideration of health risk and cost.



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Schedule•June 23 2nd Public Workshop

•September Proposed Regulation and

Staff Report Available -

Public has 45 days to comment

•October 21 Tentative Board Hearing Date



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Public Involvement •Website:

http://www.arb.ca.gov/coatings/thermal/thermal.htm

•Sign up for List Server to get updates

•Attend Workshops (can be done by phone)

•Provide Comments

•Meet with ARB

•Attend Board Hearing (can participate via internet)



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Monique Spears Davis, [email protected](916) 324-8182

Jose Gomez, [email protected](916) 324-8033

ARBStationary Source DivisionMeasures Assessment Branch1001 I Street, P.O. Box 2815Sacramento, CA 95812

ARB Points of Contact


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QUESTIONS?


1 May 4, 2004 Sacramento Thermal Spraying ATCM Public Workshop.

Documents

Transcript of 1 May 4, 2004 Sacramento Thermal Spraying ATCM Public Workshop.