Metal Fabrication and Finishing Regulations
The EPA Establishes a New Dust Collection Deadline for Calendars
(Industrial Maid is providing the following for informational purposes only. Web visitors should also consult with their legal representatives to determine which regulations apply to them and which solutions would put them in compliance.)
What are the Compliance Deadline Dates?
(A) If you own or operate an existing affected source, you must achieve compliance with the applicable provisions in this subpart by July 25, 2011.
(B) If you own or operate a new affected source, you must achieve compliance with the applicable provisions in this subpart by July 23, 2008, or upon startup of your affected source, whichever is later.
The EPA has new regulations designed to help reduce the potential health hazards to anyone who might be in position to breathe air that has been polluted by MFHAP (Metal Fabrication Hazardous Air Pollutants). In the formal copy of 40 CFR Part 63 Subpart XXXXXX states that the new regulation applies "if you use materials that contain or have the potential to emit metal fabrication or finishing metal HAP (MFHAP), defined to be the compounds of cadmium, chromium, lead, manganese, and nickel, or any of these metals in the elemental form with the exception of lead. Materials that contain MFHAP are defined to be materials that contain greater than 0.1 percent for carcinogens, as defined by OSHA at 29 CFR 1910.1200(d)(4), and greater than 1.0 percent for noncarcinogens. For the MFHAP, this corresponds to materials that contain cadmium, chromium, lead, or nickel in amounts greater than orequal to 0.1 percent by weight (of themetal), and materials that contain manganese in amounts greater than or equal to 1.0 percent by weight (of the metal), as shown in formulation dataprovided by the manufacturer or supplier, such as the Material Safety Data Sheet for the material."
Who is subject to this Subpart?
You are subject to this subpart if you own or operate an area source that is "primarily engaged" (see below for EPA's definition) in the operations in one of the following nine source categories:
- Electrical and Electronic Equipment Finishing Operations (including motor & generator manufacture, and electrical machinery, equipment, and supplies, not elsewhere classified)
- Fabricated Metal Products
- Fabricated Plate Work (Boiler Shops)
- Fabricated Structural Metal Manufacturing
- Heating Equipment, except Electric
- Industrial Machinery and Equipment Finishing Operations (including construction machinery manufacturing; oil and gas machinery manufacturing; and pumps and pumping equipment manufacturing)
- Iron and Steel Forging
- Primary Metal Products Manufacturing
- Valves and Pipe Fittings
The regulation contains requirements for five specific production processes:
- Dry abrasive blasting which use materials that contain MFHAP or that have the potential to emit MFHAP.
- Machining operations which use materials that contain MFHAP
- Dry grinding and dry polishing with machines which use materials that contain MFHAP,
- A spray painting affected source is the collection of all equipment and activities necessary to perform spray-applied painting operations using paints which contain MFHAP.
- Welding affected source which use materials that contain MFHAP
For more detailed definitions of the standards of these processes access the Electronic Code of Federal Regulations, §63.11522, Area Source Standards or 40 CFR Part 63.
NOTE: Any of these processes at a facility in one of the nine source categories listed above are subject to requirements. The requirements only apply when a process uses materials that contain compounds of cadmium, chromium, lead, manganese, and nickel. Low level use of these metals in the processes may be exempt. If you have questions about whether or not this requirement includes you consider contacting your EPA Regional Contact.
What does "primarily engaged" mean?
As stated in §63.11522, "Primarily engaged" means the manufacturing, fabricating, or forging of one or more products listed in one of the nine metal fabrication and finishing source category descriptions in Table 1, "Description of Source Categories Affected by this Subpart," where this production represents at least 50 percent of the production at a facility, and where production quantities are established by the volume, linear foot, square foot, or other value suited to the specific industry. The period used to determine production should be the previous continuous 12 months of operation. Facilities must document and retain their rationale for the determination that their facility is not "primarily engaged" pursuant to §63.10(b)(3) of the General Provisions.
Subpart XXXXXX - 9 METAL FABRICATION APPLICABILITY
By NAICS Code, with EPA Source Category
NAICS Code |
NAICS Description |
EPA Source Category |
|
1 |
332111 |
Iron and Steel Forgin |
Iron and Steel Forgin |
2 |
332117 |
Powder Metallurgy Part Manufacturing |
Fabricated Metal Products, NEC |
3 |
332312 |
Fabricated Structural Metal Manufacturing |
Fabricated Structural Metal Manufacturing |
4 |
332313 |
Plate Work Manufacturing |
Fabricated Plate Work (Boiler Shops ) |
5 |
332410 |
Powder Boiler and Heat Exchanger Manufacturing |
Fabricated Plate Work (Boiler Shops) |
6 |
332420 |
Metal Tank (Heavy Guage) Manufacturing |
Fabricated Plate Work (Boiler Shops) |
7 |
332618 |
Other Fabricated Wire Product Manufacturing |
Primary Metals Products Manufacturing |
8 |
332919 |
Other Metal Valve and Pipe Fitting Manufacturing |
Valves and Pipe Fittings, NEC |
9 |
332999 |
All Other Miscellaneous Fabricated Metal Product Mftg |
Fabricated Metal Products, NE C |
10 |
333120 |
Construction Machinery Manufacturing |
Industrial Machinery & Equipment: Finishing Ops |
11 |
333132 |
Oil and Gas Field Machinery and Equipment Mftg |
Industrial Machinery & Equipment: Finishing Ops |
12 |
333414 |
Heating Equipment (except Warm Air Furnaces) Mftg |
Heating Equipment, except electric |
13 |
333911 |
Pump and Pumping Equipment Manufacturing |
Industrial Machinery & Equipment: Finishing Ops |
14 |
335312 |
Motor and Generator Manufacturing |
Electrical & Electronic Equipment Finishing Ops |
15 |
335999 |
All Other Misc. Electrical Equipment & Component Mftg |
Electrical & Electronic Equipment Finishing Ops |
This table can be found at Subpart XXXXXX - 9 METAL FABRICATION APPLICABILITY - By NAICS Code, with EPA Source Category
Flow Charts For Determining Your Requirements:Nine Metal Fabrication and Finishing Source Categories Area Source NESHAP (subpart XXXXXX)
What are my Monitoring Requirements?
The regulation requires periodic monitoring for some operations. Visible emissions monitoring using Method 22 is required for abrasive blasting performed on large objects (i.e., greater than 8 feet in any dimension) that is not performed in an enclosure vented to a filtration control device. If visible emissions are detected, corrective actions are required until the visible fugitive emissions are eliminated. Visible emissions monitoring using Method 22 is also required for welding operations. Welding operations that only use small amounts of rod or wire that contain any of the five metals may be exempt. If visible emissions are detected, corrective actions are required until the visible fugitive emissions are eliminated. However, if visible emissions from welding operations are detected more than one time in a year, opacity testing using Method 9 is then required. An opacity reading of more than 20 percent then results in the requirement to prepare and implement a site-specific welding emissions management plan.
- For Method 9, see: http://www.epa.gov/ttn/emc/methods/method9.html
- For Method 22, see: http://www.epa.gov/ttn/emc/methods/method22.html
For more detailed monitoring requirements see the Electronic Code of Federal Regulations, §63.11517, or 40 CFR Part 63.
What are my notification, recordkeeping, and reporting requirements?
There also are reports that facilities must submit:
- Initial Notification – must be submitted by July 25, 2011 for existing sources and 120 days after startup for new sources. This must be submitted by every facility in one of the nine source categories whether or not any process at the facility is subject to the standards and management practices.
- Notification of Compliance Status Report – must be submitted by November 22, 2011 for existing sources and 120 days after initial startup for new sources.
- Annual Certification and Compliance Reports.
For more detailed monitoring requirements see the Electronic Code of Federal Regulations, §63.11517, or 40 CFR Part 63.
Where can I access a complete list of definitions as I work through the requirements?
Some of the very basic definitions were covered above but for a more complete list and easy access use §63.11522.
Now What?
Every manufacturing company has to bring all of the resources to bear to determine if 40 CFR Part63 Subpart XXXXXX applies to them. At Industrial Maid we hope that we have provided some information and links to facilitate that job. If you have determined that you fit within the parameters of the identified affected sources, then we feel like we have a job - namely, helping you become compliant.
At Industrial Maid our experienced engineers can help you figure out how to change an industrial air quality challenge due to the MFHAP found in grinding dust or welding dust, into an EPA compliant industrial ventilation system. Because we are the manufacturer and follow our metal dust collection equipment from the design table to the installation, we know which model of industrial air cleaner will do the best job of dust collection and extraction. Every model type has the same high standard of materials and construction, but we can also help configure the components to handle any unique dust extraction challenge. Take a minute to browse our application gallery. There you will see a Model RH60-4 welding dust and fume exhaust system we designed for an automaker's new plant in 2009.
While consulting with the mechanical contractor for a manufacturing company located in the western United States we determined that the best solution to handle metal grinding dust collection was a combination of Models M36 IAC & T-3500. Here ducted industrial air cleaners serve for dust source capture and free hanging ambient units placed in a push-pull design capture any remaining dust particles that enter the ambient air. We are happy to work with integrators to provide industrial ventilation equipment components when custom design work is needed. Click to see an example of a Model RH60-3 partnered with a Gorbel Freestanding Work Station Crane system.
If metal grinding dust is causing potential health issues for your employees let Industrial Maid help protect your workforce with a full line of choices including Ducted Units, Ambient Industrial Air Cleaners, Portable Industrial Air Cleaners/Downdrafts, FilterWalls, Backdrafts and Environmental and Spray Booths. But these are only a few examples of the areas of our expertise - we also specialize in finding the right quality industrial air purifiers for the collection and extraction of Wood Dust, Oil Mist, Diesel Smoke & Fumes, Fiberglass/Auto Body, and Smoke.
EPA RESOURCE LINKS: FAQ | Brief Summary | Area Source Standards | Flow Charts | EPA Regional Contacts