Environmental Protection Agency (EPA) 40 CFR Part 63
National Emission Standards for Hazardous Air Pollutants (NESHAP); Area Source Standards for Nine Metal Fabrication and Finishing Source Categories
On July 23, 2008 the Environmental Protection Agency (EPA) issued a final ruling that established National Emission Standards for Hazardous Air Pollutants from nine metal fabrication and finishing Source Categories.
The following list details the nine source categories (area sources) and includes NAISC and SIC Codes for reference:
1. Electrical and Electronics Equipment Finishing Operations
a. Electrical Equipment and Component Manufacturing; All Other Misc (NAISC Code 335999)(SIC Code 3699)
b. Motor and Generator Manufacturing (NAISC Code 335312)(SIC Code 3621)
2. Fabricated Metal Products
a. Fabricated Metal Products; All Other Miscellaneous (NAISC Code 332999)(SIC Code 3499)
b. Powder Metallurgy Part Manufacturing (NAISC Code 332117)(SIC Code 3499)
3. Fabricated Plate Work-‐Boiler Shops
a. Plate Work Manufacturing (NAISC Code 332313)(SIC Code 3443)
b. Power Boiler and Heat Exchanger Manufacturing (NAISC Code 332410)(SIC Code 3443)
c. Metal Tank (Heavy Gauge) Manufacturing (NAISC Code 332420)(SIC Code 3443)
4. Fabricated Structural Metal Manufacturing (NAISC Code 332312)(SIC Code 3441)
5. Heating Equipments, except Electric (NAISC Code 333414)(SIC Code 3433)
6. Industrial Machinery and Equipment Finishing Operations
a. Construction Machinery Manufacturing (NAISC Code 332120)(SIC Code 3531)
b. Oil and Gas Field Machinery and Equipment Manufacturing (NAISC Code 333132)(SIC Code 3533)
c. Pump and Pumping Equipment Manufacturing (NAISC Code 333911)(SIC Code 3561)
7. Iron and Steel Forging (NAISC Code 33211)(SIC Code 3462)
8. Primary Metals Products Manufacturing (NAISC Code 332618)(SIC Code 3399)
9. Valves and Pipe Fittings (NAISC Code 332919)(SIC Code 3494)
The intent of this regulation is to reduce Metal Fabrication Hazardous Air Pollutants (MFHAP) of compounds of metals such as Cadmium, Chromium, Lead, Manganese and Nickel. Any material that does not contain Cadmium, Chromium, Lead, or Nickel in amounts greater than or equal to 0.1 percent by weight (as a metal), and does not contain Manganese in amounts greater than 1 percent by weight (as a metal), are not considered to be material containing MFHAP. Material Safety Data Sheets (MSDS) provided by the manufacturer or supplier of the metal material should provide formulation and percentages.
The document applies to the “Nine Source Categories” listed above if it is deemed that their operations are “Primarily Engaged” in one of five “Primary Processes”. 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. This production represents at least fifty percent of the production at the facility and can be measured by volume, linear foot, square foot, or other values suited to the specific industry. The period used to determine production should be the previous 12 months of operation.
The Primary Processes are:
1. Dry Abrasive Blasting
2. Dry Grinding and Dry Polishing with Machines
3. Machining
4. Spray Painting
5. Welding
For this document we will be focusing on Welding.
TIMELINE
The EPA finalized the regulation on July 23, 2008 and separated compliance requirements for existing facilities from new facilities. The timelines are different for each entity and are listed below:
New Source Facilities
July 23, 2008 Each new source (facility) is required to meet the standard upon startup, or by July 23, 2008, whichever is later.
November 20, 2008 Each new source (facility) must submit their initial notification and notification of compliance status within 120 days of startup, or by November 20, 2008, whichever is later.
Annual reports. Facilities must submit an annual certification of compliance report by January 31st each year, for the previous calendar year.
Existing Source Facilities
July 25, 2011 Each existing source is required to submit an initial notification and meet the compliance requirements.
November 22, 2011 Each existing source must submit a notification of compliance status.
REQUIRED DOCUMENTATION
Initial Notification
Must contain the following:
(i) The name, address, Phone number and email address of the owner and operator;
(ii) The address (physical location) of the affected source;
(iii) An identification of the relevant standard (i.e. this subpart); and
(iv) A brief description of the type of operation. For example, a brief characterization of the types of products (e.g., aerospace components, sports equipment, etc.) the number and type of processes, and the number of workers usually employed.
Notification of Compliance
Must contain the following:
(i) Your companies name and address;
(ii) A statement by a responsible official with that official's name, title, phone number, email address and signature, certifying the truth, accuracy, and completeness of the notification and a statement of whether the source has complied with all the relevant standards and other requirements of this subpart.
DOES THIS STANDARD APPLY TO ME?
1. If your welding facility uses less than 2000 pounds per year of welding rod that contains possible MFHAP over a rolling 12 month basis, you must document your purchasing and complete your Notice of Compliance paperwork.
2. If your welding affected source uses 2000 pounds or more per year of welding rod that contains one or more MFHAP (calculated on a rolling 12 month basis), you must demonstrate that management practices or fume control measures are being implemented by performing visual inspections
3. If your welding operations are being performed with materials that do not contain any MFHAP or do not have the potential to emit MFHAP, then this standard does not apply to you.
If the standard applies to you, you must:
1. Operate all equipment, capture and control devices associated with welding operations according to manufacturer's instructions. You must demonstrate compliance with this requirement by maintaining a record of the manufacturer's specifications for the capture and control devices.
2. Implement one or more of the Welding Management Practices listed below to minimize emissions of MFHAP, as practicable, while maintaining the required weld quality through the application of sound engineering judgment.
a. Use welding processes with reduced fume generation capabilities (e.g., gas metal arc welding (GMAW) also called metal inert gas welding (MIG));
b. Use welding process variations (e.g., pulsed current GMAW), which can reduce fume generation rates;
c. Use welding filler metals, shielding gases, carrier gases, or other process materials which are capable of reduced welding fume generation;
d. Optimize welding process variables (e.g., electrode diameter, voltage, amperage, welding angle, shield gas flow rate, travel speed) to reduce the amount of welding fume generated; and
e. Use a welding fume capture system, operated according to manufacturer's specifications.
There is a three tier compliance requirement for welding:
1. Tier 1
a. In accordance with EPA Method 22, you must perform visual determinations of welding fugitive emissions at the primary vent, stack, exit, or opening from the building containing the welding operations. You must keep a record of all visual determinations of fugitive emissions along with any corrective action taken.
Requirement upon initial detection of visible emissions from welding.
b. Perform corrective actions that include, but are not limited to, inspection of welding fume sources and evaluation of the proper operation and effectiveness of the management practices or fume control measures implemented in accordance with your Welding Management Practices. After completing such corrective actions, you must perform a follow up inspection for visible fugitive emissions at the primary vent, stack, exit, or opening from the building containing the welding operations.
c. Report all instances where visible emissions are detected, along with any corrective actions taken and the results of subsequent follow up inspections for visible emissions, and submit with your annual certification and compliance report.
2. Tier 2
a. If visible fugitive emissions are detected more than once during any consecutive 12 month period (notwithstanding the results of any follow up inspections) you have met the requirements for tier 2.
Tier 2 requirements upon subsequent detection of visible emissions.
1. Within 24 hours of the end of the visual determination of fugitive emissions in which visible fugitive emissions were detected, you must conduct a visual determination of emissions opacity using EPA Method 9, at the primary vent, stack, exit, or opening from the building containing the welding operations.
2. In lieu of the requirement to perform visual determinations of fugitive emissions with EPA Method 22, you must perform visual determinations of emissions opacity using EPA Method 9, at the primary vent, stack, exit, or opening from the building containing the welding operations.
3. You must keep a record of each visual determination of emissions opacity performed along with any subsequent corrective action taken.
4. You must report the results of all visual determinations of emissions opacity performed along with any subsequent corrective action taken, and submit with your Annual Certification and Compliance Report.
Requirements for Opacities less than or equal to 20 percent but greater than zero.
1. For each visual determination of emissions opacity performed, for which the average of the average of the six minute average opacities recorded is 20 percent or less but greater than zero, you must perform corrective actions, including inspection of all weld fume sources, and evaluation of the proper operation and effectiveness of the management practices or fume control measures implemented in accordance with your Welding Management Practices.
3. Tier 3
a. For each visual determination of emissions opacity performed for which the average of the six minute average opacities recorded exceeds 20 percent, you must comply with the following requirements:
Requirements for Opacities exceeding 20 percent.
1. You must submit a report of exceedence of 20 percent opacity, along with your Annual Certification and Compliance Report.
2. Within 30 days of the opacity exceedance, you must prepare and implement a Site Specific Welding Emissions Management Plan. If you have already prepared a Site – Specific Welding Emissions Management Plan, then you must prepare and implement a new plan within 30 days.
3. During the preparation (or revision) of the Site Specific Welding Emissions Plan, you must continue to perform visual determinations of emissions opacity, beginning on a daily schedule using Method 9, at the primary vent, stack, exit, or opening from the building containing the welding operations.
4. You must maintain records of daily visual determinations of emissions opacity during preparation of the Site-‐Specific Welding Emissions Management Plan.
5. You must include these records in your Annual Certification and Compliance Report.
Site-‐Specific Welding Emissions Management Plan, must comply with the following requirements:
1. The Site Specific Welding Emissions Management Plan must contain the following information:
a. Company Name and address;
b. A list and description of all welding operations which currently comprise the welding affected source;
c. A description of all management practices and/or fume control methods in place at the time of the opacity exceedance;
d. A list and description of all management practices and/or fume control methods currently employed for the welding affected source;
e. A description of additional management practices and/or fume control methods to be implemented and the projected date of implementation; and
f. Any revisions to a Site Specific Welding Emissions Management Plan must contain copies of all previous plan entries.
2. The Site-‐Specific Welding Emissions Management Plan must be updated annually to contain current information, and submitted with your Annual Certification and Compliance Report.
3. You must maintain a copy of the Site-‐Specific Welding Emissions Management Plan in your records in a readily accessible location for inspector review.
Web Sites and Resources
www.epa.gov
http://www.epa.gov/ttn/atw/area/arearules.html
http://www.epa.gov/ttn/atw/area/regional_contacts.pdf
http://www.epa.gov/ttn/emc/methods/method22.html
http://www.epa.gov/ttn/emc/methods/method9.html
