Linn County Air Quality Division
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Metal Fabrication and Finishing



40 CFR Part 63, Subpart XXXXXX (NESHAP 6X)

FINAL RULE (PDF File)
NESHAP 6X Fact Sheets - All Processes (DOC File | PDF File)
General Requirements (DOC File)
Dry Abrasive Blasting (DOC File)
Dry Grinding and Polishing (DOC File)
Machining (DOC File)
Spray Painting (DOC File)
Welding (DOC File)
Presentation (PPT File)
Online Tutorial and other 6X compliance assistance materials (Iowa Waste Reduction Center)

Initial Notification Form - July 25, 2011 Deadline (PDF File)
Notification of Compliance Status Form - November 22, 2011 Deadline (PDF File)
Annual Compliance Report - due January 31st each year for the previous calendar year (PDF File)

Brief Summary
New EPA Regulations for
Nine Metal Fabrication and Finishing Source Categories
40 CFR Part 63 Subpart XXXXXX

EPA has new requirements to reduce air pollution of compounds of metals such as cadmium, chromium, lead, manganese and nickel from nine metal fabrication and finishing source categories. These compounds pose health risks to anyone who breathes the air when these fumes are present. These compounds are emitted to the air from various operations at metal fabrication and finishing plants.

This is a short summary of what any affected facility in the nine metal fabrication and finishing source categories must do to comply with the new rule. Existing sources must have been in compliance with the regulation by July 25, 2011. New sources must be in compliance when they begin to operate.

For more details and assistance, please talk to your local environmental contactc. The following government contacts are a good place to start:

The rule applies ONLY to area sources where the primary activity of the facility is in one of the following nine source categories:

  1. Electrical and Electrical Equipment Finishing Operations (including motor and generator manufacture; and electrical machinery, equipment, and supplies not elsewhere classified);
  2. Fabricated Metal Products;
  3. Fabricated Plate Work (boiler shops);
  4. Fabricated Structural Metal Manufacturing;
  5. Heating Equipment (except electric);
  6. Industrial Machinery and Equipment Finishing Operations (including construction machinery manufacturing; oil and gas field machinery manufacturing; and pumps and pumping equipment manufacturing);
  7. Iron and Steel Forging;
  8. Primary Metal Products Manufacturing; and
  9. Valves and Pipe Fittings

Many facilities perform the metal fabrication and finishing processes addressed by this rule, but are not subject to NESHAP 6X unless they are "primarily engaged" in operations classified in one of the listed nine source categories. To check if you are subject, cross-check your SIC/NAICS codes witht he SIC/NAICS codes subject to this rule and listed here: http://www.epa.gov/ttn/atw/area/met-fab-6x-applicability.xls. A more detailed description of the affected source categories is included in the body of the rule, which is available at: http://www.epa.gov/ttn/atw/area/arearules.html.

The regulation contains requirements for five specific processes, described below. Any of these processes at a facility in one of the nine source categories listed above are subject to the requirements of NESHAP 6X only when a processes uses materials containing compounds of cadmium (Cd), chromium (Cr), lead (Pb), manganese (Mn), and nickel (Ni). Low level use of these metals may be exempt.

  • Dry Abrasive Blasting: Most dry abrasive blasting operations must be enclosed and utilize a filtration control device. Large objects (> 8 feet) may be blasted without control devices. Small "glove box" operations have lesser requirements.
  • Dry Grinding and Dry Polishing with Machines: Emissions must be captured and vented to a filtration control device, and dust in the surrounding areas must be minimized, as practicable.
  • Dry Machining: Dust in the surrounding areas must be minimized as practicable.
  • Spray Painting: Spray paint must be applied with High Volume Low Pressure (HVLP) spray guns (or equivalent), workers must be properly trained, and spray guns must be cleaned properly. Most spray painting of objects ≤ 15 feet must be performed in a booth with filters to capture metal particulates. Note: Spray painting operations painting objects > 15 feet, or spray painting any objects in the Fabricated Structural Metal source category are not required to comply witht he paint booth and filter requirement.
  • Welding: Welding operations must implement one or more for the following management practices to minimize emissions, as practicable, and in accordance with sound welding engineering principles while maintaining weld quality: (i) Use welding processes with reduced fume generation capabilities; (ii) Use welding process variations which can reduce fume generation rates; (iii) Use welding filler metals, shielding gases, carrier gases, or other process materials capable of reduced welding fume generation; (iv) Optimize welding process variables to reduce the amount of welding fumes generated; and (v) Use a welding fume capture and control system.

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., > 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 teh 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 will result in the requirement to prepare and implement a site-specific welding emissions management plan.

For Method 9, see: https://www.epa.gov/emc/method-9-visual-opacity
For Method 22, see: https://www.epa.gov/emc/method-22-visual-determination-fugitive-emissions

There are also reports that facilities must submit.

  • Initial Notification - must have been 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 regardless of whether any process at the facility is subject to the standards and management practices.
  • Notification of Compliance Status Report - must have been submitted by November 22, 2011 for existing sources and 120 days after initial startup for new sources.
  • Annual Certification of Compliance Reports - must be submitted by January 31st each year for the previous calendar year
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