**Brief Summary**

**New EPA Regulations for**

**Nine Metal Fabrication and Finishing Source Categories**

**[40 CFR Part63 Subpart XXXXXX]{.underline}**

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 things any affected facility in the nine
metal fabrication and finishing source categories must do to comply with
the new rule. Existing sources must be in compliance with the regulation
before **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
contact. These web links to government contacts are a good place to
start:

-   <http://www.epa.gov/ttn/atw/area/regional_contacts.pdf>

-   <http://www.smallbiz-enviroweb.org/sba/seasbapweb.html>

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 Electronic 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 Subpart XXXXXX unless
they are \"primarily engaged\" in operations which are classified in one
of the listed nine source categories.** To check if you are subject,
crosscheck your SIC/NAICS codes with the SIC/NAICS codes that are
subject to this rule and listed at this web link:
[http://www.epa.gov/ttn/atw/area/met-fab-6x-applicability.xls]{.underline}.
A more detailed description of the affected source categories is
included in the text of the rule, 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 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.

-   **Dry Abrasive Blasting**: Most dry abrasive blasting operations
    must be enclosed, with 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 [\<]{.underline} 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 with the paint booth and filter requirement.

-   **Welding**: Welding operations must implement one or more of 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 which are capable of reduced welding fume generation; (iv)
    Optimize welding process variables to reduce the amount of welding
    fume 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., 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>

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.