Preparing For NESHAPS Regulations

In this era of expanding environmental awareness, it’s not surprising that the U.S. Environmental Protection Agency set in motion new regulations for controlling air emissions for metal fabrication and finishing. Officially announced in 2008, the EPA National Emissions Standard for Hazardous Air Pollutants (NESHAP) will impact the way many firms complete their work. Fabricators in the U.S. must be prepared to comply with these regulations which include a fast approaching series of important dates.

Characterizing a company or business as a source of hazardous air pollutants is actually the first step toward compliance.  It’s also generally considered an easy first step. scan the nine metal fabrication and finishing source categories defined by the EPA to determine if your manufacturing operations fall within the definition. The key differentiator to focus on is whether any of these categories are a primary production operation. 

DownFlex™ downdraft tables provide a
work surface and filtered fume extraction.

Modular Hoods encompass a personal workspace,
providing ventilation as well as arc screens.

The nine categories include:
(1) Electrical and Electronic Equipment Finishing Operations
(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
(7) Iron and Steel Forging
(8) Primary Metal Products Manufacturing
(9) Valves and Pipe Fittings

Even more specifically, there are five primary processes common to the nine categories that are considered likely to emit Metal Fabrication Hazardous Air Pollutants (MFHAP). These include:  dry abrasive blasting; dry grinding and dry polishing with machines; machining; spray painting; and welding.

What is considered a MFHAP? 
A metal fabrication potential pollutant is any compound of the following metals: cadmium, chromium, lead, manganese, or nickel, or any of these metals in the elemental form, with the exception of lead.

How do you determine if your activity meets the definition of primary production operation?
The EPA defines a primary activity as one where the manufacturing, fabrication or forging operations at a single facility are comprised of at least 50% of the production of that facility in one of these nine categories and five processes. If you and your industry define production in terms of volume, linear or square foot or other terms, you would use those terms to define the 50% threshold.  

Shop-wide central systems are popular for
vocational fabrication schools.

High vacuum systems, available with a range of nozzles and placement options, provide a very targeted level of fume control at the source.

Who will this regulation affect?
In many cases, large manufacturers are already regulated through an EPA regulation called MACT and are considered a major source of hazardous air pollutants. Metal fabrication hazardous air pollutants are a subset of these.  The EPA National Emissions Standard for Hazardous Air Pollutants (NESHAP) will affect many small to medium sized businesses.  This rule applies to those businesses the EPA defines as an area source, rather than a major source.  An area source is considered an operation that has the potential to emit less than 10 tons annually of a single hazardous air pollutant or less than 25 tons annually of a combination of multiple hazardous air pollutants.

Specifically, when it comes to welding operations, businesses will have requirements based on annual pounds used of any particular welding rod or wire.  If your business annually uses 2000 lbs or less, you will have welding management and record keeping requirements. If you annually use more than 2000 lbs of welding rod or wire, you will be required to perform certain emissions monitoring as well as the welding management and record keeping requirements.  

When can I expect this to affect my operations?
There are a number of dates that manufacturers need to know and keep in mind.  By July 25, 2011 an initial notification is required by existing sources. 

By November 22, 2011, the existing sources must submit a notification of compliance including proper operation and maintenance of equipment, a welding management plan, and visual determination of emissions at the primary stack or exit from the building with evidence of the testing results. 

The compliance guidelines for the EPA regulation include an EPA Method 9 and 22 testing methods which must be performed.  The test methods take time and reference repetitive testing which may need to be done daily, weekly, monthly or quarterly, depending on the facility and processes.  Additionally, EPA Method 9 requires training and certification, so it is not too early to get started to ensure you are prepared. 

Customized engineered solutions designed are
available for shop environments.

Low vacuum local source capture fume control systems can be configured as portable, wall mounted or overhead systems.

What will I have to do if this applies to me?
You will need to produce supporting documentation.  Regarding proper operation of equipment, you will be required to produce documentation that you are operating and maintaining the equipment to the manufacturer’s specification.

Regarding the welding management plan requirement, you will have to show that one or more welding practices have been implemented to minimize welding emissions of MFHAP while maintaining welding quality.  You can use one or more of several prescribed methods, including adopting alternative welding processes, selecting alternative filler metals or shielding gases, optimizing your procedures and / or adding fume control systems.

Seeking Help
Lincoln Electric, as a supplier of fume exhaust equipment, is working to ensure manufacturers are aware of the EPA MFHAP – NESHAPS rule.  As such, the firm cannot directly assist a fabricator with their compliance efforts regarding this regulation. However, Lincoln Electric can act as a reference to assist fabricators to gather the right materials, identifying potential solutions in a welding management plan and periodically conduct informal audits of welding fume solutions in place to suggest paths for improvement to allow the fabricator to adhere to these regulations. 

In some cases, a welding process change and the use of a weld fume control solution can be part of this plan.  In other cases or situations, welding procedural development may be required, in the form of recommendations for different welding electrodes, wire or shielding gases.   

Available fume guns capture fume at the
arc and return through the gun cable.