Thursday, June 16, 2011

Metal Fabrication And Finishing NESHAP Compliance Summary

New Federal air regulations for nine metal fabrication and finishing source categories (40 CFR Part 63 Subpart XXXXXX, or “6X”) will take effect soon. All metal fabrication and finishing operations subject to the rules will need to submit formal notifications and be in compliance by July 25, 2011.

The NESHAP 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.

The regulation contains requirements for five specific processes, listed below. The requirements only apply when a process uses materials that contain specified metal compounds. Low level use of these metals in the processes may be exempt.
• Dry Abrasive Blasting
• Dry Grinding and Dry Polishing with Machines
• Dry Machining
• Spray Painting
• Welding

The regulation requires periodic emissions monitoring for some operations. There also are reports that facilities must submit.
• Initial Notification – due by July 25, 2011
• Notification of Compliance Status report – due by November 22, 2011 and,
• Annual certification and compliance reports.

Caltha LLP provides specialized expertise to clients, including the Metal Fabrication Sector, nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.

For further information contact Caltha LLP at or Caltha LLP Website

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