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New U.S. EPA Regulations to Impact Metal Fabrication and Finishing Operations


Mark Wenclawiak, CCM

On July 23, 2008, the United States Environmental Protection Agency (USEPA) issued a new regulation that regulates air emissions of hazardous air pollutants (HAPs) from nine metal fabrication and finishing source categories. This rule, promulgated as 40 Code of Federal Regulations (CFR) Part 63, Subpart XXXXXX (“6X”), is another in a series of regulations that addresses emissions of HAPs from “area sources.” Unlike many other subparts to 40 CFR Part 63 that regulate the entire list of HAPs, 6X specifically regulates only emissions of compounds of cadmium, chromium, lead, manganese, and nickel from nine specific source categories.

Area sources are often smaller businesses or those facilities that are considered “minor” or “non-major” sources in the world of air quality permitting. For reference, Section 112(a) of the Clean Air Act defines an area source as any stationary source of HAP that is not a major source. A major source is defined as any stationary source that emits, or has the potential to emit (considering air pollution controls) 10 tons per year (tpy) or more of any single HAP or 25 tpy or more of any combination of HAPs. Therefore, if a facility does not have emissions that meet the major source category, it is considered an area source and this article will provide a summary of 6X and its potential impacts on your operations.

In this challenging economic environment, complying with another USEPA regulation is the last thing that plant managers need. On the surface, it may appear that the USEPA is “picking on” smaller businesses. In fact, in the preamble to 6X, the USEPA estimates that 6X will impact approximately 5,800 area source facilities, with approximately 5,300 of these facilities considered small business entities. But USEPA stated that 6X is needed to meet its statutory requirements to achieve the 90% reduction requirement for emissions of cadmium, chromium, lead, manganese, and nickel contained in Section 112(c)(3) of the Clean Air Act. This indicates that the USEPA is not randomly “picking on” small businesses but is implementing 6X as one means to reduce the health risks associated with exposure to these metals.

The good news, however, is that additional air pollution control devices or systems (i.e., capital or operations and maintenance costs) are not expected to be required to comply with this rule. Furthermore, the USEPA indicates that many of the management practices required by 6X are based on pollution prevention and can provide cost savings for affected facilities. While each facility’s compliance path is unique, the USEPA indicates that the annual cost for monitoring, reporting, and recordkeeping for 6X is estimated at approximately $569 per year after the first year with an additional $384 for one-time costs in the first year. Based on experience, it is likely that USEPA is underestimating the financial impact to affected facilities. Preparing for this regulation now can help ease the economic impact and provide a sustainable means to maintain environmental compliance in this ever-increasing regulatory era.

For additional details on the requirements, please refer to the full regulation. In addition, the USEPA has developed guidance documents for 6X.

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