Compliance Assistance Offered for Businesses Engaged in Metal Fabrication and Finishing
Posted: 05/26/2011

To help businesses understand new requirements to reduce air emissions from metal fabrication and finishing operations, the Iowa DNR Air Quality Bureau and the Iowa Air Emissions Assistance Program (IAEAP) at the University of Northern Iowa have developed important compliance assistance tools. These tools will help facilities determine if they are subject to the rules and how to comply with the requirements.

The federal air standard (established in 2008) regulates the emissions of Hazardous Air Pollutants (HAP), including cadmium, chromium, lead, manganese and nickel from certain manufacturing operations (e.g. shot blasting and welding), from facilities that fabricate and/or finish metal products. This rule is referred to as the "Nine Metal Fabrication and Finishing" regulation (40 CFR Part 63, Subpart XXXXXX) or "6X."

The 6X rule applies only to area sources of HAP where the primary activity of the facility is in one of the nine listed metal fabrication/finishing source categories.* The rule contains requirements for five specific processes: dry abrasive blasting, machining, dry grinding and dry polishing with machines, spray painting and welding. The 6X requirements apply only when a process uses materials that contain compounds of cadmium, chromium, lead, manganese, and nickel.

To help owners and operators determine whether a facility is subject to 6X, Iowa DNR and IAEAP created an online tutorial. To access this tutorial and other information about the 6X rule, go to 6X NESHAP Tools (IAEAP webpage). Detailed summaries of the rule’s requirements can also be found at Iowa DNR NESHAP Tools. A full copy of the rule can be found at EPA NESHAP webpage.

Existing facilities that are subject to 6X will need to comply with these new standards by July 25, 2011. Additionally, 6X subject facilities must also submit an "Initial Notification" by no later than July 25, 2011, and a "Notification of Compliance Status" by November 22, 2011. Notification forms are available at Iowa DNR NESHAP Tools.

For questions about 6X applicability, please call the Iowa DNR’s toll free air quality help line at 1-877-AIR-IOWA (1-877-247-4692). Small businesses (those with 100 or fewer Iowa employees) can also obtain free, confidential regulatory assistance from the IAEAP. You may also contact IAEAP by phone toll free at 1-800-422-3109.

* 6X applies to facilities that are primarily engaged in the fabrication of certain metal products. Facilities that have one of the following SIC codes as their primary code may be subject to the requirements of this rule:

  • 3699 – Electrical Machinery, Equipment, and Supplies, Not Elsewhere Classified
  • 3621 - Motors and Generators Manufacturing
  • 3499 - Fabricated Metal Products, Not Elsewhere Classified
  • 3443 - Fabricated Plate Work (Boiler Shops)
  • 3441 - Fabricated Structural Metal Products
  • 3433 - Heating Equipment, except Electrical and Warm Air Furnaces
  • 3531 - Construction Machinery and Equipment
  • 3533 - Oil and Gas Field Machinery and Equipment
  • 3561 - Pumps and Pumping Equipment
  • 3462 - Iron and Steel Forgings
  • 3399 - Primary Metals Products, Not Elsewhere Classified
  • 3494 - Valves and Pipe Fittings, Not Elsewhere Classified

According to EPA guidelines, applicability is based on the facility’s primary SIC (Standard Industrial Classification) code and its primary NAICS (North American Industrial Classification System) code.