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Nine Metal Fabrication and Finishing

SBEAP has added several tools to assist facilities covered by this rule. These include an Annual Certification and Compliance Report form due at the end of January (annually). SBEAP has provided a sample form for a report with visible emissions and a sample form report without visible emisssions. Also provided is a link to an updated EPA's Question and Answer and EPA's Painter Certification sample!

** Final Area Source Rule for Nine Metal Fabrication and Finishing**

EPA made effective an Area Source Rule on July 23, 2008, National Emission Standards Hazardous Air Pollutants (NESHAPs) for metal fabrication and finishing. The rule applies to operations that may produce air pollution compounds such as cadmium, chromium, lead, manganeses, and nickel from nine metal fabrication ad finishing sources. The covers ONLY sources where the primary activity of the facility is in one of the following nine source categories:

  • Electrical and Electronic Equipment Finishing Operations
  • Fabricated Metal Products
  • Fabricated Plate Work (Boiler Shops)
  • Fabricated Structural Metal Manufacturing
  • Heating Equipment, except electric
  • Industrial Machinary and Equipment Finishing Operations (Including construction machinery manufacturing; oil and gas field machinery manufacturing; and pumps and pumping equipment manufacturing)
  • Iron and Steel Forging
  • Primary Metal Products Manufacturing
  • Valves and Pipe fittings

Who must comply with this rule?

This rule applies to any facility with a primary operation in metal fabrication or metal finishing that is identified by an industry classification system. These are known as North America Industrial Classification (NAICS) or Standard Industrial Classification (SIC) code(s): To check if you are subject; you may refer to the rule or crosscheck your NAICS and SIC codes with codes that are subject to this rule and listed at EPA's web link: http://www.epa.gov/ttn/atw/area/met-fab-6x-applicability.xls.

All facilities that have the identified industry classification must review the rule and submit an initial notice by July 25, 2011. On the initial notice the facility owner should state whether or not the rule applies to their facility operation. If applicable, a Notice of Compliance (NOC) should be submitted to the Tennessee Air Pollution Control Office and the EPA by November 22, 2011. Sources located in a local air pollution control program area (Davidson, Hamilton, Knox, or Shelby counties) should contact the appropriate local air pollution control agency for instructions.

When must I comply with the Rule?

All affected facilities are required to be in compliance by July 25, 2011. New sources must be in compliance when they begin to operate and submit a NOC within 120 days of start-up. Owners and operators are required to provide notice to EPA and the State of Tennessee if applicable to primary operations such as (Dry Abrasive blasting, Dry Grinding and Dry Polishing with machines, Dry machining, Spray painting, and Welding).

Also, other requirements such as management practices, visible emissions (VE) monitoring, submitting annual reports to provide compliance status, test and certification to train staff, and record keeping may also apply.

For more information, see NINE Metal Fabrication and Finishing rule published at EPA's website and/or SBEAP assistance tools that include Annual Certification and Compliance Report with VE and without VE, Notice of Compliance (NOC), EPA's determination Flow Chart, Nine Metal Fact Sheet, brochure, List for locating Virtual Paint Training, sample Painter Certification and visible emissions tools Method 9 form, Field Manual,and Method 22a. Also provided for your summary review is a 9 Metal Fabrication and Finishing PowerPoint presentation.

Important Due Dates:

  • Annual Certification and Compliance Report End of January 2012 (annually)
  • Notice of Compliance for an Existing Source November 22, 2011
  • Initial Notice for an Existing Source July 25, 2011
  • Facility Compliance for an Existing Source July 25, 2011
  • Initial Notice for a New Source At Start-up or by November 20, 2008
  • Facility Compliance &NOC for a New Source At Start-up or by November 20, 2008

For more information about Tennessee's Small Business Environmental Assistance Program, please contact the program at 1-800-734-3619 or by email at bgsbeap@tn.gov.