September 23, 2002

EWI Project No. 43149GTH

Environmental Management Applicable

to Welding, Cutting, and Gouging
Processes in the Shipbuilding and
Repair Industry

Revision 1

NSRP ASE Project − Reduction of Worker Exposure and

Environmental Release of Welding Emissions

Technology Investment Agreement No. 2000922

Submitted to:

NSRP ASE Program

Advanced Technology Institute
North Charleston, SC

CATEGORY B DATA – GOVERNMENT PURPOSE RIGHTS

Approved for Public Release; Distribution is Unlimited.

 Report

Project No. 43149GTH

Revision 1

on

Environmental Management Applicable to Welding, Cutting, and Gouging

Processes in the Shipbuilding and Repair Industry

to

NSRP ASE Program

Advanced Technology Institute
North Charleston, SC

September 23, 2002

Bhaskar Kura, Ph.D.

KURA ENVIRONMENTAL CONSULTANT
4713 Chateau Drive
Metairie, Louisiana 70002
 Acknowledgement

This report was prepared as an account of work on the NSRP ASE Project for Reduction of
Worker Exposure and Environmental Release of Welding Emissions. The NSRP ASE Program
provided funding for this work under Technology Investment Agreement No. 20000922.

Legal Notice

The United States Government, Department of Defense, NSRP ASE Program, nor Edison
Welding Institute, nor its subcontractors, nor any of their employees, makes any warranty,
express or implied, or assumes any legal liability or responsibility for the accuracy,
completeness, or usefulness of any information, apparatus, product, or processes disclosed in
this report, or represents that its use would not infringe privately-owned rights. Reference
herein to any specific commercial product, process, or service by trade name, trademark,
manufacturer, or otherwise, does not necessarily constitute or imply its endorsement,
recommendation, or favoring by the United States Government or any agency thereof. The
views and opinions of authors expressed herein do not necessarily state or reflect those of the
United States Government or any agency thereof.

Distribution

Government Purpose Rights.

Equipment Disclaimer

No endorsement or recommendation is made for a particular equipment vendor by the Project

Team. Equipment used and evaluated during the project, and mentioned in the report, was
evaluated on a technical basis only.

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 Contents

Page

Acknowledgement ............................................................................................................................... i
Legal Notice......................................................................................................................................... i
Distribution........................................................................................................................................... i
Equipment Disclaimer .......................................................................................................................... i
1.0 Introduction ................................................................................................................................. 1
2.0 Environmental Regulations ......................................................................................................... 2
2.1 Resource Conservation and Recovery Act (RCRA)................................................................. 2
2.2 Superfund Amendments and Reauthorization Act (SARA)...................................................... 2
2.3 Clean Air Act (CAA) ................................................................................................................. 3
2.4 Clean Water Act (CWA) ........................................................................................................... 4
3.0 Emission Characterization and Quantification ............................................................................ 4
3.1 Solid Wastes Generated in Welding, Thermal Cutting and Gouging Operations..................... 4
3.2 Liquid Wastes Generated by Welding, Thermal Cutting and Gouging Operations .................. 5
3.3 Air Emissions from Welding, Thermal Cutting and Gouging Operations ................................. 6
4.0 Estimating Waste Quantities and Characteristics ....................................................................... 6
4.1 Solid Waste .............................................................................................................................. 6
4.2 Air Emissions ........................................................................................................................... 6
4.2.1 Emission Factors........................................................................................................... 8
4.2.2 Sampling and Analysis for Fume Characterization and Quantification ....................... 10
5.0 Compliance with Environmental Regulations............................................................................. 12
5.1 Resource Conservation and Recovery Act (RCRA)............................................................... 12
5.2 Clean Air Act (CAA) ............................................................................................................... 12
5.2.1 Atmospheric Dispersion Modeling............................................................................... 13
5.3 Clean Water Act (CWA) ......................................................................................................... 14
5.3.1 NPDES Permit Conditions........................................................................................... 14
5.3.2 Effluent Limitations ...................................................................................................... 15
5.3.3 Storm Water Permits ................................................................................................... 15
5.3.4 Best Management Plan (BMP) Identification and Selection........................................ 16
6.0 Record Keeping and Reporting Requirements ......................................................................... 16
6.1 Record Keeping Requirements Under Environmental Laws.................................................. 16
6.2 Environmental Reporting........................................................................................................ 16
6.2.1 Air Emissions Inventory Reports ................................................................................. 17
6.2.2 Hazardous Waste Reports .......................................................................................... 17
6.2.3 Toxics Release Inventory (TRI) Reports ..................................................................... 18
6.2.4 Discharge Monitoring Reports (DMRs) ....................................................................... 18
6.2.5 Tier II Reports.............................................................................................................. 19
7.0 Conclusions .............................................................................................................................. 19
8.0 References ............................................................................................................................... 20
9.0 Bibliography .............................................................................................................................. 21

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 Contents (continued)

Page

Tables

Table 1. Selected Metals to be Reported under SARA................................................................... 22

Table 2. National Ambient Air Quality (NAAQS) Standards ............................................................ 23
Table 3. Cutting Emission Rates..................................................................................................... 24

Appendix

Appendix A. Compilation of Air Pollutant Emission Factors, AP-42, Fifth Edition, Volume 1:
Stationary Point and Area Sources, Chapter 12, Section 12.19, January 1995, U.S.
Environmental Protection Agency, Research Triangle Park, NC

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 1.0 Introduction

The purpose of this report is to provide an overview of the environmental management

requirements that apply to shipyard welding, cutting, and gouging operations. It is important to
recognize that this report discusses the compliance with the environmental guidelines specified
by the U.S. Environmental Protection Agency (EPA) and the state agencies that aim to protect
public health and the environment and does not include U.S. Department of Labor Occupational
Safety & Health Administration (OSHA) requirements that aim to protect the worker health and
the occupational environment. Another way to express the difference is that the facility fence
line separates EPA and OSHA requirements. The EPA regulates effects of emissions outside
the fence line and the OSHA regulates effects of emissions within the fence line. Waste
streams expected from welding, cutting, and gouging operations mainly include, solid wastes,
air emissions, and limited quantities of wastewater.

The Clean Air Act (CAA), the Clean Water Act (CWA), and the Resource Conservation and
Recovery Act (RCRA) are the most important Federal environmental regulations applicable to
welding, cutting, and gouging in a shipyard setting. These Federal environmental legislations
control three primary waste streams, air pollutant emissions under CAA, wastewater discharges
under CWA, and solid/hazardous wastes under RCRA.

Truly speaking, shipyard environmental management of welding, cutting, and gouging

operations cannot be separated out because shipyard operations involve other processes as
well. Major shipyard processes include, surface preparation, painting and coating, welding,
cutting and gouging, vessel cleaning, degreasing, fiberglass manufacturing, and outfitting.
Shipyard environmental permits address all processes together in one permit for each type of
pollutant emitted from all shipyard processes. Each shipyard typically has an air permit, a
wastewater permit to process wastewater and storm water, and a hazardous waste generator
permit.

Environmental management involves several steps and typically, facilities are required to
develop and implement an environmental management plan. Environmental management is a
case specific exercise because, (1) state and local regulations differ, (2) each facility has its own
process and product requirements, (3) each facility may have its own work practices,
management guidelines, and philosophies, and other variables that influence environmental
management practices. Keeping this in view, only generic shipyard environmental management
guidelines applicable to welding, cutting, and gouging are discussed in this report.

Environmental management involves several steps and the most important ones are listed
below:

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1) Understanding processes, process variables (materials, material quality, products, product
quality, process types, process equipment types used), and their impact on waste
quantities and characteristics.

2) Emission quantification and characterization for the existing process conditions.

3) Applicable environmental regulations.

4) Environmental permits and compliance requirements.

5) Waste minimization, pollution prevention, and risk reduction.

6) Environmental performance measurement, benchmarking, feedback and improvements.

7) Optimization of environmental management costs.

This report briefly describes important components of the environmental management plan
related to welding, thermal cutting, and gouging.

2.0 Environmental Regulations

The following paragraphs summarize a number of the most important Federal environmental
regulations that cover wastes generated in industrial operations, including shipyards. The focus
is on regulations that may apply to the solid and liquid wastes, and airborne emissions
generated by welding, thermal cutting, and gouging operations.

2.1 Resource Conservation and Recovery Act (RCRA)

The Resource Conservation and Recovery Act (RCRA) of 1976 (40 CFR Parts 260-299) deals
with the management of solid and hazardous wastes from the point of generation to disposal.
Hazardous wastes include specific chemicals and materials that are ignitable, corrosive,
reactive, or toxic. The RCRA applies to companies that generate, transport, treat, store, or
dispose of hazardous waste and requires that they get a permit from the EPA or a state agency,
authorized by the EPA.

2.2 Superfund Amendments and Reauthorization Act (SARA)

In 1980, congress passed The Comprehensive Environmental Response, Compensation, and

Liability Act (CERCLA), also known as Superfund. This act directed the EPA to deal with the
release of hazardous substances that could be a risk to the environment and/or public health. A

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second act, the 1986 Superfund Amendments and Reauthorization Act (SARA) expanded the
scope and established SARA Title III, as the Emergency Planning and Community Right-to-
Know Act (EPCRA). This legislation provides the public and local governments with information
on potential chemical hazards in their communities. The Act requires facilities to provide
emergency hazardous chemical release information, chemical inventories and toxic release
reports. This information is provided to state emergency response commissions and local
emergency planning committees for use in planning chemical emergency preparation and
community awareness.

Section 313 of SARA lists the hazardous and toxic materials that must be reported. Table 1
lists some of the metals involved in welding, thermal cutting, and gouging operations that are
reportable under SARA Section 313. Hazardous elements do not need to be reported if they
make up less than the de minimus limit (minimum reportable) percentage of a material.
Hazardous material reporting is further discussed in Section 5 of this report.

2.3 Clean Air Act (CAA)

Title III of the 1990 Clean Air Act Amendments (CAAA) sets emission standards for 189
hazardous air pollutants (HAP). Facilities are generally categorized as major sources or minor
sources based on HAP emissions. Title V of the act established National Ambient Air Quality
Standards known as “NAAQS” for six criteria air pollutants. These pollutants are particulate
matter (PM10 and PM2.5), sulfur dioxide (SO2), nitrogen dioxide (NO2), carbon monoxide (CO),
ozone (O3) and particulate lead. These NAAQS are listed in Table 2.

Particulate matter is defined as follows:

• TPM – Total Particulate Matter

• PM10 – Particulate Matter less than 10 micron in size, also known as coarse particulate
matter

• PM2.5 – Particulate matter less than 2.5 micron in size, also known as the fine particulate
matter

Hazardous air pollutants (HAPs) do not have national ambient air quality standards, though
some states have target ambient standards. The goal is to eliminate HAPs from the
environment to the maximum extent possible without designating specific target levels. The
EPA uses techniques such as the MACT (Maximum Achievable Control Technology) to restrict
emissions of HAPs from industrial processes. The EPA requires the facilities to use the
maximum achievable control technologies to capture and collect pollutants before they are

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released from the industrial operation. The metals listed in Table 1 are considered to be HAPs
and have to be controlled.

2.4 Clean Water Act (CWA)

The Clean Water Act (CWA) is directed at maintaining clean surface waters in the U. S. The act
covers both direct and indirect discharge of water, including storm water, from facilities. Each
facility must obtain a permit covering their discharge. The EPA and individual states have water
quality standards that must be met. The Act’s stated objective is to “restore and maintain the
chemical, physical, and biological integrity of the nation’s waters”. To achieve this objective, the
Act establishes the following goals.

1) Elimination of discharge of pollutants into surface waters.

2) Achievement of level of water quality, which provides for the protection and propagation of
fish, shellfish, and wildlife, and for recreation in and on the water.

3) Establishment of a national policy that the discharge of toxic pollutants in toxic amounts
shall be prohibited.

3.0 Emission Characterization and Quantification

The EPA Office of Compliance report "Profile of the Shipbuilding and Repair Industry"(1) does
not list welding, thermal cutting, and gouging operations as primary sources of waste or
pollution. However, these processes do produce waste streams that include wastewater, solid
wastes, and air emissions. The following paragraphs describe the most common of these
wastes and emissions.

3.1 Solid Wastes Generated in Welding, Thermal Cutting and Gouging Operations {tc
"I-3.7.2 Solid Wastes " \l 2}

Solid wastes generated by welding, thermal cutting, and gouging operations include scrap
welding electrodes, rods, and wires; flux, slag, spatter, and dross; and other solid wastes.
These wastes are described as follows:

• Scrap welding electrodes – This category includes the stub ends of SMAW electrodes,
scrap from damaged electrodes; the ends of spools or coils of solid and flux cored

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 electrodes for GMAW, SAW, and FCAW; and damaged rods or the ends of solid GTAW
electrode or rods. Waste for SMAW electrodes may vary from 15% to 30% of the total
amount of purchased electrodes, although this figure is highly variable. As 15%-20% of
the welding electrodes become solid waste and are not used in the process, this amount
should be deducted from the total quantity of electrodes consumed in calculating the air
emissions. Scrap from solid or flux cored electrodes is on the order of 2%-6%. The
composition of these wastes is the same as the purchased electrodes.

• Flux – Scrap flux is often the result of spillage and the composition is the same as the
original material. There is a small amount of dust produced during flux handling.

• Slag , Spatter, and Dross – Slag is the residue from flux reactions produced during
SMAW, FCAW, and SAW welding operations and is primarily composed of metal and
non-metal oxides from the electrodes used for welding. Spatter is the oxidized metal
particles expelled during welding. The composition of spatter is similar to the welding
electrode. Dross is the oxidized metal expelled during thermal cutting and gouging
operations and its composition is similar to the material being cut or gouged.

• Other solid waste – Other sources of solid waste may include the dust or fume collected
in filters of ventilation systems and air pollution control devices. There may be solid
waste (suspended and dissolved solids, metals, and other contaminants) recovered from
the treatment of wastewater or storm water if the facility treats these liquid wastes (refer
to the following section).

Disposal of solid wastes is typically accomplished by sending the waste to a metal scrap
recycling facility, landfill, or waste disposal company.

3.2 Liquid Wastes Generated by Welding, Thermal Cutting and Gouging Operations

{tc "I-3.7.2 Solid Wastes " \l 2}

Welding, cutting, and gouging operations do not generate significant amounts of wastewater.
Water from water-tables used during oxy-fuel gas (flame) cutting or plasma arc cutting
operations has the potential to contain dissolved solids as well as solid metal and organic
particles. If these water tables are cleaned and disposal of this water is required, the shipyard
would be required to treat this wastewater for solids and metals before discharging into various
water bodies. An alternative would be to dispose of it using an approved disposal company.

It also is possible that the fugitive air emissions generated during welding, cutting, and gouging
operations may deposit on roof tops, on soil, and on pavements which may make their way into
storm water during rain events. In order to prevent metals in storm water, a best management
practices (BMP) plan has to be developed and implemented as part of the Storm Water Permit.

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3.3 Air Emissions from Welding, Thermal Cutting and Gouging Operations {tc "I-3.7.2
Solid Wastes " \l 2}

Air emissions are perhaps the most important waste stream resulting from welding, thermal
cutting, and gouging operations. Welding, thermal cutting, and gouging processes generate
particulate matter, metals, and limited amounts of other criteria pollutants such as ozone, oxides
of nitrogen, and carbon monoxide. Lead is involved in some operations, although limited. Air
pollutants emitted include those listed in Table 1 and Table 2 as well as others listed in the
specific legislation.

4.0 Estimating Waste Quantities and Characteristics

4.1 Solid Waste

Solid wastes from welding, thermal cutting, and gouging are discussed in the preceding section
of this report. These wastes include scrap welding electrodes, rods, and wires; flux, slag,
spatter, and dross; and other solid wastes. The composition of these wastes and the potential
hazardous materials they may contain can be estimated from the Material Safety Data Sheets
(MSDS) for the base metals being cut or gouged or for the welding electrodes used. Some
guidance on the amounts of some of these wastes that may be generated for certain operations
is contained in the preceding section.

4.2 Air Emissions

Published literature indicates that different welding and cutting processes have different
emission potentials for total fume and for hazardous air pollutants such as chromium (Cr),
manganese (Mn), nickel (Ni), and others. Both the quantity and characteristics of air emissions
can change from one welding process to another. Similarly, the quantity and characteristics of
air emission vary with each thermal cutting or gouging method. The composition of base metals
and welding electrodes as well as operating variables of each process can influence welding
emissions. Some of the most important factors that influence the quantity and characteristics of
air emissions are listed below:

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Factors Affecting Air Emissions from Welding Processes

− The welding process itself (GTAW, GMAW, SMAW, FCAW, SAW, and others)
− Base metal type and composition (consult MSDS)
− Electrode or filler rod type, composition, and manufacturer (consult MSDS)
− Welding amperage and wire feed speed
− Welding voltage
− Contact tip to work distance (GMAW and FCAW)
− Shielding gas type and flow rate (where applicable)
− Welding power source (for pulsed current GMAW)
− Base metal surface contamination and coatings (paint, zinc, etc.)

Factors Affecting Air Emissions from Cutting and Gouging Processes

− The cutting or gouging process (OAC, PAC, Laser, CAC-A, etc.)

− Base metal type, composition, and thickness (consult MSDS)
− Voltage and amperage for PAC
− Gas type, flow, or pressure
− Cutting tip size for oxyfuel cutting
− Equipment type and adjustments
− Cutting speed
− Base metal surface contamination and coating (paint, zinc, etc.)

There are a number of references that provide guidelines for estimating emissions from welding
and cutting processes, including the American Welding Society document “AWS F1.6, Guide for
Estimating Welding Emissions for EPA and Ventilation Permit Reporting”.(2) This document
suggests methods that can be used to estimate emissions from welding processes. The basic
method estimates emissions based on the quantity of welding electrodes used by the facility
and the emission factor for each process or electrode.

Emission factors can be determined by one of four methods, depending on the precision
needed for the estimate and the data available. These four methods are:

1) Estimation using emission factors based on the welding process.

2) Estimation based on emission factors for the specific classification of electrode.
3) Estimation based on more procedure specific emission factor data.
4) Estimation using on-site testing to measure emissions.

AWS F1.6 provides guideline emission factors for several welding processes that can be used
for method 1. Since about 90% of welding emissions result from the electrode material, an
estimate of emissions can be made by knowing the percentage composition of the constituents

7 43149-GTH − 9/02
in the electrode. This information is available in the MSDS provided by the manufacturer. If
more precise estimates are required, procedure specific emission factors can be determined or
on-site testing can be done. The following sections of this report discuss available emission
factor data and sampling and analysis methods that can be used for on-site testing of
emissions.

The study by NASSCO and Jacobs Environmental Engineering Services(3) has reported
usefulness of the following equation to estimate a facility’s annual metal emission:

Release of metal, E = W × PC × EF × CF

where: W = Total weight of welding electrode, pounds per year (lb/yr)

PC = Percentage composition of a specific metal, %
EF = Fume emission factor, pounds per ton (lb/ton) of electrode used
CF = Conversion factor = (1/2,000) ton/lb
E = Specific metal emitted, lb/year

4.2.1 Emission Factors

An emission factor is defined as the mass of a particular pollutant emitted per unit amount of
work done, product produced, or raw material consumed. In the case of welding, emission
factors for total particulate matter or for individual constituents can be expressed as a
percentage of the electrode converted to fume, or as a weight of the electrode converted to
fume per total weight of electrode consumed. Therefore emission factors may be expressed as:
“% of particulate per pound of electrode”, “mg of particulates per pound (lb) of electrode
consumed,” similarly for Cr, “mg of Cr per pound of electrode consumed.” Sometimes, it may
be expressed as “pound of pollutant per pound of electrode consumed”, or other units may be
used. Emission factors for cutting and gouging can be, “mg of pollutant per pound of material
cut or removed,” or other suitable units may be used.

Emission factors are useful in emission quantification and reporting to local, state, and federal
regulations. This is an important activity and an obligation under the facility air permit. The EPA
maintains emission factors data in a document known as “Compilation of Air Pollutant Emission
Factors AP-42”(4) which is available at no cost through EPA’s web site www.epa.gov. Section
12.19 of AP-42 contains information on emission factors for specific pollutants for selected arc
welding processes. The emission factors are given depending on the process and type of
electrode used. Appendix A includes a copy of Section 12.19 of this document. Thus, when
available, the emission factors can be used to estimate the amount of air emissions from the
welding processes.

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The EPA continues to collect the data as more and more research data becomes available.
Although information is available, there are several emission scenarios for which emission
factors have not been evaluated. The California Air Resources Board (CARB) has some
emission factors data, which is used by California facilities in their reporting. The National
Shipbuilding Research Program (NSRP)(3), Maritime Environmental Resources and Information
Center (MERIC), and Naval Surface Warfare Center, Carderock Division (NSWCCD)(5,6) have
evaluated emission factors recently for various welding and cutting operations.

A report by Z. F. Jacobs and NASSCO (1995)(3) lists emission factors available from research
done by NASSCO in collaboration with Dr. Richard L. Bell of Adams, Duque, and Hazeltine (AD
and H).(3) This report indicates that welding processes can be categorized into two broad
groups based on emissions of welding fumes. They are GMAW and SMAW (though this
categorization is too simplistic, it is presented here for shipyards to be aware of this source of
information). The GMAW category includes variations such as FCAW and GTAW. On the other
hand, the SMAW category includes the welding processes characterized by welding electrodes
covered by a solid flux that is vaporized in the arc to provide shielding from oxidization. The
following parameters are required to quantify emission of a certain metal:

1) Quantity of welding electrodes used

2) Process type (GMAW or SMAW)
3) Speciation of welding electrode (i.e., % chrome, etc.)

Other suitable parameters may be used to calculate the emission factors. For example, in the
case of Cr(VI), the following parameters may be used.

1) Fraction of Cr (% Cr in rod) in the electrode

2) Fraction of the electrode turned into fume (FFR) (% electrode to fume)
3) Cr content in the fume (% Cr in fume)
4) Hexavalent Cr in the fume (% Cr+6 in fume)

The emission factor may then be calculated as follows:

EF = FGR (lb fume/lb electrode as %) x

Fume Composition (lb Cr / lb fume as %) x
Hexavalent portion of Cr emission (Cr+6/Cr in fume as %)

Examples of how emission factors can be calculated were given in the report.(3)

Cutting emission factors are also available from NSWCCD/MERIC research though the data
available is on a limited number of samples. The NSWCCD study identifies a wide range of

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pollutant emissions reported in the literature. Table 3 lists the emission rates observed for
cutting processes.(5,6)

4.2.2 Sampling and Analysis for Fume Characterization and Quantification

Methods suggested by the EPA, OSHA, NOISH, or other standard methods can be used for
fume characterization. As long as the methods used are scientifically justifiable, the regulatory
agencies will accept the results.

Shipyards have to demonstrate compliance with the EPA and state environmental regulatory
departments, which is often calculating a facility’s total atmospheric emissions of permitted air
pollutants. This quantification is typically done using the published emission factor information.
However, emission factors have not been established for all pollutants emitted by a shipyard. In
the absence of emission factors, it becomes the shipyard’s responsibility to demonstrate
calculations based on sound scientific and engineering methods. In certain situations, the EPA
and state agencies may ask a facility to establish these emission factors through actual field
measurements.

Estimating pollutant emission quantities is complex in the case of fugitive emissions (fugitive
emissions are defined as the emissions escaping loosely from the process site, often without
the aid of a fan or duct; emissions other than stack or duct emissions). If emission factors (e.g.,
in welding, an emission factor may be defined as the mass of a particular pollutant emitted per
unit amount of electrode consumed) are known through source test methods, the same results
can be used in estimating emissions from fugitive emissions.

The EPA has source test methods for measuring a variety of parameters required as part of
determining mass pollutant emission rates. A number of source test methods applicable to
shipyards in determining particulate emission rates from stacks or ducts are listed below.
Copies of these methods are available from the EPA(7).

Method 1: Sample and Velocity Traverses for Stationary Sources

Method 1A: Sample and Velocity Traverses for Stationary Sources with Small
Stacks or Ducts
Method 2: Determination of Stack Gas Velocity and Volumetric Flow Rate (Type S Pitot
Tube)
Method 2A: Direct Measurement of Gas Volume through Pipes and Small Ducts
Method 2C: Determination of Gas Velocity and Volumetric Flow Rate in Small Stacks or
Ducts (Standard Pitot Tube)

10 43149-GTH − 9/02
Method 2D: Measurement of Gas Volume Flow Rates in Small Pipes and Ducts
Method 3: Gas Analysis for the Determination of Dry Molecular Weight
Method 4: Determination of Moisture Content in Stack Gases
Method 5: Determination of Particulate Matter Emissions from Stationary Sources

For example, the EPA has a source test method for estimating total particulates or total fume
using Method 5. If shipyards have information on fume composition from other sources such as
OSHA and/or a shipyard’s own data that was generated as a result of its compliance with
OSHA, the fume composition information can be used in calculating total emissions of metals
such as Cr, Mn, Ni, and others. The primary focus of the EPA is on facility atmospheric
emissions and public health, whereas OSHA’s focus is worker exposure and worker health. It is
important to know that overlap exists between the data sets gathered for EPA and OSHA
compliance. The following few paragraphs present OSHA recommended methods for
evaluating total fume and it’s composition.

The sampling of airborne fumes resulting from various welding processes using various base
and filler metals may be done using calibrated personal sampling pumps. Different sampling
rates are recommended for the collection of different types of samples, which could be collected
on filters made of different materials. For example, OSHA recommends that hexavalent
chromium (Cr(VI)) samples be collected on polyvinyl chloride (PVC) membrane filters of 5-µm
pore size. The filters, generally enclosed in filter holders consisting of a three-piece polystyrene
cassette, are placed near the collar of the welder for collecting representative breathing zone
samples. For collecting area samples, filters can be placed in the general welding area. The
influence of contaminants due to adjacent welding operations on the samples being collected
should be minimized and/or determined. For comparison of results, it is recommended that the
parameters influencing the samples be kept the same during the entire welding period.

The fumes collected on the filters can be analyzed for their constituent metals. Agencies such
as the EPA, OSHA, and the National Institute for Occupational Safety and Health (NIOSH) have
indicated standard procedures for performing extraction of the collected samples.(8)

The digested samples are then analyzed for their constituent metals using various analytical
techniques, which include ion chromatography, atomic absorption spectroscopy, and the
inductively coupled plasma method. For example, Cr(VI) can be analyzed using ion
chromatography and metals like manganese and nickel can be analyzed using atomic
absorption spectroscopy or the inductively coupled plasma method. Again, agencies like
OSHA, NIOSH, and the EPA have recommended standard methods for analyzing various
metals and non-metals. The analysis of the welding sample to estimate the amount of Cr(VI)
using OSHA’s Method 215 has been given below for illustration of the sampling procedure.

11 43149-GTH − 9/02
 5.0 Compliance with Environmental Regulations

Among environmental regulations, air quality regulations are important as welding, cutting, and
gouging operations generate significant quantities of air pollutants. Comparatively, limited
quantities of hazardous wastes and wastewater or storm water are generated as a result of
these processes.

5.1 Resource Conservation and Recovery Act (RCRA)

Shipyards are required to have a hazardous waste generator permit according to RCRA
guidelines. As most of the shipyards do not deal with treatment, storage and disposal (TSD)
operations, they do not require a permit as a TSD facility. Welding, cutting, and gouging
operations again have limited quantities of hazardous wastes. Dust collected from air pollution
control devices may be categorized as hazardous waste and should be handled accordingly.
Also, small quantities of acid wastes and waste flammable gases may be disposed according to
the standard guidelines.

All hazardous wastes have to be identified, labeled, stored, and disposed of according to the
guidelines applicable to the hazardous waste generators. When hazardous wastes are shipped,
a manifest has to be filled out, a copy of which is sent to the state regulatory agency and a copy
is maintained on-site. A set of the same is forwarded with the transporter who is responsible to
give a copy to the TSD facility owner receiving the hazardous waste. Waste generated annually
has to be reported to the state environmental regulatory agency as directed by the permit
requirements or standard guidelines.

5.2 Clean Air Act (CAA)

Several sections of the Clean Air Act (CAA) apply to welding, cutting, and gouging operations.
Compliance requirements and the pollutants permitted are specified in individual facility air
permits. It is important to note that a facility permit addresses all processes together including
welding, cutting, and gouging operations. Air permits may have specific requirements for
welding, cutting, and gouging operations in view of hazardous air pollutant (HAP) emissions.
Facilities are generally categorized as either major sources or minor sources. Based on HAP
emissions, major sources are those that emit in excess of 25 tons per year (tpy) of total HAPs
and/or 10 tpy of any single HAP. Major source categories are also evaluated based on criteria
pollutants and the attainment and non-attainment regions. Major sources are required to have a
TITLE V air permit which is complex compared to a general air permit that is issued to minor
sources.

12 43149-GTH − 9/02
Facilities have to comply with the National Ambient Air Quality Standards for six criteria air
pollutants. These are PM10, SO2, NOx, CO, O3, and particulate lead. Welding, cutting, and
gouging processes are known to emit PM10, NOx, CO, O3, and particulate lead. These NAAQS
are listed in Table 2.

Hazardous air pollutants (HAPs) do not have national ambient air quality standards, though
some states have target ambient standards. There are no risk based ambient standards for
HAPs and the goal is to eliminate HAPs from the environment to the extent possible. The EPA
uses techniques such as the MACT (Maximum Achievable Control Technology) to restrict
emissions of HAPs from industrial processes. The EPA requires facilities to use the maximum
achievable technologies to control pollutants before release from their industrial operations.
Welding, cutting, and gouging operations emit metals and metal ions, which are considered
HAPs and have to be controlled.

5.2.1 Atmospheric Dispersion Modeling

Compliance is evaluated through the use of atmospheric dispersion modeling. Knowing the
emissions from welding, cutting, and gouging operations coupled with meteorological
information and others, it is possible to estimate the incremental ambient concentration of
specific pollutants. These incremental pollutant concentrations have to comply with state
recommended limits, which has to be demonstrated before permitting, and also as a compliance
demonstration after permitting.

The dilution of pollutants in the atmosphere occurs as a result of one or more of the following
mechanisms:

• Transportation − result of wind motion

• Dispersion − due to the turbulence produced by wind
• Mass diffusion − caused by concentration gradients

Atmospheric dispersion models(9) use the basic Gaussian model, which is listed below:

Q y2 (z − H )2 (z + H )2
C( x , y ,z; H ) = exp(− ){exp( ) + exp( )}
2πuσ xσ y 2σ 2 y 2σ 2 z 2σ 2 z

C(x, y, z: H) − Ambient concentration of the pollutant at a receptor (x,y,z) when “H” is the
effective emission height
x − Downwind distance from source to receptor, in meters
y − Crosswind distance from source to receptor, in meters
z − Vertical distance from source to receptor, in meters

13 43149-GTH − 9/02
u − Wind speed at the point of release in m/sec
σx and σy − Dispersion coefficients representing crosswind and vertical spread respectively in
meters, which are functions of downwind distance “x” and the atmospheric
stability

Q − Pollutant emission rate in g/sec

H − Effective height of the stack

It may be noted from the above model that,

• increase in effective stack/emission height will decrease the concentrations downwind and
will shift the maximum concentration point to further away from stack

• increase in stack diameter will reduce the ambient concentrations

• increase in exit velocity at the tip of the stack will reduce the ambient concentrations

• maximum ambient concentration occurs on the downwind axis (y = 0)

Knowledge on dispersion of pollutants in the atmosphere will assist facilities in achieving

environmental compliance, which is a great air quality management tool.

5.3 Clean Water Act (CWA)

The Clean Water Act (CWA) is implemented through the National Pollutant Discharge
Elimination System (NPDES) permit program, which is the key component to control discharges
from industrial facilities and POTWs (publicly owned treatment works) to surface waters of the
U.S. Under the NPDES permit program regulations; the EPA may delegate authority to
individual states to administer their own permit program in lieu of the federal program. In the
absence of federal categorical standards for shipyards, CWA discharge limits are often
established on the basis of Best Management Plans (BMPs). Discharge permits are required
for all “point source” discharges of pollutants into waters of the U.S., including wetlands.
Permits may also be required for indirect discharges of pollutants into municipal collection and
treatment systems. The discharges are controlled under local or state pretreatment program
requirements.

5.3.1 NPDES Permit Conditions

Normally, the primary purpose of an NPDES permit is to establish enforceable effluent

limitations. In addition to effluent limitations, the NPDES permit establishes a number of other

14 43149-GTH − 9/02
enforceable conditions, such as monitoring and reporting requirements, a duty to properly
operate and maintain systems, upset and bypass provisions, record keeping, inspection, and
entry requirements.

In addition, an NPDES permit may require the permittee to perform BMPs, which are
procedures designed to prevent or minimize the release of toxic or hazardous pollutants. BMPs
are often simple “housekeeping” measures such as requirements to store drums in specific
locations or to clean up spills promptly. BMPs are especially appropriate for storm water
permits.

5.3.2 Effluent Limitations

All facilities are required to meet treatment levels based on the EPA’s assessment of the
capabilities of treatment technologies that are technologically and economically achievable in
the facility. More stringent treatment requirements must be met where they are found to be
necessary to achieve water quality goals for the particular body of water into which a facility
discharges. Water quality-based controls may be a combination of chemical-specific limitations,
whole effluent toxicity control, and a biological criteria/bioassay and bio-survey approach. The
effluent limitations and monitoring requirements for shipyards may vary.

5.3.3 Storm Water Permits

On September 29, 1995, the EPA issued the Multi-Sector General Permit (MSGP) (60 FR
50804), a final storm water general permit providing NPDES permit coverage for storm water
discharges associated with 29 different industry sectors in 11 states and 4 territories without
authorized NPDES programs. Shipyard facilities fall under this category.

The MSGP is based on site-specific information received from approximately 700 groups
representing about 44,000 industrial facilities throughout the country. The MSGP is available to
facilities that meet eligibility requirements, regardless of whether or not they participated in a
group application.

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5.3.4 Best Management Plan (BMP) Identification and Selection

Plans are required to contain a description of the controls and measures to prevent or minimize
pollution of storm water and a specific schedule with interim milestones as to when measures
and controls will be implemented. The measures and controls to prevent and minimize pollution
of storm water must include:

1) Good housekeeping in industrial areas exposed to storm water.

2) Preventive maintenance of storm water controls and other facility equipment.

3) Spill prevention and response procedures to minimize the potential for and the impact of
spills.

4) Training of employees on pollution prevention measures and record keeping.

5) Identification of areas with a high potential for erosion and the stabilization measures or
structural controls to be used to limit erosion.

6) Implementation of traditional storm water management measures (oil/water separators,

vegetative swales, detention ponds, etc.) where they are appropriate for the site.

6.0 Record Keeping and Reporting Requirements

6.1 Record Keeping Requirements Under Environmental Laws

A variety of information has to be maintained on-site in order to comply with their environmental
requirements. Information should be collected and recorded in such a way that the pollutant
emissions can be calculated correctly. In case of welding, (1) welding type, (2) welding process
parameters, (3) type of base metal, and (4) type, composition, and quantity of weld rods/filler
wire have to be recorded. In case of cutting, (1) type of metal cut, (2) average thickness, (3)
length of cut, (4) cut speed, (5) type of cutting method, and (6) cutting process variables should
be recorded. Similarly, for gouging all attributes have to be recorded so that the pollutant
quantities can be estimated.

6.2 Environmental Reporting

Shipyards are required to develop and submit various reports demonstrating the compliance
with environmental regulations dealing with multimedia waste streams. These reports have to

16 43149-GTH − 9/02
be submitted to various agencies such as the Environmental Protection Agency (EPA), the state
environmental regulatory agency, local agencies such as the Police Department, Fire Fighting
Department, and the Emergency Planning and Coordination Committee. Waste streams
generated from welding, cutting, and gouging have to be accounted in calculating multimedia
emissions as well as in reporting. The most common and important reports are discussed in the
following section.

6.2.1 Air Emissions Inventory Reports

The facility air permit, the local/regional air quality management goals, and various other
parameters affect reporting frequency and format. Most facilities have to characterize and
quantify pollutants emitted through each permitted source (fugitive and non-fugitive type)
monthly, quarterly, semi-annually, and annually. Typically, reporting may be semi-annually and
annually. As the permit conditions are sometimes negotiable depending on the compliance
history, current environmental practices, and proposed mitigation measures, reporting
requirements among facilities may differ within the same state.

Welding, cutting, and gouging releases are calculated based on the available literature, which
should be defendable. In case of questions on quantification methods, it is the shipyard’s
responsibility to prove that the methods used are scientifically accurate to the extent known. A
regulatory agency may ask the facility/shipyard to perform research to develop quantification
methods.

6.2.2 Hazardous Waste Reports

If any hazardous waste is produced or created at the facility, the facility becomes the generator
of that hazardous waste and is responsible for handling it properly until it is disposed of
correctly. The responsibility starts with the creation of the hazardous waste and ends with the
disposal, which is knows as “the cradle to grave concept.” Though shipyards may use a
transporter and a TSD facility (Treatment, Storage, and Disposal facility) to finally treat and
dispose of hazardous wastes, the shipyards are liable in case the transporter and/or the TSD
facility fail to properly manage the hazardous waste generated by the shipyard. Any
contamination resulting from such mismanagement will transfer as a liability to the shipyard as a
generator.

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6.2.3 Toxics Release Inventory (TRI) Reports

Emergency Planning and Community Right-to-Know (EPCRA), promulgated along with the
SARA, was designed to promote emergency planning efforts at state and local levels and
provide citizens and local governments with information concerning potential chemical hazards
in their communities. The Act, also known as SARA Title III, imposes requirements for facilities
to provide emergency hazardous chemical release notification, chemical inventory reporting,
and toxic chemical release reporting. SARA Title III gives states the authority to implement the
law’s requirements. State emergency response commissions and local emergency planning
committees have been appointed within each state to receive this information and use it for
chemical emergency preparation and community awareness.

The facilities have to file Form R under Section 313 of EPCRA, also known as Title III of the
Superfund Amendments and Re-authorization Act. This form is also known as the Toxic
Chemical Release Inventory Reporting Form. Pollutants must be quantified and reported on
Form R if a shipyard exceeds the threshold quantities (25,000 lb or 10,000 lb) mentioned in
Section 313. De Minimus limit is used while calculating the threshold quantities. For example if
Cr in weld rod is in excess of 1% by weight, then Cr present in excess of 1.0% should be
included in threshold calculations for Cr. Calculations have to be made for Cr quantity present
in all materials used in a shipyard. If the calculated value exceeds the threshold limit of 25,000
lb (or 10,000 lb if qualifies under “otherwise used” category), then Cr emissions have to be
calculated and reported as part of TRI reporting.

TRI reports are submitted annually and are due on July 1, of every year for the previous
calendar year. TRI reports include multi-media emissions resulting from the facility operation.
They include air emissions, wastewater discharges (on-site and those shipped off-site), and
solid/hazardous wastes.

6.2.4 Discharge Monitoring Reports (DMRs)

Under the NPDES permit and the Multi-Sector General Permit (MSGP), shipyards have to
analyze the wastewater quality/quantity and storm water quality/quantity and report the results
in a specified format to the state environmental permitting agency. These reports are called
DMRs and the frequency of submission depends on the permit requirements. Though welding,
cutting, and gouging operations may not generate significant wastewaters, they may contribute
to pollutants in storm water discharges.

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6.2.5 Tier II Reports

Shipyards have to report the hazardous materials that are stored at their facility to the state
regulatory agency, local police department, local fire department, and the local emergency
coordinator. Welding, cutting, and gouging processes may use certain flammable gases, the
storage of which is regulated, and should be included in TIER II reports submitted annually.

7.0 Conclusions

This report should assist in understanding the shipyard environmental responsibilities relating to
welding, cutting, and gouging operations. However, federal and state environmental regulations
constantly change, so shipyards are cautioned to review the specific laws from time to time.
Also, this report is meant to be generic and is not targeted to any specific shipyard. Emission
factors presented are also meant to be samples of the type of data that should be used in
quantifying and characterizing emissions. Presenting all available emission factors is beyond
the scope of this report. Shipyards have to identify any new emission factor data that may
become available from time to time. Shipyard environmental management activities and action
plans are site-specific, and should be updated continually to meet ever-changing environmental
regulations.

19 43149-GTH − 9/02
 8.0 References

(1) ”Profile of the Shipbuilding and Repair Industry”, U.S. Environmental Protection Agency,
Office of Compliance, 1997, 1200 Pennsylvania Avenue, N.W., Washington, D.C. 20460.

(2) “AWS F1.6 Guide for Estimating Welding Emissions for EPA and Ventilation Permit
Reporting”, published by the American Welding Society, Miami, FL.

(3) Jacobs Environmental Engineering Services and NASSCO, “Characterizing Shipyard

Welding Emissions and Associated Control Options”, NSRP 0457, 1995.

(4) “Compilation of Air Pollutant Emission Factors, AP-42, Fifth Edition, Volume I:
Stationary Point and Area Sources”, U.S. Environmental Protection Agency, Research
Triangle Park, NC, 1995, <http://www.epa.gov/ttn/chief/ap42/>.

(5) Kura, B., T. Judy, R. Stone, and T. Wisbith, “Assessment of Air Emissions from Shipyard
Cutting Processes”, U.S.-Japan Natural Resources (UJNR) Conference, Tokyo, Japan,
2000.

(6) Kura, B., T. Judy, R. Stone, and T. Wisbith, “Metal Cutting Operations: Emission
Factors for Particulates, Metals, and Metal Ions”, Conference Proceedings − The
Emission Inventory: Regional Strategies for the Future, 1999.

(7) “EPA Emission Test Methods”, Emission Measurement Center (EMC) of the
Environmental Protection Agency, 401 M Street S.W., Washington, D.C., 20460
<http://www.epa.gov/ttn/emc/>.

(8) “Sampling and Analytical Methods”, U.S. Department of Labor Occupational Safety and
Health Administration, Publications, P.O. Box 37535 Washington, D.C., 20013-7535
<http://www.osha.gov/dts/sltc/methods/index/>.

(9) Cooper, C. David and F.C. Alley, Air Pollution Control – A Design Approach, Waveland
Press, Inc., 1994.

20 43149-GTH − 9/02
 9.0 Bibliography

(1) “Toxic Chemical Release Inventory Reporting Forms and Instructions”, U.S.
Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W., Washington, D.C.
20460, <www.epa.gov/TRL>.

(2) Kura, B., ”Integrated Environmental Management Plan for Shipbuilding Facilities, Interim
Report #1”, 1996.

(3) Kura. B., “Integrated Environmental Management Plan for Shipbuilding Facilities, Interim
Report #2”, 1997.

(4) Kura. B., “Integrated Environmental Management Plan for Shipbuilding Facilities, Final
Report”, 1998.

(5) Jacobs Consulting, Inc., “Emergency Planning and Community Right-to-Know Act
(EPCRA) and Toxics Release Inventory (TRI) Reporting Guide for the Shipbuilding
Industry”, 1999.

(6) Kura, B., “Metal Cutting Emissions: Emission Factors and Size Distribution for Total
Fume and Cr(VI)”, 2000.

(7) Kura, B., “Air Quality Regulations Applicable to Shipyards and Boatyards in the Mid-
Atlantic and the Gulf-Coast States”, MISSTAP Conference, Biloxi, MS, 1998.

(8) Kura, B., “Multi-Sector General Permit for Shipyard and Boatyard Industry”, MISSTAP
Conference, Biloxi, MS, 1998.

(9) Kura, B., and R. Tadimalla, “Pollution Prevention Technologies for Shipyards”, U.S.-
Japan Natural Resources (UJNR) Conference, Washington, D.C., 1998.

(10) Kura, B., S. Lacoste, and Patibanda, “Multimedia Pollutant Emissions from the
Shipbuilding Facilities, Pollution Prevention Technologies for Shipyards”, U.S.-Japan
Natural Resources (UJNR) Conference, Washington, D.C., 1998.

(11) Kura, B. and S. Lacoste, “Typical Waste Streams in a Shipbuilding Facility”, Proceedings
of Air and Waste Management Association, 89th Annual Meeting and Exhibition,
Nashville, TN, 1996.

(12) Mid West Research Institute, Inc., “Development of Particulate and Hazardous Emission
Factors for Electric Arc Welding” (AP-42, Section 12.19), Final Report Prepared for EPA
Emission Inventory Branch, 1994, <http://www.epa.gov/>.

(13) “Development of Environmental Release Estimates for Welding Operations”, U.S.

Environmental Protection Agency Risk Reduction Engineering Laboratory, Cincinnati,
Ohio, 45268.

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Table 1. Selected Metals to be Reported under SARA

De Minimus
Hazardous Chemicals
Limit (%)

Aluminum (fume or dust) − 1.0

Lead (when Lead is contained in stainless steel, − *
brass or bronze alloys the de minimus level is 0.1)
Manganese − 1.0
Mercury − *
Nickel − 0.1
Silver − 1.0
Thallium − 1.0
Antimony − 1.0
Arsenic − 0.1
Barium − 1.0
Beryllium − 0.1
Cadmium − 0.1
Chromium − 1.0
Cobalt − 0.1
Copper − 1.0
Vanadium (except when contained in an alloy) − 1.0
Zinc (fume or dust) − 1.0
Titanium tetrachloride − 1.0
Phosphorous (yellow or white) − 1.0

Source: EPA, February 2002, Toxics Release Inventory Reporting Forms and Instructions
(Revised 2001 Version).

Note: Where (*) appears instead of a de minimus value, the chemical is a PBT (Persistent,
Bioaccumulative, and Toxic) chemical and irrespective of its concentration in the material, it
should be considered in calculations for reporting. Whereas other chemicals if present in lower
concentrations than the corresponding indicated de minimus values, they need not be
considered in calculations for reporting. Refer to the source listed below for additional
information.

TRI reporting by applicable facilities is required by section 313 of the Emergency Community
Right-to-Know Act (EPCRA, or Title III of the Superfund Amendments and Reauthorization Act
of 1986), Public Law 99-499.

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Table 2. National Ambient Air Quality (NAAQS) Standards

Pollutant/ Primary Secondary

Averaging Time Standarda Standardb Comments
Particulate Matter 15 µg/m3 Based on 3-year average of annual
PM2.5 (annual) arithmetic mean PM2.5 concentrations from
single or multiple community-oriented
monitors
PM2.5, (24-hour) 65 µg/m3 Based on 3-year average of 98th
percentile of 24-hour PM2.5 concentrations
at each population-oriented monitor within
an area
PM10, annual 50 µg/m3 50 µg/m3 Attained when expected annual arithmetic
mean 50 µg/m3
PM10, 24-hour 150 µg/m3 150 µg/m3 Based on 99th percentile of 24-hour PM10
concentrations at each monitor within an
area
Sulfur Dioxide 80 µg/m3 Never to be exceeded
SO2, annual −−−
(0.03 ppm)
SO2, 24-hour 365 µg/m3 Not to be exceeded more than once per
−−− year
(0.14 ppm)
SO2, 3-hour 1,300 µg/m3 Not to be exceed more than once per year
(0.5 ppm)
Nitrogen Dioxide 100 µg/m3 100 µg/m3 Never to be exceeded
NO2, annual (0.053 ppm) (0.053 ppm)
Ozone 157 µg/m3 157 µg/m3 Based on 3-year average of annual 4th-
O3, 8-hour (0.08 ppm) (0.08 ppm) highest daily maximum 8-hour ozone
concentrations
O3, 1-hour 235 µg/m3 235 µg/m3 Standard is attained when the expected
(0.08 ppm) (0.12 ppm) number of exceedances 1 − to be phased
out (but present non-attainment areas
must show 3 consecutive years of data
meeting 1-hour standard before becoming
attainment)
Carbon Monoxide 10 mg/m3 −−− Not to be exceed more than once per year
CO, 8-hour (9 ppm) −−− Not to be exceeded more than once per
CO, 1-hour 40 mg/m3 year
(35 ppm)
Lead
Pb, calendar 1.5 µg/m3 −−− Never to be exceeded
quarter
a
For the protection of human health, with an adequate margin of safety.
b
For the protection of other values, such as visibility, crops, materials, etc.

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Table 3. Cutting Emission Rates

Pollutant Minimum ER Maximum ER

g/sec g/sec

TPM 0.170 1.130

PM10 0.153 1.017
PM2.5 0.119 0.791
Oxides of Nitrogen (NOx) 1.930 16.700
Lead (Pb) 1.83 E-05 8.08 E-04
Chromium (Cr) 2.33 E-04 9.57 E-03
Hexavalent Chromium (Cr6) 5.45 E-07 1.44 E-04
Nickel (Ni) 6.17 E-04 4.24 E-02
Manganese (Mn) 5.67 E-04 3.13 E-03
Coblat (Co) 1.83 E-05 2.53 E-04
Copper (Cu) 7.27 E-04 1.22 E-02
Zinc (Zn) 3.02 E-04 2.81 E-03
Arsenic (As) 2.00 E-05 6.22 E-04
Molybdenum (Mo) 8.50 E-04 1.74 E-02
Cadmium (Cd) 1.66 E-06 2.66 E-05

Source: NSWCCD (5,6)

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 Appendix A

Compilation of Air Pollutant Emission Factors, AP-42, Fifth Edition,

Volume 1: Stationary Point and Area Sources
Chapter 12, Section 12.19, January 1995
U.S. Environmental Protection Agency
Research Triangle Park, NC

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12.19 Electric Arc Welding

NOTE: Because of the many Source Classification Codes (SCCs) associated with electric arc welding,
the text of this Section will give only the first 3 of the 4 SCC number fields. The last field of each
applicable SCC will be found in Tables 12.19-1 and 12.19-2 below.

12.19.1 Process Description 1-2

Welding is the process by which 2 metal parts are joined by melting the parts at the points of
contact and simultaneously forming a connection with molten metal from these same parts or from a
consumable electrode. In welding, the most frequently used methods for generating heat employ either
an electric arc or a gas-oxygen flame.

There are more than 80 different types of welding operations in commercial use. These
operations include not only arc and oxyfuel welding, but also brazing, soldering, thermal cutting, and
gauging operations. Figure 12.19-1 is a diagram of the major types of welding and related processes,
showing their relationship to one another.

Of the various processes illustrated in Figure 12.19-1, electric arc welding is by far the most
often found. It is also the process that has the greatest emission potential. Although the national
distribution of arc welding processes by frequency of use is not now known, the percentage of electrodes
consumed in 1991, by process type, was as follows:

Shielded metal arc welding (SMAW) – 45 percent

Gas metal arc welding (GMAW) – 34 percent
Flux cored arc welding (FCAW) –17 percent
Submerged arc welding (SAW) – 4 percent

12.19.1.1 Shielded Metal Arc Welding (SMAW)3

SMAW uses heat produced by an electric arc to melt a covered electrode and the welding joint at
the base metal. During operation, the rod core both conducts electric current to produce the arc and
provides filler metal for the joint. The core of the covered electrode consists of either a solid metal rod of
drawn or cast material or a solid metal rod fabricated by encasing metal powders in a metallic sheath.
The electrode covering provides stability to the arc and protects the molten metal by creating shielding
gases by vaporization of the cover.

12.19.1.2 Gas Metal Arc Welding (GMAW)3

GMAW is a consumable electrode welding process that produces an arc between the pool of
weld and a continuously supplied filler metal. An externally supplied gas is used to shield the arc.

12.19.1.3 Flux Cored Arc Welding (FCAW)3

FCAW is a consumable electrode welding process that uses the heat generated by an arc
between the continuous filler metal electrode and the weld pool to bond the metals. Shielding gas is
provided from flux contained in the tubular electrode. This flux cored electrode consists of a metal
sheath surrounding a core of various powdered materials. During the welding process, the electrode core
material produces a slag cover on the face of the weld bead. The welding pool can be protected from the
atmosphere either by self-shielded vaporization of the flux core or with a separately supplied shielding
gas.

1/95 Metallurgical Industry 12.19-1

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12.19-2 EMISSION FACTORS 1/95

A -2 43149-GTH − 9/02
12.19.1.4 Submerged Arc Welding (SAW)4
SAW produces an arc between a bare metal electrode and the work contained in a blanket of
granular fusible flux. The flux submerges the arc and welding pool. The electrode generally serves as
the filler material. The quality of the weld depends on the handling and care of the flux. The SAW
process is limited to the downward and horizontal positions, but it has an extremely low fume formation
rate.

12.19.2 Emissions And Controls4-8

12.19.2.1 Emissions
Particulate matter and particulate-phase hazardous air pollutants are the major concerns in the
welding processes. Only electric arc welding generates these pollutants in substantial quantities. The
lower operating temperatures of the other welding processes cause fewer fumes to be released. Most of
the particulate matter produced by welding is submicron in size and, as such, is considered to be all PM-
10 (i. e., particles 10 micrometers in aerodynamic diameter).

The elemental composition of the fume varies with the electrode type and with the workpiece
composition. Hazardous metals designated in the 1990 Clean Air Act Amendments that have been
recorded in welding fume include manganese (Mg), nickel (Ni), chromium (Cr), cobalt (Co), and lead
(Pb).

Gas phase pollutants are also generated during welding operations, but little information is
available on these pollutants. Known gaseous pollutants (including “greenhouse” gases) include carbon
dioxide (CO2), carbon monoxide (CO), nitrogen oxides (NOx), and ozone (O3).

Table 12.19-1 presents PM-10 emission factors from SMAW, GMAW, FCAW, and SAW
processes, for commonly used electrode types. Table 12.19-2 presents similar factors for hazardous metal
emissions. Actual emissions will depend not only on the process and the electrode type, but also on the
base metal material, voltage, current, arc length, shielding gas, travel speed, and welding electrode angle.

12.19.2.2 Controls
The best way to control welding fumes is to choose the proper process and operating variables
for the given task. Also, capture and collection systems may be used to contain the fume at the source
and to remove the fume with a collector. Capture systems may be welding booths, hoods, torch fume
extractors, flexible ducts, and portable ducts. Collection systems may be high efficiency filters,
electrostatic precipitators, particulate scrubbers, and activated carbon filters.

1/95 Metallurgical Industry 12.19-3

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12.19-4 EMISSION FACTORS 1/95

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12.19-5 Metallurgical Industry 1/95

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12.19-6 EMISSION FACTORS 1/95

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12.19-7 Metallurgical Industry 1/95

A -7 43149-GTH − 9/02
References For Section 12.19

1. Telephone conversation between Rosalie Brosilow, Welding Design And Fabrication Magazine,
Penton Publishing, Cleveland, OH, and Lance Henning, Midwest Research Institute, Kansas
City, MO, October 16, 1992.

2. Census Of Manufactures, Industry Series, U. S. Department Of Commerce, Bureau Of Census,

Washington, DC, March 1990.

3. Welding Handbook, Welding Processes, Volume 2, Eighth Edition, American Welding Society,
Miami, FL, 1991.

4. K. Houghton and P. Kuebler, "Consider A Low Fume Process For Higher Productivity",
Presented at the Joint Australasian Welding And Testing Conference, Australian Welding
Institute And Australian Institute For Nondestructive Testing, Perth, Australia, 1984.

5. Criteria For A Recommended Standard Welding, Brazing, And Thermal Cutting, Publication No.
88-110, National Institute For Occupational Safety And Health, U. S. Department Of Health
And Human Services, Cincinnati, OH, April 1988.

6. I. W. Head and S. J. Silk, "Integral Fume Extraction In MIG/CO2 Welding", Metal

Construction, 11(12):633-638, December 1979.

7. R. M. Evans, et al., Fumes And Gases In The Welding Environment, American Welding Society,
Miami, FL, 1979.

8. R. F. Heile and D. C. Hill, "Particulate Fume Generation In Arc Welding Processes", Welding
Journal, 54(7):201s-210s, July 1975.

9. J. F. McIlwain and L. A. Neumeier, Fumes From Shielded Metal Arc (MMA Welding)
Electrodes, RI-9105, Bureau Of Mines, U. S. Department Of The Interior, Rolla Research
Center, Rolla, MO, 1987.

10. I. D. Henderson, et al., "Fume Generation And Chemical Analysis Of Fume For A Selected
Range Of Flux-cored Structural Steel Wires", AWRA Document P9-44-85, Australian Welding
Research, 15:4-11, December 1986.

11. K. G. Malmqvist et al., "Process-dependent Characteristics Of Welding Fume Particles",

Presented at the International Conference On Health Hazards And Biological Effects Of
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12. J. Moreton, et al., "Fume Emission When Welding Stainless Steel", Metal Construction,
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13. R. K. Tandon, et al., "Chemical Investigation Of Some Electric Arc Welding Fumes And Their
Potential Health Effects", Australian Welding Research, 13:55-60, December 1984.

14. R. K. Tandon, et al., "Fume Generation And Melting Rates Of Shielded Metal Arc Welding
Electrodes", Welding Journal, 63(8):263s-266s, August 1984.

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15. E. J. Fasiska, et al., Characterization Of Arc Welding Fume, American Welding Society, Miami,
FL, February 1983.

16. R. K. Tandon, et al., "Variations In The Chemical Composition And Generation Rates Of Fume
From Stainless Steel Electrodes Under Different AC Arc Welding Conditions", AWRA Contract
90, Australian Welding Research, 11:27-30, December 1982.

17. The Welding Environment, Parts IIA, IIB, and III, American Welding Society, Miami, FL, 1973.

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19. L. Henning and J. Kinsey, "Development Of Particulate And Hazardous Emission Factors For
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