Shipyard Stormwater Best Management Practice #6:

Thermal Metal Cutting

BMP Goal(s)
Significant reduction or elimination of pollutant emissions per unit length or volume cut.

References

Shipyard Core Processes Pollutant of Concern Matrix document

Thermal Metal Cutting Pollution Pathway Analysis document

Thermal Metal Cutting Process Guidance section on page two

Background
This BMP addresses the discharge of pollutants of concern from the process of thermal metal cutting
processes. The significant and potentially significant pollutants of concern addressed by this BMP have
been identified in the Shipyard Core Processes & Pollutants of Concern Matrix as: copper, zinc, nickel,
lead, iron, chrome, and aluminum.
This section explains the rational for developing and implementing the BMP. It identifies the pollutant(s)
being controlled, the potential sources of the pollutant(s), and the physical pathway the pollutant(s) follows
to reach the facilitys stormwater flow. If practicable, this section also includes an estimate of the potential
pollutant loading reduction, based upon the Pollution Pathway Analysis or other referenced studies.

Best Management Practice Description

Develop and implement a comprehensive job specific process management plan for thermal metal cutting,
designed to achieve the goal of this BMP.

Monitoring and Reporting

The implementation of this BMP will be monitored to determine effectiveness in achieving the goal.
Monitoring will be done on a job-by-job basis, with specific metrics used as appropriate for the job.
Examples of metrics that may be used for this process include:

Unit length cut

Emissions/unit cut length

Emissions/unit cut volume

Training records

Control factors for add on control equipment

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Thermal Metal Cutting

Process pperation variables necessary to optimize efficiency/effectiveness

Metrics data will be recorded periodically as specified in the Process Management Plan. The results of the
monitoring will be maintained and used to determine progress in achieving the goal of this BMP.

Process Guidance Elements for Thermal Metal Cutting

Testing and Evaluation Fume and particulate emissions from thermal cutting of metal is know to vary
significantly by the substrate being cut and the presence and type of coatings on the substrate, if any.

Substrates being cut The composition of the particulates released will be broadly similar to that of
the parent metal. Consequently, the contribution of the parent metal to the fume varies from metal
to metal. For example: Carbon steel - iron oxide forms the main component of the fume;
Galvanized steel - generates zinc oxide fumes; Metal alloys containing cadmium - release
cadmium fumes; and Stainless steel - chromium (VI) and nickel will be present in the fume. An
evaluation of the base metal being cut will provide information regarding the potential for discharge
of pollutants of concern during thermal cutting operations.

Substrate coatings Coating on the substrate will substantially increase the rate of fume
generation from thermal cutting operations. Additionally, the coating may contain metals and
organic compounds that can contribute to the mass loading of pollutants of concern. In many
cases, the pollutants derived from the coating may be the majority contributor of pollutants.
Testing and/or evaluation of the substrate coating can provide critical information regarding the
potential for pollutant loading, and whether controls or process changes are required to reduce the
fume emissions.

Thermal metal cutting is broadly defined as including the processes of oxyfuel gas metal cutting
and plasma arc metal cutting.

Oxyfuel Gas Cutting (OFC) is a process used to sever metal by high-temperature exothermic
reactions of oxygen with the base metal and arc cutting. The process has been called various
names, including oxyfuel gas cutting, burning and flame cutting. The actual cutting operation is
performed by the oxygen stream. The oxygen-fuel gas flame is the mechanism used to raise the
base metal to an acceptable preheat temperature and to maintain the cutting operation. Particulate
matter and particulate-phase (fume) hazardous air pollutants are the major concerns in the OFC
processes. Most of the particulate matter produced by OFC is submicron in size and, as such, is
considered to be all PM-10. The elemental composition of the fume will vary with the oxyfuel
process utilized and with the work piece composition. Hazardous metals that have been identified
in OFC fume include manganese (Mg), nickel (Ni), chromium (Cr), cobalt (Co), and lead (Pb).
Fume particulates can be deposited on surfaces throughout the work area or job site, where they
may be exposed to rainfall and contribute to stormwater pollutant loading.

Plasma Arc Cutting (PAC) is a process that severs metal by using a constricted electric arc to melt
a localized area of a work piece, removing the molten material with a high-velocity jet of ionized
gas issuing from the constricting orifice. Plasma arcs typically operate at temperatures of 18,000
to 25,000o F. PAC generates significant amounts of metal oxide fumes and other pollutants during
cutting operations. Most of the particulate matter produced by PAC is submicron in size and, as
such, is considered to be all PM-10. The elemental composition of the fume will vary with the PAC

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Thermal Metal Cutting

process utilized and with the work piece composition. Hazardous metals that have been identified
in OFC fume include manganese (Mg), nickel (Ni), chromium (Cr), cobalt (Co), and lead (Pb).
Fume particulates can be deposited on surfaces throughout the work area or job site, where they
may be exposed to rainfall and contribute to stormwater pollutant loading.
Thermal Cutting Materials

Oxyfuel Gas Cutting Oxygen and a fuel gas are two primary materials used in the oxyfuel gas
cutting processes.
Oxygen Oxygen used for cutting operations should have purity of 99.5 or greater. Lower
concentrations will reduce the efficiency of the cutting operation by as much as 15 percent per
one percent decrease in oxygen. This will significantly decrease the production rate, requiring
longer cutting times and increased fume generation.
Fuel Gasses Types of fuel gasses commonly used for oxyfuel gas cutting include acetylene,
propane, propylene, methylacetylenepropadiene, and natural gas. The selection of which type
of fuel to use on any specific job is most often made on the factors of availability and cost.
Although it is well known how fuel gasses will effect various OFC production factors, little is
known regarding their effect on fume generation rates during cutting operations.

Plasma Arc Cutting Unlike OFC, where the gas is used as a fuel, gasses used in PAC are used
to create the flow of hot plasma than removes the metal melted by the high arc temperatures.
Types of gasses utilized for plasma arc cutting include nitrogen, argon, air, oxygen, and
mixtures of nitrogen/hydrogen and argon/hydrogen. Although it is well known how arc plasma
gasses will affect various OFC production factors, little is known regarding their effect on fume
generation rates during cutting operations.

Thermal Cutting Production Processes Variables

Oxyfuel Cutting
Burn Temperature is affected by the oxidation rate of the base metal and, therefore, the
product rate of the cutting process. The precise effect of burn temperature on the fume
generation rate is not well understood, but because it affects the cutting rate, it will most likely
affect fume generation rate as well.
Torch Tips Cutting tips, although considered to be consumable items, are precision tools that
have great effect on cutting performance. Cutting tips are selected based on the type of fuel
gas utilized for the cutting operations. It is not well understood as to how the torch tip may
affect fume generation.
Gas Flow Rate and Pressure Precisely regulating the proper gas pressure and volume as
required based upon the fuel gas selected is vital for maximizing the cutting efficiency. The
gas flow rate and pressure will affect the burn temperature, thereby affecting most other
production and environmental parameters. However, how the gas flow rate and pressure
effect the fume generation rate is not well understood.

Plasma Arc Cutting

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Thermal Metal Cutting

Torches The plasma cutting process is used with either a hand held torch or a mechanically
mounted torch. There are several types and sizes of each, depending upon the thickness of
metal to be cut. How the specific type or size of plasma torch affects the fume generation rate
is not well understood.
Power Supplies Arc torches require power supplies to generate an electric arc, similar to the
arc welding process. How the power supply affects the fume generation rate in plasma arc
cutting is not well understood. It is known to have a significant effect on the FGR of arc
welding, so is likely to also have some affect on the similar process of plasma arc cutting.
Training -- Becoming a skilled oxyfuel and/or plasma arc metal cutter requires substantial training to learn
the various metal cutting processes and the intricacies of the job. There can be a significant improvement
in environmental performance by integrating training regarding the potential environmental effects, and by
learning how to recognize and control the generation of pollutants from thermal metal cutting, into
production training programs.

Fitters Ship and Pipe fitters are required to perform cutting operations on a job specific basis.
Initial and refresher training to provide information on proper cutting techniques in order to maintain
the lowest possible FGR during operations could significantly reduce potential pollutant loading.

Supervisors Supervisors are required to ensure fitters perform their job tasks in accordance with
required procedures, including environmental procedures. Supervisors require appropriate training
in recognizing potential environmental issues resulting from cutting operations and learning to
eliminate or minimize pollutant loading.

Equipment Maintenance Poorly or improperly maintained oxyfuel and plasma arc equipment is
more likely to have higher fume generation rates than well maintained equipment. Those
personnel that are responsible for equipment maintenance require training as to how equipment
performance can impact pollutant emissions as well as how to correctly maintain the equipment to
reduce pollutant loading.

Add On Controls Control measures can be utilized to reduce pollutant loading in stormwater and other
environmental media. For cutting operations, control measures often consist of some type of capture and
collection system that prevents the fume from escaping the work area where it may be exposed to
stormwater.

Fume Collectors Capture systems may be cutting 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.

Area Ventilation/Filtration When cutting in a confined space, area ventilation is often used to
remove fumes from the work space and reduce the potential for occupational exposure. While
providing for the safety of the worker, area ventilation can disperse the cutting-derived pollutants
into the environment. If the ventilation exhaust air is filtered prior to discharge, the potential
pollutant loading can be significantly reduced.

Containment Containment of the work area in which cutting operations are conducted will allow
the fume particulates to settle out and be captured and disposed of properly. Care to protect the

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Thermal Metal Cutting

workers within the containment from harmful levels of cutting fume must be taken, if the
containment option is utilized.
Clean-Up

Cleaning Frequency Cutting fume and dust that may be exposed to rain fall should be cleaned
from the work area on a regular and frequent basis. Cleaning should never be accomplished by air
blowing, which would only re-suspend the fume particles, where they may transported to other
areas that are exposed to rainfall. Cleaning should be accomplished using vacuums equipped with
appropriate filters and/or wet cleaning methods that prevent the escape of the fume to the
environment.

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