IRON & STEEL FOUNDRY MACT OVERVIEW

40 CFR PART 63, SUBPART EEEEE40 CFR PART 63, SUBPART EEEEE

INTRO

On April 22, 2004, USEPA On April 22, 2004, USEPA promulgated the Federal standard, Iron promulgated the Federal standard, Iron & Steel Foundries NESHAP (National & Steel Foundries NESHAP (National Emission Standards for Hazardous Air Emission Standards for Hazardous Air Pollutants) 40 CFR Part 63, Subpart Pollutants) 40 CFR Part 63, Subpart EEEEE.EEEEE.

ALERT!!!!! On May 20, 2005, USEPA promulgated the On May 20, 2005, USEPA promulgated the

final amendments to the original Subpart final amendments to the original Subpart EEEEE NESHAP promulgated April 22, EEEEE NESHAP promulgated April 22, 2004. The amendments clarified the 2004. The amendments clarified the Sections Sections §63.7700, §63.7735 and §63.7765. §63.7700, §63.7735 and §63.7765. The amendments are intended to reduce The amendments are intended to reduce compliance uncertainties. Because the work compliance uncertainties. Because the work practice standards became effective April practice standards became effective April 22, 2005 (1 year after promulgation) the 22, 2005 (1 year after promulgation) the clarifications contained in the direct final clarifications contained in the direct final rule amendments are time-critical.rule amendments are time-critical.

NOTICE!!!!!

There is an EXISTING SOURCE There is an EXISTING SOURCE requirement to comply with work requirement to comply with work practice standards in practice standards in §63.7700 (b) §63.7700 (b) or (c) no later than April 22, 2005or (c) no later than April 22, 2005

What we are reviewing?

Rule applicabilityRule applicability NSR,NSPS & NESHAP focusNSR,NSPS & NESHAP focus Covered operationsCovered operations Operations not coveredOperations not covered

Standards to be followed, including work Standards to be followed, including work practice standardspractice standards

Operating Limits Operating Limits Important datesImportant dates Synthetic minor sourcesSynthetic minor sources

Review (cont’d.)

New or existing source determinationNew or existing source determination General rule requirementsGeneral rule requirements Initial compliance demonstration Initial compliance demonstration Notification, Recordkeeping and Notification, Recordkeeping and

Reporting requirementsReporting requirements Compliance optionsCompliance options Compliance examplesCompliance examples

Review (cont’d.) Facility Inspection ProtocolFacility Inspection Protocol

Pre-Inspection ReviewPre-Inspection ReviewFacility File ReviewFacility File ReviewFacility InspectionFacility InspectionPost-Inspection MeetingPost-Inspection MeetingFollow-upFollow-up

Frequently asked questionsFrequently asked questions

TYPICAL FACILITY

Video: 12 minute video on “The Video: 12 minute video on “The Process of Metal Casting”Process of Metal Casting”

Cast Metals Institute (CMI)Cast Metals Institute (CMI)

APPLICABILITY: Who is covered by this rule? (Subpart EEEEEE, §63.7681)

Own or operate an Own or operate an EFFECTED SOURCEEFFECTED SOURCE at at a facility that is a major source,a facility that is a major source,

Located at a major source, orLocated at a major source, or Part of a major source of hazardous air Part of a major source of hazardous air

pollutants (HAPs).pollutants (HAPs). NSPS for NSPS for NEWNEW sources of VOC sources of VOC

Effected Source

NSPS; FOUNDRY operations involve VOCsNSPS; FOUNDRY operations involve VOCs NESHAP similar definition; NESHAP similar definition; VOCs vs VOHAPs; similar criteria and an VOCs vs VOHAPs; similar criteria and an

increase in stringencyincrease in stringency Any new or reconstructed source Any new or reconstructed source (as defined (as defined

in in § 63.2)§ 63.2) before 12/23/2002 is an existing before 12/23/2002 is an existing facility and that is a major source and is an iron facility and that is a major source and is an iron and steel foundry.and steel foundry.

Any new or reconstructed source after Any new or reconstructed source after 12/23/2002 is a new source.12/23/2002 is a new source.

Effected Source (cont’d.)

Facility or portion of facility that Facility or portion of facility that melts scrap, ingot, and/or other forms melts scrap, ingot, and/or other forms of iron and/or steel.of iron and/or steel.

Facility pours the resulting molten Facility pours the resulting molten metal into molds. Mold sand metal into molds. Mold sand shakeout operations.shakeout operations.

Final products introduced into Final products introduced into commerce.commerce.

What are Some Operations’ Emissions Impacted by Subpart EEEEE? Metal melting furnaces;Metal melting furnaces; Scrap pre-heaters;Scrap pre-heaters; Pouring areas;Pouring areas; Pouring Stations;Pouring Stations; Automated conveyor and pallet cooling lines;Automated conveyor and pallet cooling lines; Automated shakeout lines;Automated shakeout lines; Mold & core making lines;Mold & core making lines; Fugitive emissions from foundry operations.Fugitive emissions from foundry operations.

FOUNDRY Operations Examples

1.1. EXAMPLE:EXAMPLE: For pre-heaters . generally, For pre-heaters . generally, the rule requires that a scrap selection the rule requires that a scrap selection and inspection program limit to the and inspection program limit to the extent practicable, the amount of organic extent practicable, the amount of organic HAP precursors (i.e., oils and other HAP precursors (i.e., oils and other organic liquids) entering a scrap pre-organic liquids) entering a scrap pre-heater and must comply with the work heater and must comply with the work practice standards in the rule.practice standards in the rule.

EXAMPLES (cont’d.)

2. 2. EXAMPLE:EXAMPLE: If as foundry casts in multiples of a If as foundry casts in multiples of a wide range of alloys, but has a significant iron or wide range of alloys, but has a significant iron or steel content, the facility is subject to Subpart steel content, the facility is subject to Subpart EEEEE. The facility should contact the state EEEEE. The facility should contact the state administrator for guidance.administrator for guidance.

3. 3. EXAMPLE:EXAMPLE: USEPA has revised the finalized the USEPA has revised the finalized the designation for effected source to include a broad designation for effected source to include a broad definition of the iron/steel foundry that eliminates definition of the iron/steel foundry that eliminates the somewhat artificial separation of the mold the somewhat artificial separation of the mold and core-making processes which can often occur and core-making processes which can often occur at close proximity, if not in conjunction with the at close proximity, if not in conjunction with the casting/poring operations.casting/poring operations.

EXAMPLES (cont’d.)

4.4. EXAMPLE:EXAMPLE: The final rule avoids the cases The final rule avoids the cases where an existing foundry might make where an existing foundry might make minor equipment changes that could minor equipment changes that could subject one process or a single piece of subject one process or a single piece of equipment to the new source emissions equipment to the new source emissions limits.limits.

5. 5. USEPA Applicability Determination USEPA Applicability Determination Index SiteIndex Sitehttp://www.epa.gov/Compliance/http://www.epa.gov/Compliance/planning/data/air/adi.htmplanning/data/air/adi.htm

Compliance with Work Practice Standards (63.7700) Demonstrate initial compliance by certification that Demonstrate initial compliance by certification that

“At all times, the effected source will purchase and “At all times, the effected source will purchase and use only certified metal ingots, pig iron, slitter, or use only certified metal ingots, pig iron, slitter, or other materials that do not include post consumer other materials that do not include post consumer automotive body scrap, post consumer engine blocks, automotive body scrap, post consumer engine blocks, oil filters, oily turnings, lead components, mercury oil filters, oily turnings, lead components, mercury switches,switches,

plastics, or organic liquids”plastics, or organic liquids” The effected source has submitted a written and will The effected source has submitted a written and will

operate at all times according to that planoperate at all times according to that plan

Compliance with Work Practice Standards (63.7700) Cont’d.

The effected source meets the no methanol The effected source meets the no methanol requirement for the catalyst portion of the binder requirement for the catalyst portion of the binder chemical formulationchemical formulation

The effected source has demonstrated the furan work The effected source has demonstrated the furan work practice standard for each furan warm box mold or practice standard for each furan warm box mold or core making linecore making line

The effected source has records documenting The effected source has records documenting certification of compliancecertification of compliance

For each scrap pre-heater, initial compliance has For each scrap pre-heater, initial compliance has been demonstratedbeen demonstrated

The effected source only charges certified material.The effected source only charges certified material.

What Standards Require Compliance? (63.7690)

Emissions LimitationsEmissions Limitations

I. For each existing;I. For each existing; electric arc melting furnaceelectric arc melting furnace Electric induction metal melting furnace, orElectric induction metal melting furnace, or Scrap pre-heaterScrap pre-heater

No emissions discharge that exceed the PM limit of;No emissions discharge that exceed the PM limit of;

0.005 grains on PM per dry standard cubic foot, or0.005 grains on PM per dry standard cubic foot, or 0.0004 gr/dscf of Total metal HAP.0.0004 gr/dscf of Total metal HAP.

Emissions Limitations (cont’d.)

II. For each existing cupola melting furnace, II. For each existing cupola melting furnace, no emissions discharge;no emissions discharge; 0.006 gr/dscf of PM, or0.006 gr/dscf of PM, or 0.0005 gr/sdcf of Total metal HAP0.0005 gr/sdcf of Total metal HAP

For each new cupola or new electric arc metal For each new cupola or new electric arc metal melting furnaces;melting furnaces; No emissions discharge that exceed the PM No emissions discharge that exceed the PM

limit of 0.002 gr/sdcf of PM, orlimit of 0.002 gr/sdcf of PM, or 0.0002 gr/dscf of Total metal HAP0.0002 gr/dscf of Total metal HAP

Emission Limitations (cont’d.)

For each new electric induction metal For each new electric induction metal melting furnace or new scrap pre-heater;melting furnace or new scrap pre-heater; No emissions discharge to exceed No emissions discharge to exceed

0.001 gr/dscf of PM; or0.001 gr/dscf of PM; or 0.00008 gr/dscf of Total metal HAP0.00008 gr/dscf of Total metal HAP

Emission Limitations (cont’d.)

For each existing pouring station, no For each existing pouring station, no emissions discharge to exceed;emissions discharge to exceed; 0.010 gr/dscf of PM; or0.010 gr/dscf of PM; or 0.0008 gr/dscf of Total metal HAP0.0008 gr/dscf of Total metal HAP

For each new pouring station or area, no For each new pouring station or area, no emissions discharge to exceedemissions discharge to exceed 0.002 gr/dscf of Total PM; or0.002 gr/dscf of Total PM; or 0.0002 gr/dscf of Total metal HAP0.0002 gr/dscf of Total metal HAP

Emission Limitations (cont’d.)

For building or structure housing, ANY For building or structure housing, ANY emissions source must not discharge any fugitive emissions source must not discharge any fugitive emissions that exhibit greater than 20 % opacity emissions that exhibit greater than 20 % opacity on a 6-minute average EXCEPTION: 1 (6) on a 6-minute average EXCEPTION: 1 (6) minute average per hour not to exceed 27 % minute average per hour not to exceed 27 % opacity.opacity.

For each new or existing cupola metal melting For each new or existing cupola metal melting furnace, no emissions discharge of VOHAP to furnace, no emissions discharge of VOHAP to exceed 20 ppm by volume corrected to 10% exceed 20 ppm by volume corrected to 10% oxygen.oxygen.

Emission Limitations (cont’d.)

An alternative to the work standards in An alternative to the work standards in § § 63.7700(e) existing scrap pre-heater and (f) 63.7700(e) existing scrap pre-heater and (f) new scrap pre-heater; no emissions new scrap pre-heater; no emissions discharge of VOHAP to exceed 20 ppmv.discharge of VOHAP to exceed 20 ppmv.

A new source automated conveyor and pallet A new source automated conveyor and pallet cooling system that uses a sand mold system cooling system that uses a sand mold system or automated shake-out lines using a sand or automated shake-out lines using a sand mold system must not have emissions that mold system must not have emissions that exceed 20 ppmv VOHAP.exceed 20 ppmv VOHAP.

Emission Limitations (cont’d.)

For each new or existing Triethylamine (TEA) For each new or existing Triethylamine (TEA) cold box mold or core making line, the facility cold box mold or core making line, the facility must;must; 1. No emissions discharge to exceed 1 ppmv, 1. No emissions discharge to exceed 1 ppmv, 2. Reduce emissions of TEA by at least 2. Reduce emissions of TEA by at least

99%,99%, 3. Install, operate and maintain a capture 3. Install, operate and maintain a capture

and collection system for all emission and collection system for all emission sources subject to an emissions limit sources subject to an emissions limit

4. Each capture and collection system must 4. Each capture and collection system must meet accepted engineering standardsmeet accepted engineering standards

Emission Limitations (cont’d.)

For each new or existing Triethylamine (TEA) cold For each new or existing Triethylamine (TEA) cold box mold or core making line, the facility must box mold or core making line, the facility must (Cont’d.);(Cont’d.); 5. Each combustion device applied to emissions from 5. Each combustion device applied to emissions from

a scrap pre-heater must be operated at specific a scrap pre-heater must be operated at specific criteria for VOHAP emissionscriteria for VOHAP emissions

6. Operate each wet acid scrubber applied to the 6. Operate each wet acid scrubber applied to the TEA cold box mold or core making line at specific TEA cold box mold or core making line at specific criteria outline in the standardcriteria outline in the standard

7. Prepare and submit a monitoring plan for a 7. Prepare and submit a monitoring plan for a control device other than a bag-house, wet scrubber, control device other than a bag-house, wet scrubber, wet acid scrubber or combustion devicewet acid scrubber or combustion device

Important Dates The final rule was published on April 22, The final rule was published on April 22,

2004 , under 2004 , under FR21905FR21905,, Existing major sources must comply with:Existing major sources must comply with:

Emissions limitations;Emissions limitations; Work practices standard;Work practices standard; Operation & Maintenance requirement;Operation & Maintenance requirement; Major source status determination;Major source status determination;

no later than, April 23, 2007.no later than, April 23, 2007.

Important Dates Cont’d.

ALERT !!!!!ALERT !!!!! Existing source requirement to Existing source requirement to comply with work practice standards in comply with work practice standards in §63.7700 (b) or (c) no later than April 22, §63.7700 (b) or (c) no later than April 22, 20052005

New effected sources operating on or before New effected sources operating on or before April22, 2004should have complied by April April22, 2004should have complied by April 2222, 2004, or startup, whichever was later,, 2004, or startup, whichever was later,

New effected sources operating after April 22, New effected sources operating after April 22, 2004, must comply with the regulatory 2004, must comply with the regulatory requirements upon startup.requirements upon startup.

Important Dates (cont’d.)

If the Iron & Steel Foundry is an area source, If the Iron & Steel Foundry is an area source, but becomes a major source of HAP, but becomes a major source of HAP, compliance of compliance of § 63.6©(5)§ 63.6©(5)is upon startup.is upon startup.

The effected sources must meet the The effected sources must meet the notification and scheduling requirements in notification and scheduling requirements in § § 63.7750. Some of these notifications must be 63.7750. Some of these notifications must be submitted before the effected source submitted before the effected source compliance date.compliance date.

Operations & Maintenance Requirements (§63.7710)

Effected facilities must operate and Effected facilities must operate and maintain the sources, including air maintain the sources, including air pollution control and monitoring pollution control and monitoring equipment in a manner consistent with equipment in a manner consistent with good air pollution practices that good air pollution practices that minimizes air emissions to the level minimizes air emissions to the level required in Subpart EEEEE.required in Subpart EEEEE.

Operations & Maintenance Requirements (§63.7710) Cont’d.

Effected sources must prepare and operate Effected sources must prepare and operate at all times according to a written at all times according to a written operation and maintenance plan for each operation and maintenance plan for each capture and collection control device capture and collection control device controlling emissions subject to Subpart controlling emissions subject to Subpart EEEEE.EEEEE.

Each plan must contain the elements Each plan must contain the elements required in §63.7710required in §63.7710

General Compliance Requirements (§63.7720) The effected source must be in compliance with the:The effected source must be in compliance with the:

emissions limitationsemissions limitations Work practice standardsWork practice standards Operations and maintenance;Operations and maintenance; EXCEPT, during periods of startup, shutdown, EXCEPT, during periods of startup, shutdown,

and malfunctionand malfunction Maintain a log detailing the operation and Maintain a log detailing the operation and

maintenance of the process and emissions control maintenance of the process and emissions control equipment related to the initial performance test equipment related to the initial performance test and the applicable operating limits for a effected and the applicable operating limits for a effected sourcesource

General Compliance (cont’d.)

Initial Compliance Requirements (§63.7730)Initial Compliance Requirements (§63.7730) Additional Performance Test Requirements Additional Performance Test Requirements

(§63.7731)(§63.7731) Test MethodsTest Methods

Subpart EEEEE clearly defines the test Subpart EEEEE clearly defines the test methods and other procedures in methods and other procedures in §63.7732§63.7732 used to demonstrate initial compliance with used to demonstrate initial compliance with the emissions limitationsthe emissions limitations