IRON & STEEL IRON & STEEL FOUNDRY MACT FOUNDRY MACT

COMPLIANCE COMPLIANCE ASSURANCEASSURANCE

40 CFR PART 63, SUBPART 40 CFR PART 63, SUBPART EEEEEEEEEE

ComplianceCompliance Dates Dates The final rule was published on April The final rule was published on April

22, 2004 , under 22, 2004 , under FR21905FR21905,, Existing major sources must comply Existing major sources must comply

with:with:Emissions limitations;Emissions limitations;Work practices standard;Work practices standard;Operation & Maintenance Operation & Maintenance

requirement;requirement;Major source status determination;Major source status determination;

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

Compliance Dates Compliance Dates Cont’d.Cont’d.

ALERT !!!!! Existing source requirement ALERT !!!!! Existing source requirement to comply with work practice to comply with work practice standards in standards in §63.7700 (b) or (c) no §63.7700 (b) or (c) no later than April 22, 2005later than April 22, 2005

New effected sources operating on or New effected sources operating on or before April22, 2004should have before April22, 2004should have complied by April 22, 2004, or startup, complied by April 22, 2004, or startup, whichever was later,whichever was later,

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

Compliance Dates Compliance Dates Cont’d.Cont’d.

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

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

Operations & Operations & Maintenance Maintenance

Requirements (§63.7710)Requirements (§63.7710) Effected facilities must operate and Effected facilities must operate and

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

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

O & M Requirements O & M Requirements Cont’d.Cont’d.

Each plan must contain the elements Each plan must contain the elements required in §63.7710required in §63.7710 Equipment monthly inspectionsEquipment monthly inspections Operating limits for each capture systemOperating limits for each capture system Appropriate operating limit parameters Appropriate operating limit parameters

and design scope, i.e., control of multiple and design scope, i.e., control of multiple emissions sourcesemissions sources

Preventative maintenance plan for each Preventative maintenance plan for each control device including the control device including the manufacturer’s recommended manufacturer’s recommended maintenance instructionsmaintenance instructions

O & M Requirements O & M Requirements Cont’d.Cont’d.

Each plan must contain the elements Each plan must contain the elements required in §63.7710 – Cont’d.required in §63.7710 – Cont’d. A site-specific maintenance plan for each A site-specific maintenance plan for each

bag leak detection systembag leak detection system Corrective action for each bag-houseCorrective action for each bag-house Procedures for providing an ignition Procedures for providing an ignition

source to mold vents of the sand mold source to mold vents of the sand mold systems in all effected pouring stations systems in all effected pouring stations and areasand areas

General Compliance General Compliance Requirements Requirements

(§63.7720)(§63.7720)The effected source must be in The effected source must be in

compliance with the:compliance with the:emissions limitationsemissions limitationsWork practice standardsWork practice standardsOperations and maintenance;Operations and maintenance;EXCEPT, EXCEPT, during periods of during periods of

startup, shutdown, and startup, shutdown, and malfunctionmalfunction

General Compliance General Compliance Cont’d. (§63.7720)Cont’d. (§63.7720)

Maintain a log detailing the Maintain a log detailing the operation and maintenance of the operation and maintenance of the process and emissions control process and emissions control equipment related to the initial equipment related to the initial performance test and the applicable performance test and the applicable operatingoperating limits for an effected limits for an effected sourcesource

Initial Compliance Initial Compliance Requirements (§63.7730)Requirements (§63.7730)

A performance test must be conducted A performance test must be conducted no later than 180 calendar days after no later than 180 calendar days after the compliance date specific to an the compliance date specific to an effected sourceeffected source

For each work practice standard and For each work practice standard and operation and maintenance operation and maintenance requirement that applies to an effected requirement that applies to an effected source where an initial performance source where an initial performance test is not demonstrated, the effected test is not demonstrated, the effected source must demonstrate initial source must demonstrate initial compliance no later than 30 calendar compliance no later than 30 calendar days after the specific compliance date days after the specific compliance date for the effected source.for the effected source.

Initial Compliance Initial Compliance (cont’d.)(cont’d.)

For sources constructed or For sources constructed or reconstructed between 12/23/2002 reconstructed between 12/23/2002 and 04/22/2004, compliance must be and 04/22/2004, compliance must be demonstrated no later than demonstrated no later than 10/19/2004 or no later than 180 10/19/2004 or no later than 180 calendar days after startup of the calendar days after startup of the source, whichever is later.source, whichever is later.

Initial Compliance Initial Compliance (cont’d.)(cont’d.)

If construction or reconstruction If construction or reconstruction commenced between 12/23/2002 and commenced between 12/23/2002 and 04/22/2004, and the source chooses 04/22/2004, and the source chooses the option to comply with the the option to comply with the propose emissions limit, a second propose emissions limit, a second performance test must be conducted performance test must be conducted to demonstrate compliance with the to demonstrate compliance with the promulgated emissions limit by promulgated emissions limit by 10/19/2007 or after startup of the 10/19/2007 or after startup of the source, whichever is later.source, whichever is later.

Additional Performance Additional Performance Test Requirements Test Requirements

(§63.7731)(§63.7731) The effected source must conduct The effected source must conduct

subsequent performance tests to subsequent performance tests to demonstrate compliance with;demonstrate compliance with;All applicable PM or Total metal HAP, All applicable PM or Total metal HAP,

VOHAP and TEA emissions limitations VOHAP and TEA emissions limitations at least every (5) yearsat least every (5) years

If a CEM is used, the (5) year If a CEM is used, the (5) year requirement is not requiredrequirement is not required

The opacity limit for an effected The opacity limit for an effected source at least every (6) months.source at least every (6) months.

Test MethodsTest Methods

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

The procedures in §63.7733The procedures in §63.7733 are are used to establish operating limits for:used to establish operating limits for:Each capture systemEach capture systemEach wet scrubberEach wet scrubberEach combustion deviceEach combustion deviceEach acid wet scrubberEach acid wet scrubber

Test Methods Cont’d.Test Methods Cont’d.

Operating limits for a capture system, Operating limits for a capture system, wet scrubber, acid wet scrubber, or wet scrubber, acid wet scrubber, or combustion device, can be changed if combustion device, can be changed if specific requirements listed in specific requirements listed in §63.7733§63.7733 are met by the effected are met by the effected sourcesource

Compliance with Work Compliance with Work Practice StandardsPractice Standards

Demonstrate initial compliance by Demonstrate initial compliance by certification that “AT all times, the certification that “AT all times, the effected source will purchase and use effected source will purchase and use only certified metal ingots, pig iron, only certified metal ingots, pig iron, slitter, or other materials that do not slitter, or other materials that do not include post consumer automotive include post consumer automotive body scrap, post consumer engine body scrap, post consumer engine blocks, oil filters, oily turnings, lead blocks, oil filters, oily turnings, lead components, mercury switches, components, mercury switches, plastics, or organic liquids”plastics, or organic liquids”

Work Practice Work Practice Standards Cont’d.Standards Cont’d.

The effected source has submitted a The effected source has submitted a written and will operate at all times written and will operate at all times according to that planaccording to that plan

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

Work Practice Work Practice Standards Cont’d.Standards Cont’d.

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

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

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

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

SCRAP CERTIFICATIONSCRAP CERTIFICATION

REPORTSREPORTS

Compliance reports required by Compliance reports required by specific due datesspecific due dates

Startup, Shutdown, Startup, Shutdown, Malfunction Reports Malfunction Reports

[§67751][§67751] Compare to Exceedance or Incident ReportsCompare to Exceedance or Incident Reports A Startup, Shutdown, Malfunction (SSM) A Startup, Shutdown, Malfunction (SSM)

report must be submitted immediately if report must be submitted immediately if there was a startup, shutdown, or there was a startup, shutdown, or malfunction of the control device during the malfunction of the control device during the reporting period that is not consistent with reporting period that is not consistent with the SSM Plan.the SSM Plan.

If actions were consistent with the SSM If actions were consistent with the SSM Plan, the report must be submitted during Plan, the report must be submitted during the required reporting period.the required reporting period.

Emissions Exceedance Emissions Exceedance Reports [§63.10(e)(3)]Reports [§63.10(e)(3)]

Compare to Exceedance or Compare to Exceedance or Incident ReportsIncident Reports

An exceedance report must be An exceedance report must be submitted immediately if there submitted immediately if there was a an incident was a an incident

Records [§63.7752]Records [§63.7752]

An effected facility is required to keep An effected facility is required to keep records of reported information and records of reported information and all the other information necessary to all the other information necessary to document compliance with the final document compliance with the final rule for 5 yearsrule for 5 years

There may be additional requirements There may be additional requirements depending on the compliance option depending on the compliance option that is chosen.that is chosen.

Title V ConnectTitle V Connect

Check Facilities that have Federally Check Facilities that have Federally Enforceable LimitsEnforceable Limits

Limited number of Major Facilities; Limited number of Major Facilities; who are they?who are they?

Section 112j, T5 connection (<>3 Section 112j, T5 connection (<>3 years on T5 Permityears on T5 Permit

Section 112j is no longer factor on Section 112j is no longer factor on surface coaterssurface coaters

Title V IssuesTitle V Issues

Each affected source that has Each affected source that has obtained a title V operating permit obtained a title V operating permit required by 40 CFR part 70 or 71 required by 40 CFR part 70 or 71 must report all deviations as defined must report all deviations as defined in the regulation for the semiannual in the regulation for the semiannual monitoring report required by Sec. monitoring report required by Sec. 70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A). (A).

TITLE V (cont’d.)TITLE V (cont’d.) If an affected source submits a compliance If an affected source submits a compliance

report required by Subpart EEEEE along report required by Subpart EEEEE along with, or as part of, the semiannual with, or as part of, the semiannual monitoring report required by Sec. 70.6(a)monitoring report required by Sec. 70.6(a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A), and the (3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A), and the compliance report includes all required compliance report includes all required information concerning deviations from information concerning deviations from any organic HAP emissions limitation any organic HAP emissions limitation (including any operating limit) or work (including any operating limit) or work practice requirement in subpart EEEEE, practice requirement in subpart EEEEE, submission of the compliance report shall submission of the compliance report shall be deemed to satisfy any obligation to be deemed to satisfy any obligation to report the same deviations in the report the same deviations in the semiannual monitoring report. In other semiannual monitoring report. In other words, no double jeopardy.words, no double jeopardy.

TITLE V (cont’d.)TITLE V (cont’d.)

However, submission of a However, submission of a compliance report shall not compliance report shall not otherwise affect any obligation the otherwise affect any obligation the affected source may have to report affected source may have to report deviations from permit requirements deviations from permit requirements to the permitting authority.to the permitting authority. (THIS IS (THIS IS VERY IMPORTANT)VERY IMPORTANT)

Title V Compliance Title V Compliance Report ExampleReport Example

For each affected source that is subject to For each affected source that is subject to permitting requirements required by 40 permitting requirements required by 40 CFR part 70 or 71, and if the permitting CFR part 70 or 71, and if the permitting authority has established dates for authority has established dates for submitting semiannual reports required submitting semiannual reports required by Sec. 70.6 (a)(3)(iii)(A) or Sec. 71.6(a)by Sec. 70.6 (a)(3)(iii)(A) or Sec. 71.6(a)(3)(iii)(A), you may submit the first and (3)(iii)(A), you may submit the first and subsequent compliance reports according subsequent compliance reports according to the dates the permitting authority has to the dates the permitting authority has established instead of according to the established instead of according to the dates in paragraphs (b)(1) through (4) of dates in paragraphs (b)(1) through (4) of this section. this section. (NOTE WELL)(NOTE WELL)

New Source New Source Review/PSD Review/PSD ImplicationsImplications NSR requires stationary sources of air NSR requires stationary sources of air

pollution to apply for permits before they pollution to apply for permits before they can construct/pre-construct/reconstruct. can construct/pre-construct/reconstruct. There are three types of NSR permit There are three types of NSR permit requirements:requirements:PSD permits require for new major PSD permits require for new major

sources, or major modification to an sources, or major modification to an existing source in attainment areas;existing source in attainment areas;

Non-attainment NSR permits for new or Non-attainment NSR permits for new or modifications to existing sources;modifications to existing sources;

Minor source permitsMinor source permits These permits must be included in the Title These permits must be included in the Title

V permit issued to an affected facility.V permit issued to an affected facility.

Section 112j Section 112j ImplicationsImplications

Most States allow the Initial Most States allow the Initial Notification requirements under Notification requirements under Subpart EEEEE to be satisfied by Subpart EEEEE to be satisfied by the Section 112j Notification.the Section 112j Notification.

Pollution Prevention Pollution Prevention OptionsOptions

Remove HAP organic COMPONENTS Remove HAP organic COMPONENTS from core-making operation,from core-making operation,

Reduce the use of recycled Reduce the use of recycled manufactured scrap materials.manufactured scrap materials.