1. IRON & STEEL FOUNDRY MACT QUESTION & ANSWERS
40 CFR PART 63, SUBPART EEEEE

2. Questions/Answers Frequently Asked Questions
1. If the facility builds a new building next to a current building, does the new building become a new source?
The best source to answer this question is the facility’s permitting authority because the decision may rest on site specific factors.

3. Q/A (cont’d.)
If the effected facility has determined that the core molds cannot produce a quality casting without the use of methanol in the formulation, does the facility have any options?
The facility can petition USEPA for an alternative methodology to achieve the necessary quality castings. If approved, the facility must codify the alternate in the Title V permit.

4. Q/A (cont’d.)
For facilities that are complex or collated with different FOUNDRY operations, i.e. surface coating operations; chromium and organic HAP coatings, are any consolidation options available to compliance?
Section 112(d)(2) requires that all major sources within a major source category must meet maximum emission reduction determined to be achievable. Therefore, due to the complexity of allowing such options, none are allowed in the rule, but c/c options can be used on a c/c operation basis. This is particularly true under the Title V process.

5. Q/A (cont’d.)
Does a FOUNDRY facility have to comply with the emission limitations during periods of startup, shutdown and malfunction?
The effected facility must be in compliance with the emissions limitations, work practice standards, and operation and maintenance requirements in Subpart EEEEE at all times, EXCEPT during periods of startup, shutdown and malfunction.

6. Q/A (cont’d.)
Does a Subpart EEEEE affected facility have to comply with NSPS requirements?
Since the NESHAP and NSPS regulations focus on different aspects of an affected facility:
Organic and metallic HAP vs PM & VOCs, compliance must be achieved with both regulations.

7. Q/A (cont’d.)
What are the installation, operation and maintenance requirements for the effected source monitors?
For each capture system that is subject to Subpart EEEEE, the facility must install, operate, and maintain each CPMs according to the requirements in §

8. Q/A (cont’d.)
How does the facility demonstrate continuous compliance with the work practice standards that apply to the effected source?
(Answer to next page)

9. Q/A (cont’d.)
The facility must maintain records that document continuous compliance with the certification requirements in § (b) or with the procedures in the scrap selection and inspection plan required in § ©. The records documenting compliance with the scrap selection and inspection plan must include a copy of the procedures used by the scrap supplier for either removing accessible mercury switches or for purchasing automobile bodies that have had mercury switches removed.

10. Q/A (cont’d.)
Can a facility be considered in compliance with the Initial Notification requirement if the facility had filed their Section 112J notice on time?
The Section 112J notice requires additional information above and beyond the Initial Notification requirement. As such, the facility would be considered in compliance with the IN requirement and filing the IN would be redundant.

11. Q/A (cont’d.) What does a deviation from the rule mean?
Deviation means any instance in which an affected source fails to meet any obligations required by Subpart EEEEE. This is not limited to any emissions limitation, work practice standard, or operation and maintenance requirement;
The affected source fails to meet any terms or conditions adopted to implement an applicable under Subpart EEEEE
The affected source fails to meet emissions limitations, including operating limits or work practice standards in this Subpart.

12. Q/A (cont’d.)
If a failure to meet the emissions limitation is permitted by Subpart EEEEE, is the affected source exonerated from the non-compliant condition?
Failure to meet the emissions limitation, including the operating limits or work practice standards during startup, shutdown or malfunction is considered a deviation and must be reported as an exceedance under Subpart EEEEE.

13. Q/A (cont’d.)
If the scrap supplier cannot certify that the scrap delivery is free from mercury switch material because of the cost and difficulty in removing mercury components, is the effected source free to use the suspect scrap material?
Under § of Subpart EEEEE, the effected source must prepare and operate AT ALL TIMES according to a written certification that among other requirements, the source must use only mercury free scrap material.