IRON & STEEL FOUNDRY MACT OVERVIEW 40 CFR PART 63, SUBPART EEEEE

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

ALERT!!!!! On May 20, 2005, USEPA promulgated the final amendments to the original Subpart EEEEE NESHAP promulgated April 22, 2004. The amendments clarified the Sections §63.7700, §63.7735 and §63.7765. The amendments are intended to reduce compliance uncertainties. Because the work practice standards became effective April 22, 2005 (1 year after promulgation) the clarifications contained in the direct final rule amendments are time-critical.

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

What we are reviewing? Rule applicability NSR,NSPS & NESHAP focus Covered operations Operations not covered Standards to be followed, including work practice standards Operating Limits Important dates Synthetic minor sources

Review (cont’d.) New or existing source determination General rule requirements Initial compliance demonstration Notification, Recordkeeping and Reporting requirements Compliance options Compliance examples

Review (cont’d.) Pre-Inspection Review Facility File Review Facility Inspection Protocol Pre-Inspection Review Facility File Review Facility Inspection Post-Inspection Meeting Follow-up Frequently asked questions

TYPICAL FACILITY Video: 12 minute video on “The Process of Metal Casting” Cast Metals Institute (CMI)

APPLICABILITY: Who is covered by this rule? (Subpart EEEEEE, §63.7681) Own or operate an EFFECTED SOURCE at a facility that is a major source, Located at a major source, or Part of a major source of hazardous air pollutants (HAPs). NSPS for NEW sources of VOC

Effected Source NSPS; FOUNDRY operations involve VOCs NESHAP similar definition; VOCs vs VOHAPs; similar criteria and an increase in stringency Any new or reconstructed source (as defined in § 63.2) before 12/23/2002 is an existing facility and that is a major source and is an iron and steel foundry. Any new or reconstructed source after 12/23/2002 is a new source.

Effected Source (cont’d.) Facility or portion of facility that melts scrap, ingot, and/or other forms of iron and/or steel. Facility pours the resulting molten metal into molds. Mold sand shakeout operations. Final products introduced into commerce.

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

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

EXAMPLES (cont’d.) 2. EXAMPLE: If as foundry casts in multiples of a wide range of alloys, but has a significant iron or steel content, the facility is subject to Subpart EEEEE. The facility should contact the state administrator for guidance. 3. EXAMPLE: USEPA has revised the finalized the designation for effected source to include a broad definition of the iron/steel foundry that eliminates the somewhat artificial separation of the mold and core-making processes which can often occur at close proximity, if not in conjunction with the casting/poring operations.

EXAMPLES (cont’d.) 5. USEPA Applicability Determination Index Site 4. EXAMPLE: The final rule avoids the cases where an existing foundry might make minor equipment changes that could subject one process or a single piece of equipment to the new source emissions limits. 5. USEPA Applicability Determination Index Site http://www.epa.gov/Compliance/ planning/data/air/adi.htm

Compliance with Work Practice Standards (63.7700) Demonstrate initial compliance by certification that “At all times, the effected source will purchase and use only certified metal ingots, pig iron, slitter, or other materials that do not include post consumer automotive body scrap, post consumer engine blocks, oil filters, oily turnings, lead components, mercury switches, plastics, or organic liquids” The effected source has submitted a written and will operate at all times according to that plan

Compliance with Work Practice Standards (63.7700) Cont’d. The effected source meets the no methanol requirement for the catalyst portion of the binder chemical formulation The effected source has demonstrated the furan work practice standard for each furan warm box mold or core making line The effected source has records documenting certification of compliance For each scrap pre-heater, initial compliance has been demonstrated The effected source only charges certified material.

What Standards Require Compliance? (63.7690) Emissions Limitations I. For each existing; electric arc melting furnace Electric induction metal melting furnace, or Scrap pre-heater No emissions discharge that exceed the PM limit of; 0.005 grains on PM per dry standard cubic foot, or 0.0004 gr/dscf of Total metal HAP.

Emissions Limitations (cont’d.) II. For each existing cupola melting furnace, no emissions discharge; 0.006 gr/dscf of PM, or 0.0005 gr/sdcf of Total metal HAP For each new cupola or new electric arc metal melting furnaces; No emissions discharge that exceed the PM limit of 0.002 gr/sdcf of PM, or 0.0002 gr/dscf of Total metal HAP

Emission Limitations (cont’d.) For each new electric induction metal melting furnace or new scrap pre-heater; No emissions discharge to exceed 0.001 gr/dscf of PM; or 0.00008 gr/dscf of Total metal HAP

Emission Limitations (cont’d.) For each existing pouring station, no emissions discharge to exceed; 0.010 gr/dscf of PM; or 0.0008 gr/dscf of Total metal HAP For each new pouring station or area, no emissions discharge to exceed 0.002 gr/dscf of Total PM; or 0.0002 gr/dscf of Total metal HAP

Emission Limitations (cont’d.) For building or structure housing, ANY emissions source must not discharge any fugitive emissions that exhibit greater than 20 % opacity on a 6-minute average EXCEPTION: 1 (6) minute average per hour not to exceed 27 % opacity. For each new or existing cupola metal melting furnace, no emissions discharge of VOHAP to exceed 20 ppm by volume corrected to 10% oxygen.

Emission Limitations (cont’d.) An alternative to the work standards in § 63.7700(e) existing scrap pre-heater and (f) new scrap pre-heater; no emissions discharge of VOHAP to exceed 20 ppmv. A new source automated conveyor and pallet cooling system that uses a sand mold system or automated shake-out lines using a sand mold system must not have emissions that exceed 20 ppmv VOHAP.

Emission Limitations (cont’d.) For each new or existing Triethylamine (TEA) cold box mold or core making line, the facility must; 1. No emissions discharge to exceed 1 ppmv, 2. Reduce emissions of TEA by at least 99%, 3. Install, operate and maintain a capture and collection system for all emission sources subject to an emissions limit 4. Each capture and collection system must meet accepted engineering standards

Emission Limitations (cont’d.) For each new or existing Triethylamine (TEA) cold box mold or core making line, the facility must (Cont’d.); 5. Each combustion device applied to emissions from a scrap pre-heater must be operated at specific criteria for VOHAP emissions 6. Operate each wet acid scrubber applied to the TEA cold box mold or core making line at specific criteria outline in the standard 7. Prepare and submit a monitoring plan for a control device other than a bag-house, wet scrubber, wet acid scrubber or combustion device

Important Dates The final rule was published on April 22, 2004 , under FR21905, Existing major sources must comply with: Emissions limitations; Work practices standard; Operation & Maintenance requirement; Major source status determination; no later than, April 23, 2007.

Important Dates Cont’d. ALERT !!!!! Existing source requirement to comply with work practice standards in §63.7700 (b) or (c) no later than April 22, 2005 New effected sources operating on or before April22, 2004should have complied by April 22, 2004, or startup, whichever was later, New effected sources operating after April 22, 2004, must comply with the regulatory requirements upon startup.

Important Dates (cont’d.) If the Iron & Steel Foundry is an area source, but becomes a major source of HAP, compliance of § 63.6©(5)is upon startup. The effected sources must meet the notification and scheduling requirements in § 63.7750. Some of these notifications must be submitted before the effected source compliance date.

Operations & Maintenance Requirements (§63.7710) Effected facilities must operate and maintain the sources, including air pollution control and monitoring equipment in a manner consistent with good air pollution practices that minimizes air emissions to the level required in Subpart EEEEE.

Operations & Maintenance Requirements (§63.7710) Cont’d. Effected sources must prepare and operate at all times according to a written operation and maintenance plan for each capture and collection control device controlling emissions subject to Subpart EEEEE. Each plan must contain the elements required in §63.7710

General Compliance Requirements (§63.7720) The effected source must be in compliance with the: emissions limitations Work practice standards Operations and maintenance; EXCEPT, during periods of startup, shutdown, and malfunction Maintain a log detailing the operation and maintenance of the process and emissions control equipment related to the initial performance test and the applicable operating limits for a effected source

General Compliance (cont’d.) Initial Compliance Requirements (§63.7730) Additional Performance Test Requirements (§63.7731) Test Methods Subpart EEEEE clearly defines the test methods and other procedures in §63.7732 used to demonstrate initial compliance with the emissions limitations