Transcript NESHAP Title - Illinois Environmental Protection Agency

IRON & STEEL
FOUNDRY MACT
COMPLIANCE
ASSURANCE
40 CFR PART 63, SUBPART EEEEE
Compliance 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.

Compliance 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.
Compliance 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.
 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.

O & M Requirements Cont’d.

Each plan must contain the elements
required in §63.7710
Equipment monthly inspections
 Operating limits for each capture system
 Appropriate operating limit parameters and
design scope, i.e., control of multiple emissions
sources
 Preventative maintenance plan for each control
device including the manufacturer’s
recommended maintenance instructions

O & M Requirements Cont’d.

Each plan must contain the elements
required in §63.7710 – Cont’d.
A site-specific maintenance plan for each bag
leak detection system
 Corrective action for each bag-house
 Procedures for providing an ignition source to
mold vents of the sand mold systems in all
effected pouring stations and areas

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
General Compliance Cont’d.
(§63.7720)

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 an
effected source
Initial Compliance
Requirements (§63.7730)


A performance test must be conducted no
later than 180 calendar days after the
compliance date specific to an effected
source
For each work practice standard and
operation and maintenance requirement that
applies to an effected source where an initial
performance test is not demonstrated, the
effected source must demonstrate initial
compliance no later than 30 calendar days
after the specific compliance date for the
effected source.
Initial Compliance
(cont’d.)

For sources constructed or reconstructed
between 12/23/2002 and 04/22/2004,
compliance must be demonstrated no later
than 10/19/2004 or no later than 180
calendar days after startup of the source,
whichever is later.
Initial Compliance
(cont’d.)

If construction or reconstruction
commenced between 12/23/2002 and
04/22/2004, and the source chooses the
option to comply with the propose
emissions limit, a second performance test
must be conducted to demonstrate
compliance with the promulgated
emissions limit by 10/19/2007 or after
startup of the source, whichever is later.
Additional Performance Test
Requirements (§63.7731)

The effected source must conduct subsequent
performance tests to demonstrate compliance
with;
 All applicable PM or Total metal HAP, VOHAP
and TEA emissions limitations at least every
(5) years
 If a CEM is used, the (5) year requirement
is not required
 The opacity limit for an effected source at
least every (6) months.
Test Methods
Subpart EEEEE clearly defines the test
methods and other procedures in
§63.7732 used to demonstrate initial
compliance with the emissions limitations
 The procedures in §63.7733 are used to
establish operating limits for:

Each
 Each
 Each
 Each

capture system
wet scrubber
combustion device
acid wet scrubber
Test Methods Cont’d.

Operating limits for a capture system, wet
scrubber, acid wet scrubber, or combustion
device, can be changed if specific
requirements listed in §63.7733 are met
by the effected source
Compliance with Work
Practice Standards

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”
Work Practice Standards
Cont’d.
The effected source has submitted a
written and will operate at all times
according to that plan
 The effected source meets the no
methanol requirement for the catalyst
portion of the binder chemical formulation

Work Practice Standards
Cont’d.
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.

SCRAP CERTIFICATION
REPORTS

Compliance reports required by specific
due dates
Startup, Shutdown,
Malfunction Reports [§67751]



Compare to Exceedance or Incident Reports
A Startup, Shutdown, Malfunction (SSM) report
must be submitted immediately if there was a
startup, shutdown, or malfunction of the
control device during the reporting period that
is not consistent with the SSM Plan.
If actions were consistent with the SSM Plan,
the report must be submitted during the
required reporting period.
Emissions Exceedance
Reports [§63.10(e)(3)]
Compare to Exceedance or Incident
Reports
 An exceedance report must be
submitted immediately if there was a
an incident

Records [§63.7752]
An effected facility is required to keep
records of reported information and all the
other information necessary to document
compliance with the final rule for 5 years
 There may be additional requirements
depending on the compliance option that is
chosen.

Title V Connect
Check Facilities that have Federally
Enforceable Limits
 Limited number of Major Facilities; who
are they?
 Section 112j, T5 connection (<>3 years on
T5 Permit
 Section 112j is no longer factor on surface
coaters

Title V Issues

Each affected source that has obtained a
title V operating permit required by 40 CFR
part 70 or 71 must report all deviations as
defined in the regulation for the
semiannual monitoring report required by
Sec. 70.6(a)(3)(iii)(A) or Sec.
71.6(a)(3)(iii)(A).
TITLE V (cont’d.)

If an affected source submits a compliance
report required by Subpart EEEEE along with,
or as part of, the semiannual monitoring
report required by Sec. 70.6(a)(3)(iii)(A) or
Sec. 71.6(a)(3)(iii)(A), and the compliance
report includes all required information
concerning deviations from any organic HAP
emissions limitation (including any operating
limit) or work practice requirement in subpart
EEEEE, submission of the compliance report
shall be deemed to satisfy any obligation to
report the same deviations in the semiannual
monitoring report. In other words, no double
jeopardy.
TITLE V (cont’d.)

However, submission of a compliance
report shall not otherwise affect any
obligation the affected source may have to
report deviations from permit
requirements to the permitting authority.
(THIS IS VERY IMPORTANT)
Title V Compliance Report
Example

For each affected source that is subject to
permitting requirements required by 40 CFR
part 70 or 71, and if the permitting authority
has established dates for submitting semiannual
reports required by Sec. 70.6 (a)(3)(iii)(A) or
Sec. 71.6(a)(3)(iii)(A), you may submit the first
and subsequent compliance reports according
to the dates the permitting authority has
established instead of according to the dates in
paragraphs (b)(1) through (4) of this section.
(NOTE WELL)
New Source Review/PSD
Implications


NSR requires stationary sources of air pollution to
apply for permits before they can construct/preconstruct/reconstruct. There are three types of
NSR permit requirements:
 PSD permits require for new major sources, or
major modification to an existing source in
attainment areas;
 Non-attainment NSR permits for new or
modifications to existing sources;
 Minor source permits
These permits must be included in the Title V
permit issued to an affected facility.
Section 112j Implications

Most States allow the Initial
Notification requirements under
Subpart EEEEE to be satisfied by the
Section 112j Notification.
Pollution Prevention
Options
Remove HAP organic COMPONENTS from
core-making operation,
 Reduce the use of recycled manufactured
scrap materials.
