Transcript NESHAP Title - Illinois Environmental Protection Agency

IRON & STEEL FOUNDRY
MACT OVERVIEW
40 CFR PART 63, SUBPART EEEEE
INTRO
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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!!!!!
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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?
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Rule applicability
NSR,NSPS & NESHAP focus
 Covered operations
 Operations not covered
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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
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Review (cont’d.)
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Facility Inspection Protocol
Pre-Inspection Review
 Facility File Review
 Facility Inspection
 Post-Inspection Meeting
 Follow-up
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Frequently asked questions
TYPICAL FACILITY
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Video: 12 minute video on “The
Process of Metal Casting”
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Cast Metals Institute (CMI)
APPLICABILITY: Who is covered by
this rule? (Subpart EEEEEE, §63.7681)
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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.
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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.
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What are Some Operations’
Emissions Impacted by Subpart
EEEEE?
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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
1.
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 preheater 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.)
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)
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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.
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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.
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Emissions Limitations
(cont’d.)
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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.)
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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.)
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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.)
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For building or structure housing, ANY emissions
source must not discharge any fugitive emissions
that exhibit greater than 20 % opacity on a 6minute 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.)
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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.)
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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.)
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For each new or existing Triethylamine (TEA) cold
box mold or core making line, the facility must
(Cont’d.);
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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
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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.)
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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)
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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.
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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)
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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.)
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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