Transcript NESHAP Title - Illinois Environmental Protection Agency

DRAFT IRON & STEEL
FOUNDRY MACT FACILITY
INSPECTIONS
40 CFR PART 63, SUBPART EEEEE
Inspections at Effected
Sources
Sources; Metal Melting Furnaces, Scrap
Pre-heaters, pouring areas, Mold and
Core Making Lines, and mold and Core
Coating Lines.
Capture and Collection Systems
Fugitive Emissions from Foundry
Operations
Inspections at Effected
Sources
Work Practice standards compliance
Scrap receiving, inspection and
certification
Material transport
Excess materials handling
General M/R
Photos of Facilities
Typical Control Systems
Emission Capture Systems: Ductwork,
Dampers, Sensors and Hooding.
Control Devices; Fabric Filters,
Scrubbers, Electrostatic Precipitators,
Cyclones, Condensers and Thermal
Oxidizers.
Automatic ignition sources for mold
shake-out vents
Typical Control Systems
(Cont’d.)
Subpart EEEEE requires specific data
and compliance calculations for each of
the above control systems. O & M
plans for these systems are also
required in the regulation.
Performance Testing
To be performed for all emission
sources subject to an emission limit.
PM measurement using EPA Methods
1- 4 and either 5, 5B, 5D, 5F, or 5I or 29
as applicable.
Method 25 for TGNMO (as Hexane) or
25A to measure TOC (as Hexane).
Performance Testing
Cont’d.
Use of Method 18 to determine VOHAP.
Facilities using CO or VOC CEMS;
Demonstrate compliance by conducting
CEMS performance evaluation.
Testing to be performed every 5 years.
Pre-Inspection Procedures
File Review
MACT Initial Notification Report
Initial Compliance Status Report
Performance Test Report
Continuing Compliance Report
Title V Reports
VOC/HAP reduction through
NSPS/MACT implementation
Regulation Review
Equipment Checks
Facility File Review
Semi-Annual Reports
Control Equipment Removal Reports
Previous Inspection Reports
Enforcement Action

Complaints
Notice of Violations
Enforcement Action taken
Facility File Review
Cont’d.
Variance history
Compliance test data
Equipment Malfunction reports
SSM Plan and any events
Permit to construct P/C and permit to
operate P/O
Collection and control system design plan
Entry
Enter by public access route
Identify yourself, present your
credentials
Ask to meet with the site
representative
Pre-Inspection Meeting
Explain purpose of inspection
and discuss any new rule changes
Answer questions that the source
personnel may have
Identify any equipment to be
used in the inspection
Pre-Inspection Meeting
Information
Verify facility information
Facility name, ownership
Facility address, telephone number
Facility contact name, telephone
number
Discuss safety procedures
Pre-Inspection Meeting
Information Cont’d.
Review Permit
Verify
 that permit is current and posted
 that permit is for correct equipment
 that permit operating conditions
are being met
 date permit issued
 Equipment capacity/throughput
information
Pre-Inspection Meeting
Review permit specification from
office to on-site
Emission limits to be met
Changes/modifications to
permit conditions
Site-specific monitoring
requirements
Pre-Inspection Meeting
Cont’d.
Operational Logs
Historical emission records and self
monitoring data available
Monitoring and calibration logbooks
On-site Physical Inspection
Collection and control equipment.
Comparison between source records
and visual inspection.
Observation of leaks and maintenance
Photographic documentation.
Operation according to site specific
collection system and design plan.
Post-Inspection Meeting
Note deficiencies related to physical
inspection or document review.
Advise source representative of any
additional concerns that you might
have.
Request additional information for
identified issues and copies of any
needed relevant documents.
Inspection/Documentation
Report
Each violation recorded
Recommendations for source test or
engineering evaluation
Assessment of fugitive emissions and
potential impacts
Additional Training
Resources
http://www.gov/compliance
http://www.gov/oar/oaqps/eog
http://64.27.125.175/
• Other Consortiums
- LADCO