Transcript NESHAP Title - Illinois Environmental Protection Agency

IRON & STEEL FOUNDRY
MACT QUESTION &
ANSWERS
40 CFR PART 63, SUBPART EEEEE
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.
Q/A (cont’d.)
2. 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.
Q/A (cont’d.)
3.
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.
Q/A (cont’d.)
4. 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.
Q/A (cont’d.)
5. 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.
Q/A (cont’d.)
6. 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
§ 63.7741.
Q/A (cont’d.)
7. How does the facility demonstrate
continuous compliance with the
work practice standards that apply
to the effected source?
(Answer to next page)
Q/A (cont’d.)
The facility must maintain records that
document continuous compliance with the
certification requirements in § 63.7700(b) or
with the procedures in the scrap selection
and inspection plan required in § 63.7700©.
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.
Q/A (cont’d.)
8. 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.
Q/A (cont’d.)
9. 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.
Q/A (cont’d.)
10. 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.
Q/A (cont’d.)
11. 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 §63.7700 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.