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 (Contd.) 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 Contd. 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 Complaints Notice of Violations Notice of Violations Enforcement Action taken

Facility File Review Contd. 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 Contd. Review Permit Verify that permit is current and posted that permit is current and posted that permit is for correct equipment that permit is for correct equipment that permit operating conditions are being met that permit operating conditions are being met date permit issued date permit issued Equipment capacity/throughput information 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 Contd. 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

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