1. IRON & STEEL FOUNDRY MACT COMPLIANCE ASSURANCE
40 CFR PART 63, SUBPART EEEEE

2. 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.

3. Compliance Dates Cont’d.
ALERT !!!!! Existing source requirement to comply with work practice standards in § (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.

4. 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 § Some of these notifications must be submitted before the effected source compliance date.

5. 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.

6. O & M Requirements Cont’d.
Each plan must contain the elements required in §
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

7. O & M Requirements Cont’d.
Each plan must contain the elements required in § – 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

8. 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

9. 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

10. 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.

11. 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.

12. 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.

13. 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.

14. Test Methods
Subpart EEEEE clearly defines the test methods and other procedures in § used to demonstrate initial compliance with the emissions limitations
The procedures in § are used to establish operating limits for:
Each capture system
Each wet scrubber
Each combustion device
Each acid wet scrubber

15. 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 § are met by the effected source

16. 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”

17. 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

18. 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.

19. SCRAP CERTIFICATION

20. REPORTS
Compliance reports required by specific due dates

21. 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.

22. 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

23. Records [§ ]
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.

24. 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

25. 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).

26. 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.

27. 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)

28. 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 (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)

29. New Source Review/PSD Implications
NSR requires stationary sources of air pollution to apply for permits before they can construct/pre-construct/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.

30. Section 112j Implications
Most States allow the Initial Notification requirements under Subpart EEEEE to be satisfied by the Section 112j Notification.

31. Pollution Prevention Options
Remove HAP organic COMPONENTS from core-making operation,
Reduce the use of recycled manufactured scrap materials.