NESHAP for Area Sources – Iron & Steel Foundries

Most of the National Emission Standards for Hazardous Air Pollutants (NESHAPs) promulgated to date apply to major sources emitting at least 10 tons per year of an individual HAP or 25 tons per year of total HAP. EPA has recently begun focusing on area sources, which by definition are not major sources. Numerous regulations will be promulgated in the coming year or so. To see if your industry is/will be affected, please refer to the links at the end of this article.

EPA finalized an area source regulation for Iron and Steel Foundries on January 2, 2008. The requirements vary by size. Small foundries are defined as having an annual metal melt production of 20,000 tons or less. Large foundries are ones with an annual metal melt production of greater than 20,000 tons. Facilities are to use 2008 production data for their initial classification. Below is a summary of the requirements:

Small Foundries:

Scrap Metal Pollution Prevention Management Practices: Must come into compliance by January 2, 2009. The regulation establishes material acquisition requirements that are designed to prevent the melting of scrap material containing HAPs. There are a couple of options for how your facility can establish its material specifications. Briefly, EPA is concerned with the use of certain types of scrap with a potential of containing HAPs: post-consumer automotive body scrap, engine blocks & oil filters, oily turnings, lead components, chlorinated plastics and free liquids.

Mercury Switches Pollution Prevention: Must come into compliance by January 4, 2010. Requires that scrap from motor vehicles be purchased from suppliers who are participating in an approved program for removing mercury switches.

Alcohol Warm Box Mold & Core making lines: Must come into compliance by January 2, 2009. These lines may no longer use a catalyst formulation that contains methanol.

Recordkeeping & Reporting: Various recordkeeping and reporting requirements apply – including semi-annual compliance reports. Initial notification of applicability is due no later than May 1, 2008.

Large Foundries:

Must comply with all of the requirements for small foundries. In addition, if your facility is classified as a large facility in 2008, you must come into compliance with the requirements below by January 2011.

Emission Limitations: Particulate Matter (PM) and total Metal HAP emission limits on cupolas, EAF, EIF, and similar devices. Fugitive emissions opacity limit for each building or structure that houses foundry operations.

Operation and Maintenance: Each control device used to comply with this regulation must have an Operation and maintenance plan.

Monitoring Requirements: Existing sources must conduct initial and periodic inspections of PM control equipment. A CPMS is required for new sources.

Performance Tests: Performance tests on control equipment is required.

Recordkeeping & Reporting: Various recordkeeping and reporting requirements related to the requirements above.

EES is available to assist your foundry in developing a compliance plan and the preparation of the various plans and reports required in this regulation. If you would like more details, please contact us at 215-881- 9401.

Link to EPA’s Area Source Standards Web-site
Federal Register Notice

Number 47 part 2

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