IRON & STEEL IRON & STEEL FOUNDRY MACT FOUNDRY MACT

QUESTION & QUESTION & ANSWERSANSWERS

40 CFR PART 63, SUBPART 40 CFR PART 63, SUBPART EEEEEEEEEE

Questions/AnswersQuestions/Answers

Frequently Asked QuestionsFrequently Asked Questions

1. If the facility builds a new building 1. If the facility builds a new building next to a current building, does the next to a current building, does the new building become a new source?new building become a new source?

The best source to answer this The best source to answer this question is the facility’s permitting question is the facility’s permitting authority because the decision authority because the decision may rest on site specific factors.may rest on site specific factors.

Q/A (cont’d.)Q/A (cont’d.)2.2. If the effected facility has If the effected facility has

determined that the core molds determined that the core molds cannot produce a quality casting cannot produce a quality casting without the use of methanol in the without the use of methanol in the formulation, does the facility have formulation, does the facility have any options?any options?

The facility can petition USEPA for The facility can petition USEPA for an alternative methodology to an alternative methodology to achieve the necessary quality achieve the necessary quality castings. If approved, the facility castings. If approved, the facility must codify the alternate in the must codify the alternate in the Title V permit.Title V permit.

Q/A (cont’d.)Q/A (cont’d.)

3.3. For facilities that are complex or collated For facilities that are complex or collated with different FOUNDRY operations, i.e. with different FOUNDRY operations, i.e. surface coating operations; chromium and surface coating operations; chromium and organic HAP coatings, are any consolidation organic HAP coatings, are any consolidation options available to compliance?options available to compliance?

Section 112(d)(2) requires that all major Section 112(d)(2) requires that all major sources within a major source category sources within a major source category must meet maximum emission reduction must meet maximum emission reduction determined to be achievable. Therefore, determined to be achievable. Therefore, due to the complexity of allowing such due to the complexity of allowing such options, none are allowed in the rule, but options, none are allowed in the rule, but c/c options can be used on a c/c c/c options can be used on a c/c operation basis. This is particularly true operation basis. This is particularly true under the Title V process.under the Title V process.

Q/A (cont’d.)Q/A (cont’d.)

4.4. Does a FOUNDRY facility have to Does a FOUNDRY facility have to comply with the emission limitations comply with the emission limitations during periods of startup, shutdown during periods of startup, shutdown and malfunction?and malfunction?

The effected facility must be in The effected facility must be in compliance with the emissions compliance with the emissions limitations, work practice standards, and limitations, work practice standards, and operation and maintenance operation and maintenance requirements in Subpart EEEEE at all requirements in Subpart EEEEE at all times, times, EXCEPT during periods of EXCEPT during periods of startup, shutdown and malfunction.startup, shutdown and malfunction.

Q/A (cont’d.)Q/A (cont’d.)

5.5. Does a Subpart EEEEE affected Does a Subpart EEEEE affected facility have to comply with NSPS facility have to comply with NSPS requirements?requirements?

Since the NESHAP and NSPS Since the NESHAP and NSPS regulations focus on different regulations focus on different aspects of an affected facility:aspects of an affected facility: Organic and metallic HAP vs PM & Organic and metallic HAP vs PM &

VOCs, compliance must be VOCs, compliance must be achieved with both regulationsachieved with both regulations..

Q/A (cont’d.)Q/A (cont’d.)

6.6. What are the installation, operation What are the installation, operation and maintenance requirements for and maintenance requirements for the effected source monitorsthe effected source monitors??

For each capture system that is For each capture system that is subject to Subpart EEEEE, the subject to Subpart EEEEE, the facility must install, operate, and facility must install, operate, and maintain each CPMs according to maintain each CPMs according to the requirements in § 63.7741.the requirements in § 63.7741.

Q/A (cont’d.)Q/A (cont’d.)

7.7. How does the facility How does the facility demonstrate continuous demonstrate continuous compliance with the work compliance with the work practice standards that apply practice standards that apply to the effected source?to the effected source?

(Answer to next page)(Answer to next page)

Q/A (cont’d.)Q/A (cont’d.)The facility must maintain records that The facility must maintain records that document continuous compliance with document continuous compliance with the certification requirements in § the certification requirements in § 63.7700(b) or with the procedures in the 63.7700(b) or with the procedures in the scrap selection and inspection plan scrap selection and inspection plan required in § 63.7700©. The records required in § 63.7700©. The records documenting compliance with the scrap documenting compliance with the scrap selection and inspection plan must selection and inspection plan must include a copy of the procedures used by include a copy of the procedures used by the scrap supplier for either removing the scrap supplier for either removing accessible mercury switches or for accessible mercury switches or for purchasing automobile bodies that have purchasing automobile bodies that have had mercury switches removed.had mercury switches removed.

Q/A (cont’d.)Q/A (cont’d.)

8.8. Can a facility be considered in Can a facility be considered in compliance with the Initial Notification compliance with the Initial Notification requirement if the facility had filed their requirement if the facility had filed their Section 112J notice on time?Section 112J notice on time?

The Section 112J notice requires The Section 112J notice requires additional information above and additional information above and beyond the Initial Notification beyond the Initial Notification requirement. As such, the facility would requirement. As such, the facility would be considered in compliance with the IN be considered in compliance with the IN requirement and filing the IN would be requirement and filing the IN would be redundant.redundant.

Q/A (cont’d.)Q/A (cont’d.)

9.9. What does a deviation from the rule What does a deviation from the rule mean?mean?

Deviation means any instance in which Deviation means any instance in which an affected source fails to meet any an affected source fails to meet any obligations required by Subpart EEEEE. obligations required by Subpart EEEEE. This is not limited to any emissions This is not limited to any emissions limitation, work practice standard, or limitation, work practice standard, or operation and maintenance operation and maintenance requirement; requirement; The affected source fails to meet any terms The affected source fails to meet any terms

or conditions adopted to implement an or conditions adopted to implement an applicable under Subpart EEEEEapplicable under Subpart EEEEE

The affected source fails to meet emissions The affected source fails to meet emissions limitations, including operating limits or work limitations, including operating limits or work practice standards in this Subpart.practice standards in this Subpart.

Q/A (cont’d.)Q/A (cont’d.)

10.10.If a failure to meet the emissions If a failure to meet the emissions limitation is permitted by Subpart limitation is permitted by Subpart EEEEE, is the affected source EEEEE, is the affected source exonerated from the non-compliant exonerated from the non-compliant condition?condition?

Failure to meet the emissions limitation, Failure to meet the emissions limitation, including the operating limits or work including the operating limits or work practice standards during startup, practice standards during startup, shutdown or malfunction is considered a shutdown or malfunction is considered a deviation and must be reported as an deviation and must be reported as an exceedance under Subpart EEEEE. exceedance under Subpart EEEEE.

Q/A (cont’d.)Q/A (cont’d.)11.11. If the scrap supplier cannot certify that If the scrap supplier cannot certify that

the scrap delivery is free from mercury the scrap delivery is free from mercury switch material because of the cost and switch material because of the cost and difficulty in removing mercury difficulty in removing mercury components, is the effected source free components, is the effected source free to use the suspect scrap material?to use the suspect scrap material?

Under §63.7700 of Subpart EEEEE, the Under §63.7700 of Subpart EEEEE, the effected source must prepare and effected source must prepare and operate operate AT ALL TIMES according to AT ALL TIMES according to a written certification that among a written certification that among other requirements, the source other requirements, the source must use only mercury free scrap must use only mercury free scrap material.material.