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DRAFT IRON & STEEL FOUNDRY MACT FACILITY INSPECTIONS

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

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DRAFT IRON & STEEL FOUNDRY MACT FACILITY INSPECTIONS

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  1. DRAFT IRON & STEEL FOUNDRY MACT FACILITY INSPECTIONS 40 CFR PART 63, SUBPART EEEEE

  2. 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

  3. Inspections at Effected Sources • Work Practice standards compliance • Scrap receiving, inspection and certification • Material transport • Excess materials handling • General M/R

  4. Photos of Facilities

  5. 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

  6. Typical Control Systems (Cont’d.) • 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.

  7. 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).

  8. Performance Testing Cont’d. • 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.

  9. 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

  10. Facility File Review • Semi-Annual Reports • Control Equipment Removal Reports • Previous Inspection Reports • Enforcement Action • Complaints • Notice of Violations • Enforcement Action taken

  11. Facility File Review Cont’d. • 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

  12. Entry • Enter by public access route • Identify yourself, present your credentials • Ask to meet with the site representative

  13. 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

  14. Pre-Inspection MeetingInformation • Verify facility information • Facility name, ownership • Facility address, telephone number • Facility contact name, telephone number • Discuss safety procedures

  15. Pre-Inspection Meeting Information Cont’d. • Review Permit • Verify • that permit is current and posted • that permit is for correct equipment • that permit operating conditions are being met • date permit issued • Equipment capacity/throughput information

  16. 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

  17. Pre-Inspection Meeting Cont’d. • Operational Logs • Historical emission records and self monitoring data available • Monitoring and calibration logbooks

  18. 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.

  19. 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.

  20. Inspection/Documentation Report • Each violation recorded • Recommendations for source test or engineering evaluation • Assessment of fugitive emissions and potential impacts

  21. Additional Training Resources http://www.gov/compliance http://www.gov/oar/oaqps/eog http://64.27.125.175/ - LADCO • Other Consortiums

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