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DRAFT IRON & STEEL FOUNDRY MACT FACILITY INSPECTIONS

This guide provides information on inspections at iron and steel foundries for compliance with 40 CFR Part 63, Subpart EEEEE. It covers inspections at metal melting furnaces, scrap pre-heaters, pouring areas, mold and core making lines, mold and core coating lines, and capture and collection systems. The guide includes information on work practice standards compliance, scrap receiving and inspection, material transport, excess materials handling, and general maintenance and repair. It also provides information on typical control systems and performance testing requirements.

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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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