source facility is designated as “small” if annual metal melt- ing capacity is equal to 10,000 tons or less. An existing area source is designated as small if the actual metal production for a calendar year is equal to 20,000 tons or less.


Area Source FAQs A number of area source rule compliance dates have


passed for small and large metalcasting facilities, such as pollution prevention management practices for metallic scrap and mercury, and additional large facility require- ments are quickly approaching. The following questions and answers address “existing,” “large” source iron and/ or steel casting facilities. (Note: All topics of importance to your operations may not be covered, e.g. wet or dry electrostatic precipitators, so the reader is urged to consult the fi nal rule for applicable requirements.)


Q


tices for large metalcasting facilities? In most cases, each facil-


Q


ity would need to operate a capture and collection system that meets accepted engineering standards for each metal melting furnace and stack and fugitive emis- sion limits [63.10895(b)].


melting furnaces? Not necessarily. For elec-


Q


tric induction furnaces, the rule does provide some options. If the emissions from an electric induction furnace are uncaptured and uncontrolled, the furnace may be part of an emissions averaging group. The facility could install and later remove a temporary enclosure for the purpose of conducting emissions testing. An ad- ditional option would be to test a similar furnace at the facility [63.10898(a)(5) and 63.10898(b)(3)].


Q


Do any other major requirements exist?


In addition to the above,


Electric induction furnaces can be uncontrolled if factors from part of an emission averaging group are used.


MODERN CASTING / December 2010


Must I capture the emis- sions from all my metal


What is the compliance date for the rule’s standards and management practice requirements?


The compliance date is no longer than two years from


the date the metalcasting facility submitted a written notifi - cation to the U.S. Environmental Protection Agency (EPA) identifying the plant as “large.” The last date to make that submission was Jan. 2, 2009. Because the compliance date depends on the submission date, a particular facility’s com- pliance date could be before but no later than Jan. 2, 2011 [63.10881(a)(3)].


What are the standards and management prac-


each capture and collection system must meet accepted engineering standards. The facility must have an Operations and Maintenance (O&M) Plan, and ductwork and control devices must undergo initial and periodic inspections unless a baghouse is used to control emissions from the melting operation and a bag leak detection system is used.


Q Q Q


I’m not a major source. Do the general provisions con- tained in 40 CFR Part 63 Subpart A apply to me?


General Provisions do apply to area sources of HAPs.


Table 3 of the Foundry Area Source Rule provides General Provision rule applicability to large metalcasting facilities. General Provision requirements include the development of a written Site Specifi c Test Plan and Startup, Shutdown and Malfunction Plan.


Weren’t the Startup, Shutdown and Malfunction require- ments vacated by the courts?


The court did vacate a portion of the General Provisions


that provided exemptions to emissions limitations (including opacity) during periods of startup, shutdown and malfunc- tions under certain circumstances. However, a Site Specifi c Test Plan is still required.


Do control device(s) other than those serving melting furnaces need to be included in the O&M Plan?


The rule states an O&M Plan is required for each control device that is subject to a particulate matter, metal HAP or opacity emissions limitation per the rule. The exact meaning of this requirement is still being discussed and will be up- dated in the future.


compliance date? Do any exemptions to testing exist? The rule states you must


Q


conduct the test within 180 days of your compliance date [63.10898(a)]. Some exemptions from testing are provided in the rule [63.10898(a)(1), (a)(3), a(4), (e)(3)] and discussed else- where in this article.


mance/stack testing and opac- ity observation? Stack testing is required


Q


no less frequently than ev- ery fi ve years and each time you elect to change an oper- ating limit or make a process change likely to increase HAP emissions. Testing to demonstrate compliance with the opacity limit is required no less frequently than every six months and each time you make a process change likely to


29


What is the required frequency for perfor-


Must I complete a per- formance test by my


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