increase fugitive emissions [63.10898(b) and 63.10898(i)].


averaging group? The rule provides for three possibilities. If the furnace has been previously tested (meaning emis-


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sions were previously captured and either uncontrolled or tested prior to controls), you must use those results. If the furnace has not been previously tested, use the


default emissions factor provided by the rule. Use the test results from a similar


electric induction furnace to develop an emissions factor assuming the test was conducted in a manner that meets the requirements provided in 63.10898(a)(4).


mance test to meet Foundry Area Source Rule requirements, must I always con- duct an opacity observation? Yes. Both Table 1 and the General


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If I am conducting a particulate matter or total metal HAP perfor-


What emissions factors may I use for an uncontrolled electric induction furnace that is part of an emission


visible emissions or must I measure all such points? If I have metalcasting operations in multiple buildings, must I conduct an opacity test on all of the individual buildings? Yes. The rule allows an observer to identify a limited


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If you have missed making submittals of Notification of Compliance Status and/ or semiannual reports in the past, it is likely more advantageous to submit a document late rather than not at all.


Provision requirements state that dur- ing any particulate matter or total metal HAP performance test, the facility must conduct the opacity observation concurrently with the performance test unless the opacity observation could not be conducted for a speci- fied reason [Table 1 2.a.ii and 63.6(h)(5)(i)].


ticulate matter or total metal HAP, if a written notification is provided no later than 60 days after the compliance date. Must I have a Method 9 conducted to request the use of a previous stack test? No. The rule discusses submission of a previous perfor-


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mance test for particulate matter or total metal HAPs and not opacity. Also, Table 1 2.a.ii, provides that the opacity test be conducted with the performance test, “if applicable” [63.6(h)(5)(i)].


What is the duration of the initial and subsequent opacity observations?


The Foundry Area Source Rule does not provide the dura-


tion of the initial or subsequent opacity observations. The General Provisions indicate the duration of the initial opacity observation is three one-hour test periods. EPA has stated that three one-hour test periods are expected for subsequent visible observations for Method 9 or Method 22. EPA stated it will address this issue in the future, should the rule be amended [Table 1 2.b and 63.7(g)(5)(ii)].


Can I start out using a Method 22 visible observation, or must I conduct a Method 9 for my initial test?


The rule does not differentiate by test method between


initial and subsequent opacity observations, so a Method 22 is permissible during the initial observations. If a facility decides to use a Method 22 for initial (or subsequent) opacity observations, it may be beneficial to conduct the test at least 15 days prior to your compliance date (or at the end of a six-month period for subsequent tests). This 15-day period would allow the facility to schedule and conduct a Method 9 should the Method 22 result in visible emissions greater than 10% of the sampling period. [Table 1 2.b.]


30


Section 63.10898(a)(1) of the rule allows a facility to submit the results of a prior performance test for par-


Status, how do I report my initial compliance test results? Section 63.108989(j) states you must certify in your


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“performance test report” that the capture system operated normally during the performance test. Section 63.10898(a) requires the results be reported with the Notification of Compliance Status, which is supported by the General Provi- sion requirements provided in 63.7(g)(1). To reconcile the two requirements, a facility should submit the performance testing results in a notification using the applicable Table 4 language and indicate the capture system operated normally during the performance test.


it be submitted? The Foundry Area Source Rule does not provide any guid-


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ance directly on this matter, but Table 3 identifies a portion of the General Provisions as applicable. Per 63.10(d)(3), a facility should report the results before the close of business on the 30th


day following the completion of the observations.


If opacity observations are conducted with a performance test, the opacity and performance test results are due before the close of business on the 60th


day following the comple-


tion of the performance test, unless specified otherwise by the standard or in writing by the administrator.


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To whom should I submit the results of my opacity ob- servations?


While it is clear the results of a performance test should


be submitted to the EPA region until a Title V permit is issued and then the state (as long as the state has an ap- proved Title V program), the General Provisions do not indicate where to send opacity observations. Therefore, submit them per the performance test requirement.


Do I need a Site-Specific Test Plan for initial performance tests?


MODERN CASTING / December 2010


Do I need to submit my semi-annual opacity results or just keep them on file? If a report is due, by when must


number of openings or vents that appear to have the high- est visible emissions or, alternatively, “a single observation for the entire building or structure may be performed, if the fugitive release points afford such an observation.” Because both of the above options are limited to a “building or structure,” if you have multiple buildings with metalcasting operations, multiple opacity readings would be necessary [Table 1 2.b.i.].


emissions. By what date must the initial opacity observations be conducted? Section 63.10898(h) requires a


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facility to conduct an opacity test for fugitive emissions according to the requirements in 63.6(h)(5). Section 63.6(h)(5)(i)(A) states that an opacity


test is due within 120 days if no performance test is required.


Given the rule discusses a performance test report and also requires reporting results via a Notification of Compliance


Per 63.10898(a)(1), I am using a previous performance test for stack


When conducting opacity observations, can I pick fugitive egress points, windows, openings or vents with the highest


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