Yes. Table 3 states that section 63.7(c) is applicable, with
(2)(i) requiring the preparation of a Site-Specifi c Test Plan before conducting a required performance test. Note the test plan only needs to be submitted if requested by the ad- ministrator. However, this does not alleviate the metalcaster from complying with any state notifi cation requirements.
Q
Do I need to prepare a Site-Specifi c Test Plan when con- ducting only an opacity test?
A test plan is required when conducting a performance
test, but the General Provisions differentiate between a “performance test” and “visual observations” (e.g. 63.10(d)). Given this and the limited applicability of contents of site-specifi c test plan requirements for visual observations, it appears a site-specifi c test plan would not be required, though feedback from EPA has been requested. Regardless of any requirement, a metalcasting facility should document how it is going to conduct the opacity observations.
tor in writing of the intent to conduct a test at least 60 calendar days before the test is initially scheduled. The administrator at that time can request to review and approve the Site-Specifi c Test Plan and have an observer present. Note there are also requirements to notify EPA should the metalcasting facility be unable to conduct a performance test [63.7(b)].
Q Q Q
and/or a de-mister section. How do I comply with the ini- tial and subsequent inspection requirements? You should document the
Q
wet scrubber does not have a spray nozzle and/or demister section in the O&M Plan. Per section 63.10896(a)(3), the plan must include a descrip- tion of equipment that is to be inspected, making this a good place to document the equip- ment does not exist.
Do I have to notify EPA prior to each visual observation? Yes. A metalcasting facility
must notify the administrator in writing of the anticipated date for conducting the opac- ity observations at least 30 calendar days before the test is scheduled [63.6(h)(4) and 63.9(f)].
Can I elect to use my existing bag leak detection system in-
stead of conducting the baghouse inspection requirements? Yes. The rule allows the use
of a bag leak detection system, but all requirements contained in the rule would need to be met, including preparation of a Site- Specifi c Test Plan [63.10897(d)].
My wet scrubber is not de- signed with a spray nozzle
Do I have to notify EPA prior to each performance test? Yes. A metalcasting facility must notify the administra-
section to maintain records regarding HAP-containing chemi- cal binder or coating materials. Are large facilities required to maintain this information, and if so, by when? For large metalcasting facilities, this requirement is listed
Q
I just bury my head in the sand and hope no one notices? You may want to consult your company’s legal representa-
Q Q
tion, but it is likely more advantageous to submit a document late rather than not at all.
Do I have to complete a semiannual report? If so, when was the initial report due? When are subsequent reports due? The Area Source Rule is not entirely helpful here. While
section 63.10899(c) states you must submit a semiannual com- pliance report “according to the requirements in § 63.10(e), 63.10(e),” which has the heading of “Additional report- ing requirements for sources with continuous monitoring systems,” a number of area source facilities do not have a continuous monitoring system. This would be the case for an existing metalcasting facility with electric induction furnaces controlled by a baghouse that does not elect to use a bag leak detection system. In this case, section 63.10(e) would not be applicable. While this is an issue, the preamble to the fi nal rule (p. 229 and 231) and section 63.10899(c)(3) include language regarding the contents of a semiannual report. Therefore, whether a metalcaster has a continuous monitoring system installed or not, a semiannual report should be submitted. If a facility chose to comply
with the pollution preven- tion management practices for metallic scrap and binder formulations at the last pos- sible date, Jan. 2, 2009, the fi rst report would have been due by July 30 for the period of Jan. 2, 2009-June 30, 2009. Subsequent semiannual reports must be postmarked by the 30th day following the end of each calendar half (i.e. July 30 and January 30) [63.6(e(3)(v)]. MC
For More Information
For large metalcasting facilities, the requirement to maintain records regarding HAP-containing chemical binder or coating mate- rials is listed under the recordkeeping section.
MODERN CASTING / December 2010
The AFS (
www.afsinc.org) and U.S. Environmental Protection Agency (
www.epa.gov/ttn/atw/ mactfnlalph.html) websites
provide additional information on the Foundry Area Source Rule.
31
under the recordkeeping section. While a defi nite answer cannot be provided, at a minimum a large metalcasting facil- ity would want to begin keeping records on its compliance date as determined above [63.10899(b)(5)].
I have missed making submittals of Notifi cation of Compli- ance Status and/or semiannual reports in the past. Should
For small metalcasting facilities, there is a requirement in the management practices and compliance requirements
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