plan. EPA has not yet assessed penal- ties for Subpart UUU violations. T e American Foundry Soci-
ety (AFS) took part in a clarifi ca- tion meeting with EPA offi cials this February. AFS had lobbied for metalcasting facilities to be deemed exempt from Subpart UUU, citing the high costs associated with install- ing continuous monitoring equip- ment, among other requirements. AFS reported EPA has determined
Subpart UUU does apply to thermal sand reclamation equipment. Metalcasters need to be aware of
this regulation and its potential eff ect on their operations.
Subpart UUU Requirements T e regulation applies to plants
that process minerals with calciners and/or dryers constructed, modifi ed or reconstructed after April 23, 1986. A mineral processing plant is defi ned
HISTORY OF THE RULE
April 1986—NSPS 40 CFR Part 60, Subpart UUU Rule proposed (in 1985 EPA Background Information Document, foundries were not listed as an affected industry)
1991—EPA Enabling Document; foundry SICs not listed September 1992—Final rule
October 1999—Tennessee Department of Environment and Con- servation, Division of Air Pollution Control, asks EPA for clarifi cation regarding Subpart UUU applicability to foundry operations
January 2000—EPA says it is applicable to metalcasting equipment (if constructed, reconstructed or modifi ed after April 23, 1986)
August 2003—AFS requests EPA revisit determination of applicability; EPA confi rms previous determination
January 2004—AFS tells EPA foundry calciners and dryers
do not meet the Subpart UUU defi nition for these units; EPA confi rms previous determination
March 2006—MDEQ Subpart UUU Enforcement Initiative
May 2006—MDEQ puts Subpart UUU Enforcement Initiative on temporary hold; EPA Air Quality Staff and EPA Enforcement Staff meet to discuss relative positions; consider amending Subpart UUU to exempt foundries
April 2008—EPA proposes new Subpart UUU language: Processes for thermal reclamation of industrial sand at metal foundries are exempt
April 2009—EPA decides to take no further action regarding exemption of foundries from Subpart UUU
August 2010—EPA Region V enforcement activities begin in metalcasting facilities.
Source: “Recent Developments in Regulation and Enforcement of Air Requirements for Thermal Sand Reclaimers and Sand Coolers/Dryers,” presented at the 117th AFS Metalcasting Congress, April 2013
June 2013 MODERN CASTING | 33
as any facility that processes >50% mixtures of minerals, including industrial sand. A calciner is defi ned as equipment that removes chemically bound water or gases from minerals through direct or indirect heating; a dryer removes free water from miner- als through direct or indirect heating. Metalcasters are concerned that the defi nitions could be applied beyond thermal sand reclamation to other processes in their operations.
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