Aldrich Inc., Ann Arbor, Mich., detailed the specifics of the regula- tion and AFS involvement over the past decade at the 117th Metalcast- ing Congress, held this April during CastExpo’13 in St. Louis. “Subpart UUU’s particulate matter
limitations are not particularly oner- ous compared to other limitations affecting metalcasters,” according to Oman, but he emphasized the impor- tance of maintaining new control
equipment performance levels as a preventive measure. “Records of all monitoring activities
must be retained for at least two years,” Esch explained. “Written reports must be submitted semiannually of exceed- ances of control device required operat- ing parameters.” Esch noted that the NSPS rule’s
preamble includes a discussion that emission sources generating less than 11 tons per year of emissions
could be exempted from the opacity monitoring requirements of Subpart UUU. However, EPA staff have determined this exemption does not apply to thermal sand reclama- tion units. A bipartisan letter from the House of
Representatives was sent in June to EPA Acting Administrator Robert Perciasepe, requesting foundries be exempt from Subpart UUU. AFS also is continuing its discussions with the EPA.
Thermal sand reclamation equipment is regulated under the New Source Performance Standards (NSPS) 40 CFR Part 60, Subpart UUU. June 2013 MODERN CASTING | 35
Photo courtesy of Palmer Manufacturing & Supply
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