DRAFT IRON & STEEL FOUNDRY MACT FACILITY INSPECTIONS 40 CFR PART 63, SUBPART EEEEE.

DRAFT IRON & STEEL DRAFT IRON & STEEL FOUNDRY MACT FACILITY FOUNDRY MACT FACILITY

INSPECTIONSINSPECTIONS

40 CFR PART 63, SUBPART EEEEE40 CFR PART 63, SUBPART EEEEE

Inspections at Effected Inspections at Effected SourcesSources

Sources; Metal Melting Furnaces, Scrap Sources; Metal Melting Furnaces, Scrap Pre-heaters, pouring areas, Mold and Pre-heaters, pouring areas, Mold and Core Making Lines, and mold and Core Core Making Lines, and mold and Core Coating Lines.Coating Lines.

Capture and Collection SystemsCapture and Collection Systems

Fugitive Emissions from Foundry Fugitive Emissions from Foundry OperationsOperations

Inspections at Effected Inspections at Effected SourcesSources

Work Practice standards complianceWork Practice standards compliance

Scrap receiving, inspection and Scrap receiving, inspection and certificationcertification

Material transportMaterial transport

Excess materials handlingExcess materials handling

General M/RGeneral M/R

Photos of Facilities Photos of Facilities

Typical Control SystemsTypical Control Systems

Emission Capture Systems: Ductwork, Emission Capture Systems: Ductwork, Dampers, Sensors and Hooding.Dampers, Sensors and Hooding.

Control Devices; Fabric Filters, Control Devices; Fabric Filters, Scrubbers, Electrostatic Precipitators, Scrubbers, Electrostatic Precipitators, Cyclones, Condensers and Thermal Cyclones, Condensers and Thermal Oxidizers. Oxidizers.

Automatic ignition sources for mold Automatic ignition sources for mold shake-out ventsshake-out vents

Typical Control Systems Typical Control Systems (Cont’d.)(Cont’d.)

Subpart EEEEE requires specific data Subpart EEEEE requires specific data and compliance calculations for each of and compliance calculations for each of the above control systems. O & M the above control systems. O & M plans for these systems are also plans for these systems are also required in the regulation.required in the regulation.

Performance TestingPerformance Testing

To be performed for all emission To be performed for all emission sources subject to an emission limit.sources subject to an emission limit.

PM measurement using EPA Methods PM measurement using EPA Methods 1- 4 and either 5, 5B, 5D, 5F, or 5I or 29 1- 4 and either 5, 5B, 5D, 5F, or 5I or 29 as applicable. as applicable.

Method 25 for TGNMO (as Hexane) or Method 25 for TGNMO (as Hexane) or 25A to measure TOC (as Hexane). 25A to measure TOC (as Hexane).

Performance Testing Performance Testing Cont’d.Cont’d.

Use of Method 18 to determine VOHAP.Use of Method 18 to determine VOHAP.

Facilities using CO or VOC CEMS; Facilities using CO or VOC CEMS; Demonstrate compliance by conducting Demonstrate compliance by conducting CEMS performance evaluation. CEMS performance evaluation.

Testing to be performed every 5 years.Testing to be performed every 5 years.

Pre-Inspection ProceduresPre-Inspection Procedures

File ReviewFile ReviewMACT Initial Notification ReportMACT Initial Notification ReportInitial Compliance Status ReportInitial Compliance Status ReportPerformance Test ReportPerformance Test ReportContinuing Compliance ReportContinuing Compliance ReportTitle V ReportsTitle V ReportsVOC/HAP reduction through VOC/HAP reduction through NSPS/MACT implementationNSPS/MACT implementation

Regulation ReviewRegulation ReviewEquipment ChecksEquipment Checks

Facility File ReviewFacility File Review

Semi-Annual ReportsSemi-Annual ReportsControl Equipment Removal ReportsControl Equipment Removal ReportsPrevious Inspection ReportsPrevious Inspection ReportsEnforcement ActionEnforcement Action

ComplaintsComplaintsNotice of ViolationsNotice of Violations

Enforcement Action takenEnforcement Action taken

Facility File Review Facility File Review Cont’d.Cont’d.

Variance historyVariance historyCompliance test dataCompliance test dataEquipment Malfunction reportsEquipment Malfunction reportsSSM Plan and any eventsSSM Plan and any eventsPermit to construct P/C and permit to Permit to construct P/C and permit to operate P/Ooperate P/OCollection and control system design planCollection and control system design plan

EntryEntry

Enter by public access routeEnter by public access route

Identify yourself, present your Identify yourself, present your credentials credentials

Ask to meet with the site Ask to meet with the site representativerepresentative

Pre-Inspection MeetingPre-Inspection Meeting

Explain purpose of inspection Explain purpose of inspection and discuss any new rule changesand discuss any new rule changes

Answer questions that the source Answer questions that the source personnel may have personnel may have

Identify any equipment to be Identify any equipment to be used in the inspectionused in the inspection

Pre-Inspection MeetingPre-Inspection MeetingInformationInformation

Verify facility informationVerify facility information

Facility name, ownershipFacility name, ownership

Facility address, telephone numberFacility address, telephone number

Facility contact name, telephone Facility contact name, telephone numbernumber

Discuss safety proceduresDiscuss safety procedures

Pre-Inspection Meeting Pre-Inspection Meeting Information Cont’d.Information Cont’d.

Review Permit Review Permit Verify Verify

that permit is current and postedthat permit is current and posted that permit is for correct equipmentthat permit is for correct equipment that permit operating conditions that permit operating conditions

are being metare being met date permit issueddate permit issued Equipment capacity/throughput Equipment capacity/throughput

informationinformation

Pre-Inspection MeetingPre-Inspection Meeting

Review permit specification Review permit specification from office to on-site from office to on-site

Emission limits to be metEmission limits to be met

Changes/modifications to Changes/modifications to permit conditionspermit conditions

Site-specific monitoring Site-specific monitoring requirementsrequirements

Pre-Inspection Meeting Pre-Inspection Meeting Cont’d.Cont’d.

Operational LogsOperational LogsHistorical emission records and self Historical emission records and self monitoring data available monitoring data available

Monitoring and calibration logbooksMonitoring and calibration logbooks

On-site Physical InspectionOn-site Physical Inspection

Collection and control equipment.Collection and control equipment.

Comparison between source records Comparison between source records and visual inspection.and visual inspection.

Observation of leaks and maintenanceObservation of leaks and maintenance

Photographic documentation.Photographic documentation.

Operation according to site specific Operation according to site specific collection system and design plan.collection system and design plan.

Post-Inspection MeetingPost-Inspection Meeting

Note deficiencies related to physical Note deficiencies related to physical inspection or document review.inspection or document review.Advise source representative of any Advise source representative of any additional concerns that you might additional concerns that you might have.have.Request additional information for Request additional information for identified issues and copies of any identified issues and copies of any needed relevant documents.needed relevant documents.

Inspection/Documentation Inspection/Documentation ReportReport

Each violation recordedEach violation recorded

Recommendations for source test or Recommendations for source test or engineering evaluationengineering evaluation

Assessment of fugitive emissions and Assessment of fugitive emissions and potential impactspotential impacts

Additional Training Additional Training ResourcesResources

http://www.gov/compliancehttp://www.gov/compliance

http://www.gov/oar/oaqps/eoghttp://www.gov/oar/oaqps/eog

http://64.27.125.175/http://64.27.125.175/ - LADCO - LADCO

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