DRAFT IRON

1
DRAFT IRON STEEL FOUNDRY MACT FACILITY
INSPECTIONS

• 40 CFR PART 63, SUBPART EEEEE

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Inspections at Effected Sources

• Sources Metal Melting Furnaces, Scrap
  Pre-heaters, pouring areas, Mold and Core Making
  Lines, and mold and Core Coating Lines.
• Capture and Collection Systems
• Fugitive Emissions from Foundry Operations

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Inspections at Effected Sources

• Work Practice standards compliance
• Scrap receiving, inspection and certification
• Material transport
• Excess materials handling
• General M/R

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Photos of Facilities
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Typical Control Systems

• Emission Capture Systems Ductwork, Dampers,
  Sensors and Hooding.
• Control Devices Fabric Filters, Scrubbers,
  Electrostatic Precipitators, Cyclones, Condensers
  and Thermal Oxidizers.
• Automatic ignition sources for mold shake-out
  vents

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Typical Control Systems (Contd.)

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

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Performance Testing

• To be performed for all emission sources subject
  to an emission limit.
• PM measurement using EPA Methods 1- 4 and either
  5, 5B, 5D, 5F, or 5I or 29 as applicable.
• Method 25 for TGNMO (as Hexane) or 25A to measure
  TOC (as Hexane).

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Performance Testing Contd.

• Use of Method 18 to determine VOHAP.
• Facilities using CO or VOC CEMS Demonstrate
  compliance by conducting CEMS performance
  evaluation.
• Testing to be performed every 5 years.

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Pre-Inspection Procedures

• File Review
• MACT Initial Notification Report
• Initial Compliance Status Report
• Performance Test Report
• Continuing Compliance Report
• Title V Reports
• VOC/HAP reduction through NSPS/MACT
  implementation
• Regulation Review
• Equipment Checks

10
Facility File Review

• Semi-Annual Reports
• Control Equipment Removal Reports
• Previous Inspection Reports
• Enforcement Action
• Complaints
• Notice of Violations
• Enforcement Action taken

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Facility File Review Contd.

• Variance history
• Compliance test data
• Equipment Malfunction reports
• SSM Plan and any events
• Permit to construct P/C and permit to operate P/O
• Collection and control system design plan

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Entry

• Enter by public access route
• Identify yourself, present your credentials
• Ask to meet with the site representative

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Pre-Inspection Meeting

• Explain purpose of inspection and discuss any
  new rule changes
• Answer questions that the source personnel may
  have
• Identify any equipment to be used in the
  inspection

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Pre-Inspection MeetingInformation

• Verify facility information
• Facility name, ownership
• Facility address, telephone number
• Facility contact name, telephone number
• Discuss safety procedures

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Pre-Inspection Meeting Information Contd.

• Review Permit
• Verify
• that permit is current and posted
• that permit is for correct equipment
• that permit operating conditions are being met
• date permit issued
• Equipment capacity/throughput information

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Pre-Inspection Meeting

• Review permit specification from office to
  on-site
• Emission limits to be met
• Changes/modifications to permit conditions
• Site-specific monitoring requirements

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Pre-Inspection Meeting Contd.

• Operational Logs
• Historical emission records and self monitoring
  data available
• Monitoring and calibration logbooks

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On-site Physical Inspection

• Collection and control equipment.
• Comparison between source records and visual
  inspection.
• Observation of leaks and maintenance
• Photographic documentation.
• Operation according to site specific collection
  system and design plan.

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Post-Inspection Meeting

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

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Inspection/Documentation Report

• Each violation recorded
• Recommendations for source test or engineering
  evaluation
• Assessment of fugitive emissions and potential
  impacts

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Additional Training Resources

• http//www.gov/compliance
• http//www.gov/oar/oaqps/eog
• http//64.27.125.175/ - LADCO
• Other Consortiums