Since our ‘Request for Clarification’ documents, dated October 9,
2003, April 1, 2004, and May 12, 2004,  the following additional issues
have been identified by AFS members as items in need of clarification.

30.  Operation and Maintenance Plan Requirements Overly Burdensome

The Rule contains multiple time-consuming and unnecessary requirements
that go beyond ensuring proper capture and collection system and control
device operation.  Examples include:

§63.7740 (a)(1), pg. 21932,  Continuous electronic monitoring of VOHAP
capture system flow or pressure, if dampers are not manually set and do
not remain in the same position A monthly visual preventative
maintenance inspection should be sufficient.

§63.7740 (a)(2), pg. 21932, For all other damper types, daily checks of
VOHAP capture system dampers to ensure they are in the same position as
during the initial performance test.  This requirement is also best
suited to a monthly preventative maintenance inspection.

§63.7741 (b)(3), pg. 21933, Requirements that baghouse leak detectors
be equipped with audible alarms.  In some cases, visual alarms are more
effective, and should not be excluded as an independent notification
method.

§63.7740 (b), pg. 21932-21933, The “Continuous Baghouse Compliance
Demonstration” [] is particularly onerous.  The preventative
maintenance frequencies vary, with some inspections required with
unnecessary daily or weekly intervals.

Daily monitoring of the pressure drop across each baghouse cell to
ensure it is within the range identified in the O&M Plan.

Weekly inspection to ensure dust is being removed from hoppers.

Daily checks of the compressed air supply pressure for pulse-jet
baghouses  §63.7740 (b)(3).

Daily checks of the compressed air supply for pulse-jet baghouses.

Monthly checks of bag cleaning mechanisms for proper functioning.

Monthly visual checks of bag tension if spring-loaded self-tensioning
device not used.

Quarterly visual inspections of baghouse interior for air leaks to
confirm baghouse physical integrity.

Quarterly inspections of fans for wear, material buildup, and corrosion.

The industry group recommends that the source propose capture and
collection system operational parameters, such as pressure drop across
the collection media and capture system flow, to the applicable
permitting authority for approval.  Approved parameters, such as
pressure drop across the collection media, should be checked and
recorded at a frequency not less than that suggested by the manufacturer
or that required by the permitting authority, whichever is more
frequent.

 

Likewise, preventative maintenance inspections should be performed at a
frequency not less than that suggested by the manufacturer of the
capture and collection system.  The source should propose the frequency
and content of the preventative maintenance procedure(s) to the
permitting authority for approval.

31.  §63.7732 (b)(4), (c)(4), and (b)(5), (c)(5) – Performance
Testing Procedures for Electric Furnaces and Scrap Preheaters

The rules, at §63.7732 (b)(4) and (c)(4), require that performance
testing for PM or total metal HAP emissions from electric melting
furnaces only be performed “when metal is being melted.”  Likewise,
§63.7732 (b)(5) and (c)(5) require that performance testing of scrap
preheaters be performed “only when scrap is being preheated.”  The
foundry industry requests that the Agency clarify these requirements to
address the actual operating procedures utilized in foundry operations.

It is neither typical nor practical for a foundry to operate a melting
furnace such that “metal is being melted” throughout the minimum
one-hour compliance test sampling period.  Likewise, scrap preheaters
are not continuously heating scrap for extended periods.  Rather, both
metal melting furnaces and scrap preheaters are operated as batch
processes, where gaps between charges are a part of normal operating
procedure.

A strict interpretation of the current rule language would require that
emission tests be started and stopped many times in order to sample the
minimum gas volume, increasing the potential for errors and stack test
run failure.  Therefore, the foundry industry interprets the proper
meaning of this requirement to be that test conditions should be
representative of the operating conditions at the facility, including
the normal gaps between the introduction of charges.  The NESHAP General
Provisions support this position as §63.6(f)(2)(iii)(A) states that a
performance test must be “conducted under representative operating
conditions for the source.”

The industry group requests that the Agency clarify that the testing of
electric furnaces and scrap preheaters does not dictate that sampling
occur only during select periods of operation but, rather, be continuous
and “conducted under representative operating conditions for the
source.”

32.  §63.7732(c)(1)(v) – Summing Laboratory Results to Determine
Compliance with a Total Metal HAP Limitation

When a foundry seeks to comply with an alternate total metal HAP
emissions limitation, §63.7732(c)(1)(v) specifies the use of Method 29.
 The Method 29 results will provide a concentration level for each metal
HAP within the sample.  However, the results for some individual HAP
metals are likely to be reported as “below the analytical detection
limit.”  The foundry industry requests that the Agency address the
proper means of account for, in the total metal HAP summation, those
laboratory results which are reported as “below the detection
limit.”

The industry group believes that, when laboratory analysis indicates
that a particular HAP metal is present “below the detection limit,”
this HAP metal concentration should be considered as “zero” for
purposes of determining compliance with the total metal HAP emissions
limitation.

33.  §63.7681 – Determination of Major Source Status

Section 63.7681 states that an iron and steel foundry is a major source
of HAP “if it emits or has the potential to emit … or is located at
a facility that emits or has the potential to emit” above the
threshold level.  Because the regulations do not define the term
‘facility,’ the foundry industry requests affirmation of our
understanding of the emissions sources to be considered in a “major
source” determination.

Section 112(a)(1) of the CAA and 40 CFR 63.2 define the term ‘major
source’ to encompass “any stationary source or group of stationary
sources located within a contiguous area.”  In addition, §63.2
defines the term ‘affected source’ to encompass “the collection of
equipment, activities, or both within a single contiguous area.” 
Finally, the regulations do not define “contiguous,” however,
Webster’s dictionary defines it as “touching along a boundary or at
a point.”

Based on these definitions, the industry group understands that the
determination of major source status is based on the emissions and the
potential emissions of the equipment and activities contained within a
single contiguous area.  Therefore, it is our understanding that an iron
and steel foundry that operates more than one facility should conduct an
individual “major source” determination for each facility unless the
facilities are “contiguous,” that is, unless the facilities share a
boundary or a point.  Simply put, we understand that for purposes of the
“major source” determination, emissions from various facilities are
not additive unless the facilities share “touch along a boundary or at
a point.”

34.  §63.7700(b) – Classification of Scrap Materials that Undergo a
“Cleaning” Process

The materials handling option at §63.7700(b) identifies several scrap
materials that a foundry may not purchase and use when utilizing this
option; these prohibited materials include “post-consumer engine
blocks,” and “oily turnings.”  The foundry industry requests that
the Agency provide guidance regarding the applicability of this
prohibition to those materials that, although identifiable as prohibited
materials, have been processed to remove contaminants.

Specifically, some suppliers in the scrap industry dismantle or crush,
and then wash, post-consumer engine blocks prior to shipping this as a
scrap material.  Likewise, numerous scrap metal sources process oily
turnings, using compacting and drying methods, to produce metallic
briquettes for introduction into the melting process.  These materials,
although identifiable as “post-consumer engine blocks” and “oily
turnings,” have been processed to remove the contaminants of concern,
however, §63.7700(b) could be interpreted to prohibit the use of these
materials.  The industry requests that the Agency clarify the
applicability of this provision to materials that undergo a
“cleaning” process prior to utilization.

The industry requests that the Agency provide either: 1) that scrap
materials which have been sufficiently processed to remove contaminants
be allowed under §63.7700(b); or 2) a means for site specific
determinations of the classification of these “cleaned” materials to
be included in the written certification statement required under
§63.7700(b).

35.  §63.7750(e)(2) and §63.10(d)(2) – Submission of Opacity Test
Results

The rule, at §63.7750(e)(2) and §63.10(d)(2), requires that the
results of a performance test be submitted within 60 days following the
completion of the performance test unless specified otherwise within the
rule.  The industry requests that this provision be modified to provide
an alternate submission schedule for opacity test results. 
Specifically, the industry group requests that the semi-annual opacity
test results be submitted as part of the semi-annual compliance
reporting required under §63.7751.

The industry believes that the combining of these reporting requirements
will reduce paperwork burdens and reduce the potential for
administrative noncompliance. 

NESHAP for Iron and Steel Foundries

Request for Clarification

Prepared by American Foundry Society

Submitted to EPA on June 16, 2004

Page   PAGE  2  of   NUMPAGES  3 

