
DATE:	August 09, 2016
SUBJECT:	Summary of Requirements in Major Source Foundries NESHAP 
            EPA Contract No.:  EPD11084
            EPA Project No.:  4-02
            RTI Project No.:  0213199.004.002
FROM:	Sandra Pierce, RTI International
TO:	Phil Mulrine, EPA/OAQPS/SPPD/MMG


1.	Purpose
This memorandum provides a summary of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries, 40 CFR part 63, subpart EEEEE, amended 2008. 
2.	Background
Iron and steel foundries manufacture castings by pouring molten iron or steel melted in a furnace into a mold of a desired shape. The primary processing units of interest at iron and steel foundries because of their potential to generate HAP emissions are 	metal melting furnaces, scrap preheaters, pouring, cooling, and shakeout lines, and mold and core making lines.
2.1 Hazardous Air Pollutants (HAP)
The HAP emitted by this source category include metal and organic compounds.
For iron and steel foundries that produce low alloy metal castings, metal HAP emitted are primarily lead and manganese with smaller amounts of cadmium, chromium, mercury and nickel. For iron and steel foundries that produce high alloy metal or stainless steel castings, metal HAP emissions of chromium and nickel can be significant.
Organic HAP emissions include acetophenone, benzene, cumene, dibenzofurans, dioxins, formaldehyde, methanol, naphthalene, phenol, pyrene, toluene, triethylamine, and xylene.  It was estimated that when fully implemented, the final rule would reduce HAP emissions from iron and steel foundries by about 820 tons per year (tpy).
2.2 Summary of Process Emissions
Metal melting furnaces include three types of furnaces used to melt scrap metal at iron and steel foundries: cupolas, electric arc furnaces, and electric induction furnaces. Cupolas are used exclusively to produce molten iron.  Electric induction furnaces are used to produce either molten iron or molten steel, and electric arc furnaces are used almost exclusively to produce molten steel.
All three furnace types (cupolas, electric arc furnaces, and electric induction furnaces) emit PM that is known to contain HAP metals, predominately manganese and lead. It was decided to establish standards for metal HAP emissions. Mercury emissions were also of significant concern, and a work practice standard to limit mercury in metal scrap was established as a result.
Source tests on cupolas have also shown the presence of small amounts of organic HAP including acetophenone, polychlorinated dibenzofurans, polychlorinated dibenzo-p-dioxins, and pyrene.
Pouring, cooling, and shakeout (PCS) lines include three major operations:
::	pouring molten metal into molds,
::	allowing the metal to cool and solidify, and 
::	removing the castings from the molds. 
Molds are made primarily of sand. Pouring molten metal into sand molds produces emissions from the incomplete combustion of the organic chemicals used in chemically bonded molds and cores and also from sea coal and other organic constituents of green sand. These products of incomplete combustion are known to contain benzene, formaldehyde, and toluene. In addition, small amounts of HAP metals are emitted during pouring.  PM was used as a surrogate for metal HAP emissions from pouring.   VOC was chosen as a surrogate for organic HAP emissions from pouring, cooling, and shakeout lines.
Mold and core making lines can emit HAP including cumene, formaldehyde, methanol, naphthalene, phenol, triethylamine, and xylene. In the process of mixing sand and binder chemicals, forming the sand into molds and cores, and curing the resulting shapes, volatile constituents of the binder chemicals evaporate to some extent. Emissions vary widely between different types and formulations of chemical systems; however, for each system the HAP species emitted can be identified. It was decided to establish standards to control HAP emissions from selected types of binder systems.
The source of HAP emissions from the mold and core coating operation is the liquid component of the slurry, which may contain a HAP such as methanol. Alternative liquid formulations that contain no HAP are available. It was concluded that substitution of coating material formulations is possible, and that it is feasible to establish emissions standards in this proposal based on pollution prevention that address liquid HAP used in coating operations.
It is informative to note that emissions of organic HAP from mold and core making and PCS lines are what caused foundries to be major sources of HAP emissions. The emissions of metal HAP, on the other hand, is what caused foundries to be among the top ranked source categories in the risk-weighted urban air toxics analysis.

3.	Subpart EEEEE Emission Standards
Applies to iron and steel foundries that is (or is part of) a major source of hazardous air pollutants (HAP) emissions.
3.1 Emission Limits
The emissions limitations in Subpart EEEE are summarized in Table 1. Operating limits are summarized in Table 2. 
3.2 Work Practice Standards
3.2.1 Scrap Specifications
For each segregated scrap storage area, bin or pile, either:
 Prepare and operate at all times according to a written certification that the foundry purchases and uses only metal ingots, pig iron, slitter, or other materials that do not include post-consumer automotive body scrap, post-consumer engine blocks, post-consumer oil filters, oily turnings, lead components, mercury switches, plastics, or free organic liquids. Any post-consumer engine blocks, post-consumer oil filters, or oily turnings that are processed and/or cleaned to the extent practicable such that the materials do not include lead components, mercury switches, chlorinated plastics, or free organic liquids can be included in this certification or, 

 Prepare and operate at all times according to a written plan for the selection and inspection of iron and steel scrap to minimize, to the extent practicable, the amount of organics and HAP metals in the charge materials used by the iron and steel foundry. This scrap selection and inspection plan is subject to approval by the Administrator. Each plan must include the following information:
 A materials acquisition program to limit organic contaminants [details in 63.7700 (c)(1)(i) and (ii)].

 A materials acquisition program specifying that the scrap supplier remove accessible mercury switches from the trunks and hoods of any automotive bodies contained in the scrap and remove accessible lead components such as batteries and wheel weights.
 Procedures for visual inspection of a representative portion, but not less than 10 percent, of all incoming scrap shipments to ensure the materials meet the specifications [details in 63.7700(c)(3)(i) through (iv)].

                                    Source
                                Emission Limit
                                   Pollutant
                               Existing Sources
Electric arc metal melting furnace, electric induction metal melting furnace, or scrap preheater at an existing iron and steel foundry
0.005 gr/dscf of PM or
0.0004 gr/dscf of total metal HAP
HAP metals
Cupola metal melting furnace at an existing iron and steel foundry
0.006 gr/dscf of PM; or
0.10 lb/ton of metal charged, or
0.0005 gr/dscf of total metal HAP, or
0.008 pound of total metal HAP per ton (lb/ton) of metal charged
HAP metals
Pouring station at an existing iron and steel foundry
0.010 gr/dscf of PM, or
0.0008 gr/dscf of total metal HAP
HAP metals
                                  New Sources
Electric induction metal melting furnace or scrap preheater at a new iron and steel foundry
0.001 gr/dscf of PM, or
0.00008 gr/dscf of total metal HAP
HAP metals
Cupola metal melting furnace or electric arc metal melting furnace at a new iron and steel foundry
0.002 gr/dscf of PM, or
0.0002 gr/dscf of total metal HAP
HAP metals
Pouring area or pouring station at a new iron and steel foundry
0.002 gr/dscf pf PM, or
0.0002 gr/dscf of total metal HAP
HAP metals
One or more automated conveyor and pallet cooling lines that use a sand mold system or automated shakeout lines that use a sand mold system at a new iron and steel foundry
 Volatile organic hazardous air pollutants (VOHAP) that exceed a flow-weighted average of 20 ppmv
 VOHAP
                        All Sources (Existing and New)
Building or structure housing any iron and steel foundry emissions source at the iron and steel foundry
Opacity greater than 20 percent (6-minute average), except for one 6- minute average per hour that does not exceed 27 percent opacity
Fugitive emissions
Cupola metal melting furnace at a new or existing iron and steel foundry
Volatile organic hazardous air pollutants (VOHAP) through a conveyance to the atmosphere that exceed 20 ppmv
VOHAP
A scrap preheater at a new or existing iron and steel foundry  [As an alternative to the work practice standard in § 63.7700(e) or § 63.7700(f)]
Emissions of VOHAP through a conveyance to the atmosphere that exceed 20 ppmv
VOHAP
Each triethylamine (TEA) cold box mold or core making line at a new or existing iron and steel foundry
 1 ppmv, or
reduce emissions of TEA by at least 99%
 TEA
Note: All emissions, with the exception of building opacity, are through a conveyance to the atmosphere

          Table 1. Summary of Emissions Limitations in Subpart EEEEE 
             Table 2. Summary of Operating Limits in Subpart EEEEE
                                    Device
                                 Requirements
Capture and control system for all emissions sources subject to an emissions limit for VOHAP or TEA
Must meet accepted engineering standards, such as those published by the American Conference of Governmental Industrial Hygienists; and 

You must operate each capture system at or above the lowest value or settings established as operating limits in your operation and maintenance plan
Each wet scrubber applied to emissions from a metal melting furnace, scrap preheater, pouring area, or pouring station subject to an emissions limit for PM or total metal HAP
Operate such that the 3-hour average pressure drop and scrubber water flow rate does not fall below the minimum levels established during the initial or subsequent performance test.
Each combustion device applied to emissions from a cupola metal melting furnace subject to the emissions limit for VOHAP
Operate such that the 15-minute average combustion zone temperature does not fall below 1,300 degrees Fahrenheit. Periods when the cupola is off blast and for 15 minutes after going on blast from an off blast condition are not included in the 15-minute average.
Each combustion device applied to emissions from a scrap preheater subject to the emissions limit for VOHAP or from a TEA cold box mold or core making line subject to the emissions limit for TEA
Operate such that the 3-hour average combustion zone temperature does not fall below the minimum level established during the initial or subsequent performance test.
Each wet acid scrubber applied to emissions from a TEA cold box mold or core making line 
Operate such that the 3-hour average scrubbing liquid flow rate does not fall below the minimum level established during the initial or subsequent performance test; and

The 3-hour average pH of the scrubber blowdown, as measured by a continuous parameter monitoring system (CPMS), does not exceed 4.5 or the pH of the scrubber blowdown, as measured once every 8 hours during process operations, does not exceed 4.5.
If you use a control device other than a baghouse, wet scrubber, wet acid scrubber, or combustion device, you must prepare and submit a monitoring plan for approval by the Administrator. Required information is provided in 63.7690(c).

3.2.2 Other Work Practices
Furan warm box mold or core making lines. Each line in a new or existing iron and steel foundry must use a binder chemical formulation that does not contain methanol as a specific ingredient of the catalyst formulation as determined by the Material Safety Data Sheet. This requirement does not apply to the resin portion of the binder system.
Scrap Preheaters. At existing facilities, each scrap preheater must meet one of the following: 
 Operate and maintain a gas-fired preheater where the flame directly contacts the scrap charged, or
 Charge only material that is subject to and in compliance with the scrap certification requirement, or
 Not discharge emissions of VOHAP through a conveyance to the atmosphere that exceed 20 ppmv.

At new facilities, each scrap preheater must either:
 Charge only material that is subject to and in compliance with the scrap certification requirement, or
 Not discharge emissions of VOHAP through a conveyance to the atmosphere that exceed 20 ppmv.

3.3 Operation and Maintenance Requirements
The following is a summary of operation and maintenance requirements detailed in §63.7710: 
 Always operate and maintain your iron and steel foundry, including air pollution control and monitoring equipment, in a manner consistent with good air pollution control practices for minimizing emissions.
 Prepare and operate at all times according to a written operation and maintenance plan for each capture and collection system and control device for an emissions source subject to a PM, metal HAP, TEA, or VOHAP emissions limit. This must include the elements in §63.7710 (b)(1)  -  (6), including:
 Monthly inspections of capture system equipment, 
 Operating limits for each capture system
 A preventative maintenance plan for each control device, 
 A site-specific monitoring plan for each bag leak detection system,
 A corrective action plan for each baghouse, and 
 Procedures for providing an ignition source to mold vents of sand mold systems in each pouring area and pouring station unless the mold vent gases either are not ignitable, ignite automatically, or cannot be ignited due to accessibility or safety issues.
3.4 General Compliance Requirements 
These include, "You must be in compliance with the emissions limitations, work practice standards, and operation and maintenance requirements in this subpart at all times, except during periods of startup, shutdown, or malfunction."

