
DATE:	August 11, 2016
SUBJECT:	Summary of Requirements in Area 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 Area Sources, 40 CFR part 63, subpart ZZZZZ promulgated January 2, 2008. 
2.	Background
Please refer to the Memo summarizing the NESHAP for Major Sources dated August 9, 2016 for a description of the processes and emission points at iron and steel foundries. 
3.	Subpart ZZZZZ Emission Standards
This subpart applies to iron and steel foundries that are an area source of hazardous air pollutants (HAP) emissions. Under the new area source rule, EPA defined large and small area source foundries according to the parameters in Table 1. 
         Table 1. Definition of Large and Small Area Source Foundries

                     Small Foundry: Annual melt production
                     Large Foundry: Annual melt production
                        Existing Area Source Foundries
20,000 tons or less
Greater than 20,000 tons
                           New Area Source Foundries
10,000 tons or less
Greater than 10,000 tons

If a facility is initially classified as a large foundry (or a small foundry subsequently becomes a large foundry), the facility must comply with the requirements for a large foundry for at least 3 years before reclassifying as a small foundry, even if the annual metal melt production falls below 20,000 tons (10,000 tons for new sources). After 3 years, the foundry may be reclassified as a small foundry provided the annual metal melt production for the preceding calendar year was 20,000 tons or less (10,000 tons or less for new foundries). If a large foundry is reclassified as a small foundry a notification of reclassification must be submitted to the Administrator within 30 days and the requirements for a small foundry must be complied with no later than the date the Administrator is notified of the reclassification. 
If the annual metal melt production exceeds 20,000 tons (10,000 tons for new sources) during a subsequent year, a notification of reclassification must be submitted to the Administrator within 30 days and the requirements for a large foundry must be complied with no later than the date the Administrator is notified of the reclassification.
3.1 Pollution Prevention Management Practices
3.1.1 Metallic Scrap Management Program
Each segregated metallic scrap storage area, bin or pile must comply with the materials acquisition requirements in §63.10885. A copy of the material specifications must be kept onsite and readily available to all personnel with material acquisition duties, and provided to each scrap provider. Segregated metallic scrap must classified as either restricted metallic scrap or  general iron and steel scrap, as summarized below. 
 Restricted metallic scrap. Must have written material specifications for the purchase and use of only metal ingots, pig iron, slitter, or other materials that do not include post-consumer automotive body scrap, postconsumer engine blocks, post-consumer oil filters, oily turnings, lead components, chlorinated plastics, or free liquids. The requirements for no free liquids do not apply if the owner or operator can demonstrate that the free liquid is water that resulted from scrap exposure to rain.
 General iron and steel scrap. Must written material specifications for the purchase and use of only iron and steel scrap that has been depleted (to the extent practicable) of organics and HAP metals in the charge materials used by the iron and steel foundry. The materials specifications must include at minimum:
 For scrap charged to a preheater or metal melting furnace: Specifications for metallic scrap materials to be depleted (to the extent practicable) of the presence of used oil filters, chlorinated plastic parts, accessible lead-containing components (such as batteries and wheel weights), and a program to ensure the scrap materials are drained of free liquids.
 For scrap charged to a cupola metal melting furnace that is equipped with an afterburner: specifications for metallic scrap materials to be depleted (to the extent practicable) of the presence of chlorinated plastics, accessible lead-containing components (such as batteries and wheel weights), and a program to ensure the scrap materials are drained of free liquids.

3.1.2 Mercury Requirements
For scrap that does not contain motor vehicle scrap (i.e., scrap storage area, bin or pile), each facility must certify in their notification of compliance status and maintain records of documentation that this scrap does not contain motor vehicle scrap. For scrap containing motor vehicle scrap, scrap must be procured pursuant to one of the following compliance options for each scrap provider, contract, or shipment. 
 Site-specific plan for mercury switches. This includes a requirement in scrap specifications for the removal of mercury switches from vehicle bodies used to make the scrap; operating according to a plan which demonstrates how the facility will implement the scrap specification for removal of mercury switches; a means of communicating to scrap purchasers and scrap providers the need to obtain or provide motor vehicle scrap from which mercury switches have been removed and the need to ensure the proper management of the mercury switches removed from the scrap; provisions for: obtaining assurance from scrap providers that they meet the specifications; periodic inspections or other means of corroboration; and taking corrective action, if needed. Detailed requirements can be found in §63.10885(b)(1). 
 Option for approved mercury programs. Requires certification in notification of compliance status that the facility participates in and purchases motor vehicle scrap only from scrap providers who participate in a program for removal of mercury switches that has been approved by the Administrator based on the criteria below.  If motor vehicle scrap is purchased from a broker, a facility must certify that all scrap received from that broker was obtained from other scrap providers who participate in a program for the removal of mercury switches that has been approved by the Administrator based on the following criteria: 
 The program includes outreach the dismantlers of the need for removal of mercury switches and provides training and guidance for removing mercury switches;
 The program has a goal to remove at least 80 percent of mercury switches from motor vehicle scrap the scrap provider processes; and
 The program sponsor agrees to submit progress reports to the Administrator no less frequently than once every year that provide the number of mercury switches removed or the weight of mercury recovered from the switches, the estimated number of vehicles processed, an estimate of the percent of mercury switches recovered, and certification that the recovered mercury switches were recycled at facilities with permits.
      Also requires the development of a plan which demonstrates the manner through which the facility is participating in the EPA-approved program.
 Option for specialty metal scrap. Requires certification in notification of compliance status that the only materials from motor vehicles in the scrap are materials recovered for their specialty alloy (including, but not limited to, chromium, nickel, molybdenum, or other alloys) content (such as certain exhaust systems) and, based on the nature of the scrap and purchase specifications, that the type of scrap is not reasonably expected to contain mercury switches.
3.1.3 Binder Formulations
Each furfuryl alcohol warm box mold or core making line at a new or existing iron and steel foundry, must use a binder chemical formulation that does not use methanol as a specific ingredient of the catalyst formulation. This requirement does not apply to the resin portion of the binder system.
3.2 Management Practices and Compliance Requirements
All foundries (small and large) must comply with pollution prevention management practices for metallic scrap, mercury switches, and binder formulations.  Small foundries are not subject to emission limits or compliance tests.
The following are required for all large new and existing foundries:
 Must operate a capture and collection system for each metal melting furnace at a new or existing iron and steel foundry unless that furnace is specifically uncontrolled as part of an emissions averaging group. Each capture and collection system must meet accepted engineering standards, such as those published by the American Conference of Governmental Industrial Hygienists.
 Must not discharge to the atmosphere emissions from any metal melting furnace or group of all metal melting furnaces that exceed the applicable limit below. When an alternative emissions limit is provided for a given emissions source, facilities are not restricted in the selection of which applicable alternative emissions limit is used to demonstrate compliance.
 For an existing iron and steel foundry, 0.8 pounds of particulate matter (PM) per ton of metal charged or 0.06 pounds of total metal HAP per ton of metal charged.
 For a new iron and steel foundry, 0.1 pounds of PM per ton of metal charged or 0.008 pounds of total metal HAP per ton of metal charged.
 A new iron and steel foundry must not discharge to the atmosphere fugitive emissions from foundry operations that exhibit opacity greater than 20 percent (6-minute average), except for one 6-minute average per hour that does not exceed 30 percent.
 New affected (large) sources must comply with each control device parameter operating limit in §63.10895(d) that applies.
 Must prepare and operate at all times according to a written operation and maintenance (O&M) plan for each control device for an emissions source subject to a PM, metal HAP, or opacity emissions limit [detailed requirements for contents of O&M plan can be found in §63.10896(a)(1-5)].
 Must conduct various initial, daily, and monthly inspections of emissions control equipment as specified in §63.10897.

 Conduct initial compliance tests and performance tests as specified in §63.10898 and Table 1 of subpart ZZZZZ.


