U.S. EPA Revisions of Iron and Steel Foundries Air Quality Regulations

The U.S. EPA has completed their periodic residual risk and technology review (RTR) for major source Iron and Steel Foundries and the technology review for the area source Iron and Steel Foundries regulated under the National Emission Standards for Hazardous Air Pollutants (NESHAP).  The NESHAP specifically are 40 CFR Part 63, Subpart EEEEE and Subpart ZZZZZ, respectively.  Overall, the U.S. EPA felt that the emissions standards for the industrial emissions sources regulated by both regulations had adequate margin of safety in terms of public health and did not revise the numerical emissions limits.  However, startup shutdown and malfunction (SSM) exemptions were removed, as U.S. EPA stated that emissions standards shall apply at all times.  Furthermore, language that treated malfunction events as separate from startup and shutdown was removed.  Changes included in the final rules are as follows:

• Removal and revision of provisions related to SSM except for volatile organic hazardous air pollutants (VOHAP) standards during SSM for cupola melting furnaces.
• Establishment of work practice standards for the existing 20 ppmv VOHAP emissions standard, such that this limit is to only apply during normal production operations (more specifically, what the major source NESHAP refers to as “on blast” conditions).
• Establishment of work practice standards (for “off blast” conditions) that require compliance with the building opacity limit during initial cupola startup procedures (e.g., refractory curing, cupola bed preparation, and beginning stage of cupola coke bed preparation) and final shutdown procedures (e.g., cooling and cupola banking or bottom drop).
• For other idling times, finalization of work practice standards that require owners/operators to:
  • Begin operating cupola afterburners soon after beginning the coke bed preparatory step, but no later than 30 minutes after the blast air is started to begin the coke bed burn-in; and
  • Operate the afterburner or other thermal combustion device with a flame present at all times during other off blast periods.
• Requirement for facilities to minimize emissions and ensure safety as specified in the operation and maintenance (O&M) plan.
• Addition of monitoring and recordkeeping for foundry owners or operators to demonstrate compliance with the new work practice standards.
• Requirement for owners/operators of iron and steel foundries to submit electronic copies of certain performance test reports, performance evaluation reports, and semiannual reports through the Central Data Exchange using the Compliance and Emissions Data Reporting Interface (CEDRI) as applicable to the source. Performance test results and performance evaluation results will be submitted using the Electronic Reporting Tool (ERT).
• Written plans and scrap metal supplier specifications may need to be updated or reviewed for compliance depending on the management compliance option and scrap metal source.
• Technical standards will now apply if the Cupola baghouse has a bag leak detection system (BLDS).

U.S. EPA has stated that the SSM revisions would become effective upon promulgation, which occurred on September 10, 2020.  However, they are providing 180 days to finalize new work practice standards specific to cupola startup and shutdown and to transition to electronic reporting requirements.  If you have any questions or want to discuss how this might impact your facility, please reach out to Olivia Pehanick at 1 (610) 422-1141 ext. 141 or Opehanick@all4inc.com or Nicholas Leone at 1 (610) 422-1121 ext. 121 or Nleone@all4inc.com.
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