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Clock is ticking for curbed emissions: the finalization of the Foundry Area Source Rule for iron and steel casting facilities means that metalcasters should have a plan in place to comply.


[ILLUSTRATION OMITTED]

The National Emission Standards Emission standards are requirements that set specific limits to the amount of pollutants that can be released into the environment. Many emission standards focus on regulating pollutants released by automobiles (motor cars) and other powered vehicles but they can also regulate  for Hazardous Air Pollutants pollutants

see environmental pollution.
 for Iron and Steel Foundries Area Sources (Foundry A semiconductor manufacturer that makes chips for third parties. It may be a large chip maker that sells its excess manufacturing capacity or one that makes chips exclusively for other companies.  Area Source Rule), which the U.S. Environmental Protection Agency Environmental Protection Agency (EPA), independent agency of the U.S. government, with headquarters in Washington, D.C. It was established in 1970 to reduce and control air and water pollution, noise pollution, and radiation and to ensure the safe handling and  (EPA EPA eicosapentaenoic acid.

EPA
abbr.
eicosapentaenoic acid


EPA,
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EPA,
n.
) finalized See finalization.  on Jan. 2, requires iron and steel casters casters

the small rubber wheels on surgical trolleys, patient stretchers, mobile equipment.


conductive casters
the casters are impregnated with carbon to facilitate the dispersal of static electricity from equipment.
 to make a concerted effort to reduce their emissions over the course of the next few years and will monitor the progress through a series of compliance dates and reporting plans.

The rule affects facilities that emit TO EMIT. To put out; to send forth,
     2. The tenth section of the first article of the constitution, contains various prohibitions, among which is the following: No state shall emit bills of credit.
 less than 10 tons per year of any single hazardous air pollutant pol·lut·ant
n.
Something that pollutes, especially a waste material that contaminates air, soil, or water.
 (HAP HAP. An old word which signifies to catch; as, "to hap the rent," to hap the deed poll." Techn. Dict. h.t. ) and less than 25 tons per year of any combination of HAPs (HAP minor sources).

Several compliance due dates are approaching in January January: see month.  2009. Along with meeting the upcoming deadlines, you should be forming plans to meet further compliance dates in later months and years because the required changes could affect production at your operation.

This article identifies compliance dates, best practices and reporting requirements for minor source iron and steel metalcasting facilities under the Foundry Area Source Rule.

Small or Large Area Sources

Foundry Area Source Rule requirements depend on whether a casting facility is designated as large or small. An existing area source metalcaster is designated as small if the actual metal melt production for a calendar year is equal to 20,000 tons or less. A new area source metalcaster is designated as small if annual metal melting capacity is equal to 10,000 tons or less.

An "existing" metalcasting facility is classified as constructed or reconstructed re·con·struct  
tr.v. re·con·struct·ed, re·con·struct·ing, re·con·structs
1. To construct again; rebuild.

2.
 prior to Sept. 17, 2007. A "new" metalcaster is defined as constructed on or after Sept. 17, 2007, or reconstructed with expenditures exceeding 50% of the fixed cost of a comparable new casting plant.

For metalcasting facilities designated as small, the term "annual metal melt production" is used for the existing area source category. This term can be used interchangeably INTERCHANGEABLY. Formerly when deeds of land were made, where there Were covenants to be performed on both sides, it was usual to make two deeds exactly similar to each other, and to exchange them; in the attesting clause, the words, In witness whereof the parties have hereunto  with "actual metal melted melt  
v. melt·ed, melt·ing, melts

v.intr.
1. To be changed from a solid to a liquid state especially by the application of heat.

2.
" for all furnaces at the site. On the other hand, for new area sources, the term "annual metal melting capacity" means the hourly melt rate of all melting furnaces multiplied mul·ti·ply 1  
v. mul·ti·plied, mul·ti·ply·ing, mul·ti·plies

v.tr.
1. To increase the amount, number, or degree of.

2. Mathematics To perform multiplication on.
 by 8,760, unless melting rates or hours of operations are limited within a federally enforceable permit.

Table 1 provides a brief description of some of the more important work practice requirements, emissions limitations and reporting obligations and their due dates. The dates for the large casting facility requirements assume the initial size notification was made on Jan. 2, 2009.

The date of compliance with the metal melting emissions limitation is keyed off of the small versus large notification designation. Per 63.10881(a)(3), you must comply with emissions limitations no later than two years after being designated a large metalcasting facility.

So, if you make your designation as a large metalcaster earlier than Jan. 2, 2009, your compliance date and other subsequent dates are moved up. It is in a large company's best interest to submit the large designation on Jan. 2, 2009.

While the number of requirements was reduced for small metalcasters, substantial work practice and reporting requirements remain. Large area source companies must also comply with the small company requirements identified in Table 2.

Reports should be submitted to EPA unless your state has gained approval to administer the rule. Given the limited number of approved state programs, it is easier to submit the reports to both your state and regional EPA office.

Emissions standards and additional reporting requirements that apply only to large metalcasters are provided in Table 3.

Other Requirements

Besides work practice standards, emissions standards and corresponding reporting requirements, large companies will be required to develop a plan for operation and maintenance of air pollution control devices. This includes startup (STARTing UP) "At startup" means when the computer is first turned on or when a program is first loaded. See Startup folder. , shutdown shut·down  
n.
A cessation of operations or activity, as at a factory.


shutdown
Noun

the closing of a factory, shop, or other business

Verb

shut down
 and malfunction mal·func·tion
v.
1. To fail to function.

2. To function improperly.

n.
1. Failure to function.

2. Faulty or abnormal functioning.
 plans, as well as site-specific Site-specific is used in a range of contexts:

In art Site-specific art

In molecular biology Site-specific recombination
 test plans prior to performance tests.

For the first couple of years, the Years, The

the seven decades of Eleanor Pargiter’s life. [Br. Lit.: Benét, 1109]

See : Time
 contents of the semi-annual compliance reports will change. For example, the first and second semi-annual compliance reports will only include statements regarding the compliance of the methanol methanol, methyl alcohol, or wood alcohol, CH3OH, a colorless, flammable liquid that is miscible with water in all proportions. Methanol is a monohydric alcohol. It melts at −97.  elimination and the metallic scrap management requirement. The third semiannual Semiannual

An event that occurs twice in a calendar year.

Notes:
A bond with semiannual coupons would issue payment once every six months.
See also: Annual, Bond, Coupon Bond
 report will include a compliance statement associated with the mercury management requirement.

For More Information

"Paying Green to Go Green," AFS A distributed file system for large, widely dispersed Unix and Windows networks from Transarc Corporation, now part of IBM. It is noted for its ease of administration and expandability and stems from Carnegie-Mellon's Andrew File System.

AFS - Andrew File System
 Technical Dept., MODERN CASTING, August '08, p. 24.

"Metalcasting's Carbon Footprint A carbon footprint is the total amount of carbon dioxide (CO2) and other greenhouse gases emitted over the full life cycle of a product or service. ," J. Schifo, MODERN CASTING, May '08, p. 32.

The HAPs list can be found at the U.S. Environmental Protection Agency (USEPA USEPA United States Environmental Protection Agency ) Air Toxics Web Site (www.epa.gov/ttn/atw/orig 189.html). The Foundry Area Source Rule can be found at www.epa.gov/ttn/atw/area/fr02ja08.pdf or at the American American, river, 30 mi (48 km) long, rising in N central Calif. in the Sierra Nevada and flowing SW into the Sacramento River at Sacramento. The discovery of gold at Sutter's Mill (see Sutter, John Augustus) along the river in 1848 led to the California gold rush of  Foundry Society website (www.afsinc.org See .org.

(networking) org - The top-level domain for organisations or individuals that don't fit any other top-level domain (national, com, edu, or gov). Though many have .org domains, it was never intended to be limited to non-profit organisations.

RFC 1591.
).

Mike Blankestyn and Craig Craig   , Edward Gordon 1872-1966.

British theatrical producer, director, and designer whose innovative productions and simplified stage designs influenced modern theater.
 Schmeisser Schmeis·ser  
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Any of various German automatic weapons designed for use by individual troops during World War II, especially either of two types of submachine gun.
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RMT 1. Registered Massage Therapist 2. Renal mesenchymal tumor
 Inc., Madison, Wisconsin Madison is the capital of the U.S. state of Wisconsin and the county seat of Dane County. It is also home to the University of Wisconsin–Madison.

The 2006 population estimate of Madison was 223,389, making it the second largest city in Wisconsin, after Milwaukee, and
 

Mike Blankostyn is project engineer and Craig Schmeisser is business manager for RMT Inc., Madison, Wis adv. 1. Certainly; really; indeed.
v. t. 1. To think; to suppose; to imagine; - used chiefly in the first person sing. present tense, I wis. See the Note under Ywis.
.
Table 1 Summary of Important Area Source Requirements for
Existing Metalcasters

Requirement       Summary of Requirement         Compliance Date

Initial           An initial notification of     May 1, 2008
Notification      rule applicability must be
of                submitted by the
Applicability     metalcasting facility
                  owner or operator.

Pollution         Furfuryl alcohol warmbox       Jan. 2, 2009
Prevention        mold or coremaking lines
Management        must have binders with
Practices for     a chemical formulation that
Binder            does not use methanol as
Formulation       a specific ingredient of
                  the catalyst.

Pollution         A scrap specification must     Jan. 2, 2009
Prevention        be developed and made
Management        available to personnel
Practices for     responsible for scrap
Metallic Scrap    acquisition duties and
                  scrap providers. In
                  addition, each facility
                  must comply with the
                  restricted metallic scrap
                  and/or the general iron
                  and steel scrap requirement,
                  which allows the use of
                  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, chlorinated
                  plastics or free liquids.
                  The requirement includes
                  the preparation of written
                  material specifications for
                  purchase and use of only
                  iron and steel scrap that
                  has been depleted of
                  certain substances
                  required by the rule.

Metalcaster       A written notification must    Jan. 2, 2009
Size              be submitted to the
Designation       administrator that
Notification      identifies the area source
                  as a large or small
                  metalcasting facility
                  (i.e. metal melt production
                  for calendar year is greater
                  than 20,000 tons for a large
                  company or less than 20,000
                  tons for a small company).

Pollution         For scrap containing motor     Jan. 4, 2010
Prevention        vehicle parts, the
Management        metalcaster must either
Practices for     create a site-specific
Mercury           plan for mercury switch
                  removal or purchase scrap
                  from a vendor that
                  participates in an approved
                  mercury program. The rule
                  provides special
                  considerations for
                  motorvehicle scrap that
                  is recovered for their
                  specialty alloy content
                  and not reasonably
                  expected to contain
                  mercury switches.

Emission          Large metalcasters must        Jan. 2, 2011
Limitations,      comply with furnace
Standards         capture and collection
and Management    system operation standard,
Practices         furnace emissions standard,
for Large         control device parameter
Metalcasters      operating limits, and the
                  fugitive emissions standard.

Initial           Large metalcasters must        March 3, 2011
Inspection        conduct inspections of
of Each           system ductwork and melting
Melting Furnace   air pollution control
Particulate       devices, such as baghouses,
Control Device    wet scrubbers and
for Large         electrostatic
Metalcasters      precipitators.

Intent to         For large metalcasting         March 3, 2011
Use Previous      facilities, in order to
Compliance        use the results of a
Testing Data      prior performance test
Notification      to meet the area source
for Large         rule testing requirements,
Metalcasters      a notification of intent
                  must be submitted.

                  The notification must
                  contain a full copy of
                  the performance test
                  and information
                  to demonstrate that
                  either no process
                  changes have been made
                  since the test or the
                  results of the test
                  reliably demonstrate
                  compliance despite some
                  process changes.

Performance       For large metalcasters,        July 1, 2011
Testing to        testing to demonstrate
Demonstrate       compliance with the
Initial           furnace emissions
Compliance        limits and the building
with Applicable   of fugitive opacity
Emissions and     limits must be conducted
Opacity Limits    and be repeated every
for Large         five years and whenever
Metalcasters      changes to operating
                  limits or processing
                  is likely to increase
                  HAP emissions.
                  Testing to demonstrate
                  compliance with the
                  building fugitive
                  opacity limits must
                  be repeated every
                  six months and whenever
                  processing changes are
                  likely to increase
                  fugitive emissions.

Table 2. Small and Large Metalcaster Work
Practice and Reporting Requirements

                Compliance or
Compliance      Reporting               Rule
Date            Requirement             Reference

May 1, 2008     Initial                 40 CFR 63.10890(b)
                notification of
                applicability (R)

Jan. 2, 2009    Small or large          40 CFR 63.10880(f)
                metalcaster
                designation (R)

Jan. 2, 2009    Metallic scrap          40 CFR 63.10881(a)(1)
                management
                practice (WP)

Jan. 2, 2009    Elimination of          40 CFR 63.10881(a)(1)
                methanol in furfuryl
                alcohol warm box
                binder system
                catalyst (WP)

Feb. 1, 2009    Notification of         40 CFR 63.10890(c)
                compliance with
                metallic scrap and
                furfuryl alcohol
                catalyst methanol
                exclusion (R)

July 30, 2009   semi-annual             40 CFR 63.10890(f)
                compliance (R)          40 CFR 63.10890(e)(3)(ii)
                                        40 CFR 63.10899(c) *
                                        40 CFR 63.10899(b)(2)(ii) *

Jan. 4, 2010    Mercury scrap           40 CFR 63.10881(a)(2)
                management (WP)

Jah. 30, 2010   2nd semi-annual         40 CFR 63.10890(f)
                compliance (R)          40 CFR 63.10890(e)(3)(ii)
                                        40 CFR 63.10899(c) *
                                        40 CFR 63.10899(b)(2)(ii) *

Feb. 3, 2010    Notification of         40 CFR 63.10890(c)
                compliance with
                mercury scrap
                management (R)

July 30         Compliance with         40 CFR 63.10890(f)
(Semi-Annual)   above requirements      40 CFR 63.10890(e)(3)(ii)
                during applicable       40 CFR 63.10899(c) *
                1st semi-annual         40 CFR 63.10899(b)(2)(ii) *
                period (R)

Jan. 30         Compliance with above   40 CFR 63.10890(f)
(Semi-Annual)   requirements during     40 CFR 63.10890(e)(3)(ii)
                applicable 1st          40 CFR 63.10899(c) *
                semi-annual
                period (R)

(WP) denotes work practices, (r) denotes reporting requirement

* Rule reference regarding semi-annual reporting for large metalcasters.

Table 3. Larde Metalcaster Emission Standards and Reporting Requirements

Compliance    Compliance or Reporting          Rule
Date          Requirement                      Reference

Jan. 2,       Compliance with emissions        40 CFR
2011 *        limitations associated with      63.10881(x)(3)
              melting operations

March 3,      Complete initial inspection      40 CFR
2011 *        of melting furnace               63.10897(x)
              particulate control device

March 3,      Intent to use previous           40 CFR
2011 *        compliance testing data (R)      63.10898(x)(2)

July 1,       Complete performance testing     40 CFR
2011 *        to demonstrate initial           63.10898(x)
              compliance with emissions
              and opacity limits

60 days       Notification of compliance       40 CFR 63.9(h)
following     status with emissions
performance   and opacity limits (R)
test

(R) denotes reporting requirement.

* Dates shown assume a large metalcaster designation
notification submitted on Jan. 2, 2009.
COPYRIGHT 2008 American Foundry Society, Inc.
No portion of this article can be reproduced without the express written permission from the copyright holder.
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Author:Blankestyn, Mike; Schmeisser, Craig
Publication:Modern Casting
Date:Nov 1, 2008
Words:1739
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