Members of the American Foundry Society Air Quality Committee met recently with EPA officials regarding the upcoming Residual Risk and Technology Review (RTR) for the iron and steel foundry National Emission Standards for Hazardous Air Pollutants (NESHAP) rule for major sources.
The May 8 meeting in Research Triangle Park, N.C., included discussions on the following issues:
Rulemaking schedule
EPA officials provided an overview of the RTR process and confirmed the rulemaking schedule, with a planned proposed rule date of June 27, 2019, and a final rule date of June 30, 2020. While EPA does have some flexibility regarding the date for the proposed rule, the date for the final rule is firm because it is set by a court order. The rulemaking schedule is aggressive, but both AFS and EPA vowed to work together to meet these deadlines.
Data collection
Over the past two years, AFS has been assisting EPA in identifying the iron and steel foundries that are major sources subject to the rule. Based on the list that has been prepared cooperatively, EPA will research its databases, particularly the 2014 National Emissions Inventory (NEI), to determine the emissions levels for each of these facilities. EPA will also rely, albeit to a lesser degree, on data from EPA's Toxic Release Inventory (TRI) and ECHO data bases for applicable information. EPA will conduct a quality assurance (QA) validation of this information by June or July of this year and share this information with AFS for review and comment. EPA indicated that it will allow AFS 30-60 days to review this information and provide comments.
Risk and technology review
The revised QA validation data will be used to conduct the residual risk analysis for this source category. Assuming that the residual risk is acceptable, i.e., less than 100 in a million cancer risk, EPA will then conduct a technology review to determine if there are any new economically achievable control technologies that can be used to reduce emissions further. In addition, EPA will consider developments in practices, processes and control technologies that can reduce emissions in an economically efficient manner. If the risk is not acceptable, i.e., more than 100 in a million cancer risk, then EPA can require control technologies to reduce emissions without considering economic achievability.
Regulatory clarifications
The AFS group also discussed several issues with EPA, including how startup, shutdown, and malfunction (SSM) provisions may be handled in the final rule. EPA officials indicated that the agency cannot rely on exemptions or planned noncompliance, but must develop some standard to address these issues. EPA indicated that it would look to the industry for some suggestions on appropriate work practices and other standards that should apply during periods of startup, shutdown, and malfunction.
Finally, EPA asked for input from AFS on needed clarifications for existing provisions in the current rule that could be incorporated into the final RTR rule. The AFS group identified several issues that needed regulatory clarifications and the EPA officials indicated that they were willing to consider them. AFS asked EPA if committee representatives could confer with the broader Air Quality Committee to refine the list of regulatory clarifications needed and provide input in the near future. EPA agreed, and AFS plans to include this as an agenda item for the next Air Quality Committee meeting in June.
Foundry visits
AFS also asked EPA if they were interested in visiting some foundry operations as part of their efforts in developing this new rule. EPA enthusiastically agreed and will be scheduling a series of site visits in the near future. EPA also agreed to make a presentation on the RTR rule development process at the AFS EHS Conference this fall in Cleveland. AFS may also try to schedule some additional foundry visits for EPA officials at that time.
The American Foundry Society is a dynamic technical and advocacy organization that serves and represents the $33 billion metalcasting industry. AFS is the only association serving the entire industry, including all metals and processes, with a three-part focus on advocacy, education, and innovation. AFS also publishes Modern Casting and Metal Casting Design & Purchasing magazines and presents Metalcasting Congress and CastExpo, the largest metalcasting trade events in North America. Founded in 1896, the organization is based in Schaumburg, Illinois, with an advocacy office in Washington, D.C. More information is available at afsinc.org.