As part of its Urban Air Toxics Strategy under the Clean Air Act and a consent decree with the Sierra Club, the Environmental Protection Agency is required to promulgate new air emissions standards for smaller or area sources of hazardous air pollutants (HAPs) from a broad range in industry sectors.
EPA recently promulgated a final area source rule for iron and steel foundries and has now begun the process of developing area source rules for copper, non-ferrous and aluminum foundries. The HAPs of concern identified by EPA include beryllium, cadmium, chromium lead, manganese and nickel. Pursuant to the terms of the court order, EPA must issue a final rule for these three foundry area sources by June 15, 2009.
For each of the area source categories, EPA must develop standards based on generally available control technology (GACT) used to reduce emissions of HAPs. GACT may be in the form of pollution control devices or best management practices.
EPA has contacted AFS and NFFS about helping to collect data on these foundry operations and potential emissions of HAPs. Based on recent discussions with EPA officials and their contractor, the agency is looking for available emissions data and operations information for these foundries. In addition, EPA plans to send out a survey to nine companies in each of the three area source categories. EPA would also like AFS and NFFS to send a voluntary survey to provide additional information about these foundry operations. EPA is currently working with the industry to develop an appropriate survey and process for collecting the information.
Currently, EPA is contemplating three separate rulemakings – one for copper foundries, one for other non-ferrous foundries, and one for aluminum foundries. Ultimately, these efforts may be combined into one or two regulatory packages with different subparts, but EPA believes that it make sense initially to develop the standards separately. AFS through the 10E Committee will continue working cooperatively with EPA to develop reasonable area source rules. Although it is still very early in the rulemaking process, EPA has discussed possible regulatory options that could include appropriate production threshold levels for applicability and the development of best management practices for uncontrolled sources at copper, non-ferrous and aluminum foundries.