Aluminum, Copper, and Other Nonferrous Foundries
The Environmental Protection Agency (EPA) published a new rule on June 25, 2009 that impacts aluminum, copper, and other nonferrous foundries at small/area sources. This new rule is the National Standard for Hazardous Air Pollutants (NESHAP) for these small/area source categories as published in 40 CFR Part 63, Subpart ZZZZZZ. Areas sources are those that do not emit or have the potential to emit more than 10 tons per year of a single hazardous air pollutant (HAP) or more than 25 tons per year of any combination of HAP. The rule defines a small affected foundry as a copper or other nonferrous foundry that has an annual metal melt production (existing source) or capacity (new source) of less than 6,000 tons.
Who Must Comply with the Rule?
The three source categories subject to this rule include (1) aluminum, (2) copper, and (3) other nonferrous foundries. All affected existing and new sources of aluminum, copper, and other nonferrous foundries are affected by this rule if they melt (existing sources) or have the capacity to melt (new sources) at least 600 tons per year of material that contain aluminum, copper or nonferrous foundry hazardous air pollutants (HAPs).
A foundry is an existing affected source if construction or reconstruction of the melting operations commenced on or before February 9, 2009. A foundry is a new affected source if construction or reconstruction of the melting operation commenced after February 9, 2009.
- Material containing “aluminum foundry HAP” is any material that contains beryllium, cadmium, lead, and nickel in amount greater than or equal to 0.1 percent by weight (as the metal), or contain manganese in amounts greater than or equal to 1.0 percent by weight (as metal).
- Material containing “copper foundry HAP” is any material that contains lead or nickel in amounts greater than 0.1 percent by weight (as the metal), or contains manganese in amounts greater than or equal to 1.0 percent by weight (as the metal).
- Material containing “other nonferrous foundry HAP” is any material that contains chromium, lead, or nickel in amounts greater than or equal to 0.1 percent by weight (as the metal).
The owner or operator must determine whether materials contain aluminum, copper, or other nonferrous foundry HAP, by using formulation provided by the manufacturer or supplier, such as the material safety data sheet (MSDS).
What are the Standards and Management Requirements?
Affected Foundries that Melt 600 Tons per Year or Greater of Metal are Required to:
- Cover or enclose melting furnaces during melting operation
- Purchase scrap that has been depleted of hazardous metals to the extent possible
- Prepare and operate according to a written management practice plan
Sources affected by the rule and located at a large foundry have additional operating requirements. A large foundry is one that has an annual melt production (existing) or capacity (new) of copper, other nonferrous metals and alloys (excluding aluminum) of 6,000 tons or more.
Existing Affected Sources Located at Large Foundries are Required to:
- Comply with an emission limit of 0.015 grains per dry standard cubic foot of particulate matter (PM), or
- Route PM emissions from the melting furnace through a PM control device that achieves a control efficiency of at least 95 percent efficiency.
New Affected Sources Located at Large Foundries are Required to:
- Comply with an emission limit of 0.01grains per dry standard cubic foot of PM,
- Route PM emissions from the melting furnace through a PM control device that achieves a control efficiency of at least 99 percent.
Note that other requirements such as monitoring, performance testing, and record keeping and reporting may apply for all affected sources. See aluminum, copper, and other nonferrous foundries rule published at the following link:
When Must I Comply with the Rule?
The regulation requires all existing sources to notify their regulatory agency that the rule applies to them. This notification is referred to as an Initial Notification. All affected existing facilities must submit the Initial Notice to their regulatory agency no later than 120 days after the publication of the final rule in the Federal register (on or before October 23, 2009). Sources not located in the counties of Davidson, Shelby, Knox and Hamilton, should submit the notice to the Tennessee Division of Air Pollution Control and the Environmental Protection Agency. New sources must submit an Initial Notification within 120 days of start-up. Call the SBEAP for initial notification submittal information at 1-800-734-3619. Please reference the aluminum, copper, and other nonferrous foundries rule.
Compliance with the Rule:
All affected existing facilities must comply with the rule by June 27, 2011. New sources must comply with the rule when they begin to operate. See aluminum, copper, and other nonferrous foundries rule published at the following link: