Government and Regulatory

General Information on Iron & Steel MACT Standards

Final Iron & Steel Foundry MACT rule can be found at 40 CFR Part 63 National Emission Standards for Hazardous Air Pollutants for Iron and Steel Foundries.

Quick Reference Table on the Iron and Steel Foundry MACT requirements (Sept 10, 2003).

Important developments since final Iron & Steel Foundry MACT standards:

Organic HAP Emission Factors: Iron Foundries (update 07/12/2007)

During the late 1990s it became apparent that there was a need for more accurate information on the types and quantities of organic HAPs emitted from the PCS operations in iron foundries. In addition while there was a patch work of data being generated by various sources, there was no single source that a foundry could consult to estimate their PCS HAP emissions. To address this first need, the Casting Emissions Reduction Program (CERP) was created to evaluate the HAP emission potential of various mold and coremaking processes and systems.  To address the second need, the American Foundry Society’s (AFS) Air Quality Committee (10E) formed an Emission Factor Sub-committee, which was tasked to review and existing emission data, as well as provide guidance to insure consistent use of available emission factors. The result is the HAP Emission Factors & Guidance. Please note that this is a "living" document which will be updated as new formation becomes available.

Scrap Metal Amendments in May 20, 2005 Federal Register (update 05/24/2005)

Amendments modifying the work practices requirements for material certification and scrap metal selection/inspection provisions of the Iron and Steel Foundry MACT were published in the Federal Register on May 20, 2005. Comments on either notice must be submitted by June 20, 2005. In the event that the Agency receives no adverse comments on the Direct to Final rule, it will go into effect on August 18, 2005. If there are adverse comments, then the Direct to Final will be withdrawn and the regulatory process will continue under the proposed rule.

Direct to Final (FR Vol 70, No 97 Page 29400)
Proposed (FR Vol 70, No 97 Page 29406) rules

Scrap Selection and Inspection Program Guidance (update 03/04/05)

Under the I&S MACT rule, major source iron and steel foundries are required by April 22, 2005 to implement a Scrap Selection and Inspection Program or a Scrap Certification Program to meet Subpart EEEEE, 40CFR, Part 63, §63.7700(c).

In order to assist foundries that select to implement a Scrap Selection and Inspection Program, you can utilize the Environmental Management Program template. Be sure to modify the provisions outlined in these templates to meet your site specific requirements.

NOTE: This document does not cover all the requirements of the MACT standard, nor is it a comprehensive assessment of the requirements of the Scrap Selection and Inspection Program. Rather, it can be used as a suggested starting point to address one requirement of the MACT. You should individually review the MACT standard to insure that you are addressing all applicable requirements.

Background information:

Final Ferrous Foundry MACT Standards (update 04/23/04)

On Thursday April 22, 2004 the Final Rule of the National Emission Standards for Hazardous Air Pollutants for Iron and Steel Foundries appeared in the Federal Register (Vol. 69, No. 78 page 21906).

Foundries that may be covered by the standards must file an Initial Notification Report with their state permitting authorities by August 20, 2004. Iron and Steel foundries that are major sources of Hazardous Air Pollutants will have to be in full compliance with the new standards by April 23, 2007. The Agency can grant a one-year extension but only when a company request, in writing with reasons, such an extension. These requests are only granted on a case by case basis.

AFS MACT Task Force in Place

In order to assist the ferrous foundry industry work with EPA on the development of MACT Standards for Iron & Steel Foundries, AFS formed the MACT Task Force. This ad hoc group was formally sanctioned by the AFS Board of Directors with the purpose to work with EPA to insure that the final standards meet the requirements of the CAAA without placing any unnecessary burden on our industry. Since these regulations apply only to iron and steel foundries, voting membership on the MTF was limited to those companies operating metalcasting facilities that have made a financial commitment to the MTF. Originating companies of the MTF included Caterpillar, Inc., Charlotte Pipe & Foundry Co., Chrysler Corp., Citation Corp., Deere & Company, East Jordan Iron Works, General Motors, Griffin Wheel/Amsted, Intermet Corporation, McWane Inc., Osco Industries, Steel Founders Society of America, Stockham Valve, *U.S. Pipe and Foundry, Wagner Castings, Waupaca Foundry, and Wheland Foundry Co.

* Denotes an AFS Corporate Member

Background Information Document
EPA document detailing the background information for the proposed standards.

Economic Impact Analysis
EPA document detailing their analysis on the costs and economic impact on the foundry industry, of the proposed standards.

Docket List
List of the materials that are in the Iron and Steel Foundry MACT Docket complied by EPA during the rulemaking process.

AFS comments on the proposal
Document submitted to EPA on February 21, 2003 detailing the AFS concerns and comments relative to the proposed. These comments were generated by the members of the AFS MACT ad hoc Committee (MAHC).