MICHIGAN DEPARTMENT OF ENVIRONMENT, GREAT LAKES, AND ENERGY
AIR QUALITY DIVISION
SEMIANNUAL COMPLIANCE REPORT
NESHAP for Iron and Steel Foundry Area Sources
40 CFR Part 63, Subpart ZZZZZ (40 CFR 63.10880 – 40 CFR 63.10906)
EGLE Environmental Assistance Center Page 1 of 15 Michigan.gov/EGLE
Phone: 800-662-9278 EQP3589(Rev. 01/2021)
Instructions
1. Who Must Complete This Form?
On January 2, 2008, the United States Environmental Protection Agency (USEPA) promulgated a
National Emissions Standard for Hazardous Air Pollutants (NESHAP) for iron and steel foundries. Iron
and steel foundries that meet the definition of an area source are required to submit Semiannual
Compliance Reports to the USEPA and the Michigan Department of Environment, Great Lakes, and
Energy (EGLE).
2. Definitions
An iron and steel foundry is a facility or a portion of a facility that melts scrap, ingot, and/or other forms
of iron and/or steel, and pours the resulting molten metal into molds to produce final or near final shape
products for sale. Research and development facilities, operations that only produce non-commercial
castings, and operations associated with nonferrous metal production are not included in this definition.
An area source has the potential to emit less than 10 tons per year of a single hazardous air pollutant
(HAP) and less than 25 tons per year of any combination of HAPs. If a facility emits more than these
amounts, they are “major sources” and not subject to this Rule.
An existing source means that the foundry startup or reconstruction occurred on or before
September 17, 2007.
A new source means the initial startup of the foundry or reconstruction occurred after September 17,
2007.
Reconstruction means that the fixed capital costs exceed 50 percent of the fixed capital cost that would
be required to construct a comparable new foundry.
Small and Large Foundries. If your foundry is an existing source, determine your metal melt production
for the calendar year 2008. If the production is equal to or less than 20,000 tons, then your foundry is
considered small. If production is more than 20,000 tons, it is considered large. If your foundry is a new
source and the annual melt capacity is equal to or less than 10,000 tons, then your foundry is considered
small. If it is more than 10,000 tons, then your foundry is considered large.
Annual metal melt production means the total quantity of metal charged to all metal melting furnaces at
the foundry in a given calendar year.
Annual metal melt capacity depends on whether or not the furnace(s) are permitted by EGLE, Air Quality
Division. If not, then the capacity is determined by assuming the furnaces are operating at 8,760 hours
per year. If they are permitted, then the capacity is determined by the maximum permitted production
rate calculated on an annual basis. If the permit limits the operating hours of the furnaces, then the
permitted hours are used in annualizing the maximum permitted metal production rate.
Semi Annual Compaliance Report
40 CFR Part 63, Subpart ZZZZZ
EGLE Environmental Assistance Center Page 2 of 15 Michigan.gov/EGLE
Phone: 800-662-9278 EQP3589(Rev. 01/2021)
3. What Sections of the Form Must Be Completed and When?
All small and large foundries must complete the Semiannual Compliance Report, including the facility
section, Parts A, B, and C, and the certification section of this form. The Excess Emissions and
Continuous Monitoring System (CMS) performance report and summary report
(pages 8-14) must be
submitted by large new foundries or the large existing foundries that have installed a bag leak detection
system to a baghouse as an alternative to the baghouse inspection requirements in 40 CFR
63.10897(a)(1). For your convenience, the relevant sections of the Code of Federal Regulations (CFR)
are referenced through out the form. To obtain copies of the CFRs, go to www.michigan.gov/air, select
“Clean Air Assistance” and then “Iron and Steel Foundry Area Sources” under “Federal Regulations.”
There is also a fact sheet entitled “Federal Hazardous Air Pollutant Standard: Iron and Steel Foundry
Area Sources” at this web page which provides an overview of the regulation.
Existing small and large foundries must submit semiannual annual reports every six months (by July 30
for the calendar half January 1 through June 30, and by January 30 for the calendar half July 1 through
December 31). New small and large foundries are required to submit their first report six months after
startup. Semiannual reports are then submitted every six months after the initial submittal according to
the same schedule for existing foundries.
4. Where Do I Send the Completed Form?
In accordance with the September 10, 2020 technology review, beginning on March 9, 2021, you must
submit all subsequent compliance, notification and semiannual reports to the USEPA via the
Compliance and Emissions Data Reporting Interface (CEDRI). You must also submit reports to the
appropriate Michigan Department of Environment, Great Lakes, and Energy, Air Quality Division district
office (see Attachment A). Send the form to the attention of the “AQD District Supervisor.”
Semi Annual Compaliance Report
40 CFR Part 63, Subpart ZZZZZ
EGLE Environmental Assistance Center Page 4 of 15 Michigan.gov/EGLE
Phone: 800-662-9278 EQP3589(Rev. 01/2021)
SEMIANNUAL COMPLIANCE REPORT
NESHAP for Iron and Steel Foundry Area Sources
40 CFR Part 63, Subpart ZZZZZ (40 CFR 63.10880 – 40 CFR 63.10906)
Please review the instructions before completing this form. Please print or type all information.
FACILITY INFORMATION
Pl
ease print or type all information.
Company Name
Com
pany Telephone Area Code & Number
Mailing Address City State Zip Code
Owner/Operator Contact Name and Title Owner Telephone Area Code & Number
Owner Mailing Address (if different than company) City State Zip Code
Owner/Operator E-Mail Address
Facility Name
(if different than company)
Facility Telephone Area Code & Number
Facility Address (if different than company) City State Zip Code
State Registration Number (SRN)
(if known)
Pl
ease check whether the person listed above is owner or operator of the area source:
Owner Operator
Ident
ify the beginning and ending dates of the six-month reporting period
(Either January 1 through June 30, or July 1 through December 31.)
Begi
nning: Ending:
Please check whether the area source is a new or existing source (see instructions for definitions):
New Source (Date of Startup: )
Existing Source
If
an existing source, metal melt production for the previous calendar year: (tons)
Check one: Small Foundry (≤20,000) Large Foundry (>20,000)
If
a New Source, annual metal melt capacity at startup: (tons)
Check one: Small Foundry (≤10,000) Large Foundry (>10,000)
Semi Annual Compaliance Report
40 CFR Part 63, Subpart ZZZZZ
EGLE Environmental Assistance Center Page 5 of 15 Michigan.gov/EGLE
Phone: 800-662-9278 EQP3589(Rev. 01/2021)
PAR
T A – MANAGEMENT PRACTICES FOR METALLIC SCRAP
1. Dur
ing the reporting period, were there any periods during which the facility operated out of
compliance with the metallic scrap management requirements? [40 CFR 63.10885(a)]
No
Yes. Summarize the deviation(s) and indicate the dates and times when the facility operated
out of compliance with the metallic scrap management requirements and explain what
corrective actions were taken.
PA
RT B - MANAGEMENT PRACTICES FOR MERCURY SCRAP
1. Dur
ing the reporting period, were there any periods during which the facility operated out of
compliance with the mercury scrap management requirements? [40 CFR 63.10885(b)]
No
Yes. Summarize the deviation(s) and indicate the dates and times when the facility operated
out of compliance with the mercury scrap management requirements and corrective
actions taken.
2. Indi
cate below which mercury management option(s) the facility is using.
Site-specific plan for mercury switches
Approved mercury program
Specialty metal scrap
Scrap that does not contain motor vehicle scrap
3. Dur
ing the reporting period did the facility conduct periodic inspections or take other actions of
corroboration as required under [40 CFR 63.10885(b)(1)(ii)(c) or 40 CFR 63.10885(b)(2)(iv)(C)]?
No
Yes. Indicate the dates and times when the facility conducted inspections or other actions of
corroboration.
NA. Facility does not melt motor vehicle scrap.
Semi Annual Compaliance Report
40 CFR Part 63, Subpart ZZZZZ
EGLE Environmental Assistance Center Page 6 of 15 Michigan.gov/EGLE
Phone: 800-662-9278 EQP3589(Rev. 01/2021)
4. If
using a site-specific plan for mercury switches, please complete the following:
A) Pr
ovide the following information for the reporting period: number of switches removed or
the weight of mercury recovered from the switches and properly managed, the estimated
number of vehicles processed an estimate of the percent of mercury switches recovered,
and identify which mercury management option applies to each scrap provider, contact, or
shipment (Attach records as needed).
B) Wer
e all removed mercury switches recycled at an RCRA permitted facility as required
under [40 CFR 63.10885(b)(1)(iv)]?
No
Yes
NA The facility does not operate under a site-specific plan for mercury switches.
PA
RT C - MANAGEMENT PRACTICES FOR BINDER FORMULATIONS
1. Dur
ing the reporting period, were there any periods during which the facility operated out of
compliance with the management practices for binder formulations? According to Subpart ZZZZZ,
the facility shall not use a binder formulation that contains methanol as a specific ingredient of the
catalyst formulation for a furfuryl alcohol warm box mold or core making line. [40 CFR 63.10886]
No
Yes. Summarize the deviation(s) and indicate the dates and times when the facility operated
out of compliance with the management practices for binder formulations and corrective
actions taken.
Semi Annual Compaliance Report
40 CFR Part 63, Subpart ZZZZZ
EGLE Environmental Assistance Center Page 7 of 15 Michigan.gov/EGLE
Phone: 800-662-9278 EQP3589(Rev. 01/2021)
CERTIFICATION
I certify that, based on information and belief formed after reasonable inquiry, the statements and
information in this report and the supporting enclosures are true, accurate and complete.
Pr
int or type the name and title of the “Responsible Official*” for the plant:
Signature of “Responsible Official”* Date
Printed Name of “Responsible Official” Title
*A “Responsible Official” can be:
• The president, vice-president, secretary, or treasurer of the company who owns the facility.
• The owner of the facility.
• The facility engineer or supervisor.
• A government official if the plant is owned by the federal, state city or county government.
• A ranking military officer if the plant is located on a military base.
In accordance with the September 10, 2020 technology review, beginning on March 9, 2021, you must
submit all subsequent compliance, notification and semiannual reports to the USEPA via the
Compliance and Emissions Data Reporting Interface (CEDRI). You must also submit reports to the
appropriate Michigan Department of Environment, Great Lakes, and Energy, Air Quality Division district
office (see Attachment A). Send the form to the attention of the “AQD District Supervisor.”
Semi Annual Compaliance Report
40 CFR Part 63, Subpart ZZZZZ
EGLE Environmental Assistance Center Page 8 of 15 Michigan.gov/EGLE
Phone: 800-662-9278 EQP3589(Rev. 01/2021)
EXCESS EMISSIONS AND CONTINUOUS MONITORING SYSTEM (CMS) PERFORMANCE
REPORT AND SUMMARY REPORT
A. Excess
Emissions
1. Have any excess emissions or exceedances of a monitored parameter occurred during this
reporting period?
Yes No (If no, go to B.1.) [40 CFR 63.10(e)(3)(v)]
2. If y
ou answered yes, complete Table 1 for each period of excess emissions and/or parameter
monitoring exceedances, as defined in the relevant standard(s), that occurred during startups,
shutdowns, and/or malfunctions of your affected source, or during periods other than startups,
shutdowns, and/or malfunctions of your affected source. (Go to B.1.) [40 CFR 63.10(c)(7)-(11)]
Semi Annual Compaliance Report
40 CFR Part 63, Subpart ZZZZZ
EGLE Environmental Assistance Center Page 9 of 15 Michigan.gov/EGLE
Phone: 800-662-9278 EQP3589 (Rev. 01/2021)
Table 1 – Excess Emissions and/or Parameter Monitoring Exceedances
Note: Use a separate line for each period of excess emissions and/or parameter monitoring exceedances of your affected source.
Nature of Event or
Problem
Excess Emissions and/or Parameter Monitoring
Exceedances Occurred:
Excess
Emissions
Parameter
Monitoring
Exceedance
During
Startup
During
Shutdown
During
Malfunction
During
Another
Period
Start Date
(mm/dd/yyyy)
Completion
Date
(mm/dd/yyyy)
Nature and Cause of any
Malfunction
(if known)
Corrective Action Taken
or Preventive Measures
Adopted
Semi Annual Compaliance Report
40 CFR Part 63, Subpart ZZZZZ
EGLE Environmental Assistance Center Page 10 of 15 Michigan.gov/EGLE
Phone: 800-662-9278 EQP3589 (Rev. 01/2021)
B. Con
tinuous Monitoring System Performance
1. Has a CMS been inoperative (except for zero/low-level and high-level checks), out of control
(as defined in [40 CFR 63.8(c)(7)(i)], repaired, or adjusted during this reporting period?
Yes No (If no, go to B.3.) 40 CFR 63.10(e)(3)(v)
Note: A CMS is out of control if (a) the zero (low-level), mid-level (if applicable), or high-level calibration drift
(CD) exceeds two times the applicable CD specification in the applicable performance specification or in the
relevant standard; or (b) the CMS fails a performance test audit (e.g., cylinder gas audit), relative accuracy
audit, relative accuracy test audit, or linearity test audit; or (c) the COMMS CD exceeds two times the limit in
the applicable performance specification in the relevant standard. (40 CFR 63.8(c)(7(i))
When the CMS is out of control, the owner or operator of the affected source shall take the necessary
corrective action and shall repeat all necessary tests which indicate that the system is out-of-control. The
owner or operator shall take corrective action and conduct retesting until the performance requirements are
below the applicable limits. The beginning of the out-of-control period is the hour the owner or operator
conducts a performance check (e.g., calibration drift) that indicates an exceedance of the performance
requirements established under this part. The end of the out-of-control period is the hour following the
completion of corrective action and successful demonstration that the system is within the allowable limits.
During the period the CMS is out-of-control, recorded data shall not be used in data averages and calculations,
or to meet any data availability requirement established under this part. (40 CFR 63.8(c)(7(ii))
2. If you answered yes, complete Table 2 for each period a CMS was out of control, repaired,
or adjusted: (40 CFR 63.10(c)(5)-(6), (10)-(12), 40 CFR 63.8(c)(8))
3. Indicate the total process operating time during the reporting period. (40 CFR 63.10(c)(13))
Total process operating time (days)
Semi Annual Compaliance Report
40 CFR Part 63, Subpart ZZZZZ
EGLE Environmental Assistance Center Page 11 of 15 Michigan.gov/EGLE
Phone: 800-662-9278 EQP3589 (Rev. 01/2021)
Table 2 - Continuous Monitoring System Performance Reporting.
Note: Use a separate line for each period a CMS was out of control, repaired, or adjusted.
CMS Type Manufacturer
Process
ID
Number
Start Date
(mm/dd/yyyy)
Completion
Date
(mm/dd/yyyy)
Nature and Cause of Any
Malfunction (if known)
Corrective Action Taken or
Preventive Measures
Adopted
Nature of the Repairs or
Adjustments Made to the
CMS that was Inoperative or
Out of Control
Semi Annual Compaliance Report
40 CFR Part 63, Subpart ZZZZZ
EGLE Environmental Assistance Center Page 12 of 15 Michigan.gov/EGLE
Phone: 800-662-9278 EQP3589 (Rev. 01/2021)
SUMMARY REPORT: GASEOUS AND OPACITY EXCESS EMISSION AND CONTINUOUS
MONITORING SYSTEM PERFORMANCE
Note: One summary report shall be submitted for the hazardous air pollutants monitored at each affected
source (unless the relevant standard specifies that more than one summary report is required, e.g., one
summary report for each hazardous air pollutant monitored). (40 CFR 63.10(e)(3)(vi))
A. Report Date and Submittal Reporting Period
Indicate the reporting period covered by this submittal and the date of this summary report. [40 CF
R
63.10(e)(3)(vi)(C), and (M)]
Reporting period beginning
date (mm/dd/yyyy)
Reporting period ending date
(mm/dd/yyyy)
Summary report date
(mm/dd/yyyy)
B. Process Description and Monitoring Equipment Information
Complete the following process description and monitoring equipment information table for each
affected source process unit: (40 CFR 63.10(e)(3)(vi)(B), (D), (E), (F), (G), and (H))
Total operating time of affected source during the reporting period (days)
Process unit name
Process unit description
Emission and/or operating parameter limitations specified in the relevant standard(s)
Monitoring Equipment Information
Type
Latest
Certification or
Audit Date
(mm/dd/yyyy)
Manufacturer Model HAPs Monitored
Semi Annual Compaliance Report
40 CFR Part 63, Subpart ZZZZZ
EGLE Environmental Assistance Center Page 13 of 15 Michigan.gov/EGLE
Phone: 800-662-9278 EQP3589 (Rev. 01/2021)
C. Emission Data Summary
Complete the following emission data summary table for each affected source: [40 CFR
63
.10(e)(3)(vi)(I)]
Total duration of excess emissions/parameter exceedances (minutes for opacity, hours for
gases)
Opacity (minutes):
Gases (hours):
Total operating time of affected source during the reporting period (days)
Percent of total source operating time during which excess emissions/parameter exceedances
occurred (percent)
Summary of causes of excess emissions/parameter exceedances (percent of total duration by
cause)
Startup/shutdown
%
Control equipment problems
%
Process problems
%
Other known causes
%
Other unknown causes
%
TOTAL
100%
D. CM
S Performance Summary
Complete the following CMS performance summary table for each affected source:
(40 CFR 63.10(e)(3)(vi)(J))
Total duration of CMS downtime (minutes for opacity, hours for gases)
Opacity (minutes): Gases (hours):
Total operating time of affected source during the reporting period (days)
Percent of total source operating time during which CMS were down (percent)
Summary of causes of CMS downtime (percent of downtime by cause)
Monitoring equipment malfunctions
%
Nonmonitoring equipment malfunctions
%
Quality assurance/quality control calibrations
%
Semi Annual Compaliance Report
40 CFR Part 63, Subpart ZZZZZ
EGLE Environmental Assistance Center Page 14 of 15 Michigan.gov/EGLE
Phone: 800-662-9278 EQP3589 (Rev. 01/2021)
Other known causes
%
Other unknown causes
%
TOTAL
100%
E. CMS, Process, or Control Changes
1. Have you made any changes in CMS, processes, or controls since the last reporting period?
Yes No (If no, go to CERTIFICATION) (40 CFR 63.10(e)(3)(vi)(K))
2. If you answered yes, please describe the changes below, and then go to CERTIFICATION:
Changes in CMS, processes, or controls since the last reporting period
Semi Annual Compaliance Report
40 CFR Part 63, Subpart ZZZZZ
EGLE Environmental Assistance Center Page 15 of 15 Michigan.gov/EGLE
Phone: 800-662-9278 EQP3589 (Rev. 01/2021)
CERTIFICATION
I c
ertify that, based on information and belief formed after reasonable inquiry, the statements and
information in this report and the supporting enclosures are true, accurate and complete.
Pr
int or type the name and title of the “Responsible Official*” for the plant:
Signature of “Responsible Official”* Date
Printed Name of “Responsible Official” Title
*A
“Responsible Official” can be:
• The president, vice-president, secretary, or treasurer of the company who owns the facility.
• The owner of the facility.
• The facility engineer or supervisor.
• A government official if the plant is owned by the federal, state city or county government.
• A ranking military officer if the plant is located on a military base.
In accordance with the September 10, 2020 technology review, beginning on March 9, 2021, you must
submit all subsequent compliance, notification and semiannual reports to the USEPA via the
Compliance and Emissions Data Reporting Interface (CEDRI). You must also submit reports to the
appropriate Michigan Department of Environment, Great Lakes, and Energy, Air Quality Division district
office (see Attachment A). Send the form to the attention of the “AQD District Supervisor.”
For information or assistance on this publication, please contact the Air Quality Division, through EGLE Environmental
Assistance Center at 800-662-9278. This publication is available in alternative formats upon request.
EGLE does not discriminate on the basis of race, sex, religion, age, national origin, color, marital status, disability, political
beliefs, height, weight, genetic information, or sexual orientation in the administration of any of its program or activities, and
prohibits intimidation and retaliation, as required by applicable laws and regulations. Questions or concerns should be
directed to the Nondiscrimination Compliance Coordinator at EGLE-NondiscriminationCC@Michigan.gov
or 517-249-0906.
This form and its contents are subject to the Freedom of Information Act and may be released to the public.
