Non-Ferrous Foundries Face Initial Area Source Notification Deadline

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The EPA Area Source Rule for Aluminum, Copper and Other Nonferrous Foundries that was finalized earlier this year does not officially take effect until June of 2011, but there is an early notification requirement contained in the rule that foundries must meet within the next week.

Even thought the base year to determine where a foundry falls under the rule is Calendar Year 2010, companies must file an initial Notice of Compliance Status by no later than October 23rd.  That notice must include:

1. The name and address of the owner or operator;

2. The address (i.e., physical location) of the affected source; and

3. An identification of the relevant standard or other requirement that is the basis of the notification and source’s compliance date.

To help member foundries be certain that they are correctly filing their initial compliance notification, the Non-Ferrous Founders’ Society has prepared a template letter that its member foundries can complete and print on their company letterhead.  In addition, they have prepared a MACT Compliance Summary that details the various requirements that apply to all aluminum and copper-alloy foundries.  (These documents have been posted in the “Members Only” section of the NFFS website.) 

Non-member foundries should reference the initial notification requirements as published in the Federal Register / Vol. 74, No. 121 / Thursday, June 25, 2009 / Page 30396, Section 63.11553(a).