(MERAF) for the Base Metals Smelting Sector - CCME

In the permitting process, facilities must demonstrate compliance with all federal,
state and local regulations. Pollutants, which are reasonably suspected to be
emitted from the source will have limits, set in the permit. Permits for the base
metals industry will typically contain limits for a combination of PM10 (particulate
matter of less than 10 microns in diameter), sulphur dioxide (SO 2 ), carbon
monoxide (CO), nitrogen oxides (NOx), lead and volatile organic compounds
(VOCs). Limits on these pollutants may also have the effect of controlling the
releases of heavy metals. Alternatively, limits for toxic substances may also be
specified in the permit.
Permits may also control releases by specifying the use of specific technologies
so as to reach the desired level.
In general, air permits:
• Must comply with National Emission Standards for Hazardous Air
Pollutants (NESHAP), National Ambient Air Quality Standards
(NAAQS), New Source Performance Standards (NSPS);
• Must demonstrate Best Achievable Control Technology (BACT) in
attainment areas;
• Must demonstrate Lowest Achievable Emission Rate (LAER) in nonattainment
areas;
• Include requirements for scheduling air stack testing and installation of
continuous environmental monitoring; and
• May include additional limits for heavy metals and other toxics.
Under the U.S. EPA’s Risk Management Planning (RMP) Rule [s112 of the Clean
Air Act Amendments, 1990], sulphur dioxide is listed as a toxic substance with a
threshold quantity of 5,000 lbs. Therefore, those facilities with the potential of
hazardous emissions or releases, covered by the RMP rule, must develop and
implement a risk management program and maintain documentation of the
program at the site. The program includes an analysis of the potential off-site
consequences of an accidental release, a 5-year accident history, a release
prevention program and an emergency response program. With the RMP rule,
releases of sulphur dioxide will be more closely monitored.
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