OUTOKUMPU STAINLESS USA, LLC CALVERT, AL FACILITY NO.: MAJOR SOURCE OPERATING PERMIT INITIAL TITLE V DRAFT

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1 CALVERT, AL FACILITY NO.: MAJOR SOURCE OPERATING PERMIT INITIAL TITLE V DRAFT

2 (THIS PAGE LEFT BLANK INTENTIONALLY)

3 Table of Contents PROCESS DESCRIPTION... 2 MELT SHOP... 4 STATE REGULATIONS... 5 ADEM Admin. Code r , Prevention of Significant Deterioration (PSD) Permitting... 5 FEDERAL REGULATIONS... 9 NEW SOURCE PERFORMANCE STANDARDS (NSPS) CFR Part 60, Subpart A, General Provisions CFR Part 60 Subpart AAa, Standards of Performance for Steel Plants: Electric Arc Furnaces and Argon-Decarburization Vessels Constructed After August 17, NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) CFR Part 63 Subpart YYYYY, National Emission Standards for Hazardous Air Pollutants for Area Sources: Electric Arc Furnace Steelmaking Facilities CFR 64, COMPLIANCE ASSURANCE MONITORING (CAM) MELT SHOP BAGHOUSE EMISSIONS MMBTU/HR PASSIVE ANNEALING FURNACE STATE REGULATIONS ADEM Admin. Code r (1)(a) and (b), Visible Emissions for Control of Particulate Emissions ADEM Admin. Code r , Prevention of Significant Deterioration (PSD) Permitting FEDERAL REGULATIONS NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) CFR Part 63, Subpart A, General Provisions CFR Part 63 Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters CFR 64, COMPLIANCE ASSURANCE MONITORING (CAM) PASSIVE ANNEALING FURNACE EMISSIONS SLAB HOLDING FURNACE STATE REGULATIONS i

4 ADEM Admin. Code r (1)(a) and (b), Visible Emissions for Control of Particulate Emissions ADEM Admin. Code r , Prevention of Significant Deterioration (PSD) Permitting FEDERAL REGULATIONS NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) CFR Part 63, Subpart A, General Provisions CFR Part 63 Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters CFR 64, COMPLIANCE ASSURANCE MONITORING (CAM) SLAB HOLDING FURNACE EMISSIONS HOT ANNEALING AND PICKLING LINE (HAPL) STATE REGULATIONS ADEM Admin. Code r , Prevention of Significant Deterioration (PSD) Permitting FEDERAL REGULATIONS NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) CFR Part 63, Subpart A, General Provisions CFR Part 63 Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters CFR 64, COMPLIANCE ASSURANCE MONITORING (CAM) HAPL EMISSIONS COLD ANNEALING AND PICKLING LINE (CAPL) STATE REGULATIONS ADEM Admin. Code r , Prevention of Significant Deterioration (PSD) Permitting FEDERAL REGULATIONS NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) CFR Part 63, Subpart A, General Provisions CFR Part 63 Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters CFR 64, COMPLIANCE ASSURANCE MONITORING (CAM) ii

5 CAPL EMISSIONS MIXED ACID REGENERATION PLANT STATE REGULATIONS ADEM Admin. Code r , Prevention of Significant Deterioration (PSD) Permitting FEDERAL REGULATIONS CFR 64, COMPLIANCE ASSURANCE MONITORING (CAM) MIXED ACID REGENERATION PLANT EMISSIONS ACID REGENERATION PLANT TANK FARM STATE REGULATIONS ADEM Admin. Code r (1)(a) and (b), Visible Emissions for Control of Particulate Emissions ADEM Admin. Code r , Prevention of Significant Deterioration (PSD) Permitting FEDERAL REGULATIONS CFR 64, COMPLIANCE ASSURANCE MONITORING (CAM) ACID REGENERATION PLANT TANK FARM EMISSIONS COLD ROLLING MILLS STATE REGULATIONS ADEM Admin. Code r (1)(a) and (b), Visible Emissions for Control of Particulate Emissions ADEM Admin. Code r , Prevention of Significant Deterioration (PSD) Permitting FEDERAL REGULATIONS CFR 64, COMPLIANCE ASSURANCE MONITORING (CAM) COLD ROLLING MILLS EMISSIONS TWO (2) 28.6 MMBTU/HR NATURAL GAS FIRED BOILERS STATE REGULATIONS ADEM Admin. Code r (1)(a) and (b), Visible Emissions for Control of Particulate Emissions ADEM Admin. Code r , Prevention of Significant Deterioration (PSD) Permitting iii

6 FEDERAL REGULATIONS NEW SOURCE PERFORMANCE STANDARDS (NSPS) CFR Part 60, Subpart A, General Provisions CFR Part 60, Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) CFR Part 63, Subpart A, General Provisions CFR Part 63 Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters CFR 64, COMPLIANCE ASSURANCE MONITORING (CAM) BOILER EMISSIONS NSPS IIII EMERGENCY GENERATORS STATE REGULATIONS ADEM Admin. Code r (1)(a) and (b), Visible Emissions for Control of Particulate Emissions FEDERAL REGULATIONS NEW SOURCE PERFORMANCE STANDARDS (NSPS) CFR Part 60 Subpart A, General Provisions CFR Part 60 Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) CFR Part 63 Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines CFR 64, COMPLIANCE ASSURANCE MONITORING (CAM) NSPS IIII EMERGENCY GENERATORS EMISSIONS NSPS JJJJ EMERGENCY GENERATORS STATE REGULATIONS ADEM Admin. Code r (1)(a) and (b), Visible Emissions for Control of Particulate Emissions FEDERAL REGULATIONS NEW SOURCE PERFORMANCE STANDARDS (NSPS) iv

7 40 CFR Part 60 Subpart A, General Provisions CFR Part 60 Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal Combustion Engines NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) CFR Part 63 Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines CFR 64, COMPLIANCE ASSURANCE MONITORING (CAM) NSPS JJJJ EMERGENCY GENERATORS EMISSIONS RECOMMENDATIONS v

8 MOBILE COUNTY, AL STATEMENT OF BASIS This proposed Title V Major Source Operating Permit (MSOP) is issued under the provisions of ADEM Admin. Code r The above named applicant has requested authorization to perform the work or operate the facility shown on the application and drawings, plans and other documents attached hereto or on file with the Air Division of the Alabama Department of Environmental Management, in accordance with the terms and conditions of this permit. The air permits ( X001 through X027) to commence construction of the facility were issued to the original owner ThyssenKrupp Stainless USA, LLC on August 17, Temporary Authorization to Operate (TAO) was issued to ThyssenKrupp for several sources on July 27, Per ADEM Admin. Code r (2), a facility must apply for a Major Source Operating Permit (MSOP) within 12 months after commencing operation. An initial MSOP application was submitted to the Department on July 15, Therefore, the application was submitted in a timely manner. On January 30, 2013, the Department received an application from Outokumpu Stainless USA, LLC (Outokumpu) regarding the name/ownership change of the facility. On February 14, 2013, the Department reissued Air Permit Nos X001, X002, X008, X010, X011, X013, X019, X021, and X022 to Outokumpu to reflect the new facility name and ownership. The additional construction permits had been previously voided. On June 23, 2014, Outokumpu submitted an air permit application proposing to modify the existing NOX and SO2 emission limits associated with the electric arc furnace. Additional information was received on September 10, 2014 and January 27, The Department reissued Air Permit No X001 on June 13, 2017 to reflect the changes. On June 28, 2018, Outokumpu submitted an updated Title V application which included only the units that are currently operating at the facility. Additional information was received on August 6, With regards to Title V regulations, this facility is major for all criteria pollutants (potential to emit greater than 100 tons per years of PM, SO2, NOX, CO, and VOC) and major for hazardous air pollutants (potential to emit greater than 10 TPY of a single HAP or 25 TPY of a combination of all HAPs). This facility is also classified as a major source with regards to PSD. 1

9 PROCESS DESCRIPTION The following significant sources of air pollution are located at this facility (a list of insignificant sources can be found in the application): Melt Shop o Electric Arc Furnace w/ DEC and Elephant House and Deslagging w/ Baghouse (LO1) o Argon-Oxygen Decarburization Converter w/ Elephant House, Two (2) Ladle Metallurgy Stations, and Continuous Caster w/ Baghouse (LO2) o Slab Grinder w/ Baghouse (LO4) o Alloys, Scrap, and Lime Hoppers w/ Baghouse (LO5, LO12) o Torch Cutoff w/ Baghouse (LO11) 95 MMBtu/hr Passive Annealing Furnace (LO41A) 25 MMBtu/hr Slab Holding Furnace (LO42) Hot Annealing and Pickling Line (HAPL) o 143 MMBtu/hr Natural Gas Fired Annealing Furnace (LO43) o Shotblaster/Scale Breaker w/ Baghouse (LO45) o Sodium Sulfate Pickling w/ Wet Scrubber (LO46) o Nitric Hydrofluoric Acid Pickling w/ Wet Scrubber + de-nox SCR (LO47) Cold Annealing and Pickling Line (CAPL) o Degreasing w/ Wet Scrubber (LO52) o 125 MMBtu/hr Natural Gas Fired Annealing Furnace (LO53) o Sodium Sulfate Pickling w/ Wet Scrubber (LO55) o Nitric Hydrofluoric Acid Pickling w/ Wet Scrubber + de-nox SCR (LO57) Mixed Acid Regeneration Plant o Acid Regeneration Line w/ Wet Scrubber + de-nox SCR (LO72) o Iron Oxide Storage Bins and Baggers w/ Baghouse (LO71) Acid Regeneration Plant Tank Farm w/ Scrubber Three (3) Cold Rolling Mills w/ Mist Eliminators (LO48-LO50) Two (2) 28.6 MMBtu/hr Natural Gas Fired Boilers (S26, S27) Four (4) Diesel Fired Emergency Generators (Admin [170 BHP], Building 67 [657 BHP], CAPL [729 BHP], HAPL [800 BHP]) 383 BHP Natural Gas Fired Emergency Generator (Meltshop Admin) 2

10 The production of stainless steel starts with the processing of stainless steel scrap and various alloys in the electric arc furnace (EAF). Numerous additives are also included in the melt such as lime to remove impurities. To produce stainless steel, elemental carbon and sulfur must be removed from the molten steel. This is accomplished in the Argon- Oxygen Decarburization (AOD) vessel. Adjustment of the final composition of specific grades of stainless steels is accomplished by adding chromium, nickel, and other alloying agents in ladle metallurgical stations (LMS). Once the melt has attained the specified composition at the ladles (which have a preheater), the molten steel is poured into a tundish (with preheaters) which feeds a continuous caster. The caster produces a continuous bar. Water is sprayed on the bar to solidify the steel. A torch then cuts the bar into individual slabs that are taken to a slab grinder before proceeding to a hot rolling mill where coils would be produced. The EAF and Raw Material Handling and Storage are controlled by Baghouse # 1 (LO-1) and the AOD and LMS are controlled by Baghouse # 2 (LO-2). Hot rolled coils are loaded into the entry of the hot annealing and pickling line (HAPL). The coils are uncoiled and joined by a welding operation so that the strip is subject to continuous annealing and de-sacling through the line. Hydrofluoric acid is used to remove scale oxides (primarily iron oxides) from the surface of the steel. Hot rolled, annealed and pickled coils are loaded in one of three cold rolling mills and uncoiled. This process reduces the strip of steel to the proper thickness. This is achieved by applying roll force to the strip as well as applying high strip tension. After the cold rolling process, the coils are sent to the cold annealing and pickling line (CAPL) to recover mechanical properties. Waste mixed acid from the HAPL and CAPL processes is pumped into a preconcentrator. Moisture and mixed acids are evaporated and enter an absorption column where the acid is recovered and re-used in the pickling process. The exhaust gas is passed through a scrubber. The concentrated liquid from the pre-concentrator enters a reactor where the remaining moisture is evaporated and iron oxide is conveyed to a silo for shipment offsite. The natural gas boilers are used for process heat. The passive annealing furnace is used to heat material for proper grain structure prior to further processing at the HAPL. The slab holding furnace is utilized for the ferritic grade of stainless steel this material must be maintained at a certain temperature while waiting to be processed in the hot rolling mill. 3

11 MELT SHOP DESCRIPTION POLLUTANT EMISSION LIMIT REGULATIONS 126 TPH Electric Arc Furnace w/ DEC and Elephant House and Deslagging w/ Baghouse (LO1) PM gr/dscf lb/hr Rule SO lb/ton lb/hr NO X 0.60 lb/ton lb/hr CO 2.0 lb/ton lb/hr VOC 0.03 lb/ton 3.77 lb/hr Pb lb/hr Opacity Less than 3% 40 CFR a(a)(2) Argon-Oxygen Decarburization Converter w/ Elephant House, Two (2) Ladle Metallurgy Stations, and Continuous Caster w/ Baghouse (LO2) PM SO gr/dscf lb/hr 0.15 lb/ton lb/hr Rule NO X 0.35 lb/ton lb/hr CO 2.0 lb/ton lb/hr VOC 0.03 lb/ton 3.77 lb/hr Pb lb/hr 4

12 Opacity Less than 3% 40 CFR a(a)(2) Slab Grinding w/ Baghouse (LO4) PM gr/dscf 1.35 lb/hr Rule Opacity Less than 10% Rule Alloys, Scrap, and Lime Hoppers w/ Baghouses (LO5, LO12) PM gr/dscf 2.09 lb/hr Rule Opacity Less than 10% Rule Torch Cutoff w/ Baghouse (LO11) PM gr/dscf lb/hr Rule Opacity Less than 10% Rule Meltshop Building Opacity Less than 6% 40 CFR a(a)(3) Baghouse Dust Handling System Opacity Less than 10% 40 CFR a(b) STATE REGULATIONS ADEM Admin. Code r , Prevention of Significant Deterioration (PSD) Permitting The emission points associated with the melt shop are subject to PSD/BACT limits and requirements. The limits/requirements in this section are being rolled into the Initial Title V Permit from Air Permit No X001, issued on June 13, Emission Standards: The facility shall comply with the following limits for LO1: The opacity of emissions from the stack associated this unit shall not exceed three percent (3%) opacity as determined by a six (6) minute average. Particulate matter (PM) emissions shall not exceed gr/dscf and lb/hr. Sulfur dioxide (SO2) emissions shall not exceed lb/hr and lb/ton of steel 5

13 produced. Nitrogen oxide (NOX) emissions shall not exceed lb/hr and 0.60 lb/ton of steel produced. Carbon monoxide (CO) emissions shall not exceed lb/hr and 2.0 lb/ton of steel produced. Volatile organic compound (VOC) emissions as carbon shall not exceed 3.77 lb/hr and 0.03 lb/ton of steel produced. Lead emissions shall not exceed lb/hr. The facility shall comply with the following limits for LO2: The opacity of emissions from the stack associated this unit shall not exceed three percent (3%) opacity as determined by a six (6) minute average. PM emissions shall not exceed gr/dscf and lb/hr. SO2 emissions shall not exceed lb/hr and 0.15 lb/ton of steel produced. NOX emissions shall not exceed lb/hr and 0.35 lb/ton of steel produced. CO emissions shall not exceed lb/hr and 2.0 lb/ton of steel produced. VOC (as C) emissions as carbon shall not exceed 3.77 lb/hr and 0.03 lb/ton of steel produced. Lead emissions shall not exceed lb/hr. The facility shall comply with the following limits: The opacity of emissions from LO4, LO5, LO11, and LO12 shall not exceed ten percent (10%) opacity as determined by a six (6) minute average. PM emissions from LO4 shall not exceed gr/dscf and 1.35 lb/hr. PM emissions from LO5 and LO12 shall not exceed gr/dscf and 2.09 lb/hr. PM emissions from LO11 shall not exceed gr/dscf and lb/hr. The facility shall comply with the following requirements: The EAF and AOD vessel shall be located in an enclosure (elephant house) located inside the melt shop building. This enclosure shall be equipped with a capture system, which shall be routed to the Melt Shop Baghouses (LO1 LO2). The system shall be operated in a manner such that an optimum pressure is maintained on the elephant house. All dust handling systems (screw conveyors, silos, dumpsters, etc.) from the baghouse hoppers shall be enclosed to prevent fugitive emissions from these handling systems. A drawing or diagram showing roadway areas connected to the melt shop shall be 6

14 submitted to the Department. The drawing should indicate which roads would be paved. All paved roads shall be vacuum swept or flushed of surface material at least once every five (5) days. Paved road flushing is not required when the temperature is below 32 F. Paved road cleaning is not required when precipitation during the previous 24-hour period has exceeded 0.01 inches. The production of molten steel from the electric arc furnace shall not exceed 1,100,000 tons in any consecutive 12-month period. These sources shall fire only natural gas as a fuel. Compliance and Performance Test Methods and Procedures: The facility shall comply with the following test methods/procedures: Method 9 of 40 CFR part 60, appendix A shall be used in the determination of opacity. Method 5 of 40 CFR part 60, appendix A shall be used in the determination of PM emissions. Methods 6 or 6C of 40 CFR part 60, appendix A shall be used in the determination of SO2 emissions. Method 7E of 40 CFR part 60, appendix A shall be used in the determination of NOX emissions. Method 10 of 40 CFR part 60, appendix A shall be used in the determination of CO emissions. Methods 18 or 25A of 40 CFR part 60, appendix A shall be used in the determination of VOC emissions. Method 12 of 40 CFR part 60, appendix A shall be used in the determination of lead emissions. Emission Monitoring: The Permittee shall conduct performance tests for PM/PM10 and CO emissions from the stacks associated with LO1 and LO2 at least once every 12 months. If there are any changes in the operation of or control equipment on LO1 and/or LO2, performance tests for NOX emissions shall be conducted at least once every 12 months. The stacks associated with LO1 and LO2 are equipped with continuous emissions monitor systems (CEMS). The CEMS will be operated and maintained according to the procedures in Performance Specification 2 of 40 CFR part 60, appendix B. CEMS data will be used to demonstrate compliance with the SO2 standard. 7

15 The Permittee will be required to monitor the sulfur content from each load of coal received to be used as charge in the EAF. The Permittee may use vendor test data or shipment certifications to verify the sulfur content in the coal. If the sulfur content in the coal is greater than 1.0%, the Department must be notified within 24 hours. A daily visual inspection of the stacks associated with the melt shop shall be performed by a person familiar with Method 9 procedures. If visible emissions are observed at any time and not corrected within one (1) hour, a visible emissions observation shall be conducted according to Method 9 within four (4) hours of the initial observation. Quarterly inspections of the direct evacuation control system (DEC) shall be conducted to ensure proper operation. The stacks associated with LO1 and LO2 are equipped with continuous opacity monitoring systems (COMS). The COMS will be operated and maintained according to the procedures in Performance Specification 1 of 40 CFR part 60, appendix B. Recordkeeping and Reporting Requirements: The facility shall maintain the following records in a for suitable for inspection for a period of at least five (5) years: Records documenting each occasion in which paved areas are cleaned in accordance with the permit and any occasion in which these paved areas are not cleaned according to required schedule. This record shall include any justification for failure to meet the required schedule, such as equipment breakdown or inclement weather conditions. Sulfur content in the coal charged in the EAF. Amount of lime added per batch (heat) of steel produced. Monthly and 12-month rolling total steel production. Each visible inspection, to include Method 9 visible observations. This should also include problems observed and corrective actions taken. Quarterly inspections performed on the DEC. The Permittee shall submit an Excess Emissions report for LO1 and LO2 to the Department quarterly. The report will include the following information: Opacity: The magnitude of excess emissions of 3% as computed from 6-minute averages. SO2: Emission rates over lb/hr (LO1) and lb/hr (LO2) as computed from a 3-hour average. The date and time each excess emissions event commenced and ended. The nature and cause of the excess emissions (if known) and the corrective action(s) 8

16 taken or preventative measure(s) adopted. The date and time of each period during which any of the monitors were inoperative (except zero and span checks) and the nature of the repairs or adjustments. The equations used to convert SO2 emissions data as monitored to the required reporting standard (lb/hr). If, during a reporting period, no excess emission events occur and the monitoring systems are operable at all times, a statement to that effect will be included in the report. FEDERAL REGULATIONS NEW SOURCE PERFORMANCE STANDARDS (NSPS) 40 CFR Part 60, Subpart A, General Provisions Provided that the facility is subject to one of the applicable subparts found under this part, the facility shall comply with this regulation as specified in that subpart. 40 CFR Part 60 Subpart AAa, Standards of Performance for Steel Plants: Electric Arc Furnaces and Argon-Decarburization Vessels Constructed After August 17, 1983 Per a(a), the electric arc furnace (EAF) and argon-oxygen decarburization converter (AOD) are subject to this subpart. Emission Standards: Per a(a)(1), particulate matter (PM) emissions from the control device(s) shall not exceed 12 mg/dscm ( gr/dscf). Per a(a)(2), the opacity of emissions from the control device(s) shall not exceed 3%. Per a(a)(3), the opacity of emissions from the melt shop building shall not exceed 6%. Per a(b), the opacity of emissions from the dust handling system shall not exceed 10%. Compliance and Performance Test Methods and Procedures: Per a(e)(1), Method 5 of 40 CFR part 60, appendix A shall be used in the 9

17 determination of PM emissions. Per a(e)(3), Method 9 of 40 CFR part 60, appendix A shall be used in the determination of opacity. Emission Monitoring: Per a(a), the baghouses shall be equipped with a continuous opacity monitoring system (COMS). Per a(d), daily observations of the shop opacity shall be performed when the furnace is operating in the meltdown and refining period. Shop opacity shall be determined as the arithmetic average of 24 consecutive 15-second opacity observations of emissions from the shop taken in accordance with Method 9. The Permittee shall comply with the monitoring requirements in a, summarized below: Check and record furnace static pressure of DEC system once per shift and either check and record the control system fan motor amperes and damper position on a once-per-shift basis; install, calibrate, and maintain a monitoring device that continuously records the volumetric flow rate through each separately ducted hood; or install, calibrate, and maintain a monitoring device that continuously records the volumetric flow rate at the control device inlet and check and record damper positions on a once-per-shift basis [ a(b)]. When demonstrating compliance with the shop opacity requirement, the control system fan motor amperes and all damper positions, the volumetric flow rate through each separately ducted hood, or the volumetric flow rate at the control device inlet and all damper positions shall be determined during all periods in which a hood is operated for the purpose of capturing emissions from the EAF [ a(c)]. Perform monthly operational status inspections of the equipment that is important to the performance of the total capture system (i.e., pressure sensors, dampers, and damper switches) [ a(d)]. Except as provided for under a(d), if emissions during any phase of the heat time are controlled by the use of a DEC system, the owner or operator shall install, calibrate, and maintain a monitoring device that allows the pressure in the free space inside the EAF to be monitored. The pressure shall be recorded as 15-minute integrated averages [ a(f)]. Except as provided for under a(d), the pressure in the free space inside the furnace shall be determined during the meltdown and refining period(s) using the monitoring device required under a(f) [ a(g)]. 10

18 Recordkeeping and Reporting Requirements: Per a(a), a record of the data obtained under a(b) and a record of all monthly operational status inspection performed under a(c) shall be maintained for a period of at least two (2) years. Per a(b), the Permittee shall submit a written report of exceedances of the control device opacity, as indicated by the COMs, to the Department semi-annually. For the purposes of these reports, exceedances are defined as all 6-minute periods during which the average opacity is 3 percent or greater. Per a(g), the Permittee shall submit a written report of exceedances of the EAF shop and dust handling equipment opacity limits to the Department semi-annually. For purposes of these reports, exceedances are defined as opacity observations from the EAF shop and/or the dust handling equipment in excess of the emission limits specified in the permit. Copies of Method 9 observations performed shall be included with the report. NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) 40 CFR Part 63 Subpart YYYYY, National Emission Standards for Hazardous Air Pollutants for Area Sources: Electric Arc Furnace Steelmaking Facilities Per (a), this subpart applies to an electric arc furnace (EAF) steelmaking facility that is an area source of hazardous air pollutant (HAP) emissions. Since this facility is a major source of HAP emissions, this subpart does not apply. 40 CFR 64, COMPLIANCE ASSURANCE MONITORING (CAM) This subpart is applicable to an emission source provided the source meets the following criteria: it is subject to an emission limit or standard, it uses a control device to achieve compliance with the emissions limit or standard, and it has pre-controlled emissions from a regulated air pollutants that are equal to or greater than 100 percent of the amount, in tons per year, required for a source to be classified as a major source [40 CFR 64.2(a)]. Therefore, LO1 and LO2 would be subject to CAM requirements for PM. However, per 64.5(b), the facility is not required to submit a CAM plan until an application for the renewal of the Title V permit is required. Therefore, CAM requirements will be included in the first renewal of the Title V permit. 11

19 MELT SHOP BAGHOUSE EMISSIONS Expected meltshop baghouse emissions (lb/hr) were calculated using stack test data and actual steel production for the year MELT SHOP BAGHOUSE EMISSIONS (lb/hr) PM SO2 NOX CO VOC Lead BH BH

20 95 MMBTU/HR PASSIVE ANNEALING FURNACE DESCRIPTION POLLUTANT EMISSION LIMIT REGULATIONS 95 MMBtu/hr Passive Annealing Furnace (LO41A) NO X lb/mmbtu 7.84 lb/hr [Anti-PSD] CO 0.05 lb/mmbtu 4.75 lb/hr [Anti-PSD] Opacity No more than one 6 min avg. > 20% Rule (1)(a) AND No 6 min avg. > 40% Rule (1)(b) STATE REGULATIONS ADEM Admin. Code r (1)(a) and (b), Visible Emissions for Control of Particulate Emissions The opacity of the particulate off of the stack associated with the passive annealing furnace would be subject to the standards in this subpart. Emissions Standards: ADEM Admin. Code r (1)(a) states that except for one 6-minute period during any 60-minute periods, stationary emission sources shall not discharge into the atmosphere particulate that results in an opacity greater than 20%, as determined by a 6-minute average. ADEM Admin. Code r (1)(b) states that at no time shall a stationary emission source discharge into the atmosphere particulate that results in an opacity greater than 40%, as determined by a six minute average. Compliance and Performance Test Methods and Procedures: Method 9 of 40 CFR part 60, appendix A would be used in the determination of opacity. Emissions Monitoring: A visual inspection of the stack associated with the passive annealing furnace will be 13

21 performed at least once per day by a person familiar with Method 9. If visible emissions are noted at any time and not corrected within an hour, an observation shall be performed in accordance with Method 9, and appropriate actions shall be taken to eliminate the emissions within four hours of the initial observation. Recordkeeping and Reporting Requirements: The facility shall maintain the following records in a for suitable for inspection for a period of at least five (5) years: Each visible inspection, to include Method 9 visible observations. This should also include problems observed and corrective actions taken. ADEM Admin. Code r , Prevention of Significant Deterioration (PSD) Permitting The stack associated with the passive annealing furnace is subject to Anti-PSD limits. The limits/requirements in this section are being rolled into the Initial Title V Permit from Air Permit No X021, issued on March 21, Emission Standards: The facility shall comply with the following limits/requirements: Nitrogen oxide (NOX) emissions from the stack associated with the passive annealing furnace shall not exceed 7.84 lb/hr and lb/mmbtu. Carbon monoxide (CO) emissions from the stack associated with the passive annealing furnace shall not exceed 4.75 lb/hr and 0.05 lb/mmbtu. The passive annealing furnace shall fire only natural gas. The passive annealing furnace shall consume no more than a total of 800,000 million cubic feet of natural gas in any consecutive 12-month period. Compliance and Performance Test Methods and Procedures: The facility shall comply with the following test methods/procedures: Method 7E of 40 CFR part 60, appendix A shall be used in the determination of NOX emissions. Method 10 of 40 CFR part 60, appendix A shall be used in the determination of CO emissions. 14

22 Emission Monitoring: There are no monitoring requirements for this subpart. Recordkeeping and Reporting Requirements: The Permittee shall maintain a record of the monthly and twelve (12) month rolling total amount of natural gas combusted in the passive annealing furnace. FEDERAL REGULATIONS NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) 40 CFR Part 63, Subpart A, General Provisions Provided that the facility is subject to one of the applicable subparts found under this part, the facility shall comply with this regulation as specified in that subpart. 40 CFR Part 63 Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters Per , this subpart applies to boilers and process heaters located at a major source of HAP emissions. Per , a process heater is defined as an enclosed device using controlled flame, and the unit's primary purpose is to transfer heat indirectly to a process material (liquid, gas, or solid) or to a heat transfer material (e.g., glycol or a mixture of glycol and water) for use in a process unit, instead of generating steam. Since the passive annealing furnace is located at a major source of HAP emissions and meets the definition of a process heater, this subpart would be applicable. Emission Standards: Per (a)(3), the Permittee must operate and maintain the passive annealing furnaces, at all times, in a manner consistent with safety and good air pollution control practices for minimizing emissions. 15

23 Compliance and Performance Test Methods and Procedures: This subpart does not require testing for these units. Emission Monitoring: Per (a)(1), the Permittee must conduct a one-time energy assessment according to Table 3 (No. 4) of the passive annealing furnace to be performed by a qualified energy assessor. The energy assessment shall include the following: A visual inspection of the furnace system. An evaluation of operating characteristics of the furnace systems, specifications of energy using systems, operating and maintenance procedures, and unusual operating constraints. An inventory of major energy use systems consuming energy from the affected furnaces and which are under the control of the furnace owner/operator. A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage. A review of the facility s energy management practices and provide recommendations for improvements consistent with the definition of energy management practices, if identified. A list of cost-effective energy conservation measures that are within the facility s control. A list of the energy savings potential of the energy conservation measure identified. A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments. The Permittee must conduct an annual tune-up of each passive annealing furnace based on the requirements in (a)(10)(i) through (vi): As applicable, inspect the burner, and clean or replace any components of the burner as necessary (you may delay the burner inspection until the next scheduled unit shutdown). Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer s specifications, if available. Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly. Optimize total emissions of CO. This optimization should be consistent with the manufacturer s specifications, if available. 16

24 Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Per (a)(13), if the passive annealing furnace is not operating on the required date for a tune-up, the tune-up must be conducted within 30 days of startup. Recordkeeping and Reporting Requirements: Per (a)(10)(vi), the Permittee shall maintain on-site and submit, if requested by the Department, a report containing the following information: The concentrations of CO in in the effluent stream in parts per million by volume, and oxygen in volume percent, measured before and after the adjustments of the boiler. A description of any corrective actions taken as a part of the tune-up. The type and amount of fuel used over the 12 months prior to the annual adjustment, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel use by each unit. The Permittee must submit an annual compliance report as required by (b)(1)-(4). 40 CFR 64, COMPLIANCE ASSURANCE MONITORING (CAM) This subpart is applicable to an emission source provided the source meets the following criteria: it is subject to an emission limit or standard, it uses a control device to achieve compliance with the emissions limit or standard, and it has pre-controlled emissions from a regulated air pollutants that are equal to or greater than 100 percent of the amount, in tons per year, required for a source to be classified as a major source [40 CFR 64.2(a)]. Since the passive annealing furnace is not equipped with control devices, CAM does not apply. PASSIVE ANNEALING FURNACE EMISSIONS The expected passive annealing furnace CO and NOX emissions are 0.22 lb/hr and 0.37 lb/hr, respectively. This is based on the actual fuel usage for the year

25 SLAB HOLDING FURNACE DESCRIPTION POLLUTANT EMISSION LIMIT REGULATIONS 25 MMBtu/hr Slab Holding Furnace (LO42) NO X lb/mmbtu 2.12 lb/hr [Anti-PSD] CO 1.65 lb/mmbtu lb/hr [Anti-PSD] Opacity No more than one 6 min avg. > 20% Rule (1)(a) AND No 6 min avg. > 40% Rule (1)(b) STATE REGULATIONS ADEM Admin. Code r (1)(a) and (b), Visible Emissions for Control of Particulate Emissions The opacity of the particulate off of stack associated with the slab holding furnace would be subject to the standards in this subpart. Emissions Standards: ADEM Admin. Code r (1)(a) states that except for one 6-minute period during any 60-minute periods, stationary emission sources shall not discharge into the atmosphere particulate that results in an opacity greater than 20%, as determined by a 6-minute average. ADEM Admin. Code r (1)(b) states that at no time shall a stationary emission source discharge into the atmosphere particulate that results in an opacity greater than 40%, as determined by a six minute average. Compliance and Performance Test Methods and Procedures: Method 9 of 40 CFR part 60, appendix A would be used in the determination of opacity. 18

26 Emissions Monitoring: A visual inspection of the stack associated with the skull lancing operation will be performed at least once per day by a person familiar with Method 9. If visible emissions are noted at any time and not corrected within an hour, an observation shall be performed in accordance with Method 9, and appropriate actions shall be taken to eliminate the emissions within four hours of the initial observation. Recordkeeping and Reporting Requirements: The facility shall maintain the following records in a for suitable for inspection for a period of at least five (5) years: Each visible inspection, to include Method 9 visible observations. This should also include problems observed and corrective actions taken. ADEM Admin. Code r , Prevention of Significant Deterioration (PSD) Permitting The stack associated with the slab holding furnace is subject to Anti-PSD limits. The limits/requirements in this section are being rolled into the Initial Title V Permit from Air Permit No X022, issued on March 21, Emission Standards: The facility shall comply with the following limits/requirements: Nitrogen oxide (NOX) emissions from the stack associated with the slab holding furnace shall not exceed 2.12 lb/hr and lb/mmbtu. Carbon monoxide (CO) emissions from the stack associated with the slab holding furnace shall not exceed lb/hr and 1.65 lb/mmbtu. The slab holding furnace shall fire only natural gas. The slab holding furnace shall consume no more than a total of 70 million cubic feet of natural gas in any consecutive 12-month period. Compliance and Performance Test Methods and Procedures: The facility shall comply with the following test methods/procedures: Method 7E of 40 CFR part 60, appendix A shall be used in the determination of NOX emissions. Method 10 of 40 CFR part 60, appendix A shall be used in the determination of CO emissions. 19

27 Emission Monitoring: There are no monitoring requirements for this subpart. Recordkeeping and Reporting Requirements: The Permittee shall maintain a record of the monthly and twelve (12) month rolling total amount of natural gas combusted in the slab holding furnace. FEDERAL REGULATIONS NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) 40 CFR Part 63, Subpart A, General Provisions Provided that the facility is subject to one of the applicable subparts found under this part, the facility shall comply with this regulation as specified in that subpart. 40 CFR Part 63 Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters Per , this subpart applies to boilers and process heaters located at a major source of HAP emissions. Per , a process heater is defined as an enclosed device using controlled flame, and the unit's primary purpose is to transfer heat indirectly to a process material (liquid, gas, or solid) or to a heat transfer material (e.g., glycol or a mixture of glycol and water) for use in a process unit, instead of generating steam. Since the slab holding furnace is located at a major source of HAP emissions and meets the definition of a process heater, this subpart would be applicable. Emission Standards: Per (a)(3), the Permittee must operate and maintain the slab holding furnace, at all times, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Compliance and Performance Test Methods and Procedures: This subpart does not require testing for this unit. 20

28 Emission Monitoring: Per (a)(1), the Permittee must conduct a one-time energy assessment according to Table 3 (No. 4) of the slab holding furnace to be performed by a qualified energy assessor. The energy assessment shall include the following: A visual inspection of the furnace system. An evaluation of operating characteristics of the furnace systems, specifications of energy using systems, operating and maintenance procedures, and unusual operating constraints. An inventory of major energy use systems consuming energy from the affected furnaces and which are under the control of the furnace owner/operator. A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage. A review of the facility s energy management practices and provide recommendations for improvements consistent with the definition of energy management practices, if identified. A list of cost-effective energy conservation measures that are within the facility s control. A list of the energy savings potential of the energy conservation measure identified. A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments. The Permittee must conduct an annual tune-up of the slab holding furnace based on the requirements in (a)(10)(i) through (vi): As applicable, inspect the burner, and clean or replace any components of the burner as necessary (you may delay the burner inspection until the next scheduled unit shutdown). Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer s specifications, if available. Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly. Optimize total emissions of CO. This optimization should be consistent with the manufacturer s specifications, if available. Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis 21

29 before and after the adjustments are made). Per (a)(13), if the slab holding furnace is not operating on the required date for a tune-up, the tune-up must be conducted within 30 days of startup. Recordkeeping and Reporting Requirements: Per (a)(10)(vi), the Permittee shall maintain on-site and submit, if requested by the Department, a report containing the following information: The concentrations of CO in in the effluent stream in parts per million by volume, and oxygen in volume percent, measured before and after the adjustments of the boiler. A description of any corrective actions taken as a part of the tune-up. The type and amount of fuel used over the 12 months prior to the annual adjustment, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel use by each unit. The Permittee must submit an annual compliance report as required by (b)(1)-(4). 40 CFR 64, COMPLIANCE ASSURANCE MONITORING (CAM) This subpart is applicable to an emission source provided the source meets the following criteria: it is subject to an emission limit or standard, it uses a control device to achieve compliance with the emissions limit or standard, and it has pre-controlled emissions from a regulated air pollutants that are equal to or greater than 100 percent of the amount, in tons per year, required for a source to be classified as a major source [40 CFR 64.2(a)]. Since the slab holding furnace is not equipped with a control device, CAM does not apply. SLAB HOLDING FURNACE EMISSIONS The expected slab holding furnace CO and NOX emissions are 1.52 lb/hr and 0.08 lb/hr, respectively. This is based on the actual fuel usage for the year

30 HOT ANNEALING AND PICKLING LINE (HAPL) DESCRIPTION POLLUTANT EMISSION LIMIT REGULATIONS 143 MMBtu/hr Natural Gas Fired Annealing Furnace (LO43) PM lb/mmbtu 1.09 lb/hr SO lb/mmbtu lb/hr NO X 0.06 lb/mmbtu 8.58 lb/hr CO 0.06 lb/mmbtu 8.58 lb/hr VOC lb/mmbtu 0.79 lb/hr Opacity Less than 10% Shotblaster/Scale Breaker w/ Baghouse (LO45) PM lb/mmbtu 4.13 lb/hr Opacity Less than 10% Sodium Sulfate Pickling w/ Wet Scrubber (LO46) PM lb/mmbtu 0.40 lb/hr Opacity Less than 10% Nitric Hydrofluoric Acid Pickling w/ Wet Scrubber + de-no X SCR (LO47) PM lb/mmbtu 0.40 lb/hr NO X 100 ppmvd 6.73 lb/hr 23

31 HF 10 ppmvd 0.29 lb/hr Opacity Less than 10% STATE REGULATIONS ADEM Admin. Code r , Prevention of Significant Deterioration (PSD) Permitting The emission points associated with the HAPL are subject to PSD/BACT limits and requirements. The limits/requirements in this section are being rolled into the Initial Title V Permit from Air Permit No X008, issued on March 21, Emission Standards: The facility shall comply with the following limits for LO43: The opacity of emissions from the stack associated this unit shall not exceed ten percent (10%) opacity as determined by a six (6) minute average. Particulate matter (PM) emissions shall not exceed lb/mmbtu and 1.09 lb/hr. Sulfur dioxide (SO2) emissions shall not exceed lb/mmbtu and lb/hr. Nitrogen oxide (NOX) emissions shall not exceed 0.06 lb/mmbtu and 8.58 lb/hr. Carbon monoxide (CO) emissions shall not exceed 0.06 lb/mmbtu and 8.58 lb/hr. Volatile organic compound (VOC) emissions as carbon shall not exceed lb/mmbtu and 0.79 lb/hr. The facility shall comply with the following limits: The opacity of emissions from LO45, LO46, and LO47 shall not exceed ten percent (10%) opacity as determined by a six (6) minute average. PM emissions from LO45 shall not exceed gr/dscf and 4.13 lb/hr. PM emissions from LO46 and LO47 shall not exceed gr/dscf and 0.40 lb/hr. NOX emissions from LO47 shall not exceed 100 ppmvd and 6.73 lb/hr. Hydrofluoric acid (HF) emissions from LO47 shall not exceed 10 ppmvd and 0.29 lb/hr. 24

32 These sources shall fire only natural gas. Compliance and Performance Test Methods and Procedures: The facility shall comply with the following test methods/procedures: Method 9 of 40 CFR part 60, appendix A shall be used in the determination of opacity. Method 5 of 40 CFR part 60, appendix A shall be used in the determination of PM emissions. Methods 6 or 6C of 40 CFR part 60, appendix A shall be used in the determination of SO2 emissions. Method 7E of 40 CFR part 60, appendix A shall be used in the determination of NOX emissions. Method 10 of 40 CFR part 60, appendix A shall be used in the determination of CO emissions. Methods 18 or 25A of 40 CFR part 60, appendix A shall be used in the determination of VOC emissions. Method 26A of 40 CFR part 60, appendix A shall be used in the determination of HF emissions. Emission Monitoring: The Permittee shall conduct performance tests for NOX and CO emissions from the annealing furnace (LO43) at least once every 12 months. The stack associated with LO47 is equipped with a continuous emissions monitor system (CEMS). The CEMS will be operated and maintained according to the procedures in Performance Specification 2 of 40 CFR part 60, appendix B. CEMS data will be used to demonstrate compliance with the NOX standard. The Permittee shall continuously (at least once every 15 minutes) monitor and record the scrubber (LO47) makeup water flow rate and recirculation water flow rate. The Permittee shall maintain the scrubber makeup water flow rate at a level greater than 1.35 m 3 /hr (based on a rolling three hour average) and the recirculation water flow rate at a level greater than 22 m 3 /hr (based on a rolling three hour average). Corrective action must be performed within (2) two hours if the flow rates fall below the minimum. The Permittee shall continuously (at least once every 15 minutes) monitor the ammonia injection rate to the SCR (LO47) and the amount of NOX in the flue product. The average NOX concentration in any 1-hour period shall be maintained at concentrations less than or equal to 80 ppmvd. Corrective action must be performed within (2) two hours if the NOX 25