Attachment 1

Current Felman Title V Permit

#R30-05300004
Joe Manchin, III Stephanie R. Timmermeyer

 Governor Cabinet Secretary

West Virginia Department of Environmental Protection

Division of Air Quality

Permit to Operate

Pursuant to

Title V

of the Clean Air Act

Issued to:

Felman Production, Inc.

New Haven, West Virginia

R30-05300004-2007

John A. Benedict

Director

Issued: August 8, 2007 • Effective: August 22, 2007

Expiration: August 8, 2012 • Renewal Application Due: February 8, 2012
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 1 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

Permit Number: R30-05300004-2007

Permittee: Felman Production, Inc.

Permittee Mailing Address: Route 3 Box 127 Letart, WV 25253

This permit is issued in accordance with the West Virginia Air Pollution Control Act (West Virginia Code §§ 22-5-1 et seq.) and

45CSR30 — Requirements for Operating Permits. The permittee identified at the above-referenced facility is authorized to

operate the stationary sources of air pollutants identified herein in accordance with all terms and conditions of this permit.

Facility Location: New Haven, Mason County, West Virginia

Mailing Address: Route 3 Box 127 Letart, WV 25253

Telephone Number: 304-882-1181

Type of Business Entity: Corporation

Facility Description: Manufacturing of Manganese and Silicon Based Ferroalloys

SIC Codes: Primary 3313; Secondary 3341;

UTM Coordinates: 419.73 km Easting • 4312.468 km Northing • Zone 17

Permit Writer: Bobbie Scroggie

Any person whose interest may be affected, including, but not necessarily limited to, the applicant and any person who

participated in the public comment process, by a permit issued, modified or denied by the Secretary may appeal such action

of the Secretary to the Air Quality Board pursuant to article one [§§ 22B-1-1 et seq.], Chapter 22B of the Code of West

Virginia. West Virginia Code §22-5-14.

Issuance of this Title V Operating Permit does not supersede or invalidate any existing permits under 45CSR13, 14 or 19,

although all applicable requirements from such permits governing the facility's operation and compliance have been

incorporated into the Title V Operating Permit.
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 2 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

Table of Contents

1.0. Emission Units. ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . . 4

2.0. General Conditions. ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 5

2.1. Definitions. .... .... .... .... .... .... .... .... .... .... .... .... .... .... .... 5

2.2. Acronyms. .... .... .... .... .... .... .... .... .... .... .... .... .... .... .... 5

2.3. Permit Expiration and Renewal. .... .... .... .... .... .... .... .... .... .... .... 6

2.4. Permit Actions. .... .... .... .... .... .... .... .... .... .... .... .... .... .... . 6

2.5. Reopening for Cause. .... .... .... .... .... .... .... .... .... .... .... .... .... 6

2.6. Administrative Permit Amendments. .... .... .... .... .... .... .... .... .... .... 7

2.7. Minor Permit Modifications. .... .... .... .... .... .... .... .... .... .... .... . . 7

2.8. Significant Permit Modification. .... .... .... .... .... .... .... .... .... .... ... 7

2.9. Emissions Trading. .... .... .... .... .... .... .... .... .... .... .... .... .... . . 7

2.10. Off-Permit Changes. .... .... .... .... .... .... .... .... .... .... .... .... .... . 7

2.11. Operational Flexibility..... .... .... .... .... .... .... .... .... .... .... .... ... 8

2.12. Reasonably Anticipated Operating Scenarios. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

2.13. Duty to Comply. .... .... .... .... .... .... .... .... .... .... .... .... .... .... 9

2.14. Inspection and Entry. .... .... .... .... .... .... .... .... .... .... .... .... .... 9

2.15. Schedule of Compliance. .... .... .... .... .... .... .... .... .... .... .... .... . 9

2.16. Need to Halt or Reduce Activity not a Defense.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

2.17. Emergency..... .... .... .... .... .... .... .... .... .... .... .... .... .... ... 10

2.18. Federally-Enforceable Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

2.19. Duty to Provide Information........ .... .... .... .... .... .... .... .... .... . . 11

2.20. Duty to Supplement and Correct Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

2.21. Permit Shield. .... .... .... .... .... .... .... .... .... .... .... .... .... .... . 11

2.22. Credible Evidence. .... .... .... .... .... .... .... .... .... .... .... .... .... . 12

2.23. Severability. .... .... .... .... .... .... .... .... .... .... .... .... .... .... . . 12

2.24. Property Rights. .... .... .... .... .... .... .... .... .... .... .... .... .... ... 12

2.25. Acid Deposition Control.... .... .... .... .... .... .... .... .... .... .... .... . 12

3.0. Facility-Wide Requirements. ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . . 13

3.1. Limitations and Standards. .... .... .... .... .... .... .... .... .... .... .... ... 13

3.2. Monitoring Requirements. .... .... .... .... .... .... .... .... .... .... .... ... 16

3.3. Testing Requirements. .... .... .... .... .... .... .... .... .... .... .... .... . . 17

3.4. Recordkeeping Requirements. .... .... .... .... .... .... .... .... .... .... .... 19

3.5. Reporting Requirements. .... .... .... .... .... .... .... .... .... .... .... .... 21

3.6. Compliance Plan........ .... .... .... .... .... .... .... .... .... .... .... ... 25

3.7. Permit Shield. .... .... .... .... .... .... .... .... .... .... .... .... .... .... . 25

4.0. Requirements for Furnaces.... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 26

4.1. Limitations and Standards. .... .... .... .... .... .... .... .... .... .... .... ... 26

4.2. Monitoring Requirements. .... .... .... .... .... .... .... .... .... .... .... ... 27

4.3. Testing Requirements. .... .... .... .... .... .... .... .... .... .... .... .... . . 29

4.4. Recordkeeping Requirements. .... .... .... .... .... .... .... .... .... .... .... 30

4.5. Reporting Requirements. .... .... .... .... .... .... .... .... .... .... .... .... 31

4.6. Compliance Plan........ .... .... .... .... .... .... .... .... .... .... .... ... 32
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 3 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

5.0. Manufacturing Processes Requirements. ....... ....... ....... ....... ....... ....... ....... . . 33

5.1. Limitations and Standards. .... .... .... .... .... .... .... .... .... .... .... ... 33

5.2. Monitoring Requirements. .... .... .... .... .... .... .... .... .... .... .... ... 34

5.3. Testing Requirements. .... .... .... .... .... .... .... .... .... .... .... .... . . 34

5.4. Recordkeeping Requirements. .... .... .... .... .... .... .... .... .... .... .... 34

5.5. Reporting Requirements. .... .... .... .... .... .... .... .... .... .... .... .... 34

5.6. Compliance Plan........ .... .... .... .... .... .... .... .... .... .... .... ... 34

6.0. Requirements for R13-2857 Equipment. ... ... ... ... ... ... ... ... ... ... ... ... . 36

6.1. Limitations and Standards. .... .... .... .... .... .... .... .... .... .... .... ... 36

6.2. Testing Requirements. .... .... .... .... .... .... .... .... .... .... .... .... . . 38

6.3. Monitoring and Recordkeeping Requirements. .... .... .... .... .... .... .... ... 38

6.4. Reporting Requirements. .... .... .... .... .... .... .... .... .... .... .... .... 40

6.5. Compliance Plan........ .... .... .... .... .... .... .... .... .... .... .... ... 40

APPENDIX A - Inspection and Maintenance Program

APPENDIX B - Rule 10 Monitoring Plan
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 4 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

1.0 Emission Units

Emission

Unit ID

Emission

Point ID

Emission Unit Description Year Installed Design Capacity Control

Device

001-01 No. 2 Furnace; Elkem 1966 10.1 tons/hr No.2 baghouse

001-02 No. 5 Furnace; Lectromelt 1974 5.0 tons/hr No.5 baghouse

001-03 No. 7 Furnace; Lectromelt 1975 5.0 tons/hr No.7 baghouse

002-0B Outdoor Storage Piles 1952 N/A N/A

005-01 Unpaved Road - Raw Material Delivery N/A N/A N/A

005-02 Unpaved Road - Gravel Delivery N/A N/A N/A

005-03 Unpaved Road - Wood Chips Delivery N/A N/A N/A

005-04 Unpaved Road - Scrap Metal Delivery N/A N/A N/A

005-05 Unpaved Road - Product Shipments N/A N/A N/A

005-06 Unpaved Road - Raw Materials Transfer N/A N/A N/A

005-07 Unpaved Road - Endloaders N/A N/A N/A

009-01 Crushing and Screening System #1 N/A 33 tons/hr Baghouses

009-02 Crushing and Screening System #2 N/A 33 tons/hr Baghouses

009-03 Crushing and Screening System #4 N/A 20 tons/hr Baghouse

009-04 Crushing and Screening System #5 N/A 20 tons/hr Baghouse

009-06 Transfer Points N/A 28 tons/hr N/A

00A-01 Product Casting Operations N/A 20 tons/hr Baghouses

00C-01 Ladle Burners (No. 2 oil) N/A 140 MMBtu, 40 gal/hr N/A

SC-1C SC-1CE Grizzly Feeder 2010 400 tons/hr Baghouse

BC-1C T3C Screen Reject Belt Conveyor 2010 400 tons/hr Water Sprays

CR-1C 009-03 Jaw Crusher 2010 400 tons/hr Baghouse

BC-2C T6C Belt Conveyor 2010 400 tons/hr Water Sprays

OS-1C OS-1CE Unsized Stockpile 2010 5,000 sq. ft. Water Sprays

OS-2C OS-2CE Sized Stockpile 2010 5,000 sq. ft. Water Sprays

EX-1 EX-1E Extruder Unit 2010 20 tons/hr Full Enclosure

OS-1X OS-1XE Briquette Stockpile 2010 5,000 sq. ft. None

PT-1 PT-1E Pelletizing Unit 2010 6 tons/hr Full Enclosure

OS-1P OS-1PE Pellet Stockpile 2010 5,000 sq. ft. None
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 5 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

2.0. General Conditions

2.1. Definitions

2.1.1. All references to the "West Virginia Air Pollution Control Act" or the "Air Pollution Control Act" mean those

provisions contained in W.Va. Code §§ 22-5-1 to 22-5-18.

2.1.2. The "Clean Air Act" means those provisions contained in 42 U.S.C. §§ 7401 to 7671q, and regulations

promulgated thereunder.

2.1.3. "Secretary" means the Secretary of the Department of Environmental Protection or such other person to whom

the Secretary has delegated authority or duties pursuant to W.Va. Code §§ 22-1-6 or 22-1-8 (45CSR§30-2.12.).

The Director of the Division of Air Quality is the Secretary's designated representative for the purposes of this

permit.

2.1.4. Unless otherwise specified in a permit condition or underlying rule or regulation, all references to a “rolling

yearly total” shall mean the sum of the data, values or parameters being measured, monitored, or recorded, at

any given time for the previous twelve (12) consecutive calendar months.

2.2. Acronyms

CAAA Clean Air Act Amendments

CBI Confidential Business Information

CEM Continuous Emission Monitor

CES Certified Emission Statement

C.F.R. or CFR Code of Federal Regulations

CO Carbon Monoxide

C.S.R. or CSR Codes of State Rules

DAQ Division of Air Quality

DEP Department of Environmental

Protection

FOIA Freedom of Information Act

HAP Hazardous Air Pollutant

HON Hazardous Organic NESHAP

HP Horsepower

lbs/hr Pounds per Hour

LDAR Leak Detection and Repair

M Thousand

MACT Maximum Achievable Control

Technology

M M Million

MMBtu/hr or Million British Thermal Units

 mmbtu/hr per Hour

MMCF/hr or Million Cubic Feet Burned per

 mmcf/hr Hour

NA Not Applicable

NAAQS National Ambient Air Quality

Standards

NESHAPS National Emissions Standards for

Hazardous Air Pollutants

NOx Nitrogen Oxides

NSPS New Source Performance Standards

PM Particulate Matter

PM10 Particulate Matter less than 10μm in

diameter

pph Pounds per Hour

ppm Parts per Million

PSD Prevention of Significant Deterioration

psi Pounds per Square Inch

SIC Standard Industrial Classification

SIP State Implementation Plan

SO2 Sulfur Dioxide

TAP Toxic Air Pollutant

TPY Tons per Year

TRS Total Reduced Sulfur

TSP Total Suspended Particulate

USEPA United States Environmental Protection

Agency

UTM Universal Transverse Mercator

VEE Visual Emissions Evaluation

VOC Volatile Organic Compounds
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 6 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

2.3. Permit Expiration and Renewal

2.3.1. Permit duration. This permit is issued for a fixed term of five (5) years and shall expire on the date specified

on the cover of this permit, except as provided in 45CSR§30-6.3.b. and 45CSR§30-6.3.c.

[45CSR§30-5.1.b.]

2.3.2. A permit renewal application is timely if it is submitted at least six (6) months prior to the date of permit

expiration.

[45CSR§30-4.1.a.3.]

2.3.3. Permit expiration terminates the source's right to operate unless a timely and complete renewal application has

been submitted consistent with 45CSR§30-6.2. and 45CSR§30-4.1.a.3.

[45CSR§30-6.3.b.]

2.3.4. If the Secretary fails to take final action to deny or approve a timely and complete permit application before the

end of the term of the previous permit, the permit shall not expire until the renewal permit has been issued or

denied, and any permit shield granted for the permit shall continue in effect during that time.

[45CSR§30-6.3.c.]

2.4. Permit Actions

2.4.1. This permit may be modified, revoked, reopened and reissued, or terminated for cause. The filing of a request

by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of

planned changes or anticipated noncompliance does not stay any permit condition.

[45CSR§30-5.1.f.3.]

2.5. Reopening for Cause

2.5.1. This permit shall be reopened and revised under any of the following circumstances:

a. Additional applicable requirements under the Clean Air Act or the Secretary's legislative rules become

applicable to a major source with a remaining permit term of three (3) or more years. Such a reopening

shall be completed not later than eighteen (18) months after promulgation of the applicable requirement.

No such reopening is required if the effective date of the requirement is later than the date on which the

permit is due to expire, unless the original permit or any of its terms and conditions has been extended

pursuant to 45CSR§§30-6.6.a.1.A. or B.

b. Additional requirements (including excess emissions requirements) become applicable to an affected

source under Title IV of the Clean Air Act (Acid Deposition Control) or other legislative rules of the

Secretary. Upon approval by U.S. EPA, excess emissions offset plans shall be incorporated into the permit.

c. The Secretary or U.S. EPA determines that the permit contains a material mistake or that inaccurate

statements were made in establishing the emissions standards or other terms or conditions of the permit.

d. The Secretary or U.S. EPA determines that the permit must be revised or revoked and reissued to assure

compliance with the applicable requirements.

[45CSR§30-6.6.a.]
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 7 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

2.6. Administrative Permit Amendments

2.6.1. The permittee may request an administrative permit amendment as defined in and according to the procedures

specified in 45CSR§30-6.4.

[45CSR§30-6.4.]

2.7. Minor Permit Modifications

2.7.1. The permittee may request a minor permit modification as defined in and according to the procedures specified

in 45CSR§30-6.5.a.

[45CSR§30-6.5.a.]

2.8. Significant Permit Modification

2.8.1. The permittee may request a significant permit modification, in accordance with 45CSR§30-6.5.b., for permit

modifications that do not qualify for minor permit modifications or as administrative amendments.

[45CSR§30-6.5.b.]

2.9. Emissions Trading

2.9.1. No permit revision shall be required, under any approved economic incentives, marketable permits, emissions

trading, and other similar programs or processes for changes that are provided for in the permit and that are in

accordance with all applicable requirements.

[45CSR§30-5.1.h.]

2.10. Off-Permit Changes

2.10.1. Except as provided below, a facility may make any change in its operations or emissions that is not addressed

nor prohibited in its permit and which is not considered to be construction nor modification under any rule

promulgated by the Secretary without obtaining an amendment or modification of its permit. Such changes

shall be subject to the following requirements and restrictions:

a. The change must meet all applicable requirements and may not violate any existing permit term or

condition.

b. The permittee must provide a written notice of the change to the Secretary and to U.S. EPA within two (2)

business days following the date of the change. Such written notice shall describe each such change,

including the date, any change in emissions, pollutants emitted, and any applicable requirement that would

apply as a result of the change.

c. The change shall not qualify for the permit shield.

d. The permittee shall keep records describing all changes made at the source that result in emissions of

regulated air pollutants, but not otherwise regulated under the permit, and the emissions resulting from

those changes.

e. No permittee may make any change subject to any requirement under Title IV of the Clean Air Act (Acid

Deposition Control) pursuant to the provisions of 45CSR§30-5.9.
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 8 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

f. No permittee may make any changes which would require preconstruction review under any provision of

Title I of the Clean Air Act (including 45CSR14 and 45CSR19) pursuant to the provisions of 45CSR§30-

5.9.

[45CSR§30-5.9]

2.11. Operational Flexibility

2.11.1. The permittee may make changes within the facility as provided by § 502(b)(10) of the Clean Air Act. Such

operational flexibility shall be provided in the permit in conformance with the permit application and applicable

requirements. No such changes shall be a modification under any rule or any provision of Title I of the Clean

Air Act (including 45CSR14 and 45CSR19) promulgated by the Secretary in accordance with Title I of the

Clean Air Act and the change shall not result in a level of emissions exceeding the emissions allowable under

the permit.

[45CSR§30-5.8]

2.11.2. Before making a change under 45CSR§30-5.8., the permittee shall provide advance written notice to the

Secretary and to U.S. EPA, describing the change to be made, the date on which the change will occur, any

changes in emissions, and any permit terms and conditions that are affected. The permittee shall thereafter

maintain a copy of the notice with the permit, and the Secretary shall place a copy with the permit in the public

file. The written notice shall be provided to the Secretary and U.S. EPA at least seven (7) days prior to the date

that the change is to be made, except that this period may be shortened or eliminated as necessary for a change

that must be implemented more quickly to address unanticipated conditions posing a significant health, safety,

or environmental hazard. If less than seven (7) days notice is provided because of a need to respond more

quickly to such unanticipated conditions, the permittee shall provide notice to the Secretary and U.S. EPA as

soon as possible after learning of the need to make the change.

[45CSR§30-5.8.a.]

2.11.3. The permit shield shall not apply to changes made under 45CSR§30-5.8., except those provided for in

45CSR§30-5.8.d. However, the protection of the permit shield will continue to apply to operations and

emissions that are not affected by the change, provided that the permittee complies with the terms and

conditions of the permit applicable to such operations and emissions. The permit shield may be reinstated for

emissions and operations affected by the change:

a. If subsequent changes cause the facility's operations and emissions to revert to those authorized in the

permit and the permittee resumes compliance with the terms and conditions of the permit, or

b. If the permittee obtains final approval of a significant modification to the permit to incorporate the change

in the permit.

[45CSR§30-5.8.c.]

2.11.4. "Section 502(b)(10) changes" are changes that contravene an express permit term. Such changes do not include

changes that would violate applicable requirements or contravene enforceable permit terms and conditions that

are monitoring (including test methods), recordkeeping, reporting, or compliance certification requirements.

[45CSR§30-2.39]

2.12. Reasonably Anticipated Operating Scenarios

2.12.1. The following are terms and conditions for reasonably anticipated operating scenarios identified in this permit.
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 9 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

a. Contemporaneously with making a change from one operating scenario to another, the permittee shall

record in a log at the permitted facility a record of the scenario under which it is operating and to document

the change in reports submitted pursuant to the terms of this permit and 45CSR30.

b. The permit shield shall extend to all terms and conditions under each such operating scenario; and

c. The terms and conditions of each such alternative scenario shall meet all applicable requirements and the

requirements of 45CSR30.

[45CSR§30-5.1.i.]

2.13. Duty to Comply

2.13.1. The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation

of the West Virginia Code and the Clean Air Act and is grounds for enforcement action by the Secretary or

USEPA; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal

application.

[45CSR§30-5.1.f.1.]

2.14. Inspection and Entry

2.14.1. The permittee shall allow any authorized representative of the Secretary, upon the presentation of credentials

and other documents as may be required by law, to perform the following:

a. At all reasonable times (including all times in which the facility is in operation) enter upon the permittee's

premises where a source is located or emissions related activity is conducted, or where records must be

kept under the conditions of this permit;

b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this

permit;

c. Inspect at reasonable times (including all times in which the facility is in operation) any facilities,

equipment (including monitoring and air pollution Control equipment), practices, or operations regulated

or required under the permit;

d. Sample or monitor at reasonable times substances or parameters to determine compliance with the permit

or applicable requirements or ascertain the amounts and types of air pollutants discharged.

[45CSR§30-5.3.b.]

2.15. Schedule of Compliance

2.15.1. For sources subject to a compliance schedule, certified progress reports shall be submitted consistent with the

applicable schedule of compliance set forth in this permit and 45CSR§30-4.3.h., but at least every six (6)

months, and no greater than once a month, and shall include the following:

a. Dates for achieving the activities, milestones, or compliance required in the schedule of compliance, and

dates when such activities, milestones or compliance were achieved; and
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 10 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

b. An explanation of why any dates in the schedule of compliance were not or will not be met, and any

preventative or corrective measure adopted.

[45CSR§30-5.3.d.]

2.16. Need to Halt or Reduce Activity not a Defense

2.16.1. It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or

reduce the permitted activity in order to maintain compliance with the conditions of this permit. However,

nothing in this paragraph shall be construed as precluding consideration of a need to halt or reduce activity as

a mitigating factor in determining penalties for noncompliance if the health, safety, or environmental impacts

of halting or reducing operations would be more serious than the impacts of continued operations.

[45CSR§30-5.1.f.2.]

2.17. Emergency

2.17.1. An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the

control of the source, including acts of God, which situation requires immediate corrective action to restore

normal operation, and that causes the source to exceed a technology-based emission limitation under the permit,

due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include

noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance,

careless or improper operation, or operator error.

[45CSR§30-5.7.a.]

2.17.2. Effect of any emergency. An emergency constitutes an affirmative defense to an action brought for

noncompliance with such technology-based emission limitations if the conditions of 45CSR§30-5.7.c. are met.

[45CSR§30-5.7.b.]

2.17.3. The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous

operating logs, or other relevant evidence that:

a. An emergency occurred and that the permittee can identify the cause(s) of the emergency;

b. The permitted facility was at the time being properly operated;

c. During the period of the emergency the permittee took all reasonable steps to minimize levels of emissions

that exceeded the emission standards, or other requirements in the permit; and

d. Subject to the requirements of 45CSR§30-5.1.c.3.C.1, the permittee submitted notice of the emergency to

the Secretary within one (1) working day of the time when emission limitations were exceeded due to the

emergency and made a request for variance, and as applicable rules provide. This notice, report, and

variance request fulfills the requirement of 45CSR§30-5.1.c.3.B. This notice must contain a detailed

description of the emergency, any steps taken to mitigate emissions, and corrective actions taken.

[45CSR§30-5.7.c.]

2.17.4. In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency has the

burden of proof.

[45CSR§30-5.7.d.]
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 11 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

2.17.5. This provision is in addition to any emergency or upset provision contained in any applicable requirement.

[45CSR§30-5.7.e.]

2.18. Federally-Enforceable Requirements

2.18.1. All terms and conditions in this permit, including any provisions designed to limit a source's potential to emit

and excepting those provisions that are specifically designated in the permit as "State-enforceable only", are

enforceable by the Secretary, USEPA, and citizens under the Clean Air Act.

[45CSR§30-5.2.a.]

2.18.2. Those provisions specifically designated in the permit as "State-enforceable only" shall become "Federallyenforceable" requirements upon SIP approval by the USEPA.

2.19. Duty to Provide Information

2.19.1. The permittee shall furnish to the Secretary within a reasonable time any information the Secretary may request

in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit

or to determine compliance with the permit. Upon request, the permittee shall also furnish to the Secretary

copies of records required to be kept by the permittee. For information claimed to be confidential, the permittee

shall furnish such records to the Secretary along with a claim of confidentiality in accordance with 45CSR31.

If confidential information is to be sent to USEPA, the permittee shall directly provide such information to

USEPA along with a claim of confidentiality in accordance with 40 C.F.R. Part 2.

[45CSR§30-5.1.f.5.]

2.20. Duty to Supplement and Correct Information

2.20.1. Upon becoming aware of a failure to submit any relevant facts or a submittal of incorrect information in any

permit application, the permittee shall promptly submit to the Secretary such supplemental facts or corrected

information.

[45CSR§30-4.2.]

2.21. Permit Shield

2.21.1. Compliance with the conditions of this permit shall be deemed compliance with any applicable requirements

as of the date of permit issuance provided that such applicable requirements are included and are specifically

identified in this permit or the Secretary has determined that other requirements specifically identified are not

applicable to the source and this permit includes such a determination or a concise summary thereof.

[45CSR§30-5.6.a.]

2.21.2. Nothing in this permit shall alter or affect the following:

a. The liability of an owner or operator of a source for any violation of applicable requirements prior to or

at the time of permit issuance; or

b. The applicable requirements of the Code of West Virginia and Title IV of the Clean Air Act (Acid

Deposition Control), consistent with § 408 (a) of the Clean Air Act.
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 12 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

c. The authority of the Administrator of U.S. EPA to require information under § 114 of the Clean Air Act

or to issue emergency orders under § 303 of the Clean Air Act.

[45CSR§30-5.6.c.]

2.22. Credible Evidence

2.22.1. Nothing in this permit shall alter or affect the ability of any person to establish compliance with, or a violation

of, any applicable requirement through the use of credible evidence to the extent authorized by law. Nothing

in this permit shall be construed to waive any defenses otherwise available to the permittee including but not

limited to any challenge to the credible evidence rule in the context of any future proceeding.

[45CSR§30-5.3.e.3.B. and 45CSR38]

2.23. Severability

2.23.1. The provisions of this permit are severable. If any provision of this permit, or the application of any provision

of this permit to any circumstance is held invalid by a court of competent jurisdiction, the remaining permit

terms and conditions or their application to other circumstances shall remain in full force and effect.

[45CSR§30-5.1.e.]

2.24. Property Rights

2.24.1. This permit does not convey any property rights of any sort or any exclusive privilege.

[45CSR§30-5.1.f.4]

2.25. Acid Deposition Control

2.25.1. Emissions shall not exceed any allowances that the source lawfully holds under Title IV of the Clean Air Act

(Acid Deposition Control) or rules of the Secretary promulgated thereunder.

a. No permit revision shall be required for increases in emissions that are authorized by allowances acquired

pursuant to the acid deposition control program, provided that such increases do not require a permit

revision under any other applicable requirement.

b. No limit shall be placed on the number of allowances held by the source. The source may not, however,

use allowances as a defense to noncompliance with any other applicable requirement.

c. Any such allowance shall be accounted for according to the procedures established in rules promulgated

under Title IV of the Clean Air Act.

[45CSR§30-5.1.d.]

2.25.2. Where applicable requirements of the Clean Air Act are more stringent than any applicable requirement of

regulations promulgated under Title IV of the Clean Air Act (Acid Deposition Control), both provisions shall

be incorporated into the permit and shall be enforceable by the Secretary and U. S. EPA.

[45CSR§30-5.1.a.2.]
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 13 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

3.0. Facility-Wide Requirements

3.1. Limitations and Standards

3.1.1. Open burning. The permittee shall prohibit and prevent open burning of refuse. A written policy prohibiting

any and all open burning of refuse at the facility shall be posted in the facility and provided to all employees.

Such policy shall be presented and included in any safety programs developed by the company. Compliance

with this limit shall demonstrate compliance with the less stringent limitation of 45CSR§6-3.1.

[CO-R7-95-13, Condition 7.a.11.A and 45CSR§6-3.1.]

3.1.2. Asbestos. The permittee is responsible for thoroughly inspecting the facility, or part of the facility, prior to

commencement of demolition or renovation for the presence of asbestos and complying with 40 C.F.R. §

61.145, 40 C.F.R. § 61.148, and 40 C.F.R. § 61.150. The permittee must notify the Secretary at least ten (10)

working days prior to the commencement of any asbestos removal on the forms prescribed by the Secretary if

the permittee is subject to the notification requirements of 40 C.F.R. § 61.145(b)(3)(i). A copy of this notice

is required to be sent to the USEPA, the Division of Waste Management and the Bureau for Public Health -

Environmental Health.

[40 C.F.R. 61 and 45CSR15]

3.1.3. Odor. No person shall cause, suffer, allow or permit the discharge of air pollutants which cause or contribute

to an objectionable odor at any location occupied by the public.

[45CSR§4-3.1 State-Enforceable only.]

3.1.4. Standby plan for reducing emissions. When requested by the Secretary, the permittee shall prepare standby

plans for reducing the emissions of air pollutants in accordance with the objectives set forth in Tables I, II, and

III of 45CSR11.

[45CSR§11-5.2]

3.1.5. Emission inventory. The permittee is responsible for submitting, on an annual basis, an emission inventory

in accordance with the submittal requirements of the Division of Air Quality.

[W.Va. Code § 22-5-4(a)(14)]

3.1.6. Ozone-depleting substances. For those facilities performing maintenance, service, repair or disposal of

appliances, the permittee shall comply with the standards for recycling and emissions reduction pursuant to 40

C.F.R. Part 82, Subpart F, except as provided for Motor Vehicle Air Conditioners (MVACs) in Subpart B:

a. Persons opening appliances for maintenance, service, repair, or disposal must comply with the prohibitions

and required practices pursuant to 40 C.F.R. §§ 82.154 and 82.156.

b. Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the

standards for recycling and recovery equipment pursuant to 40 C.F.R. § 82.158.

c. Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved

technician certification program pursuant to 40 C.F.R. § 82.161.

[40 C.F.R. 82, Subpart F]

3.1.7. Risk Management Plan. Should this stationary source, as defined in 40 C.F.R. § 68.3, become subject to Part

68, then the owner or operator shall submit a risk management plan (RMP) by the date specified in 40 C.F.R.
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 14 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

§ 68.10 and shall certify compliance with the requirements of Part 68 as part of the annual compliance

certification as required by 40 C.F.R. Part 70 or 71.

[40 C.F.R. 68]

3.1.8. No person shall cause, suffer, allow or permit any manufacturing process or storage structure generating fugitive

particulate matter to operate that is not equipped with a system, which may include, but not be limited to,

process equipment design, control equipment design or operation and maintenance procedures, to minimize the

emissions of fugitive particulate matter. To minimize means such system shall be installed, maintained and

operated to ensure the lowest fugitive particulate matter emissions reasonably achievable.

[45CSR§7-5.1. and 45CSR13, R13-2857, Condition 4.1.15.]

3.1.9. The owner or operator of a plant shall maintain particulate matter control of the plant premises, and plant

owned, leased or controlled access roads, by paving, application of asphalt, chemical dust suppressants or other

suitable dust control measures. Good operating practices shall be implemented and when necessary particulate

matter suppressants shall be applied in relation to stockpiling and general material handling to minimize

particulate matter generation and atmospheric entrainment.

[45CSR§7-5.2.]

3.1.10. The permittee shall maintain on site and operate a pressurized particulate suppressant spray truck, as often as

necessary, to minimize fugitive emissions from plant access roads, lots, or access areas.

[CO-R7-95-13, Condition 7.a.11.C.]

3.1.11. Implementation of a Preventative Maintenance Program

a. The permittee shall maintain a computerized spare parts inventory tracking system for inventory, purchases,

suppliers and availability of all components and materials necessary for operation of all emission control

systems at the facility and the permittee's air pollution control spare parts inventory shall be updated

monthly;

b. The permittee shall use its best efforts to maintain availability of all components and materials identified

in the permittee's air pollution control spare parts inventory as being prone to failure or otherwise requiring

frequent replacement and shall provide monthly reports to the Secretary;

c. The permittee shall take all steps necessary to implement the requirements of Sections 3.1.10. through

3.1.13., and 5.1.4. through 5.1.7. of this permit, including the air pollution control spare parts inventory

and the Inspection and Maintenance Program submitted by the permittee as Appendix A of Consent Order

agreement of April 16, 1993, a copy of which is attached hereto as Appendix A.

[CO-R7-95-13, Condition 7.a.12.]

3.1.12. General Operating Provision. The permittee shall implement all measures necessary, including, but not

limited to reducing furnace power input levels and stoking of furnaces, to abate or minimize, to the greatest

extent practicable any fugitive or process emissions released or emitted as the result of the complete failure of

the air pollution control equipment serving a source of fugitive or process emissions. This provision applies

following the failure of any air pollution control equipment, and, such measures shall include the cessation of

material tapping, crushing, sizing, or any other manufacturing, processing, or handling, to the extent emissions

from such manufacturing, processing, or handling equipment is directly captured or controlled by the associated

air pollution control equipment experiencing failure. Notwithstanding the above, a furnace, following the

failure of that furnace's associated air pollution control equipment, may be tapped once; thereby reducing the
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 15 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

level of molten material in the furnace and protecting the immediate health and safety of plant personnel and

equipment. 

This provision does not limit or waive the permittee's right to pursue a variance request pursuant to 45CSR§7-

10. Any decision by the Secretary in regards to such a variance request shall, for purposes of Consent

Judgement CO-R7-95-13: Civil Action 94-C-1084, be deemed a final agency action, appealable directly to the

Kanawha County Circuit Court pursuant to W.Va.R.C.p.81(a)(1). The permittee shall abide by the above

referenced provisions pending review of this matter by the Kanawha County Circuit Court.

[CO-R7-95-13, Condition 7.a.13.]

3.1.13. Notwithstanding the provisions of Section 3.1.12. of this permit, the permittee may achieve compliance with

this permit and any other applicable requirement through shutdown of a source, group of sources, or the facility.

The permittee may restart any source, group of sources, or facility shut down to achieve compliance provided

that prior to restarting, the permittee, to the extent applicable, complies with all preceding compliance

milestones applicable to the source, group of sources, or facility, as the case may be. To the extent that the

permittee and the DAQ cannot agree regarding shutdown, restarting, and applicable preceding compliance

milestones, either party may petition the Court for dispute resolution in accordance with Section 3.1.12. of this

permit.

[CO-R7-95-13, Condition 7.a.14.]

3.1.14. Operational and work practice standards: Fugitive dust sources.

a. Each owner or operator of an affected ferromanganese and silicomanganese production facility must

prepare, and at all times operate according to, a fugitive dust control plan that describes in detail the

measures that will be put in place to control fugitive dust emissions from the individual fugitive dust

sources at the facility.

b. The owner or operator must submit a copy of the fugitive dust control plan to the designated permitting

authority no later than November 21, 2001. The requirement for the owner or operator to operate the

facility according to a written fugitive dust control plan is hereby incorporated in the operating permit.

c. The owner or operator may use existing manuals that describe the measures in place to control fugitive dust

sources required as part of a State implementation plan or other federally enforceable requirement for

particulate matter to satisfy the requirements of Section 3.1.14.a. above.

[40 CFR §§ 63.1654(a)(1), (2), (3) and 45CSR34]

3.1.15. Maintenance requirements.

a. The owner or operator of an affected source must comply with the requirements of 40 CFR §63.6(e).

b. 1. The owner or operator must develop and implement a written maintenance plan for each air pollution

control device associated with submerged arc furnaces, and crushing and screening operations subject

to 40 CFR part 63, subpart XXX. The owner or operator must keep the maintenance plan on record

and available for the Administrator's inspection for the life of the air pollution control device or until

the affected source is no longer subject to the provisions of 40 CFR Part 63.

2. To satisfy the requirement to develop maintenance plans, the owner or operator may use the affected

source's standard operating procedures (SOP) manual or other plan, provided the alternative plan
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 16 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

meets the requirements of this paragraph and is made available for inspection when requested by the

Administrator.

c. The procedures specified in the maintenance plan must include a preventive maintenance schedule that is

consistent with good air pollution control practices for minimizing emissions and, for baghouses, ensure

that the requirements specified in Section 3.2.3. of this permit are met.

d. The owner or operator must perform monthly inspections of the equipment that is important to the

performance of the furnace capture system. This inspection must include an examination of the physical

condition of the equipment, suitable for detecting holes in ductwork or hoods, flow constrictions in

ductwork due to dents or accumulated dust, and operational status of flow rate controllers (pressure

sensors, dampers, damper switches, etc.). Any deficiencies must be recorded and proper maintenance and

repairs performed.

[40 CFR § 63.1655 and 45CSR34]

 3.1.16. Compliance demonstration with the operational and work practice standards. Fugitive dust sources.

Failure to have a fugitive dust control plan or failure to report deviations from the plan and take necessary

corrective action would be a violation of the general duty to ensure that fugitive dust sources are operated and

maintained in a manner consistent with good air pollution control practices for minimizing emissions per 40

CFR §63.6(e)(1)(i).

[40 CFR § 63.1656(e)(1) and 45CSR34]

3.2. Monitoring Requirements

3.2.1. The permittee shall conduct visual emission (VE) observations in accordance with the methodology set forth

in 45CSR7A "Compliance Test Proceduresfor 45CSR7". Emissions from all operating baghouses shall be read

at least once per shift during daylight hours for a period of at least six (6) minutes while such source is in

operation and venting to the associated baghouse. This requirement does not replace any VE observation

requirements under Regulation 16 or any other permit requirements. Compliance with this limit shall

demonstrate compliance with the less stringent limitation of 40 CFR§ 63.1657(a)(1).

[CO-R7-95-13, Condition 7.b.1.A., 40 CFR § 63.1657(a)(1) and 45CSR34]

3.2.2. All VE observation reports shall be conducted and completed by certified VE observers, and verified as true

and accurate, and shall contain sufficient documentation to verify that all VE observations were taken in

accordance with 45CSR7A. Thereafter, these records shall be maintained on file for five years at the facility

as a permanent record of the permittee's VE observations.

[CO-R7-95-13, Conditions 7.b.3.]

3.2.3. a. Baghouses. The owner or operator must conduct the following activities:

1. Daily monitoring of pressure drop across each baghouse cell, or across the baghouse if it is not

possible to monitor each cell individually, to ensure the pressure drop is within the normal operating

range identified in the baghouse maintenance plan. (Note: Applies to crushing and screening

baghouses. See Section 4.2.2.c. of this permit for furnace baghouses requirements.)

2. Weekly confirmation that dust is being removed from hoppers through visual inspection, or equivalent

means of ensuring the proper functioning of removal mechanisms.
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 17 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

3. Daily check of compressed air supply for pulse-jet baghouses.

4. An appropriate methodology for monitoring cleaning cycles to ensure proper operation.

5. Monthly check of bag cleaning mechanisms for proper functioning through visual inspection or

equivalent means.

6. Quarterly visual check of bag tension on reverse air and shaker-type baghouses to ensure that the bags

are not kinked (kneed or bent) or laying on their sides. Such checks are not required for shaker-type

baghouses using self-tensioning (spring loaded) devices.

7. Quarterly confirmation of the physical integrity of the baghouse structure through visual inspection

of the baghouse interior for air leaks.

8. Semiannual inspection of fans for wear, material buildup, and corrosion through visual inspection,

vibration detectors, or equivalent means.

[40 CFR § 63.1657(a)(2) and 45CSR34]

b. As part of the maintenance plan required by Section 3.1.15.b. of this permit, the owner or operator must

develop and implement corrective action procedures to be followed in the case of the observation of visible

emissions from the baghouse, or the indication through the periodic baghouse system inspections that the

system is not operating properly. The owner or operator must initiate corrective action as soon as

practicable after the occurrence of the observation or event indicating a problem.

[40 CFR § 63.1657(a)(4) and 45CSR34]

c. The corrective action plan in Section 3.2.3.b. of this permit must include procedures used to determine the

cause of a deviation or other indications of problems as well as actions to minimize emissions. These

actions may include the following:

1. Inspecting the baghouse for air leaks, torn or broken bags or filter media, or any other condition that

may cause an increase in emissions.

2. Sealing off defective bags or filter media.

3. Replacing defective bags or filter media, or otherwise repairing the control device.

4. Sealing off a defective baghouse compartment.

5. Shutting down the process producing the particulate matter emissions.

[40 CFR § 63.1657(a)(5) and 45CSR34]

d. Failure to monitor or failure to take corrective action under the requirements of Section 3.2.3. of this permit

would be a violation of the general duty to operate in a manner consistent with good air pollution control

practices that minimizes emissions per 60 CFR §63.6(e)(1)(i).

[40 CFR § 63.1657(a)(6) and 45CSR34]
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 18 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

3.3. Testing Requirements

3.3.1. Stack testing. As per provisions set forth in this permit or as otherwise required by the Secretary, in

accordance with the West Virginia Code, underlying regulations, permits and orders, the permittee shall conduct

test(s) to determine compliance with the emission limitations set forth in this permit and/or established or set

forth in underlying documents. The Secretary, or his duly authorized representative, may at his option witness

or conduct such test(s). Should the Secretary exercise his option to conduct such test(s), the operator shall

provide all necessary sampling connections and sampling ports to be located in such manner as the Secretary

may require, power for test equipment and the required safety equipment, such as scaffolding, railings and

ladders, to comply with generally accepted good safety practices. Such tests shall be conducted in accordance

with the methods and procedures set forth in this permit or as otherwise approved or specified by the Secretary

in accordance with the following:

a. The Secretary may on a source-specific basis approve or specify additional testing or alternative testing

to the test methods specified in the permit for demonstrating compliance with 40 C.F.R. Parts 60, 61, and

63, if applicable, in accordance with the Secretary’s delegated authority and any established equivalency

determination methods which are applicable.

b. The Secretary may on a source-specific basis approve or specify additional testing or alternative testing

to the test methods specified in the permit for demonstrating compliance with applicable requirements

which do not involve federal delegation. In specifying or approving such alternative testing to the test

methods, the Secretary, to the extent possible, shall utilize the same equivalency criteria as would be used

in approving such changes under Section 3.3.1.a. of this permit.

c. All periodic tests to determine mass emission limits from or air pollutant concentrations in discharge stacks

and such other tests as specified in this permit shall be conducted in accordance with an approved test

protocol. Unless previously approved, such protocols shall be submitted to the Secretary in writing at least

thirty (30) days prior to any testing and shall contain the information set forth by the Secretary. In addition,

the permittee shall notify the Secretary at least fifteen (15) days prior to any testing so the Secretary may

have the opportunity to observe such tests. This notification shall include the actual date and time during

which the test will be conducted and, if appropriate, verification that the tests will fully conform to a

referenced protocol previously approved by the Secretary.

[WV Code § 22-5-4(a)(15)]

3.3.2. Performance testing, test methods, and compliance demonstrations.

a. All performance tests must be conducted according to the requirements in 40 CFR §63.7.

b. Each performance test must consist of three separate and complete runs using the applicable test methods.

c. Each run must be conducted under conditions that are representative of normal process operations.

d. Performance tests conducted on air pollution control devices serving submerged arc furnaces must be

conducted such that at least one tapping period, or at least 20 minutes of a tapping period, whichever is

less, is included in at least two of the three runs. The sampling time for each run must be at least as long

as three times the average tapping period of the tested furnace, but no less than 60 minutes.
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 19 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

e. The sample volume for each run must be at least 30 dscf.

[40 CFR § 63.1656(a) and 45CSR34]

3.3.3. Test methods. The following test methods in 40 CFR part 60, Appendix A must be used to determine

compliance with the emission standards.

a. Method 1 to select the sampling port location and the number of traverse points.

b. Method 2 to determine the volumetric flow rate of the stack gas.

c. Method 3 to determine the dry molecular weight of the stack gas.

d. Method 4 to determine the moisture content of the stack gas.

e. Method 5 to determine the particulate matter concentration of the stack gasfor negative pressure baghouses

and positive pressure baghouses with stacks.

f. Method 5D to determine particulate matter concentration and volumetric flow rate of the stack gas for

positive pressure baghouses without stacks.

g. Method 9 to determine opacity.

h. The owner or operator may use equivalent alternative measurement methods approved by the Administrator

following the procedures described in 40 CFR §63.7(f).

[40 CFR § 63.1656(b) and 45CSR34]

3.4. Recordkeeping Requirements

3.4.1. Monitoring information. The permittee shall keep records of monitoring information that include the

following:

a. The date, place as defined in this permit, and time of sampling or measurements;

b. The date(s) analyses were performed;

c. The company or entity that performed the analyses;

d. The analytical techniques or methods used;

e. The results of the analyses; and

f. The operating conditions existing at the time of sampling or measurement.

[45CSR§30-5.1.c.2.A. and 45CSR13, R13-2857, Condition 4.3.1.]

3.4.2. Retention of records. The permittee shall retain records of all required monitoring data and support

information for a period of at least five (5) years from the date of monitoring sample, measurement, report,

application, or record creation date. Support information includes all calibration and maintenance records and

all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 20 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

by the permit. Where appropriate, records may be maintained in computerized form in lieu of the above

records.

[45CSR§30-5.1.c.2.B.]

3.4.3. Odors. For the purposes of 45CSR4, the permittee shall maintain a record of all odor complaints received,

any investigation performed in response to such a complaint, and any responsive actions taken.

[45CSR§30-5.1.c. State-Enforceable only.]

3.4.4. The permittee shall record on a daily basis the hours of operation and gallons of water or other materials used

in operation of pressurized particulate suppressant truck.

[CO-R7-95-13, Condition 7.b.2.B.]

3.4.5. a. General recordkeeping requirements.

1. The owner or operator of a ferromanganese and silicomanganese production facility must comply with

all of the recordkeeping requirements under 40 CFR §63.10.

2. As required by 40 CFR §63.10(b)(2), the owner or operator must maintain records for 5 years from

the date of each record of:

i. The occurrence and duration of each startup, shutdown, or malfunction of operation (i.e., process

equipment and control devices);

ii. The occurrence and duration of each malfunction of the source or air pollution control equipment;

iii. All maintenance performed on the air pollution control equipment;

iv. Actions taken during periods of startup, shutdown, and malfunction (including corrective actions

to restore malfunctioning process and air pollution control equipment to its normal or usual

manner of operation) when such actions are different from the procedures specified in the startup,

shutdown, and malfunction plan;

v. All information necessary to demonstrate conformance with the startup, shutdown, and

malfunction plan when all actions taken during periods of startup, shutdown, and malfunction

(including corrective actions) are consistent with the procedures specified in such plan. This

information can be recorded in a checklist or similar form (see 40 CFR §63.10(b)(2)(v));

vi. All required measurements needed to demonstrate compliance with the standard and to support

data that the source is required to report, including, but not limited to, performance test

measurements (including initial and any subsequent performance tests) and measurements as may

be necessary to determine the conditions of the initial test or subsequent tests;

 vii. All results of initial or subsequent performance tests;

viii. If the owner or operator has been granted a waiver from recordkeeping or reporting requirements

under 40 CFR § 63.10(f), any information demonstrating whether a source is meeting the

requirements for a waiver of recordkeeping or reporting requirements;
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 21 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

ix. If the owner or operator has been granted a waiver from the initial performance test under 40 CFR

§63.7(h), a copy of the full request and the Administrator's approval or disapproval;

x. All documentation supporting initial notifications and notifications of compliance status required

by 40 CFR §63.9; and

xi. As required by 40 CFR §63.10(b)(3), records of any applicability determination, including

supporting analyses.

[40 CFR § 63.1660(a) and 45CSR34]

b. Specific recordkeeping requirements.

1. In addition to the general records required by Section 3.4.5.a. of this permit, the owner or operator

must maintain records for 5 years from the date of each record of:

i. Records of manufacturer certification that monitoring devices are accurate to within 5 percent

(unless otherwise specified in 40 CFR part 63, subpart XXX) and of calibrations performed at the

manufacturer's recommended frequency, or at a frequency consistent with good engineering

practice, or as experience dictates.

ii. Copy of the written maintenance plan for each air pollution control device.

iii. Copy of the fugitive dust control plan.

iv. Records of each maintenance inspection and repair, replacement, or other corrective action.

[40 CFR §§ 63.1660(b)(1)(ii), (v), (vi), (vii) and 45CSR34]

2. All records for the most recent 2 years of operation must be maintained on site. Records for the

previous 3 years may be maintained off site.

[40 CFR § 63.1660(b)(2) and 45CSR34]

3.5. Reporting Requirements

3.5.1. Responsible official. Any application form, report, or compliance certification required by this permit to be

submitted to the DAQ and/or USEPA shall contain a certification by the responsible official that states that,

based on information and belief formed after reasonable inquiry, the statements and information in the

document are true, accurate and complete.

[45CSR§30-4.4. and 5.1.c.3.D.]

3.5.2. A permittee may request confidential treatment for the submission of reporting required under 45CSR§30-

5.1.c.3. pursuant to the limitations and procedures of W.Va. Code § 22-5-10 and 45CSR31.

[45CSR§30-5.1.c.3.E.]

3.5.3. All notices, requests, demands, submissions and other communications required or permitted to be made to the

Secretary of DEP and/or USEPA shall be made in writing and shall be deemed to have been duly given when

delivered by hand, mailed first class, or by private carrier with postage prepaid to the address(es) set forth below

or to such other person or address as the Secretary of the Department of Environmental Protection may

designate:
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 22 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

If to the DAQ: If to the US EPA:

Director

WVDEP

Division of Air Quality

601 57th Street SE

Charleston, WV 25304

Phone: 304/926-0475

FAX: 304/926-0478

Associate Director

Office of Enforcement and Permits Review

(3AP12)

U. S. Environmental Protection Agency

Region III

1650 Arch Street

Philadelphia, PA 19103-2029

3.5.4. Certified emissions statement. The permittee shall submit a certified emissions statement and pay fees on an

annual basis in accordance with the submittal requirements of the Division of Air Quality.

[45CSR§30-8.]

3.5.5. Compliance certification. The permittee shall certify compliance with the conditions of this permit on the

forms provided by the DAQ. In addition to the annual compliance certification, the permittee may be required

to submit certifications more frequently under an applicable requirement of this permit. The annual certification

shall be submitted to the DAQ and USEPA on or before March 15 of each year, and shall certify compliance

for the period ending December 31. The permittee shall maintain a copy of the certification on site for five (5)

years from submittal of the certification.

[45CSR§30-5.3.e.]

3.5.6. Semi-annual monitoring reports. The permittee shall submit reports of any required monitoring on or before

September 15 for the reporting period January 1 to June 30 and on or before March 15 for the reporting period

July 1 to December 31. All instances of deviation from permit requirements must be clearly identified in such

reports. All required reports must be certified by a responsible official consistent with 45CSR§30-4.4.

[45CSR§30-5.1.c.3.A.]

3.5.7. Emergencies. For reporting emergency situations, refer to Section 2.17 of this permit.

3.5.8. Deviations.

a. In addition to monitoring reports required by this permit, the permittee shall promptly submit supplemental

reports and notices in accordance with the following:

1. Any deviation resulting from an emergency or upset condition, as defined in 45CSR§30-5.7., shall be

reported by telephone or telefax within one (1) working day of the date on which the permittee

becomes aware of the deviation, if the permittee desires to assert the affirmative defense in accordance

with 45CSR§30-5.7. A written report of such deviation, which shall include the probable cause of

such deviations, and any corrective actions or preventative measures taken, shall be submitted and

certified by a responsible official within ten (10) days of the deviation.

2. Any deviation that poses an imminent and substantial danger to public health, safety, or the

environment shall be reported to the Secretary immediately by telephone or telefax. A written report

of such deviation, which shall include the probable cause of such deviation, and any corrective actions

or preventative measures taken, shall be submitted by the responsible official within ten (10) days of

the deviation.
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 23 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

3. Deviations for which more frequent reporting is required under this permit shall be reported on the

more frequent basis.

4. All reports of deviations shall identify the probable cause of the deviation and any corrective actions

or preventative measures taken.

[45CSR§30-5.1.c.3.C.]

b. The permittee shall, in the reporting of deviations from permit requirements, including those attributable

to upset conditions as defined in this permit, report the probable cause of such deviations and any

corrective actions or preventive measures taken in accordance with any rules of the Secretary.

[45CSR§30-5.1.c.3.B.]

3.5.9. New applicable requirements. If any applicable requirement is promulgated during the term of this permit,

the permittee will meet such requirements on a timely basis, or in accordance with a more detailed schedule if

required by the applicable requirement.

[45CSR§30-4.3.h.1.B.]

3.5.10. The permittee shall maintain all VE observation records on site for a period of at least five years and shall

provide to the Director on a monthly basis a copy of all visible emissions observations certified by plant

management to be an accurate and true report for the previous month.

[CO-R7-95-13, Conditions 7.b.1.C.]

3.5.11. For any failure of air pollution control equipment subject to the provisions in Section 3.1.12. of this permit, with

a duration in excess of two (2) hours, the permittee is required to: notify the Division of Air Quality regarding

the failure of air pollution control equipment within twenty-four (24) hours, excluding weekends and holidays,

by telephone; and record the date, time, and duration of the failure of air pollution control equipment, the steps

taken to determine the cause of the failure of air pollution control equipment, and the steps taken by the

permittee to minimize emissions and their impact. The permittee is required to summarize this information in

a written report to be submitted within fourteen (14) days to the Director, Division of Air Quality. The

permittee shall retain a copy of this notice letter in its files for a period of five (5) years.

[CO-R7-95-13, Conditions 7.b.7.]

3.5.12. Any reports required under the provisions of Section 3.5.10. of this permit shall be provided to the Director

within thirty (30) days of the end of the month.

[CO-R7-95-13, Conditions 7.b.8.]

3.5.13. As required by 40 CFR §63.9(b), unless otherwise specified, the owner or operator must submit the following

written notifications to the Administrator:

a. As required by 40 CFR §63.9(b)(2), the owner or operator of an affected source that has an initial startup

before the effective date of the standard must notify the Administrator that the source is subject to the

requirements of the standard. The notification must be submitted no later than 120 calendar days after May

20, 1999 (or within 120 calendar days after the source becomes subject to this standard) and must contain

the information specified in 40 CFR §63.9(b)(2)(i) through (b)(2)(v).
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 24 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

b. As required by 40 CFR §63.9(b)(5), the owner or operator who, after the effective date of this standard,

intends to construct a new affected source or reconstruct an affected source subject to this standard, or

reconstruct a source such that it becomes an affected source subject to this standard, must notify the

Administrator, in writing, of the intended construction or reconstruction.

[40 CFR §§ 63.1658(a)(1),(2), (5) and 45CSR34]

3.5.14. Notification of compliance status. The owner or operator of an affected source must submit a notification of

compliance status as required by 40 CFR §63.9(h). The notification must be sent in accordance with Sections

3.5.6. and 3.5.15.a.1. of this permit.

[40 CFR § 63.1658(f) and 45CSR34]

3.5.15. a. General reporting requirements. The owner or operator of a ferromanganese and silicomanganese

production facility must comply with all of the reporting requirements under 40 CFR §63.10 of subpart A,

unless otherwise specified in 40 CFR part 63, subpart XXX.

1. Frequency of reports. As provided by 40 CFR §63.10(a)(5), if the owner or operator is required to

submit periodic reports to a State on an established time line, he or she may change the dates by which

periodic reports submitted under this part may be submitted (without changing the frequency of

reporting) to be consistent with the State's schedule by mutual agreement between the owner or

operator and the State. This provision may be applied at any point after the source's compliance date.

2. Reporting results of performance tests. As required by 40 CFR §63.10(d)(2), the owner or operator

of an affected source must report the results of the initial performance test as part of the notification

of compliance status required in Section 3.5.14. of this permit.

3. Periodic startup, shutdown, and malfunction reports.

i. As required by 40 CFR §63.10(d)(5)(i), if actions taken by an owner or operator during a startup,

shutdown, or malfunction of an affected source (including actions taken to correct a malfunction)

are consistent with the procedures specified in the startup, shutdown, and malfunction plan, the

owner or operator must state such information in a semiannual report. The report, to be certified

by the owner or operator or other responsible official, must be submitted semiannually in

accordance with Section 3.5.6. of this permit; and

ii. Any time an action taken by an owner or operator during a startup, shutdown, or malfunction

(including actions taken to correct a malfunction) is not consistent with the procedures in the

startup, shutdown, and malfunction plan, the owner or operator must comply with all requirements

of 40 CFR §63.10(d)(5)(ii).

b. Specific reporting requirements. In addition to the information required under 40 CFR §63.10, reports

required under Section 3.5.15.a. of this permit must include the information specified in paragraphs b.1.

through b.4. below. As allowed by 40 CFR §63.10(a)(3), if any State requires a report that contains all of

the information required in a report listed in this section, an owner or operator may send the Administrator

a copy of the report sent to the State to satisfy the requirements of this section for that report.

1. Air pollution control devices. The owner or operator must submit reports that summarize the records

maintained as part of the practices described in the maintenance plan for air pollution control devices

required under Section 3.1.15.b. of this permit, including an explanation of the periods when the

procedures were not followed and the corrective actions taken.
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 25 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

2. Fugitive dust. The owner or operator must submit reports that explain the periods when the

procedures outlined in the fugitive dust control plan pursuant to Section 3.1.14.a. were not followed

and the corrective actions taken.

3. Capture system. The owner or operator must submit reports that summarize the monitoring

parameter excursions measured pursuant to Section 4.2.4. of this permit and the corrective actions

taken.

4. Frequency of reports. The owner or operator must submit reports pursuant to 40 CFR §63.10(e)(3)

that are associated with excess emissions events. These reports are to be submitted on a quarterly

basis, unless the owner or operator can satisfy the requirements in 40 CFR §63.10(e)(3) to reduce the

frequency to a semiannual basis. All other reports specified in paragraphs b.1. through b.3. above

must be submitted semiannually.

[40 CFR § 63.1659 and 45CSR34]

3.6. Compliance Plan

3.6.1. The permittee shall submit a fugitive dust control plan in accordance with Section 3.1.14. of this permit within

90 days of the effective date of the Title V Permit.

[45CSR§30-4.3.h.1.c.]

3.6.2. The permittee shall submit a written notification that the source is subject to the MACT in accordance with

Section 3.5.13.b. of this permit within 60 days of the effective date of the Title V Permit.

[45CSR§30-4.3.h.1.c.]

3.7. Permit Shield

3.7.1. The permittee is hereby granted a permit shield in accordance with 45CSR§30-5.6. The permit shield applies

provided the permittee operates in accordance with the information contained within this permit.

3.7.2. The following requirements specifically identified are not applicable to the source based on the determinations

set forth below. The permit shield shall apply to the following requirements provided the conditions of the

determinations are met.

a. R13-1110 authorized the construction of Furnace No. 9, however the Furnace has since been dismantled.

b. Consent Orders - CO 5-16-1989 required the permittee to obtain a Rule 13 permit for the construction of

Furnace No. 9 which has since been dismantled. CO-R7-95-13, Condition 7.a.5.A. required the permittee

to maintain the pressure drop monitors on the MGO baghouse, which will not be used. CO-R7-E-2004-13

required the permittee to obtain a permit for the jig plant and No. 9 Furnace which are no longer at the

facility. Amendment to MM-06-001 amended Consent Order MM-06-001 by extending the deadline to

submit a completed Title V Permit application. The Title V Permit application has been submitted.

c. 40 CFR Part 60, subpart K, Ka, and Kb - The facility has three above ground storage tanks with capacities

less than 19,813 gallons.
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 26 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

d. 40 CFR Part 60, subpart Z does not apply to Electric Arc Furnaces No. 2 and No. 5, which were installed

in 1966, and in January, 1974, respectively. Nor does it apply to Electric Arc Furnace No. 7, which

commenced construction in March 1974 when the owner or operator entered into contractual obligations.

2

e. 40 CFR 64 - Compliance Assurance Monitoring (CAM). The Electric Arc Furnaces are subject to SO

limits in accordance with 45CSR10, however there are no control devices used to comply with the limit,

2

thus the Furnaces are not pollutant specific emissions units (PSEUs) for SO in accordance with 40 CFR

§64.2(a)(2). The Electric Arc Furnaces, the crushing and screening equipment, and fugitive dust sources

are subject to the Ferroalloys Production MACT which regulates PM emissions, thus these sources are not

subject to CAM for PM in accordance with 40 CFR §64.2(b)(1)(i). 
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 27 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

4.0. Requirements for Furnaces [No. 2 (001-01), No. 5 (001-02), and No. 7 (001-03)]

4.1. Limitations and Standards

4.1.1. No person shall cause, suffer, allow or permit emission of smoke and/or particulate matter into the open air from

any process source operation which is greater than twenty (20) percent opacity, except for smoke and/or

particulate matter emitted from any process source operation which is less than forty (40) percent opacity for

any period or periods aggregating no more than five (5) minutes in any sixty (60) minute period. Compliance

with this limit shall demonstrate compliance with the less stringent limitation of 40 CFR § 63.1653.

[45CSR§§7-3.1. and 3.2., 40 CFR § 63.1653, and 45CSR34]

4.1.2. No person shall circumvent the provisions of 45CSR7 by adding additional gas to any exhaust or group of

exhausts for the purpose of reducing the stack gas concentration.

[45CSR§7-4.3.]

4.1.3. Type 'b' duplicate source operations whose air pollution control equipment efficiency is a minimum of ninetynine percent (99%) by weight and whose total process weight rate is less than two hundred fifty thousand

(250,000) pounds per hour shall be exempted from the requirements of 45CSR§7-4.1 provided that smoke

emitted into the open air from any such duplicate source operation is less than twenty percent (20%) opacity.

[45CSR§7-4.7.a.] 

4.1.4. Any stack serving any process source operation or air pollution control equipment on any process source

operation shall contain flow straightening devices or a vertical run of sufficient length to establish flow patterns

consistent with acceptable stack sampling procedures.

[45CSR§7-4.12.]

4.1.5. Potential Hazardous Material Emissions--Persons responsible for manufacturing process source operations from

which hazardous particulate matter material may be emitted such as, but not limited to, lead, arsenic, beryllium

and other such materials shall give the utmost care and consideration to the potential harmful effects of the

emissions resulting from such activities. Evaluations of these facilities as to adequacy, efficiency and emission

potential will be made on an individual basis by the Director working in conjunction with other appropriate

governmental agencies.

[45CSR§7-4.13.]

4.1.6. No person shall cause, suffer, allow or permit any manufacturing process generating fugitive particulate matter

to operate that is not equipped with a system, which may include, but not be limited to, process equipment

design, control equipment design or operation and maintenance procedures, to minimize the emissions of

fugitive particulate matter. To minimize means such system shall be installed, maintained and operated to

ensure the lowest fugitive particulate matter emissions reasonably achievable.

[45CSR§7-5.1.]

4.1.7. Sections 4.1.1. and 4.1.6. of this permit shall not apply to particulate matter emitted from the operation of an

existing ferroalloy electric submerged arc furnace during blowing taphole events, poling and oxygen lancing

operations. Poling emissions shall not exceed five (5) minutes in duration during any poling operation.

Compliance with this limit shall demonstrate compliance with the less stringent limitation of 40 CFR §

63.1653(b).

[45CSR§7-5.3., 40 CFR § 63.1653(b), and 45CSR34]
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 28 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

4.1.8. No person shall cause, suffer, allow or permit the emission into the open air from any source operation an instack sulfur dioxide concentration exceeding 2,000 parts per million by volume from existing source operations,

except as provided in subdivisions 4.1.a through 4.1.e. of 45CSR10.

[45CSR§10-4.1.]

4.1.9. Within ninety (90) days after startup of any furnace, the company shall be in compliance with all provisions set

forth in 40CFR Part 63, Subpart XXX - National Emission Standards for Ferromanganese and Silicomanganese

Production.

[CO-R7-E-2004-13, Condition III.4.]

4.1.10. Prior to restarting Furnace #9, the company shall apply for and obtain a Rule 13 permit.

[CO-R7-E-2004-13, Condition III.10.]

4.1.11. No owner or operator shall cause to be discharged into the atmosphere from any existing open submerged arc

furnace exhaust gases (including primary and tapping) containing particulate matter in excess of the following:

Emission

Unit ID

Furnace ID PM Limit in pounds per hour

Ferromanganese Production Silicomanganese Production

001-01 No. 2 29.8 35.9

001-02 No. 5 21.7 27.2

001-03 No. 7 21.7 27.2

[40 CFR § 63.1652(b) and 45CSR34]

4.2. Monitoring Requirements

4.2.1. The permittee shall conduct visual emission (VE) observations in accordance with Sections 3.2.1. and 3.2.2.

of this permit.

a. Visible emissions observations on the No. 5 and No. 7 furnace baghouse are not required during any shift

in which proper observer location cannot be achieved; 

b. For each incident during daylight hours where any furnace by-pass cap is opened, regardless of furnace

power input or operations status, VE observations shall be initiated no later than ten (10) minutes from the

time such by-pass caps are opened and shall continue for at least four (4) hours, until such time as the bypass caps are closed, or VE observations of the by-pass cap are 10% or less for at least ten minutes,

whichever occurs first;

[CO-R7-95-13, Conditions 7.b.1.A. and B. and 40 CFR § 63.1652(b) and 45CSR34]

4.2.2. The permittee shall continue to calibrate, maintain, and operate instrumentation to continuously monitor and

record the following:

a. Power input to each furnace.

b. Current or power input and winding temperature for each furnace baghouse fan motor.
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 29 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

c. Pressure drop across each furnace baghouse fan. Compliance with this limit shall demonstrate compliance

with the less stringent limitation of 40 CFR§ 63.1657(a)(2)(i).

[CO-R7-95-13, Condition 7.b.4. and 40 CFR§ 63.1657(a)(2)(i). and 45CSR34]

4.2.3. Compliance demonstration with opacity standards.

a. 1. The owner or operator must conduct initial opacity observations of the shop building to demonstrate

compliance with the applicable opacity standards according to 40 CFR §63.6(h)(5), which addresses

the conduct of opacity or visible emission observations.

2. In conducting the opacity observations of the shop building, the observer must limit his or her field

of view to the area of the shop building roof monitor that corresponds to the placement of the affected

submerged arc furnaces.

3. The owner or operator must conduct the opacity observations according to EPA Method 9 of 40 CFR

part 60, appendix A, for a minimum of 60 minutes.

b. 1. When demonstrating initial compliance with the shop building opacity standard, as required by Section

4.2.3.a.1. of this permit, the owner or operator must simultaneously establish parameter values for one

of the following: the control system fan motor amperes and all capture system damper positions, the

total volumetric flow rate to the air pollution control device and all capture system damper positions,

or volumetric flow rate through each separately ducted hood that comprises the capture system.

2. The owner or operator may petition the Administrator to reestablish these parameters whenever he or

she can demonstrate to the Administrator's satisfaction that the submerged arc furnace operating

conditions upon which the parameters were previously established are no longer applicable. The

values of these parameters determined during the most recent demonstration of compliance must be

maintained at the appropriate level for each applicable period.

c. The owner or operator must demonstrate continuing compliance with the opacity standards by following

the monitoring requirements specified in Section 4.2.4. of this permit and the reporting and recordkeeping

requirements specified in Sections 3.5.15.b.3. and 3.4.5.b. of this permit.

[40 CFR § 63.1656(d) and 45CSR34]

4.2.4. Shop opacity. The owner or operator subject to the opacity standards in 40 CFR §63.1653 must comply with

one of the monitoring options in paragraphs a., b., or c. below. The selected option must be consistent with that

selected during the initial performance test described in Section 4.2.3.b. of this permit. Alternatively, the owner

or operator may use the provisions of 40 CFR §63.8(f) to request approval to use an alternative monitoring

method.

a. The owner or operator must check and record the control system fan motor amperes and capture system

damper positions once per shift.

b. The owner or operator must install, calibrate, and maintain a monitoring device that continuously records

the volumetric flow rate through each separately ducted hood.

c. The owner or operator must install, calibrate, and maintain a monitoring device that continuously records

the volumetric flow rate at the inlet of the air pollution control device and must check and record the

capture system damper positions once per shift.
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 30 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

d. The flow rate monitoring devices must meet the following requirements:

1. Be installed in an appropriate location in the exhaust duct such that reproducible flow rate monitoring

will result.

2. Have an accuracy ±10 percent over its normal operating range and be calibrated according to the

manufacturer's instructions.

e. The Administrator may require the owner or operator to demonstrate the accuracy of the monitoring

device(s) relative to Methods 1 and 2 of 40 CFR part 60, appendix A.

f. Failure to maintain the appropriate capture system parameters (fan motor amperes, flow rate, and/or

damper positions) establishes the need to initiate corrective action as soon as practicable after the

monitoring excursion in order to minimize excess emissions.

g. Failure to monitor or failure to take corrective action under the requirements of Section 4.2.4. of this permit

is a violation of the general duty to operate in a manner consistent with good air pollution control practices

that minimizes emissions per 40 CFR §63.6(e)(1)(i).

[40 CFR § 63.1657(c) and 45CSR34]

4.3. Testing Requirements

4.3.1. The permittee shall demonstrate compliance with Section 4.1.8. of this permit by periodic testing in accordance

with 40 CFR Part 60, Appendix A, Method 6 or other equivalent EPA testing method approved by the Director

and the approved monitoring plan (See Appendix B.)

[45CSR§10-8.1.]

4.3.2. Stack tests in accordance with 40 CFR Part 63, Subpart XXX shall be performed within ninety (90) days of

startup of any furnace. At least sixty (60) days prior to conducting stack tests, a test protocol shall be submitted

to DAQ outlining test methodologies, operating conditions, port locations, and any other information deemed

necessary by DAQ. Compliance with these limits shall demonstrate compliance with the less stringent

limitations of 40 CFR §§63.1658(d) and (e), and 40 CFR § 63.7.

[CO-R7-E-2004-13, Condition III.4., 40 CFR §§ 63.1658(d) and (e), 40 CFR § 63.7, and 45CSR34]

4.3.3. Within 45 days of initiating furnace operations, the permittee will submit a stack testing plan for the operating

furnace(s) at the facility.

[CO MM-06-001, Order for Compliance - Air Quality, Condition 5.]

4.3.4. W x x ithin 180 days of initiating furnace operations, the permittee will conduct stack testing for PM, NO , SO ,

VOCs and CO for all operating furnaces at the facility.

[CO MM-06-001, Order for Compliance - Air Quality, Condition 6.]

4.3.5. Compliance demonstration with the emission standards.

a. The owner or operator must conduct an initial performance test for air pollution control devices or vent

stacks subject to Section 4.1.11. of this permit to demonstrate compliance with the applicable emission

standards.
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 31 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

b. The owner or operator must conduct annual performance tests for the air pollution control devices and vent

stacks associated with the submerged arc furnaces, with the exception of any air pollution control devices

that serve tapping emissions combined with non-furnace emissions, such as equipment associated with

crushing and screening. Also excluded are air pollution control devices that serve dedicated non-furnace

emissions, such as equipment associated with crushing and screening. The results of these annual tests will

be used to demonstrate compliance with the emission standards in Section 4.1.11. of this permit, as

applicable.

c. Following development, and approval, if required, of the site-specific test plan, the owner or operator must

conduct a performance test for each air pollution control device or vent stack to measure particulate matter

and determine compliance with the applicable standard.

An owner or operator of sources subject to the particulate mass rate standards in Section 4.1.11. of this

permit must determine compliance as follows:

1. Determine the particulate matter concentration and volumetric flow rate using Method 5 or 5D, as

applicable.

2. Compute the mass rate (EM) of particulate matter for each run using the following equation:

Where:

EM = mass rate of particulate matter, kg/hr (lb/hr).

N = total number of exhaust streams at which emissions are quantified.

Csi = concentration of particulate matter from exhaust stream “i”, mg/dscm (gr/dscf).

Qsdi = volumetric flow rate of effluent gas from exhaust stream “i”, dscm/hr (dscf/hr)

K = conversion factor, 1 × 10 mg/kg (7,000 gr/lb). 6

3. Compliance is demonstrated if the average of the mass rates for the three runs comprising the

performance test does not exceed the standard.

[40 CFR §§ 63.1656(c)(1), (2), (3)(ii), and 45CSR34]

4.4. Recordkeeping Requirements

4.4.1. Records of the visible emission checks conducted in accordance with Section 4.2.1. of this permit shall be

maintained in accordance with Section 3.2.2. of this permit..

[CO-R7-95-13, Conditions 7.b.3.]

4.4.2. The permittee shall record on a daily basis:

a. During each incident of by-pass cap usage or where any visual emissions are observed from such by-pass

cap, the permittee shall record the following information:

i. Exact time that the by-pass cap was opened;
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 32 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

ii. Exact time that the by-pass cap was closed;

iii. Cause or causes leading to the by-pass cap usage;

iv. Actions taken to prevent recurrence of cause or causes leading to by-pass cap usage;

v. Reports of any citizen complaints filed with or received by the permittee;

vi. Power input to the furnace.

[CO-R7-95-13, Condition 7.b.2.A.]

4.4.3. The permittee shall maintain on file at the facility a permanent record of the fan performance curve or

representative fan performance curve prepared for a specific temperature for each furnace baghouse fan.

[CO-R7-95-13, Condition 7.b.5.]

4.4.4. The permittee shall maintain a certified log of the time, duration and furnace number of all "blowing tap holes,"

"poling," and "oxygen lancing" at each furnace. This log must be made available upon request of any

representative of the Division of Air Quality and must be retained for five (5) years.

[CO-R7-95-13, Condition 7.b.6.]

4.5. Reporting Requirements

4.5.1. The permittee shall notify DAQ at least 48 hours prior to restarting any furnace at the facility.

[CO-R7-E-2004-13, Condition III.11.]

4.5.2. The permittee will provide notice to the DAQ no less than 5 days prior to initial operation of any furnace at the

facility.

[CO MM-06-001, Order for Compliance - Air Quality, Condition 2.]

4.5.3. Within 60 days of completing stack testing, the permittee will submit a report of stack testing on all furnaces

operating at the facility.

[CO MM-06-001, Order for Compliance - Air Quality, Condition 7.]

4.5.4. If any event occurs which causes delay in the achievement of the requirements of Consent Order 1-2006 MM,

the permittee shall have the burden of proving that the delay was caused by circumstances beyond its reasonable

control which could not have been overcome by due diligence (i.e., force majeure). Force majeure shall not

include delays caused or contributed to by the lack of sufficient funding. Within three (3) working days after

the permittee becomes aware of such a delay, notification shall be provided to the Director/Chief Inspector and

shall, within ten (10) working days of initial notification, submit a detailed written explanation of the anticipated

length and cause of the delay, the measures taken and/or to be taken to prevent or minimize the delay, and a

timetable by which the permittee intends to implement these measures. If the Director agrees that the delay has

been or will be caused by circumstances beyond the reasonable control of the permittee (i.e., force majeure),

the time for performance hereunder shall be extended for a period of time equal to the delay resulting from such

circumstances. A force majeure amendment granted by the Director shall be considered a binding extension

of this Order and of the requirements herein. The determination of the Director shall be final and not subject

to appeal.

[CO MM-06-001, Other Provisions, Condition 3.]
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 33 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

4.6. Compliance Plan

4.6.1. The permittee shall submit a test protocol to DAQ in accordance with Section 4.3.2. of this permit within 30

days of the effective date of the Title V Permit.

[45CSR§30-4.3.h.1.c.]

4.6.2. The permittee shall conduct stack tests in accordance with Sections 4.3.2. and 4.3.5. of this permit within 90

days of the effective date of the Title V Permit.

[45CSR§30-4.3.h.1.c.]

4.6.3. The permittee shall submit a stack testing plan for the operating furnace(s) at the facility in accordance with

Section 4.3.3. of this permit within 45 days of the effective date of the Title V Permit.

[45CSR§30-4.3.h.1.c.]

4 x x .6.1. The permittee shall conduct stack tests for PM, NO , SO , VOCs and CO for all operating furnaces at the

facility in accordance with Section 4.3.4. of this permit within 180 days of the effective date of the Title V

Permit.

[45CSR§30-4.3.h.1.c.]
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 34 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

5.0. Manufacturing Processes Requirements [009-01, 009-02, 009-03, 009-04, 009-06, 00A-01, and 00C-01]

5.1. Limitations and Standards

5.1.1. No person shall cause, suffer, allow or permit emission of smoke and/or particulate matter into the open air from

any process source operation which is greater than twenty (20) percent opacity, except for smoke and/or

particulate matter emitted from any process source operation which is less than forty (40) percent opacity for

any period or periods aggregating no more than five (5) minutes in any sixty (60) minute period.

[45CSR§§7-3.1. and 3.2.]

5.1.2. No person shall cause, suffer, allow, or permit PM to be vented into the open air from any type source operation

or duplicate source operation, or from all air pollution control equipment installed on any type source operation

or duplicate source operation in excess of the quantities specified in this permit.

Emission

Unit ID

Equipment Description Max. Allowable PM

Emission Limit (lb/hr)

009-06 Transfer Points 31.24

[45CSR§§7-4.1. (009-06)]

5.1.3. Type 'b' duplicate source operations whose air pollution control equipment efficiency is a minimum of ninetynine percent (99%) by weight and whose total process weight rate is less than two hundred fifty thousand

(250,000) pounds per hour shall be exempted from the requirements of 45CSR§7-4.1 provided that smoke

emitted into the open air from any such duplicate source operation is less than twenty percent (20%) opacity.

[45CSR§7-4.7.a. (009-01, 009-02, 009-03, 009-04 and 00A-01)]

5.1.4. The permittee shall maintain instrumentation to continuously monitor water pressures at or near each spray

nozzle of the wet suppression systems for slag crushing systems. The permittee shall repair or replace any

nozzle failing to provide effective flow characteristics at anytime that the slag crushing is in operation.

[CO-R7-95-13, Condition 7.a.10.A. and CO-R7, 13, 16-93-1, Condition IV.9.]

5.1.5. The permittee shall not employ soderburg paste to provide refractory lining for any ladle.

[CO-R7-95-13, Condition 7.a.11.B.]

5.1.6. All ladle to ladle repouring of molten material shall be conducted with a system to minimize fugitive emissions.

[CO-R7-95-13, Condition 7.a.6.E.]

5.1.7. The permittee shall maintain the product crushing and sizing operations in good operating condition.

[CO-R7-95-13, Condition 7.a.9.A.]

5.1.8. Within sixty (60) days after restarting the facility, at least one casting station must be fully operational. The

station(s) shall be used during all casting at the facility.

[CO-R7-E-2004-13, Condition III.3.]

5.1.9. Crushing and screening equipment. No owner or operator shall cause to be discharged into the atmosphere

from any existing piece of equipment associated with crushing and screening exhaust gases containing

particulate matter in excess of 0.03 gr/dscf.

[40 CFR § 63.1652(e)(2) and 45CSR34]
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 35 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

5.2. Monitoring Requirements

5.2.1. The permittee shall conduct visual emission (VE) observations in accordance with Sections 3.2.1. and 3.2.2 of

this permit.

[CO-R7-95-13, Conditions 7.b.1.A. and B.]

5.3. Testing Requirements

5.3.1. Compliance demonstration with the emission standards.

a. The owner or operator must conduct an initial performance test for air pollution control devices or vent

stacks subject to Section 5.1.9. of this permit to demonstrate compliance with the applicable emission

standards.

b. Following development, and approval, if required, of the site-specific test plan, the owner or operator must

conduct a performance test for each air pollution control device or vent stack to measure particulate matter

and determine compliance with the applicable standard.

An owner or operator of sources subject to the particulate matter concentration standards in Section 5.1.9.

of this permit must determine the particulate matter concentration using Method 5 or 5D, as applicable.

Compliance is demonstrated if the average concentration for the three runs comprising the performance

test does not exceed the standard.

[40 CFR §§ 63.1656(c)(1), (3)(i) and 45CSR34]

5.4. Recordkeeping Requirements

5.4.1. Records of the visible emission checks conducted in accordance with Section 5.2.1. of this permit shall be

maintained in accordance with Section 3.2.2. of this permit.

[CO-R7-95-13, Conditions 7.b.3.]

5.4.2. The permittee shall record on a daily basis the hours of operation and gallons of water used in operation on the

slag crushing plant.

[CO-R7-95-13, Conditions 7.b.2.c.]

5.5. Reporting Requirements

5.5.1. None.

5.6. Compliance Plan

5.6.1. None.
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 36 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

6.0. Manufacturing Processes Requirements [SC-1C, BC-1C, CR-1C, BC-2C, OS-1C, OS-2C, EX-1, OS-1X,

PT-1, OS-1P]

6.1. Limitations and Standards

6.1.1. Emissions from the operations covered under this permit shall not exceed the following:

PM 10 /Mn Compounds PM /Mn Compounds

lb/hr TPY lb/hr TPY

Crushing 21.8 2.45 10.31 1.16

Screening 21.8 2.45 10.31 1.16

Pelletizer 0.01 0.01 0.01 0.01

Extruder 0.39 0.10 0.18 0.05

Transfer Points 29.0 3.32 13.71 1.57

Stockpiles 3.36 0.61 1.59 0.29

Total 76.36 8.94 36.11 4.24

[45CSR13, R13-2857, Condition 4.1.1.]

6.1.2. Total combined throughput of material into the Crusher CR-1C shall not exceed 400 tons per hour nor 90,000

tons per year. Compliance with this limit shall be based on a 12 month rolling total. For the purposes of this

permit a 12 month rolling total means the sum of material throughput at the end of any given month for the

previous 12 months.

[45CSR13, R13-2857, Condition 4.1.2.]

6.1.3. Total combined throughput of material into the Screen SC-1C shall not exceed 400 tons per hour nor 90,000

tons per year. Compliance with this limit shall be based on a 12 month rolling total.

[45CSR13, R13-2857, Condition 4.1.3.]

6.1.4. Total combined throughput of material into the Extruder EX-1 shall not exceed 20 tons per hour nor 10,000

tons per year. Compliance with this limit shall be based on a 12 month rolling total.

[45CSR13, R13-2857, Condition 4.1.4.]

6.1.5. Total combined throughput of material into the Pelletizer PT-1 shall not exceed 6 tons per hour nor 10,000 tons

per year. Compliance with this limit shall be based on a 12 month rolling total.

[45CSR13, R13-2857, Condition 4.1.5.]

6.1.6. The base area of stockpile OS-1C shall not exceed 5,000 sq. ft.

[45CSR13, R13-2857, Condition 4.1.6.]

6.1.7. The base area of stockpile OS-2C shall not exceed 5,000 sq. ft.

[45CSR13, R13-2857, Condition 4.1.7.]
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 37 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

6.1.8. The base area of stockpile OS-1X shall not exceed 5,000 sq. ft.

[45CSR13, R13-2857, Condition 4.1.8.]

6.1.9. The base area of stockpile OS-1P shall not exceed 5,000 sq. ft.

[45CSR13, R13-2857, Condition 4.1.9.]

6.1.10. Emissions from Crusher CR-1C and Screen SC-1C shall be controlled by use of a baghouse. Said baghouse

shall be designed, installed, operated and maintained so as to achieve a minimum overall efficiency of at least

89%.

[45CSR13, R13-2857, Condition 4.1.10.]

6.1.11. The following transfer points shall be controlled by enclosures:T1C, T2C, T4C, T7C, T1P, T3P, T1X and T3X.

[45CSR13, R13-2857, Condition 4.1.11.]

6.1.12. Transfer points T3C and T6C shall be controlled by water sprays.

[45CSR13, R13-2857, Condition 4.1.12.]

6.1.13. Transfer point T5C shall be controlled by both an enclosure and water sprays.

[45CSR13, R13-2857, Condition 4.1.13.]

6.1.14. Opacity from any process source operation shall not exceed 20% except for opacity which is less than 40% for

a period or periods aggregating no more than 5 minutes in any 60 minute period.

[45CSR§7-3.1, 45CSR§7-3.2, and 45CSR13, R13-2857, Condition 4.1.14.]

6.1.15. When processing limestone, the permittee shall comply with all applicable standards of 40 CFR Part 60,

Subpart OOO including but not limited to the following:

a. The Crusher CR-1C and Screen SC-1C must both meet a PM limit of 0.014 grain/dscf.

b. The transfer points associated with belts BC-1C and BC-2C must meet an opacity limit of 7%.

[45CSR16, 40CFR§§ 60.672(a) and (b), and 45CSR13, R13-2857, Condition 4.1.16.]

6.1.16. When not processing limestone, the permittee shall comply with all applicable standards of 40 CFR Part 63,

Subpart XXX including Sections 3.1.14., 3.1.15. 3.1.16. of this permit and the following:

No owner or operator shall cause to be discharged into the atmosphere from any new or reconstructed piece of

equipment associated with crushing and screening exhaust gases containing particulate matter in excess of 50

mg/dscm (0.022 gr/dscf).

[45CSR34, 40CFR§63.1652(e)(1) and 45CSR13, R13-2857, Condition 4.1.17.]

6.1.17. Operation and Maintenance of Air Pollution Control Equipment. The permittee shall, to the extent

practicable, install, maintain, and operate all pollution control equipment permitted by R13-2857, and

associated monitoring equipment in a manner consistent with safety and good air pollution control practices for

minimizing emissions, or comply with any more stringent limits set forth in this permit or as set forth by any

State rule, Federal regulation, or alternative control plan approved by the Secretary.

[45CSR§13-5.11. and 45CSR13, R13-2857, Condition 4.1.18. (Baghouses to SC-1C and CR-1C; Water

sprays to BC-1C, BC-2C, OS-1C, and OS-2C, Full enclosures on EX-1 and PT-1)]
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 38 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

6.2. Testing Requirements

6.2.1. The permittee shall comply with all applicable testing requirements of 40 CFR Part 60, Subpart OOO including

but not limited to the following:

The owner or operator shall determine compliance with the PM standards in Section 6.1.15.a. as follows:

a. Except as specified in 40 CFR §§ 60.675(e)(3) and (4), Method 5 of Appendix A3 of this part or Method

17 of Appendix A6 of this part shall be used to determine the particulate matter concentration. The sample

volume shall be at least 1.70 dscm (60 dscf). For Method 5 (40 CFR part 60, Appendix A3), if the gas

stream being sampled is at ambient temperature, the sampling probe and filter may be operated without

heaters. If the gas stream is above ambient temperature, the sampling probe and filter may be operated at

a temperature high enough, but no higher than 121EC (250EF), to prevent water condensation on the filter.

b. Method 9 of Appendix A4 of this part and the procedures in 40 CFR § 60.11 shall be used to determine

opacity.

[45CSR16, 40CFR§§ 60.675(b)(1) and (b)(2) and 45CSR13, R13-2857, Condition 4.2.1.]

6.2.2. The permittee shall comply with all applicable standards of 40 CFR Part 63, Subpart XXX including but not

limited to the following:

The owner or operator must conduct an initial performance test for air pollution control devices or vent stacks

subject to Section 6.1.16. of this permit to demonstrate compliance with the applicable emission standards.

[45CSR34, 40CFR§ 63.1656(c)(1) and 45CSR13, R13-2857, Condition 4.2.2.]

6.3. Monitoring and Recordkeeping Requirements

6.3.1. Record of Maintenance of Air Pollution Control Equipment. For all pollution control equipment permitted

by R13-2857, the permittee shall maintain accurate records of all required pollution control equipment

inspection and/or preventative maintenance procedures.

[45CSR13, R13-2857, Condition 4.3.2. (Baghouses to SC-1C and CR-1C; Water sprays to BC-1C, BC-2C,

OS-1C, and OS-2C, Full enclosures on EX-1 and PT-1)]

6.3.2. Record of Malfunctions of Air Pollution Control Equipment. For all air pollution control equipment

permitted by R13-2857, the permittee shall maintain records of the occurrence and duration of any malfunction

or operational shutdown of the air pollution control equipment during which excess emissions occur. For each

such case, the following information shall be recorded:

a. The equipment involved.

b. Steps taken to minimize emissions during the event.

c. The duration of the event.

d. The estimated increase in emissions during the event.

For each such case associated with an equipment malfunction, the additional information shall also be recorded:
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 39 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

e. The cause of the malfunction.

f. Steps taken to correct the malfunction.

g. Any changes or modifications to equipment or procedures that would help prevent future recurrences of

the malfunction.

[45CSR13, R13-2857, Condition 4.3.3. (Baghouses to SC-1C and CR-1C; Water sprays to BC-1C, BC-2C,

OS-1C, and OS-2C, Full enclosures on EX-1 and PT-1)]

6.3.3. The permittee shall comply with all applicable monitoring and recordkeeping requirements of 40 CFR Part 60,

Subpart OOO including but not limited to the following:

The owner or operator of any affected facility for which construction, modification, or reconstruction

commenced on or after April 22, 2008, that uses wet suppression to control emissions from the affected facility

must perform monthly periodic inspections to check that water is flowing to discharge spray nozzles in the wet

suppression system. The owner or operator must initiate corrective action within 24 hours and complete

corrective action as expediently as practical if the owner or operator finds that water is not flowing properly

during an inspection of the water spray nozzles. The owner or operator must record each inspection of the water

spray nozzles, including the date of each inspection and any corrective actions taken, in the logbook required

under Section 6.4.1.

Except as specified in 40 CFR §§ 60.674(d) or (e), the owner or operator of any affected facility for which

construction, modification, or reconstruction commenced on or after April 22, 2008, that uses a baghouse to

control emissions must conduct quarterly 30-minute visible emissions inspections using EPA Method 22 (40

CFR part 60, Appendix A7). The Method 22 (40 CFR part 60, Appendix A7) test shall be conducted while the

baghouse is operating. The test is successful if no visible emissions are observed. If any visible emissions are

observed, the owner or operator of the affected facility must initiate corrective action within 24 hours to return

the baghouse to normal operation. The owner or operator must record each Method 22 (40 CFR part 60,

Appendix A7) test, including the date and any corrective actions taken, in the logbook required under Section

6.4.1. The owner or operator of the affected facility may establish a different baghouse-specific success level

for the visible emissions test (other than no visible emissions) by conducting a PM performance test according

to 40 CFR § 60.675(b) simultaneously with a Method 22 (40 CFR part 60, Appendix A7) to determine what

constitutes normal visible emissions from that affected facility's baghouse when it is in compliance with the

applicable PM concentration limit in Table 2 of this subpart. The revised visible emissions success level must

be incorporated into the permit for the affected facility.

[45CSR16, 40CFR§§ 60.674(b) and (c), and 45CSR13, R13-2857, Condition 4.3.4.]

6.3.4 The permittee shall comply with all applicable monitoring and recordkeeping requirements of 40 CFR Part 63,

Subpart XXX including Sections 3.2.1., 3.2.3., 3.4.5. and the following:

For the baghouses serving the submerged arc furnaces, the metal oxygen refining process, and crushing and

screening operations, the owner or operator must observe on a daily basis for the presence of any visible

emissions.

[45CSR34, 40CFR§ 63.1657(a)(1) and 45CSR13, R13-2857, Condition 4.3.5.]

6.3.5 In order to determine compliance with sections 6.1.2. and 6.1.3. of this permit the permittee shall monitor and

record the amount of material processed through the screen SC-1C on a monthly basis.

[45CSR13, R13-2857, Condition 4.3.6.]
Title V Operating Permit R30-05300004-2007 (AA01 SM01) Page 40 of 49

Felman Production, Inc.

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: August 8, 2007 • Revised: July 21, 2010 March 8, 2011

6.3.6 In order to determine compliance with section 6.1.4. of this permit the permittee shall monitor and record the

amount of material processed through the Extruder EX-1 on a monthly basis.

[45CSR13, R13-2857, Condition 4.3.7.]

6.3.7 In order to determine compliance with section 6.1.5. of this permit the permittee shall monitor and record the

amount of material processed through the Pelletizer PT-1 on a monthly basis.

[45CSR13, R13-2857, Condition 4.3.8.]

6.4. Reporting Requirements

6.4.1. The permittee shall comply with all applicable monitoring and recordkeeping requirements of 40 CFR Part 60

Subpart OOO.

Owners or operators of affected facilities for which construction, modification, or reconstruction commenced

on or after April 22, 2008, must record each periodic inspection required under Section 6.3.3., including dates

and any corrective actions taken, in a logbook (in written or electronic format). The owner or operator must

keep the logbook onsite and make hard or electronic copies (whichever is requested) of the logbook available

to the Administrator upon request.

[45CSR16, 40CFR§ 60.676(b)(1), and 45CSR13, R13-2857, Condition 4.4.1.]

6.4.2 The permittee shall comply with all applicable monitoring and recordkeeping requirements of 40 CFR Part 63

Subpart XXX including Sections 3.5.13., 3.5.14., and 3.5.15. of this permit.

[45CSR13, R13-2857, Condition 4.4.2.]

6.5. Compliance Plan

6.5.1. None.
APPENDIX A

Inspection and Maintenance Program
Felman Production, Inc.

Emission Control System ("ECS")

Inspection and Maintenance Program

Item Inspection

Frequency

Condition Comments

I. Submerged Arc Furnaces ("SAF")

a) Furnace Doors 1/week

b) Furnace Hoods

i) Electrode Fume Seals 1/day

ii) Mix Chutes 1/day

iii) ECS "Draw" 1/day

c) Tapping Hoods

i) Alignment 1/day

ii) Hydraulic Operation 1/month

iii) Fan & Damper Operation 1/month

iv) ECS "Draw" 1/week

II. ECS Ductwork

a) Flexible Duct Seals 1/week

b) Stack Cap Seals 1/week

c) Expansion Joints & Ductwork 1/Q

d) Multiclones 1/Q

e) Heat Exchangers 1/Q

f) Tempering Air Dampers 1/month

III. Pouring Hoods

a) Alignment 1/day

b) Hydraulic Operation 1/month

c) Fan & Damper Operation 1/month

d) ECS "Draw" 1/week

IV. Baghouses (2, 5, 7)

a) Filter Bags & their attachments 1/day

b) Compartment Hoppers

i) Door Seals 1/day

ii) Steel Plating 1/week

iii) Screw Conveyors & their drives 1/week
Item Inspection

Frequency

Condition Comments

c) Primary Fan & Motors

i) Bearings (Lubrication & Vibration) 1/day

ii) Pre-Spin Dampers 1/week

iii) Flexible Connections to Duct 1/week

d) Instrumentation

i) Magnahelic Gages and/or 

Manometers

1/shift

ii) Vibration Monitors 1/month

iii) Damper Controller 1/month

iv) Temperature Monitoring Inst. 1/month

v) Pneumatic Damper Operators & 

Solenoids

1/month

vi) Annunciation 1/week

e) Bullseye Dampers

i) Isolation Damper Seals 1/week

ii) Reverse Air Damper Seals 1/week

f) Miscellaneous Steelwork

i) Baffleplates 1/week

ii) Dirty Air Ductwork 1/day

g) Bag Cleaning Apparatus

i) Reverse Air Fan (2,5,7,) 1/week

h) Fume Removal Systems

i) Rotary Gate Valves 1/week

ii) Vibrators 1/week

iii) Pneumatic Blowers 1/month

iv) Pneumatic Piping 1/Q

v) Fume Storage Silos 1/week

vi) Pelletizer 1/day

i) Miscellaneous

i) General Clean Up 1/day

ii) Compressed Air System 1/Q
APPENDIX B

Rule 10 Monitoring Plan
Electric Arc Furnace SO2 Monitoring Plan

45CSR10 Control Limits of Sulfur Dioxide from Furnaces

Felman Production, Inc. (Felman) operates electric arc furnaces (EAF) for the production of ferroalloy metal. Sulfur

dioxide emissions are generated in the EAFs Nos. 2, 5, and 7 from the use of sulfur bearing raw materials. Initial

em 2ission testing for SO will be conducted as required. An EPA study related to emission testing from five EAFs stated

no 2 2 significant SO concentrations were found in the exhaust gas. The SO loss from furnaces equipped with air

po 2llution control devices did not exceed 7 PPH. SO concentrations ranged from 1 to 17 ppm. EPA stated that for this

2

reason, SO is rarely included in an emission test program (EPA-450/2-74-008, EPA-450/2-74-018A, and EPA-450/3-

80-041) 2. Based on a similar process, SO testing data from W est Virginia Alloy, Inc. on EAF No. 15 in 1998 that

2 2 showed the average SO concentration was 18 ppm. The calculated worst case SO concentration for Felman is 48

ppm v, which is well within the 2,000-ppm requirement of 45CSR§10-4.1. This is based on the following:

• Raw material sulfur content ranges from 0.6 to 2.0 percent

• Maximum design exhaust flow rate

• W orst case coal/coke usage rate (FeSi production)

• Final product sulfur analysis (SiMn production)

• Slag sulfur analysis (SiMn production)

• Baghouse dust/particulate sulfur analysis (SiMn production)

Applicable Standard:

No person shall cause, suffer, allow, or permit the emission into the open air from any source operation an in-stack

sulfur dioxide concentration exceeding 2,000 parts per million by volume from existing source operations. 45 CSR

10§4.

Initial Compliance Testing:

45 CSR 10A §5.2.a. provides for an initial compliance test conducted in accordance with 40 CFR Part 60, Appendix

A, Method 6 or other equivalent EPA testing method, and the results of this initial testing will be utilized to demonstrate

compliance with this monitoring plan. Initial testing per Felman’s Consent Order will be performed as soon as possible.

A 2s stated above it is expected that the SO concentration will be only a fraction of the 45 CSR 10 §4 regulatory

standard of 2,000 ppm. Based on these results Felman Production will be requesting an exemption from any further

SO2 testing.

Monitoring:

CEMS are required only if there is both the potential to emit 100 tons per year (TPY) of sulfur dioxide and the potential

to emit sulfur dioxide at a rate greater than or equal to 90% of the applicable emission standard, which is 2,000 ppm.

45 CSR 10A, §6.2.b. Therefore, Felman does not anticipate the need for the installation of stack gas monitoring

devices. 

Coal or coke will be the only raw material utilized in the ferroalloy furnaces with any significant sulfur content. The

average sulfur content of these materials is expected not to exceed 2.0%. Prior to stack testing Felman will monitor

the following:

• Sulfur content of each coal/coke shipment received.

• Sulfur content of coal/coke consumed per furnace.

• Daily coal/coke usage per furnace.

• Daily operating hours per furnace.

Felman will maintain historical supplier sulfur content data for a period of five (5) years. If the coal/coke supplier fails

to provide certificates of analysis, the following procedures will be utilized:

a. The owner or operator of a ferroalloy furnace shall meet the following minimum sampling requirements:

1. The sample acquisition point shall be at a location where representative samples of the total raw material flow

to the furnace may be obtained.

2. The sulfur bearing material shall be sampled at least once per day

3. Minimum sample size shall be five hundred (500) grams.

4. Samples shall be composited and analyzed at the end of each calendar month

b. The samples shall be prepared for analysis in accordance with procedures specified in ASTM D2013-86.

“Standard Method of Preparing Coal Samples for Analysis.”
c. The sulfur content of the samples will be determined in accordance with procedures specified in ASTM D3177-

84, “Standard Test Methods for Total Sulfur in the Analysis Sample of Coal and Coke”, or ASTM D4239-85,

“Standard Test Methods for Sulfur in the Analysis Sample of Coal and Coke Using High Temperature Tube

Furnace Combustion Methods.”

Based on 2 the worst-case sulfur content, the theoretical SO concentration is 48 ppm (see attached calculation). Even

at this worst-case sulfur content, compliance with the 2,000-ppm stack concentration limit is easily achieved. It is

e 2xpected that stack testing will demonstrate that the SO is only a fraction of the allowable limit. Based upon this

margin of compliance with the 2,000-ppm limit, Felman does not believe that on-going monitoring of the sulfur content

wi 2ll be necessary. Felman therefore requests that these requirements be waived once the initial SO stack test

demonstrates compliance with this standard. Felman realizes this is contingent upon no operational or raw material

changes.

An approved monitoring plan shall contain a response plan to be implemented during excursions (45 CSR 10A, 6.4.g.).

A 2s stated above, the worst -case sulfur content of 2.0% equates to an SO concentration of 48 ppm. Therefore, it is

not 2 possible to exceed the 2,000-ppm SO limit and no response plan will be required.

Reporting:

7.2.b. Non-CEMS Based Monitoring.

Each owner or operator employing monitoring pursuant to subsection 6.4 shall submit a “Monitoring Summary Report”

and an “Excursion and Monitoring Plan Performance Report” to the Secretary on a quarterly basis, to the extent

required under paragraphs 7.2.b.1 through 7.2.b.4; the Secretary may, on a case-by-case basis, require more frequent

reporting if the Secretary deems it necessary to accurately assess the compliance status of the fuel burning unit(s).

All reports shall be postmarked by the thirtieth (30th) day following the end of each calendar quarter. The Monitoring

Summary Report shall contain the information and be in a format approved by the Secretary.

Since it is not possible that the 45 CSR 10 §4 standard of 2,000 ppm can be violated by the electric arc furnaces, it

is requested the reporting requirement be waived for these units.

The 2 owner or operator of a ferroalloy furnace shall calculate the SO emissions based on operating hours, daily

coal/coke usage, and the results of the analysis for sulfur according to the following equations:

EQUATIONS

Mass Emission

SO2 f i (lb/hr) = (Q / OpHrs) x (C / 100) x (64 / 32) x 2000

W here:

SO2 (lb/hr) = hourly mass sulfur dioxide emissions, lb/hr

Qf = coal/coke usage, tons/day

OpHrs = Furnace operating hours, hr/day

Ci = sulfur concentration of pollutant, percent

64 = Molecular weight of sulfur dioxide, lb/lb-mole

32 = Molecular weight of sulfur, lb/lb-mole

SiMn Sulfur Breakdown as of 2/20/07

Sulfur in slag = 53%

Sulfur in final product = 1%

Sulfur to baghouse = 46%

Emission Concentration

SO2 2 (ppmv) = SO (lb/hr) x (385/64) x (1/Qs) x (1/60) x 10

6

W here:

SO2 (ppmv) = Sulfur dioxide concentration by volume

SO2 (lb/hr) = Sulfur dioxide hourly mass emission

385 = Molar volume, scf/lb-mole (ideal gas law)

64 = Molecular weight of sulfur dioxide, lb/lb-mole

Qs = Exhaust fan volumetric exhaust flow rate, scfm

60 = Minutes per hour

Design Exhaust Flow Rates

Furnace #2 = 450,000 acfm @ 500 F

"

Furnace #5 = 250,000 acfm @ 500 F

"

Furnace #7 = 350,000 acfm @ 550 F

"

SULFUR CALCULATIONS: MASS BALANCE / MATERIAL ANALYSIS

Mass Emission Concentration

SO2 2 2 s (lb/hr) = (Qf / OpHrs) x (Ci / 100) x (64 / 32) x 2000 SO (ppmv) = SO (lb/hr) x (385/64) x (1/Q ) x (1/60) x 106

SO2 2 (lb/hr) = hourly mass sulfur dioxide emissions, lb/hr SO (ppmv) = Sulfur dioxide concentration by volume
Qf

 = coal/coke usage, tons/day 385 = Molar volume, scf/lb-mole (ideal gas law)

OpHrs = Furnace operating hours, hr/day 64 = Molecular weight of sulfur dioxide, lb/lb-mole

Ci s = sulfur concentration of pollutant, percent Q = Exhaust fan volumetric exhaust flow rate, scfm

64 = Molecular weight of sulfur dioxide, lb/lb-mole 60 = Minutes per hour

32 = Molecular weight of sulfur, lb/lb-mole

Furnace #2 Furnace #5 Furnace #7

OpHrs 24 24 24 hrs/day

Qf 77.0 42.0 42.0 tons/day maximum projected coal/coke usage

3.2 1.8 1.8 TPH*** based on FeSi Alloy

6,417 3,500 3,500 lb/hr

Ci 2.0 2.0 2.0 % maximum sulfur (coal/coke) -as received basis

MWp 64 64 64 lb/lb-mole sulfur dioxide

EWf 32 32 32 lb/lb-mole sulfur

Potential Furnace

SO2 Manufactured

256.67 140.00 140.00 lb/hr sulfur dioxide

Portion of Sulfur in

Slag/ Waste*

53% 53% 53% based on SiMn Alloy

Portion of Sulfur in

Final Product

1% 1% 1% based on SiMn Alloy

Portion of Sulfur in

Exhaust Gas

46% 46% 46% based on SiMn Alloy

SO2 Emitted to

Baghouse**

118.1 64.4 64.4 lb/hr

517.1 282.1 282.1 TPY

Exhaust

Temperature

500 500 550 F

"

Exhaust Pressure 29.6 29.6 29.6 inHg@ 670 ft. elev. above sea level & +5 static

pressure

Design Exhaust

Flow Rate

450,000 250,000 350,000 ACFM

244,999 136,111 181,121 SCFM

SO2 Emitted to

Baghouse**

48 47 36 ppmv

Notes:

* The raw material mix includes lime/limestone, which adsorbs sulfur released by the coal/coke. This is reflected by the portion

of sulfur in the slag.

2

** SO emitted to the baghouse. It is expected that some of the sulfur is converted to particulate sulfates which would be

collected by 2 the baghouse and reduce the sulfur emissions further. An EPA study stated no significant SO concentrations

were 2 found in the exhuast gas for five furnaces tested. The SO loss from furnaces equipped with control devices did not

exceed 7 PPH. 2 2 SO concentrations ranged from 1 to 17 ppm. EPA stated that for this reason, SO is rarely included in an

emission test program (EPA-450/2-74-008, EPA-450/2-74-018A, and EPA-450/3-80-041).

*** Metric tons
Felman Production, Inc.

New Haven Plant Month / Year

Furnace #_______

DAILY RECORD SHEET

Day Time Hours

Operated

Coal/Coke

Usage

(tons)

Initials Comments and/or Excursion Incidents

(ATTACH ADDITIONAL INFO. AS NEEDED)

Startup Shutdown

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

Totals

This Record must be kept for 5 years from the above ending date.

Rev: 2/22/07
Felman Production, Inc.

New Haven Plant

Furnace #_____

Year______

SO2 MONITORING SUMMARY REPORT

Time Period Hours

Operated

Coal/Coke

Usage

(Tons)

Coal/Coke

Analysis

Sulfur (A/R)

Comments and/or Excursion

Incidents

1 Quarter st

January

February

March

Quarterly Totals

2 Quarter nd

April

May

June

Quarterly Totals

3 Quarter rd

July

August

September

Quarterly Totals

4 Quarter th

October

November

December

Quarterly Totals

Grand Total

This Record must be kept for 5 years from the above ending date.

Rev: 2/22/07
Attachment 2

Felman Title V Permit Renewal Application

February, 2012
TITLE V 

RENEWAL APPLICATION 

PERMIT NUMBER 

R30-05300004-2007 

Felman Production, Inc. 

New Haven Facility 

Mason County, West Virginia 

Prepared for: 

Felman Production, Inc. 

4442 Graham Station Road 

Letart, West Virginia 25253-8701 

Prepared by: 

Potesta & Associates, Inc. 

7012 MacCorkle Avenue, SE 

Charleston, West Virginia 25304 

Phone: (304) 342-1400 Fax: (304) 343-9031 

Email: potesta@potesta.com

Project No. 0101-11-0444 

February 2012
Title V Renewal - Permit Number R30-05300004-2007 – Felman Production, Inc., New Haven Facility (0101-11-0444), February 2012 

TABLE OF CONTENTS 

Title V Permit Application General Forms...............................................................SECTION I-VI 

Area Map ........................................................................................................... ATTACHMENT A 

Plot Plans ........................................................................................................... ATTACHMENT B 

Process Flow Diagrams...................................................................................... ATTACHMENT C 

Equipment Table................................................................................................ ATTACHMENT D 

Emission Unit Forms ..........................................................................................ATTACHMENT E 

Schedule of Compliance Forms..........................................................................ATTACHMENT F 

Air Pollution Control Device Forms.................................................................. ATTACHMENT G 

Compliance Assurance Monitoring (CAM) Forms ........................................... ATTACHMENT H 
SECTION I-VI 

TITLE V PERMIT APPLICATION GENERAL FORMS 

































ATTACHMENT A 

AREA MAP 
SITE LOCATION

0 1,000 2,000 4,000

μ

Feet P:\Projects\2011\11-0188 Felman Production Inc\Map 

Documents\FIGURE 1.mxd

DATE: JULY 2011

FIGURE 1

SITE LOCATION MAP

FELMAN PRODUCTION INC.

MASON COUNTY, WEST VIRGINIA
ATTACHMENT B 

PLOT PLANS 

ATTACHMENT C 

PROCESS FLOW DIAGRAMS 







ATTACHMENT D 

EQUIPMENT TABLE 
Title V Equipment Table (equipment_table.doc) 

Page 1 of 1 

 D1 of D1 Revised 4/11/05 

ATTACHMENT D - Title V Equipment Table

(includes all emission units at the facility except those designated as 

insignificant activities in Section 4, Item 24 of the General Forms) 

Emission 

Point ID1

 

Control 

Device1

Emission 

Unit ID1

Emission Unit Description Design Capacity Year Installed/ 

Modified 

001-01 BH2 001-01 No. 2 Furnace 32 MW 1966 

001-02 BH5 001-02 No. 5 Furnace 20 MW 1974 

001-03 BH7 001-03 No. 7 Furnace 20 MW 1975 

002-0B NA 002-0B Outdoor Storage Piles 3 Acres 1952 

005-01 NA 005-01 Unpaved Road – Raw Material Delivery NA NA 

005-02 NA 005-02 Unpaved Road – Gravel Delivery NA NA 

005-03 NA 005-03 Unpaved Road – Wood Chips Delivery NA NA 

005-04 NA 005-04 Unpaved Road – Scrap Metal Delivery NA NA 

005-05 NA 005-05 Unpaved Road – Products Shipments NA NA 

005-06 NA 005-06 Unpaved Road – Raw Material Transfer NA NA 

005-07 NA 005-07 Unpaved Road – Endloaders NA NA 

009-01 BH 009-01 Crushing and Screening System #1 33 TPH NA 

009-02 BH 009-02 Crushing and Screening System #2 33 TPH NA 

009-03 BH 009-03 Crushing and Screening System #4 20 TPH NA 

009-04 BH 009-04 Crushing and Screening System #5 20 TPH NA 

009-06 NA 009-06 Transfer Points 28 TPH NA 

00A-01 BH 00A-01 Product Casting Operations 20 TPH NA 

00C-01 NA 00C-01 Ladle Burners (Two Systems) 140 MMBtu NA 

SC-1C, 

T3C, 

009-03, 

T6C, 

05-1CE, and 

OS-2CE 

Various SC-1E, 

BC-1C, 

CR-1C, 

BC-2C, 

0S-1C, and 

0S-2C 

Portable Screener/Crusher and Stockpiles 400 TPH Proposed 

EX-01E and 

05-1X 

NA EX-01 and 

05-1X 

Extruder Unit and Stockpile 20 TPH Proposed 

PT-1E and 

OS-1PE 

FE/N PT-1 and 

OS-1P 

Peletizer Unit and Stockpile 6 TPH 2010 

1

For 45CSR13 permitted sources, the numbering system used for the emission points, control devices, and emission units should be consistent with the numbering system used in the 

45CSR13 permit. For grandfathered sources, the numbering system should be consistent with registrations or emissions inventory previously submitted to DAQ. For emission points, 

control devices, and emissions units which have not been previously labeled, use the following 45CSR13 numbering system: 1S, 2S, 3S,... or other appropriate description for 

emission units; 1C, 2C, 3C,... or other appropriate designation for control devices; 1E, 2E, 3E, ... or other appropriate designation for emission points. 
ATTACHMENT E 

EMISSION UNIT FORMS 
Page 1 of 85 

Emission Unit Form (emission_unit.doc) 

Page 1 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

001-01 

 

Emission unit name: 

No. 2 Furnace 

 

List any control devices associated 

with this emission unit: 

No. 2 Baghouse 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

This is a submerged electric arc furnace used in the production of 75% FeSi ferroalloy which operates continuously. 

Raw materials are added to the furnace at regular intervals. Emissions from this unit are controlled by the No. 2 

Baghouse. 

Manufacturer: 

Elkem 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

1966 

Installation date: 

1966 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): 32 MW 

 

 

Maximum Hourly Throughput: 

10.1 tph Production Rate 

Maximum Annual Throughput: 

88,476 (10.1 tph x 8,760 hr/yr) 

Production Rate 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 2 of 85 

Emission Unit Form (emission_unit.doc) 

Page 2 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 96.10 420.93 

Nitrogen Oxides (NOX) 1.64 7.19 

Lead (Pb) 0.000007 0.00003 

Particulate Matter (PM2.5) 4.73 20.75 

Particulate Matter (PM10) 4.73 20.75 

Total Particulate Matter (TSP) 4.73 20.75 

Sulfur Dioxide (SO2) 243.46 1,067.78 

Volatile Organic Compounds (VOC) 51.30 255.01 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

Arsenic 0.00071 0.00031 

Cadmium 0.00071 0.00031 

Chromium 0.03 0.13 

Manganese 0.08 0.34 

Mercury 0.0012 0.0052 

Nickel 0.02 0.08 

Selenium 0.000071 0.00031 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

CO – No published emission factor for CO was found. AP-42 indicates that all CO reacts above the furnace to form 

CO2. CO estimated from stack test results of 58.32 pph with a 20% buffer and production ratio of 1.37 based on 

actual operating rate of 7.355 tph during testing and yearly operation of 8,760 hrs/year which results in 96.10 pph 

and 420.93 tpy. 

NOx – No emission factor for NOx from ferroalloy furnaces were found. Emission factor was obtained from AP42, 4th Edition, Table 7.13-1 for electric arc furnaces used in steel foundries. 

Total particulate matter emission factor = 344 lb/ton. Lead in baghouse dust = 25 ppm. Therefore, emission factor 

= 344 lb PM/ton x 0.000025 lb Pb/lb PM = 0.000160 lb/ton. 

PM10 and PM2.5 – Conservatively assume all PM is PM10 and PM2.5. 

TSP – AP42 
Page 3 of 85 

Emission Unit Form (emission_unit.doc) 

Page 3 of 85 

Revised – 07/31/07

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

SO2 – Emissions based on material balance. 

Assume 97% of sulfur furnace exits to air as SO2. 

Coal used = 57,355,700 lb/yr, Avg. %S (by wt) = 0.76%, SO2 emissions = 422.8 ton/yr 

Charcoal used = 0 lb/yr, Avg. %S (by wt) = 0.10%, SO2 emissions = o ton/yr 

Coke used = 1,120,780 lb/yr, Avg. %S (by wt) = 0.85%, SO2 emissions = 9.2 ton/yr 

Total SO2 emissions = 432.0 ton/yr 

VOC – AP42 

Total particulate matter emission factor = 344 lb/ton. Arsenic in baghouse dust = 5 ppm. Therefore, emission factor 

= 344 lb PM/ton x 0.000005 lb As/lb PM = 0.001720 lb/ton. 

Total particulate matter emission factor = 344 lb/ton. Cadmium in baghouse dust = 5 ppm. Therefore, emission 

factor = 344 lb PM/ton x 0.000005 lb CD/lb PM = 0.001720 lb/ton. 

Total particulate matter emission factor = 344 lb/ton. Chromium in baghouse dust = 2000 ppm. Therefore, 

emission factor = 344 lb PM/ton x 0.002000 lb CR/lb PM = 0.688000 lb/ton. 

Total particulate matter emission factor = 344 lb/ton. Manganese in baghouse dust = 5500 ppm. Therefore, 

emission factor = 344 lb PM/ton x 0.005500 lb Mn/lb PM = 1.892000 lb/ton. 

Total particulate matter emission factor = 344 lb/ton. Mercury in baghouse dust = 250 ppm. Therefore, emission 

factor = 344 lb PM/ton x 0.000005 lb Hg/lb PM = 0.086000 lb/ton. 

Total particulate matter emission factor = 344 lb/ton. Nickel in baghouse dust = 1300 ppm. Therefore, emission 

factor = 344 lb PM/ton x 0.001300 lb Ni/lb PM = 0.447200 lb/ton. 

Total particulate matter emission factor = 344 lb/ton. Selenium in baghouse dust = 5 ppm. Therefore, emission 

factor = 344 lb PM/ton x 0.000005 lb As/lb PM = 0.001720 lb/ton. 
Page 4 of 85 

Emission Unit Form (emission_unit.doc) 

Page 4 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

See Pages 13 to 18 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

See Pages 19 to 21 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 5 of 85 

Emission Unit Form (emission_unit.doc) 

Page 5 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

001-02 

 

Emission unit name: 

No. 5 Furnace 

 

List any control devices associated 

with this emission unit: 

No. 5 Baghouse 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

This is a submerged electric arc furnace used in the production of 75% FeSi ferroalloy which operates continuously. 

Raw materials are added to the furnace at regular intervals. Emissions from this unit are controlled by the No. 5 

Baghouse. 

Manufacturer: 

Lectromelt 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

1974 

Installation date: 

1974 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): 20 MW 

 

Maximum Hourly Throughput: 

5.0 tph Production Rate 

Maximum Annual Throughput: 

43,800 (5 tph x 8,760 hr/yr) 

Production Rate 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 6 of 85 

Emission Unit Form (emission_unit.doc) 

Page 6 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 82.17 359.90 

Nitrogen Oxides (NOX) 0.84 3.68 

Lead (Pb) 0.00012 0.00052 

Particulate Matter (PM2.5) 4.73 20.75 

Particulate Matter (PM10) 4.73 20.75 

Total Particulate Matter (TSP) 4.73 20.75 

Sulfur Dioxide (SO2) 89.44 391.72 

Volatile Organic Compounds (VOC) 18.46 80.85 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

Arsenic 0.00003 0.00012 

Cadmium 0.00003 0.00012 

Chromium 0.01 0.05 

Manganese 0.03 0.12 

Mercury 0.0012 0.0052 

Nickel 0.0062 0.027 

Selenium 0.00003 0.00012 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

CO – No published emission factor for CO was found. AP-42 indicates that all CO reacts above the furnace to form 

CO2. CO estimated from stack test result of 74.7 pph with a 10% buffer and yearly operation of 8,760 hrs/year 

which results in 82.17 pph and 359.90 tpy. 

NOx – No emission factor for NOx from ferroalloy furnaces were found. Emission factor was obtained from 

AP-42, 4th Edition, Table 7.13-1 for electric arc furnaces used in steel foundries. 

Lead – Emission factor based on stack test results which indicate 4.1 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8183 hr/yr operation, 28750 ton/yr alloy 

produced) and includes emissions from product casting. Lead in baghouse dust = 25 ppm. Therefore, emissions = 

1.1277 lb PM/ton x 0.000025 lb PB/lb PM = 0.000028 lb/ton. 

PM10 and PM2.5 – Emission factor based on stack test results which indicate 4.1 lb/hr (controlled) of particulate 

matter. Emission factor was derived using actual production data for this furnace (8183 hr/yr operation, 28750 

ton/yr alloy produced) and includes emissions from product casting. Conservatively assume all PM is PM10 and 

PM2.5. 

TSP – Emission factor based on stack test results which indicate 4.1 lb/hr (controlled) of particulate matter. 
Page 7 of 85 

Emission Unit Form (emission_unit.doc) 

Page 7 of 85 

Revised – 07/31/07

Emission factor was derived using actual production data for this furnace (8183 hr/yr operation, 28750 ton/yr alloy 

produced) and includes emissions from product casting. 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

SO2 – Assume 97% of sulfur furnace exits to air as SO2. 

Coal used = 42,451,038 lb/yr, Avg. %S (by wt) = 0.76%, SO2 emissions = 312.9 ton/yr 

Charcoal used = 0 lb/yr, Avg. %S (by wt) = 0.10%, SO2 emissions = 0 ton/yr 

Coke used = 465,154 lb/yr, Avg. %S (by wt) = 0.85%, SO2 emissions = 3.8 ton/yr 

Total SO2 emissions = 316.7 ton/yr 

VOC – AP42 

Arsenic – Emission factor based on stack test results which indicate 4.1 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8183 hr/yr operation, 28750 ton/yr alloy 

produced) and includes emissions from product casting. Arsenic in baghouse dust = 5 ppm. Therefore, emissions = 

1.1277 lb PM/ton x 0.000005 lb As/lb PM = 0.000006 lb/ton. 

Cadmium – Emission factor based on stack test results which indicate 4.1 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8183 hr/yr operation, 28750 ton/yr alloy 

produced) and includes emissions from product casting. Cadmium in baghouse dust = 5 ppm. Therefore, emissions 

= 1.1277 lb PM/ton x 0.000005 lb Cd/lb PM = 0.000006 lb/ton. 

Chromium – Emission factor based on stack test results which indicate 4.1 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8183 hr/yr operation, 28750 ton/yr alloy 

produced) and includes emissions from product casting. Chromium in baghouse dust = 2000 ppm. Therefore, 

emissions = 1.1277 lb PM/ton x 0.002255 lb Cr/lb PM = 0.002255 lb/ton. 

Manganese – Emission factor based on stack test results which indicate 4.1 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8183 hr/yr operation, 28750 ton/yr alloy 

produced) and includes emissions from product casting. Manganese in baghouse dust = 5500 ppm. Therefore, 

emissions = 1.1277 lb PM/ton x 0.005500 lb Mn/lb PM = 0.006202 lb/ton. 

Mercury – Emission factor based on stack test results which indicate 4.1 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8183 hr/yr operation, 28750 ton/yr alloy 

produced) and includes emissions from product casting. Mercury in baghouse dust = 250 ppm. Therefore, 

emissions = 1.1277 lb PM/ton x 0.000250 lb Hg/lb PM = 0.000282 lb/ton. 

Nickel - Emission factor based on stack test results which indicate 4.1 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8183 hr/yr operation, 28750 ton/yr alloy 

produced) and includes emissions from product casting. Nickel in baghouse dust = 1300 ppm. Therefore, emissions 

= 1.1277 lb PM/ton x 0.001300 Ni/lb PM = 0.001466 lb/ton. 

Selenium - Emission factor based on stack test results which indicate 4.1 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8183 hr/yr operation, 28750 ton/yr alloy 

produced) and includes emissions from product casting. Selenium in baghouse dust = 5 ppm. Therefore, emissions 

= 1.1277 lb PM/ton x 0.000005 lb Se/lb PM = 0.000006 lb/ton. 
Page 8 of 85 

Emission Unit Form (emission_unit.doc) 

Page 8 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

See Pages 13 to 18 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

See Pages 19 to 21 

 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 9 of 85 

Emission Unit Form (emission_unit.doc) 

Page 9 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

001-03 

Emission unit name: 

No. 7 Furnace 

 

List any control devices associated 

with this emission unit: 

No. 7 Baghouse 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

This is a submerged electric arc furnace used in the production of either 50% or 75% FeSi ferroalloy which operates 

continuously. Raw materials are added to the furnace at regular intervals. Emissions from this unit are controlled 

by the No. 7 Baghouse. 

Manufacturer: 

Lectromelt 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

01/01/1976 

Installation date: 

01/01/1976 

Modification date(s): 

MM/DD/YYYY 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): 20 MW 

 

Maximum Hourly Throughput: 

5.0 tph Production Rate 

Maximum Annual Throughput: 

43,800 tpy (5.0 tph x 8,760 hr/yr) 

Production Rate 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 10 of 85 

Emission Unit Form (emission_unit.doc) 

Page 10 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 83.38 365.20 

Nitrogen Oxides (NOX) 0.84 3.68 

Lead (Pb) 0.00026 0.0012 

Particulate Matter (PM2.5) 10.06 44.06 

Particulate Matter (PM10) 10.06 44.06 

Total Particulate Matter (TSP) 10.06 44.06 

Sulfur Dioxide (SO2) 111.93 490.24 

Volatile Organic Compounds (VOC) 24.15 105.78 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

Arsenic 0.00005 0.00022 

Cadmium 0.00005 0.00022 

Chromium 0.02 0.09 

Manganese 0.06 0.25 

Mercury 0.0026 0.011 

Nickel 0.013 0.058 

Selenium 0.00005 0.00022 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

CO – No published emission factor for CO was found. AP-42 indicates that all CO reacts above the furnace to form 

CO2. CO estimated from stack test result of 75.8 pph with a 10% buffer and yearly operation of 8,760 hrs/year 

which result in 83.38 pph and 365.20 tpy. 

NOx - No emission factor for NOx from ferroalloy furnaces were found. Emission factor was obtained from AP-42, 

4th Edition, Table 7.13-1 for electric arc furnaces used in steel foundries. 

Lead – Emission factor based on stack test results which indicate 6.6 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8181 hr/yr operation, 22550 ton/yr alloy 

produced) and includes emissions from product casting. Lead in baghouse dust = 0.000025 ppm. Therefore, 2.395 

lb PM/ton x 0.000025 lb Pb/lb PM = 0.000060 lb/ton. 
Page 11 of 85 

Emission Unit Form (emission_unit.doc) 

Page 11 of 85 

Revised – 07/31/07

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 and PM2.5 – Emission factor based on stack test results which indicate 6.6 lb/hr (controlled) of particulate 

matter. Emission factor was derived using actual production data for this furnace (8181 hr/yr operation, 22550 

ton/yr alloy produced) and includes emissions from product casting. Conservatively assume all PM is PM10 and 

PM2.5. 

TSP – Emission factor based on stack test results which indicate 6.6 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8181 hr/yr operation, 22550 ton/yr alloy 

produced) and includes emissions from product casting. 

SO2 – Assume 97% of sulfur present in coal is emitted to the air as SO2. 

Coal used = 40,234,948 lb/yr, Avg. %S (by wt) = 0.76%, SO2 emissions from coal – 296.6 ton/yr 

Charcoal used = 0 lb/yr, Avg. %S (by wt) = 0.10%, SO2 emissions = 0 ton/yr 

Coke used = 461,841 lb/yr, Avg. 5S (by wt) = 0.85%, SO2 emissions = 3.8 ton/yr 

Total SO2 emissions = 300.4 ton/yr 

VOC – AP42 

Arsenic – Emission factor based on stack test results which indicate 6.6 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8181 hr/yr operation, 22550 ton/yr alloy 

produced) and includes emissions from product casting. Emissions from Arsenic = 2.395 lb PM/ton x 0.000005 lb 

As/lb PM = 0.000012 lb As/ton. 

Cadmium – Emission factor based on stack test results which indicate 6.6 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8181 hr/yr operation, 22550 ton/yr alloy 

produced) and includes emissions from product casting. Emissions from Cadmium = 2.395 lb PM/ton x 0.000005 lb 

Cd/lb PM = 0.000012 lb Cd/ton. 

Chromium - Emission factor based on stack test results which indicate 6.6 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8181 hr/yr operation, 22550 ton/yr alloy 

produced) and includes emissions from product casting. Emissions from Chromium = 2.395 lb PM/ton x 0.002000 

lb Cr/lb PM = 0.004790 Cr/ton. 

Manganese - Emission factor based on stack test results which indicate 6.6 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8181 hr/yr operation, 22550 ton/yr alloy 

produced) and includes emissions from product casting. Emissions from Manganese = 2.395 lb PM/ton x 0.005500 

lb Mn/lb PM = 0.013173 lb Mn/ton. 

Mercury - Emission factor based on stack test results which indicate 6.6 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8181 hr/yr operation, 22550 ton/yr alloy 

produced) and includes emissions from product casting. Emissions from Mercury = 2.395 lb PM/ton x 0.000250 lb 

Hg/lb PM = 0.000599 lb Hg/ton. 

Nickel – Emission factor based on stack test results which indicate 6.6 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8181 hr/yr operation, 22550 ton/yr alloy 

produced) and includes emissions from product casting. Emissions from Nickel = 2.395 lb PM/ton x 0.001300 lb 

Ni/lb PM = 0.003114 lb Ni/ton. 

Selenium - Emission factor based on stack test results which indicate 6.6 lb/hr (controlled) of particulate matter. 

Emission factor was derived using actual production data for this furnace (8181 hr/yr operation, 22550 ton/yr alloy 

produced) and includes emissions from product casting. Emissions from Selenium = 2.395 lb PM/ton x 0.002000 lb 

Se/lb PM = 0.004790 lb Se/ton. 

 
Page 12 of 85 

Emission Unit Form (emission_unit.doc) 

Page 12 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

See Pages 13 to 18 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

See Pages 19 to 21 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 13 of 85 

List all applicable requirements for this emission unit. For each applicable requirement, include the underlying rule/regulatioconstruction permit with the condition number. (Note: Title V permit condition numbers alone are not the underlying applicable req

emission limit is calculated based on the type of source and design capacity or if a standard is based on a design parameter, this inform

be included.

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Requirement 

1 45CSR§§7-3.1 and 3.2 

40CFR§3.1653, and 45CSR34 

4.1.1 Opacity No person shall cause, suffer, allow or permit emission of smoke and/or particulate matter into 

process source operation which is greater than twenty (20) percent opacity, except for smoke aemitted from any process source operation which is less than forty (40) percent opacity for 

aggregating no more than five (5) minutes in any sixty (60) minute period. Compliance with thicompliance with the less stringent limitation of 40 CFR §63.1653. 

2 45CSR§§7-4.3. 4.1.2 Dilution 

Prohibition 

No person shall circumvent the provisions of 45CSR7 by adding additional gas to any exhaust or gpurpose of reducing the stack gas concentration. 

3 45CSR§7-4.7.a.. 4.1.3 Regulation 7 

Exemption 

Type ‘b’ duplicate source operations whose air pollution control equipment efficiency is a minimu(99%) by weight and whose total process weight rate is less than two hundred fifty thousand (25

shall be exempted from the requirements of 45CSR§7-4.1 provided that smoke emitted into the duplicate source operation is less than twenty percent (20%) opacity. 

4 45CSR§7-4.12. 4.1.4. Stack 

Requirement 

Any stack serving any process source operation or air pollution control equipment on any proce

contain flow straightening devices or a vertical run of sufficient length to establish flow patterns co

stack sampling procedures. 

5 45CSR§7-4.13. 4.1.5. HAP Potential Hazardous Material Emissions—Persons responsible for manufacturing processing sourc

hazardous particulate matter material may be emitted such as, but not limited to, lead, arsenic, bmaterials shall give the utmost care and consideration to the potential harmful effects of the emissactivities. Evaluations of these facilities as to adequacy, efficiency and emission potential will bbasis by the Director working in conjunction with other appropriate governmental agencies. 

6 45CSR§7-5.1 4.1.6. Minimization of 

Fugitive PM 

No person shall cause, suffer, allow or permit any manufacturing process generating fugitive part

that is not equipped with a system, which may include, but not be limited to, process equipment d

design or operation and maintenance procedures, to minimize the emissions of fugitive particulameans such system shall be installed, maintained and operated to ensure the lowest fugitive part

reasonably achievable. 

7 45CSR§7-5.3., 40 

CFR§63.1653(b), and 

45CSR34 

4.1.7. 4.1.1. and 4.1.6. 

Exclusions 

Sections 4.1.1. and 4.1.6. of this permit shall not apply to particulate matter emitted from the 

ferroalloy electric submerged arc furnace during blowing taphole events, poling and oxygen lan

emissions shall not exceed five (5) minutes in duration during any poling operation. Compliademonstrate compliance with the less stringent limitation of 40CFR§63.1653(b). 

8 45CSR§10-4.1. 4.1.8. Sulfur Dioxide 

Limit 

No person shall cause, suffer, allow or permit the emission into the open air from any source opedioxide concentration exceeding 2,000 parts per million by volume from existing source operationsubdivisions 4.1.a through 4.1.e. of 45CSR10. 

9 CO-R7-E-2004-13, 

Condition III.4. 

4.1.9. 40 CFR63, XXX Within ninety (90) days after startup of any furnace, the company shall be in compliance with a

40CFR Part 63, Subpart XXX – National Emission Standards for Ferromanganese and Silicomangan

10 CO-R7-E-2004-13, 

Condition III.10. 

4.1.10. Furnace 9 Restart Prior to restarting Furnace #9, the company shall apply for and obtain a Rule 13 permit. 
Page 14 of 85 

List all applicable requirements for this emission unit. For each applicable requirement, include the underlying rule/regulatioconstruction permit with the condition number. (Note: Title V permit condition numbers alone are not the underlying applicable req

emission limit is calculated based on the type of source and design capacity or if a standard is based on a design parameter, this inform

be included.

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Requirement 

11 40CFR§63.1652(b) and 

45CSR34 

4.1.11. PM Limits No owner or operator shall cause to be discharged into the atmosphere from any existing open 

exhaust gases (including primary and tapping) containing particulate matter in excess of the followin

Emission Unit ID 001-01; Furnace ID No. 2; Ferromanganese Production 29.8; Silicomanganese PrEmission Unit ID 001-02; Furnace ID No. 5; Ferromanganese Production 21.7; Silicomanganese PrEmission Unit ID 001-03; Furnace ID No. 7; Ferromanganese Production 21.7; Silicomanganese Pr

12 CO-R7-95-13, Conditions 

7.b.1.A. and B. and 

40CFR§63.1652(b) and 

45CSR34 

4.2.1. Visible Emissions The permittee shall conduct visual emission (VE) observations in accordance with Sections 3.2.1. an

a. Visible emissions observations on the No. 5 and No. 7 furnace baghouse are not required during 

observer location cannot be achieved; b. For each incident during daylight hours where any furnace by-pass cap is opened, regardless o

operations status, VE observations shall be initiated no later than ten (10) minutes form the timopened and shall continue for at least four (4) hours, until such time as the by-pass caps are closethe by-pass cap are 10% or less for at least ten minutes, whichever occurs first. 

13 CO-R7-95-13, Condition 7.b.4. 

and 40CFR§63.1657(a)(2)(i). 

and 45CSR34 

4.2.2. Recording The permittee shall continue to calibrate, maintain, and operate instrumentation to continuously 

following: a. Power input to each furnace b. Current or power input and winding temperature for each furnace baghouse fan motor. c. Pressure drop across each furnace baghouse fan. Compliance with this limit shall demonstrate 

stringent limitation of 40CFR§63.1657(a)(2)(i). 

14 40CFR§63.1656(d) and 

45CSR34 

4.2.3. Compliance 

demonstration 

with opacity 

standards

Compliance demonstration with opacity standards. a. 1. The owner or operator must conduct initial opacity observations for the shop building to dem

the applicable opacity standards according to 40CFR§63.6(h)(5), which addresses the conduct of op

observations.  2. In conducting the opacity observations of the shop building, the observer must limit his or her 

of the shop building roof monitor that corresponds to the placement of the affected submerged arc fu

 3. The owner or operator must conduct the opacity observations according to EPA Method 9 of 4A, for a minimum of 60 minutes. b. 1. When demonstrating initial compliance with the shop building opacity standard, as required 

this permit, the owner or operator must simultaneously establish parameter values for one of the system fan motor amperes and all capture system damper positions, the total volumetric flow rate to device and all capture system damper positions, or volumetric flow rate through each separately duthe capture system.  2. The owner or operator may petition the Administrator to reestablish these parameters w

demonstrate to the Administrator’s satisfaction that the submerged arc furnace operating conparameters were previously established are no longer applicable. The values of these parametermost recent demonstration of compliance must be maintained at the appropriate level for each applicc. The owner or operator must demonstrate continuing compliance with the opacity standards by frequirements specified in Section 4.2.4. of this permit and the reporting and recordkeeping reSections 3.5.15.b.c. and 3.4.5.b. of this permit. 
Page 15 of 85 

List all applicable requirements for this emission unit. For each applicable requirement, include the underlying rule/regulatioconstruction permit with the condition number. (Note: Title V permit condition numbers alone are not the underlying applicable req

emission limit is calculated based on the type of source and design capacity or if a standard is based on a design parameter, this inform

be included.

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Requirement 

15 40CFR§63.1657(c) and 

45CSR34 

4.2.4. Shop Opacity The owner or operator subject to the opacity standards in 40CFR§63.1653 must comply with one o

in paragraphs a., b., or c. below. The selected option must be consistent with that selected during thdescribed in Section 4.2.3.b. of this permit. Alternatively, the owner or operator may use the prov

to request approval to use an alternative monitoring method. a. The owner or operator must check and record the control system fan motor amperes and capture once per shift. b. The owner or operator must install, calibrate, and maintain a monitoring device that continuousflow rate through each separately ducted hood. c. The owner or operator must install, calibrate, and maintain a monitoring device that continuouslflow rate at the inlet of the air pollution control device and must check and record the capture syste

per shift. d. The flow rate monitoring devices must meet the following requirements: 

1. Be installed in an appropriate location in the exhaust duct such that reproducible flow rate monito

2. Have an accuracy ±10 percent over its normal operating range and be calibrated accordininstructions. e. The Administrator may require the owner or operator to demonstrate the accuracy of the monitoMethods 1 and 2 of 40CFR part 60, appendix A. f. Failure to maintain the appropriate capture system parameters (fan motor amperes, flow rate, aestablishes the need to initiate corrective action as soon as practicable after the monitoring excurs

excess emissions. g. Failure to monitor or failure to take corrective action under the requirements of Section 4.2.4. of of the general duty to operate in a manner consistent with good air pollution control practices that 40CFR§63.6(e)(1)(i). 

16 45CSR§10-8.1. 4.3.1. Sulfur Dioxide 

Limit 

The permittee shall demonstrate compliance with Section 4.1.8. of this permit by periodic testing in 

Part 60, Appendix A, Method 6 or other equivalent EPA testing method approved by the Dir

monitoring plan (See Appendix B). 

17 CO-R7-E-2004.13, Condition 

III.4., 40CFR§§63.1658(d) and 

(e), 40CFR§63.7, and 

45CSR34 

4.3.2. Stack Testing 

40CFR63, 

Subpart XXX 

Stack tests in accordance with 40CFR Part 63, Subpart XXX shall be performed within ninety (90furnace. At least sixty (60) days prior to conducting stack tests, a test protocol shall be submittemethodologies, operating conditions, port locations, and any other information deemed necessary with these limits shall demonstrate compliance with the less stringent limitations of 40CFR§§40CFR§63.7. 

18 CO MM-06-001, Order for 

Compliance – Air Quality, 

Condition 5. 

4.3.3. Stack Test 

Protocol 

Within 45 days of initiating furnace operations, the permitee will submit a stack testing plan for ththe facility. 

19 CO MM-06-001, Order for 

Compliance – Air Quality, 

Condition 6. 

4.3.4. Stack Testing Within 180 days of initiating furnace operations, the permittee will conduct stack testing for PM, N

for all operating furnaces at the facility. 
Page 16 of 85 

List all applicable requirements for this emission unit. For each applicable requirement, include the underlying rule/regulatioconstruction permit with the condition number. (Note: Title V permit condition numbers alone are not the underlying applicable req

emission limit is calculated based on the type of source and design capacity or if a standard is based on a design parameter, this inform

be included.

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Requirement 

20 40CFR§§63.1656(c)(1), (2), 

(3)(ii), and 45CSR34 

4.3.5. Compliance 

Demonstration 

with the 

Emissions 

Standards 

Compliance demonstration with the emissions standards.

a. The owner or operator must conduct an initial performance test for air pollution control devices Section 4.1.11. of this permit to demonstrate compliance with the applicable emission standards. b. The owner or operator must conduct annual performance tests for the air pollution control associated with the submerged arc furnaces, with the exception of any air pollution control de

emissions combined with non-furnace emissions, such as equipment associated with crushing and s

are air pollution control devices that serve dedicated non-furnace emissions, such as equipment assoscreening. The results of these annual tests will be used to demonstrate compliance with the emis4.1.11. of this permit, as applicable. c. Following development, and approval, if required, of the site-specific test plan, the owner or 

performance test for each air pollution control device or vent stack to measure particulate matter anwith the applicable standard. An owner or operator of sources subject to the particulate mass rate standards in Section 4.1determine compliance as follows: 1. Determine the particulate matter concentration and volumetric flow rate using Method 5 or 5D, a

2. Compute the mass rate (EM) of particulate matter for each run using the following equation: 

] KsiQsdiCEM

N

i

/

1

⎢⎣⎡ = ∑−

Where: EM = mass rate of particulate matter, kg/hr (lb/hr). N = total number of exhaust streams at which emissions are quantified. Csi = concentration of particulate matter from exhaust stream “i”, mg/dscm (gr/dscf). Qsdi = volumetric flow rate of effluent gas from exhaust stream “i”, dscm/hr (dscf/hr) 

K = conversion factor, 1 × 106 mg/kg (7,000 gr/lb). 3. Compliance is demonstrated if the average of the mass rates for the three runs comprising the pexceed the standard.

21 CO-R7-95-13, Conditions 

7.b.3. 

4.4.1. Recordkeeping Records of the visible emission checks conducted in accordance with Section 4.2.1. of this perm

accordance with Section 3.2.2. of this permit.
Page 17 of 85 

List all applicable requirements for this emission unit. For each applicable requirement, include the underlying rule/regulatioconstruction permit with the condition number. (Note: Title V permit condition numbers alone are not the underlying applicable req

emission limit is calculated based on the type of source and design capacity or if a standard is based on a design parameter, this inform

be included.

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Requirement 

22 CO-R7-95-13, Condition 

7.b.2.A. 

4.4.2. Recordkeeping The permittee shall record on a daily basis: 

a. During each incident of by-pass cap usage or where any visual emissions are observed from such permittee shall record the following information: i. Exact time that the by-pass cap was opened; ii. Exact time that the by-pass cap was closed; iii. Cause or causes leading to the by-pass cap usage; iv. Actions taken to prevent recurrence of cause or causes leading to by-pass cap usage; v. Reports of any citizen complaints filed with or received by the permittee; vi. Power input to the furnace.

23 CO-R7-95-13, Condition 7.b.5. 4.4.3. Fan Curve Record The permittee shall maintain on file at the facility a permanent record of the fan performance cu

performance curve prepared for a specific temperature for each furnace baghouse fan.

24 CO-R7-95-13, Condition 7.b.6. 4.4.4. Log of “blowing 

tap holes,” poling, 

and oxygen 

lancing 

The permittee shall maintain a certified log of the time, duration and furnace number of all "blow

and "oxygen lancing" at each furnace. This log must be made available upon request of any represeAir Quality and must be retained for five (5) years.

25 CO-R7-E-2004.13, Condition 

III.11. 

4.5.1 Restart of Furnace 

Notification 

The permittee shall notify DAQ at least 48 hours prior to restarting any furnace at the facility.

26 CO MM-06-001, Order for 

Compliance – Air Quality, 

Condition 2. 

4.5.2. Restart of Furnace 

Notification 

The permittee will provide notice to the DAQ no less than 5 days prior to initial operation of any fur

27 CO MM-06-001, Order for 

Compliance – Air Quality, 

Condition 7. 

4.5.3. Stack Test Report Within 60 days of completing stack testing, the permittee will submit a report of stack testing on all 

facility.

28 CO MM-06-001, Other 

Provisions, Condition 3. 

4.5.4. CO 1-2006 MM If any event occurs which causes delay in the achievement of the requirements of Consent Order 1-

shall have the burden of proving that the delay was caused by circumstances beyond its reasonable 

have been overcome by due diligence (i.e., force majeure). Force majeure shall not include delays 

by the lack of sufficient funding. Within three (3) working days after the permittee becomes 

notification shall be provided to the Director/Chief Inspector and shall, within ten (10) working da

submit a detailed written explanation of the anticipated length and cause of the delay, the measures 

to prevent or minimize the delay, and a timetable by which the permittee intends to implemen

Director agrees that the delay has been or will be caused by circumstances beyond the reasonable 

(i.e., force majeure), the time for performance hereunder shall be extended for a period of time eqfrom such circumstances. A force majeure amendment granted by the Director shall be considere

this Order and of the requirements herein. The determination of the Director shall be final and not su
Page 18 of 85 

List all applicable requirements for this emission unit. For each applicable requirement, include the underlying rule/regulatioconstruction permit with the condition number. (Note: Title V permit condition numbers alone are not the underlying applicable req

emission limit is calculated based on the type of source and design capacity or if a standard is based on a design parameter, this inform

be included.

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Requirement 

29 45CSR§30-4.3.h.1.c. 4.6.1. Test Protocol The permittee shall submit a test protocol to DAQ in accordance with Section 4.3.2. of this perm

effective date of the Title V Permit.

30 45CSR§30-4.3.h.1.c. 4.6.2 Stack Test The permittee shall conduct stack tests in accordance with Sections 4.3.2. and 4.3.5. of this perm

effective date of the Title V Permit.

31 45CSR§30-4.3.h.1.c 4.6.3. Stack Testing Plan The permittee shall submit a stack testing plan for the operating furnace(s) at the facility in accordan

this permit within 45 days of the effective date of the Title V Permit.

32 45CSR§30-4.3.h.1.c 4.6.4. Stack Test The permittee shall conduct stack tests for PM, NOx, SOx, VOCs and CO for all operating fu

accordance with Section 4.3.4. of this permit within 180 days of the effective date of the Title V Per
Page 19 of 85 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall be used to demonstrate method is based on a permit or rule, include the condition number or citation. (Note: Each requirement listed above must have an as

demonstrating compliance. If there is not already a required method in place, then a method must be proposed.) 

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Method of Compliance 

1 45CSR§§7-3.1 and 3.2 

40CFR§3.1653, and 45CSR34 

4.1.1 Opacity Opacity Testing as required. 

2 45CSR§§7-4.3. 4.1.2 Dilution 

Prohibition 

NA 

3 45CSR§7-4.7.a.. 4.1.3 Regulation 7 

Exemption 

NA 

4 45CSR§7-4.12. 4.1.4. Stack 

Requirement 

NA 

5 45CSR§7-4.13. 4.1.5. HAP NA 6 45CSR§7-5.1 4.1.6. Minimization of 

Fugitive PM 

NA 

7 45CSR§7-5.3., 40 

CFR§63.1653(b), and 

45CSR34 

4.1.7. 4.1.1. and 4.1.6. 

Exclusion 5 

NA 

8 45CSR§10-4.1. 4.1.8. Sulfur 

DioxideLimit 

Regulation 10 Monitoring Plan Required 

9 CO-R7-E-2004-13, 

Condition III.4. 

4.1.9. 40CFR63, 

Subpart XXX Compliance with 40CFR63, Subpart XXX, within 90 days of start up. 

10 CO-R7-E-2004-13, 

Condition III.10. 

4.1.10. Furnace 9 Restart Permit required to restart Furnace No. 9. 

11 40CFR§63.1652(b) and 

45CSR34 

4.1.11. PM Limits Stack testing as required. 

12 CO-R7-95-13, Conditions 

7.b.1.A. and B. and 

40CFR§63.1652(b) and 

45CSR34 

4.2.1. Visible Emissions Conduct VE observations as required. 

13 CO-R7-95-13, Condition 7.b.4. 

and 40CFR§63.1657(a)(2)(i). 

and 45CSR34 

4.2.2. Recording Calibrate, maintain, and operate instruments to continuously monitor and record power input to 

power input and winding temperature for baghouse for motor and pressure drop across the baghouse

14 

40CFR§63.1656(d) and 

45CSR34 4.2.3. 

Compliance 

Demonstration 

with Opacity 

Standards 

Conduct VE/opacity testing as required. 
Page 20 of 85 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall be used to demonstrate method is based on a permit or rule, include the condition number or citation. (Note: Each requirement listed above must have an as

demonstrating compliance. If there is not already a required method in place, then a method must be proposed.)

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Method of Compliance 

15 40CFR§63.1657(c) and 

45CSR34 

4.2.4. Shop Opacity 40CFR63.1653 monitoring. 

16 45CSR§10-8.1. 4.3.1. Sulfur Dioxide 

Limit 

Sulfur monitoring and periodic testing. 

17 CO-R7-E-2004.13, Condition 

III.4., 40CFR§§63.1658(d) and 

(e), 40CFR§63.7, and 

45CSR34 

4.3.2. Stack Testing 

40CFR63, 

Subpart XXX 

40CFR63, Subpart XXX stack testing after startup. 

18 CO MM-06-001, Order for 

Compliance – Air Quality, 

Condition 5. 

4.3.3. Stack Test 

Protocol 

Stack test plan submission. 

19 CO MM-06-001, Order for 

Compliance – Air Quality, 

Condition 6. 

4.3.4. Stack Testing Stack test after initiating furnace operations. 

20 40CFR§§63.1656(c)(1), (2), 

(3)(ii), and 45CSR34 

4.3.5. Compliance 

Demonstration 

with the 

Emissions 

Standards 

Stack testing/performance test. 

21 CO-R7-95-13, Conditions 

7.b.3. 

4.4.1. Recordkeeping VE observations and records. 

22 CO-R7-95-13, Condition 

7.b.2.A. 

4.4.2. Recordkeeping Daily required records for by-pass cap. 

23 CO-R7-95-13, Condition 7.b.5. 4.4.3. Record Fan Curve Record of fan performance curve on site. 24 CO-R7-95-13, Condition 7.b.6. 4.4.4. Log of “blowing 

tap holes,” poling, 

and oxygen 

lancing 

Certified log of time, duration, and furnace number for blowing tap holes, poling, and oxygen lancin

25 CO-R7-E-2004.13, Condition 

III.11. 

4.5.1 Restart of Furnace 

Notifications 

Restart notifications. 

26 CO MM-06-001, Order for 

Compliance – Air Quality, 

Condition 2. 

4.5.2. Restart of Furnace 

Notifications 

Restart notifications. 
Page 21 of 85 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall be used to demonstrate method is based on a permit or rule, include the condition number or citation. (Note: Each requirement listed above must have an as

demonstrating compliance. If there is not already a required method in place, then a method must be proposed.)

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Method of Compliance 

27 CO MM-06-001, Order for 

Compliance – Air Quality, 

Condition 7. 

4.5.3. Stack Test Report Stack test report required. 

28 CO MM-06-001, Other 

Provisions, Condition 3. 

4.5.4. CO 1-2006MM Submit as needed updates on CO MM-06-001. 

29 45CSR§30-4.3.h.1.c. 4.6.1. Test Protocol Submit test protocol for stack testing. 30 45CSR§30-4.3.h.1.c. 4.6.2 Stack Test Stack Testing. 31 45CSR§30-4.3.h.1.c 4.6.3. Stack Testing Plan Stack Testing Plan. 32 45CSR§30-4.3.h.1.c 4.6.4. Stack Test Conduct Stack Testing: Parameters. 
Page 22 of 85 

Emission Unit Form (emission_unit.doc) 

Page 22 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

00A-01 

 

Emission unit name: 

Product Casting Operations 

 

List any control devices associated 

with this emission unit: 

Baghouses 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

This emission unit quantifies emissions from the casting of molten ferroalloy product. Casting is carried out on four 

large casting wheels; one dedicated to each of the four submerged electric arc furnaces. Emissions from casting 

operations are controlled by the same baghouses used to control emissions from the furnaces. 

 

 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

NA 

Installation date: 

NA 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): 

20 tph and 165,367 tpy 

 

Maximum Hourly Throughput: 

20 tpy 

Maximum Annual Throughput: 

165,367 tpy 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 23 of 85 

Emission Unit Form (emission_unit.doc) 

Page 23 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 0.44 0.19 

Particulate Matter (PM10) 0.44 0.19 

Total Particulate Matter (TSP) 0.44 0.19 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 – Emission factor for ferroalloy casting was obtained from the Ohio EPA Study, “Reasonably Available 

Control Measures for Fugitive Dust Sources”, September 1980, Ohio Environmental Protection Agency, Division 

for Air Pollution Control. Emission factor is as follows: 2.4 lb/ton processed. Conservatively assume PM2.5 is 

equal to PM10. 

Emissions from casting are fugitive within the building and, based on observation and engineering judgment, 

approximately 20% of emissions are released through the roof monitors. The remaining 80% is captured by the 

baghouses. Therefore, emission factor is as follows: 2.4 lb/ton x (1-0.80) = 0.48 lb/ton. Conservatively assume all 

PM is PM10. 

TSP – Emission factor for ferroalloy casting was obtained from the Ohio EPA Study “Reasonably Available Control 

Measures for Fugitive Dust Sources”, September 1980, Ohio Environmental Protection Agency, Division for Air 

Pollution Control. Emission factor is as follows: 2.4 lb/ton processed. 

Emissions from casting are fugitive within the building and, based on observation and engineering judgment, 

approximately 20% of emissions are released through the roof monitors. The remaining 80% is captured by the 

baghouses. Therefore, emission factor is as follows: 2.4 lb/ton x (1-0.80) = 0.48 lb/ton. Conservatively assume all 

PM is PM10. 
Page 24 of 85 

Emission Unit Form (emission_unit.doc) 

Page 24 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

See Pages 67 and 68 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

See Page 69 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 25 of 85 

Emission Unit Form (emission_unit.doc) 

Page 25 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

00C-01 

 

Emission unit name: 

Ladle Burners 

 

List any control devices associated 

with this emission unit: 

NA 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

Ladle burners are used to heat/reheat ladles containing molten ferroalloy. The ladle burners fire No. 2 oil. 

 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

NA 

Installation date: 

NA 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): 140 MMBtu/hr 

 

 

Maximum Hourly Throughput: 

40 gph each 

Maximum Annual Throughput: 

44,000 gpy 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? X Yes ___ No If yes, is it? 

___ Indirect Fired X Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

140 MMBtu/hr 

 

Type and Btu/hr rating of burners: 

140 MMBtu/hr 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

No. 2 Fuel Oil 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

No. 2 Fuel Oil 0.05% NA ~140MMBtu / 

1,000 gal 

 

 

 
Page 26 of 85 

Emission Unit Form (emission_unit.doc) 

Page 26 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 0.0479 0.21 

Nitrogen Oxides (NOX) 0.10 0.44 

Lead (Pb) 

Particulate Matter (PM2.5) 4.47 19.57 

Particulate Matter (PM10) 4.47 19.57 

Total Particulate Matter (TSP) 4.47 19.57 

Sulfur Dioxide (SO2) 0.069 0.30 

Volatile Organic Compounds (VOC) 0.003 0.01 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 – Emission factor for PM = 2 lb/1,000 gal burned 

44,000 gal/yr used 

50% of PM is PM-10 

Therefore, PM10 emission factor = 1 lb/1,000 gal. Conservatively assume PM 2.5 is equal to PM10. 

TSP – Emission factor = 2 lb/1,000 gal burned 

44,000 gal/yr used 

SO2 – Emission factor – 124S lb/1,000 gal burned 

44,000 gal/yr used 

S = 0.05% 

Emission Factor = 7.1 lb/1,000 gal burned 

VOC – Emission factor = 0.34 lb/1,000 gal burned 

44,000 gal/yr used 

NOx – Emission factor = 20 lb/1,000 gal burned 

44,000 gal/yr used 

CO – Emission factor = 5 lb/1,000 gal burned 

44,000 gal/yr used 
Page 27 of 85 

Emission Unit Form (emission_unit.doc) 

Page 27 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

See Pages 67 and 68 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

See Page 69 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 28 of 85 

Emission Unit Form (emission_unit.doc) 

Page 28 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

002-0B 

 

Emission unit name: 

Outdoor Storage Piles 

 

List any control devices associated 

with this emission unit: 

NA 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

Raw materials are stored outside of the main facility building on approximately 3 acres of land. 

 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

1952 

Installation date: 

1952 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): 3 Acres 

 

 

Maximum Hourly Throughput: 

NA 

Maximum Annual Throughput: 

NA 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 29 of 85 

Emission Unit Form (emission_unit.doc) 

Page 29 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 0.44 1.93 

Particulate Matter (PM10) 0.44 1.93 

Total Particulate Matter (TSP) 0.44 1.93 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 – Emissions from raw material storage piles based on WV emission factor of 3.5 lb/acre/day. Emissions were 

calculated as follows: 

Lb/hr = (3.5 lb/acre/day)(3 acres)/(24 hr/day) = 0.4375 lb/hr 

Ton/yr = (3.5 lb/acre/day)(3 acres)(365 day/yr)/(2000 lb/ton) = 1.92 ton/yr 

Conservatively assume PM2.5 is equal to PM10. 

TSP – Emissions from raw material storage piles based on WV emission factor of 2.5 lb/acre/day. Emissions were 

calculated as follows: 

Lb/hr = (3.5 lb/acre/day)(3 acres)/(24 hr/day) = 0.44 lb/hr 

Ton/yr = (3.5 lb/acre/day)(3 acres)(365 day/yr)/(2000 lb/ton) = 1.92 ton/yr 

 
Page 30 of 85 

Emission Unit Form (emission_unit.doc) 

Page 30 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 31 of 85 

Emission Unit Form (emission_unit.doc) 

Page 31 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

005-01 

 

Emission unit name: 

Unpaved Roads – Raw Material 

Delivery 

 

List any control devices associated 

with this emission unit: 

NA 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

This emission unit quantifies emissions caused by vehicle traffic occurring during raw material delivery. 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

NA 

Installation date: 

NA 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): NA 

 

Maximum Hourly Throughput: 

NA 

Maximum Annual Throughput: 

NA 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 32 of 85 

Emission Unit Form (emission_unit.doc) 

Page 32 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 0.02 0.099 

Particulate Matter (PM10) 0.02 0.099 

Total Particulate Matter (TSP) 0.05 0.221 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 – Emissions estimated using the method described in AP-42 5th Edition, Chapter 13.2.2 and assuming a 50% 

control efficiency since roadways are sprayed regularly to keep dust down. Particle size multiplier for PM is 0.80. 

Emission factor = 5.89 lb/VMT x (1-0.50) = 2.945 lb/VMT. Particle size multiplier for PM10 is 0.36. Therefore, 

PM10 emissions = (2.945 lb/hr)(0.36)/(0.80) = 1.325 lb/hr. 

Conservatively assume PM 2.5 is equal to PM10. 

TSP – Emissions estimated using the method described in AP-42 5th Edition, Chapter 13.2.2 and assuming a 50% 

control efficiency since roadways are sprayed regularly to keep dust down. Particle size multiplier for PM is 0.80. 

Emission factor is 5.89 lb/VMT x (1-0.50) = 2.945 lb/VMT. 

 

 

 

 

 
Page 33 of 85 

Emission Unit Form (emission_unit.doc) 

Page 33 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 34 of 85 

Emission Unit Form (emission_unit.doc) 

Page 34 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

005-02 

 

Emission unit name: 

Unpaved Roads – Gravel Delivery 

 

List any control devices associated 

with this emission unit: 

NA 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

This emission unit quantifies emissions caused by vehicle traffic occurring during gravel delivery. 

 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

NA 

Installation date: 

NA 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): NA 

Maximum Hourly Throughput: 

NA 

Maximum Annual Throughput: 

NA 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 35 of 85 

Emission Unit Form (emission_unit.doc) 

Page 35 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 0.06 0.25 

Particulate Matter (PM10) 0.06 0.25 

Total Particulate Matter (TSP) 0.13 0.56 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 – Emissions estimated using the method described in AP-42 5th Edition, Chapter 13.2.2 and assuming a 50% 

control efficiency since roadways are sprayed regularly to keep dust down. Particle size multiplier for PM is 0.80. 

Emission factor = 5.89 lb/VMT x (1-0.50) = 2.945 lb/VMT. Particle size multiplier for PM10 is 0.36. Therefore, 

PM10 emissions = (2.945 lb/hr)(0.36)/(0.80) = 1.325 lb/hr. 

Conservatively assume PM2.5 is equal to PM10. 

TSP – Emissions estimated using the method described in AP-42 5th Edition, Chapter 13.2.2 and assuming a 50% 

control efficiency since roadways are sprayed regularly to keep dust down. Particle size multiplier for PM is 0.80. 

Emission factor is 5.89 lb/VMT x (1-0.50) = 2.945 lb/VMT. 

 

 

 

 

 

 

 

 
Page 36 of 85 

Emission Unit Form (emission_unit.doc) 

Page 36 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 37 of 85 

Emission Unit Form (emission_unit.doc) 

Page 37 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

005-03 

 

Emission unit name: 

Unpaved Roads – Wood Chips 

Delivery 

List any control devices associated 

with this emission unit: 

NA 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

This emission unit quantifies emissions caused by vehicle traffic occurring during wood chip delivery. 

 

 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

NA 

Installation date: 

NA 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): NA 

 

 

Maximum Hourly Throughput: 

NA 

Maximum Annual Throughput: 

NA 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 38 of 85 

Emission Unit Form (emission_unit.doc) 

Page 38 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 0.15 0.68 

Particulate Matter (PM10) 0.15 0.68 

Total Particulate Matter (TSP) 0.34 1.50 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 – Emissions estimated using the method described in AP-42 5th Edition, Chapter 13.2.2 and assuming a 50% 

control efficiency since roadways are sprayed regularly to keep dust down. Particle size multiplier for PM is 0.80. 

Emission factor = 5.89 lb/VMT x (1-0.50) = 2.945 lb/VMT. Particle size multiplier for PM10 is 0.36. Therefore, 

PM10 emissions = (2.945 lb/hr)(0.36)/(0.80) = 1.325 lb/hr. 

Conservatively assume PM2.5 is equal to PM10. 

TSP – Emissions estimated using the method described in AP-42 5th Edition, Chapter 13.2.2 and assuming a 50% 

control efficiency since roadways are sprayed regularly to keep dust down. Particle size multiplier for PM is 0.80. 

Emission factor is 5.89 lb/VMT x (1-0.50) = 2.945 lb/VMT. 

 

 

 

 

 

 

 

 
Page 39 of 85 

Emission Unit Form (emission_unit.doc) 

Page 39 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 40 of 85 

Emission Unit Form (emission_unit.doc) 

Page 40 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

005-04 

 

Emission unit name: 

Unpaved Roads – Scrap Metal 

Delivery 

List any control devices associated 

with this emission unit: 

NA 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

This emission unit quantifies emissions caused by vehicle traffic occurring during scrap metal delivery. 

 

 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

NA 

Installation date: 

NA 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): NA 

 

Maximum Hourly Throughput: 

NA 

Maximum Annual Throughput: 

NA 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 41 of 85 

Emission Unit Form (emission_unit.doc) 

Page 41 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 0.06 0.25 

Particulate Matter (PM10) 0.06 0.25 

Total Particulate Matter (TSP) 0.13 0.56 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 – Emissions estimated using the method described in AP-42 5th Edition, Chapter 13.2.2 and assuming a 50% 

control efficiency since roadways are sprayed regularly to keep dust down. Particle size multiplier for PM is 0.80. 

Emission factor = 5.89 lb/VMT x (1-0.50) = 2.945 lb/VMT. Particle size multiplier for PM10 is 0.36. Therefore, 

PM10 emissions = (2.945 lb/hr)(0.36)/(0.80) = 1.325 lb/hr. 

Conservatively assume PM2.5 is equal to PM10. 

TSP – Emissions estimated using the method described in AP-42 5th Edition, Chapter 13.2.2 and assuming a 50% 

control efficiency since roadways are sprayed regularly to keep dust down. Particle size multiplier for PM is 0.80. 

Emission factor is 5.89 lb/VMT x (1-0.50) = 2.945 lb/VMT. Emissions estimated using the method described in 

AP-42 5th Edition, Chapter 13.2.2 and assuming a 50% control efficiency since roadways are sprayed regularly to 

keep dust down. Particle size multiplier for PM10 is 0.36. Therefore, PM10 emissions = (2.945 lb/hr)(0.36)/(0.80) 

= 1.325 lb/hr. 

 

 

 

 
Page 42 of 85 

Emission Unit Form (emission_unit.doc) 

Page 42 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 43 of 85 

Emission Unit Form (emission_unit.doc) 

Page 43 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

005-05 

Emission unit name: 

Unpaved Roads – Product 

Shipments 

List any control devices associated 

with this emission unit: 

NA 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

This emission quantifies emissions caused by vehicle traffic occurring during product shipments. 

 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

NA 

Installation date: 

NA 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): NA 

 

 

Maximum Hourly Throughput: 

NA 

Maximum Annual Throughput: 

NA 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 44 of 85 

Emission Unit Form (emission_unit.doc) 

Page 44 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 0.24 1.05 

Particulate Matter (PM10) 0.24 1.05 

Total Particulate Matter (TSP) 0.53 2.34 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 – Emissions estimated using the method described in AP-42 5th Edition, Chapter 13.2.2 and assuming a 50% 

control efficiency since roadways are sprayed regularly to keep dust down. Particle size multiplier for PM is 0.80. 

Emission factor = 5.89 lb/VMT x (1-0.50) = 2.945 lb/VMT. Particle size multiplier for PM10 is 0.36. Therefore, 

PM10 emissions = (2.945 lb/hr)(0.36)/(0.80) = 1.325 lb/hr. 

Conservatively assume PM2.5 is equal to PM10. 

TSP – Emissions estimated using the method described in AP-42 5th Edition, Chapter 13.2.2 and assuming a 50% 

control efficiency since roadways are sprayed regularly to keep dust down. Particle size multiplier for PM is 0.80. 

Emission factor is 5.89 lb/VMT x (1-0.50) = 2.945 lb/VMT. 

 

 

 

 

 

 

 

 
Page 45 of 85 

Emission Unit Form (emission_unit.doc) 

Page 45 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 46 of 85 

Emission Unit Form (emission_unit.doc) 

Page 46 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

005-06 

Emission unit name: 

Unpaved Roads – Raw Material 

Transfer 

List any control devices associated 

with this emission unit: 

NA 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

This emission unit quantifies emissions caused by vehicle traffic occurring during raw material transfer from storage 

piles to the facility by two trucks. 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

NA 

Installation date: 

NA 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): NA 

 

 

Maximum Hourly Throughput: 

NA 

Maximum Annual Throughput: 

NA 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 47 of 85 

Emission Unit Form (emission_unit.doc) 

Page 47 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 1.35 5.91 

Particulate Matter (PM10) 1.35 5.91 

Total Particulate Matter (TSP) 3.00 13.14 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 – Emissions estimated using the method described in AP-42 5th Edition, Chapter 13.2.2 and assuming a 50% 

control efficiency since roadways are sprayed regularly to keep dust down. Particle size multiplier for PM is 0.80. 

Emission factor = 0.98 lb/VMT x (1-0.50) = 0.49 lb/VMT. Particle size multiplier for PM10 is 0.36. Therefore, 

PM10 emissions = (0.49 lb/hr)(0.36)/(0.80) = 0.2205 lb/hr. 

Conservatively assume PM2.5 is equal to PM10. 

TSP – Emissions estimated using the method described in AP-42 5th Edition, Chapter 13.2.2 and assuming a 50% 

control efficiency since roadways are sprayed regularly to keep dust down. Particle size multiplier for PM is 0.80. 

Emission factor is 0.98 lb/VMT x (1-0.50) = 0.49 lb/VMT. 

 

 

 

 

 

 

 

 
Page 48 of 85 

Emission Unit Form (emission_unit.doc) 

Page 48 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 49 of 85 

Emission Unit Form (emission_unit.doc) 

Page 49 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

005-07 

Emission unit name: 

Unpaved Roads - Endloaders 

List any control devices associated 

with this emission unit: 

NA 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

This emission unit quantifies emissions caused by vehicle traffic occurring during raw material transfer by front-end 

loaders. 

 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

NA 

Installation date: 

NA 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): NA 

 

 

Maximum Hourly Throughput: 

NA 

Maximum Annual Throughput: 

NA 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 50 of 85 

Emission Unit Form (emission_unit.doc) 

Page 50 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 2.19 9.59 

Particulate Matter (PM10) 2.19 9.59 

Total Particulate Matter (TSP) 4.87 21.32 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 – Emissions estimated using the method described in AP-42 5th Edition, Chapter 13.2.2 and assuming a 50% 

control efficiency since roadways are sprayed regularly to keep dust down. Particle size multiplier for PM is 0.80. 

Emission factor = 1.59 lb/VMT x (1-0.50) = 0.795 lb/VMT. Particle size multiplier for PM10 is 0.36. Therefore, 

PM10 emissions = (0.795 lb/hr)(0.36)/(0.80) = 0.35775 lb/hr. 

Conservatively assume PM2.5 is equal to PM10. 

TSP – Emissions estimated using the method described in AP-42 5th Edition, Chapter 13.2.2 and assuming a 50% 

control efficiency since roadways are sprayed regularly to keep dust down. Particle size multiplier for PM is 0.80. 

Emission factor is 1.59 lb/VMT x (1-0.50) = 0.795 lb/VMT. 

 

 

 

 

 

 

 

 

 
Page 51 of 85 

Emission Unit Form (emission_unit.doc) 

Page 51 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

No Specific Requirement. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 52 of 85 

Emission Unit Form (emission_unit.doc) 

Page 52 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

009-01 

Emission unit name: 

Crushing and Screening System #1 

List any control devices associated 

with this emission unit: 

Baghouses 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

Crushing and Screening System #1 consists of a primary, secondary, and tertiary crushing system and screening 

operations used to size the ferroalloy according to buyer specifications prior to shipment. Emissions from this 

operation are controlled by three baghouses operating in parallel. 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

NA 

Installation date: 

NA 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): 33 tph 

 

 

Maximum Hourly Throughput: 

33 tph 

Maximum Annual Throughput: 

26,439.3 tpy 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 53 of 85 

Emission Unit Form (emission_unit.doc) 

Page 53 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 0.13 0.58 

Particulate Matter (PM10) 0.13 0.58 

Total Particulate Matter (TSP) 0.13 0.58 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 – Crushing System No. 1 which consists of four stages: primary crushing, secondary crushing, tertiary 

crushing, and screening. An emission factor was obtained for each of the two types of processes from the Ohio EPA 

Feasibility Study, “Reasonably Available Control Measures for Fugitive Dust Sources” (September 1980), Ohio 

Environmental Protection Agency, Division of Air Pollution Control. Emission factors are as follows: 

7.2 lb/ton processed for each of the crushing operations 

4.5 lb/ton for the screening operation 

Total EF = (7.2 lb/ton) x 3 + 4.5 lb/ton = 26.1 lb/ton processed. Conservatively assume all PM is PM10 and PM2.5. 

TSP - Crushing System No. 1 which consists of four stages: primary crushing, secondary crushing, tertiary 

crushing, and screening. An emission factor was obtained for each of the two types of processes from the Ohio EPA 

Feasibility Study, “Reasonably Available Control Measures for Fugitive Dust Sources” (September 1980), Ohio 

Environmental Protection Agency, Division of Air Pollution Control. Emission factors are as follows: 

7.2 lb/ton processed for each of the crushing operations 

4.5 lb/ton for the screening operation 

Total EF = (7.2 lb/ton) x 3 + 4.5 lb/ton = 26.1 lb/ton processed. Conservatively assume all PM is PM10. 

Particulate matter from this system is controlled by three baghouses in parallel. This stream represents one-third of 

the total emissions from this unit. Therefore, emission factor = (1/3) x 26.1 = 8.7 lb/ton. 
Page 54 of 85 

Emission Unit Form (emission_unit.doc) 

Page 54 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

See Pages 67 and 68 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

See Page 69 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 55 of 85 

Emission Unit Form (emission_unit.doc) 

Page 55 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

009-02 

Emission unit name: 

Crushing and Screening System #2 

List any control devices associated 

with this emission unit: 

Baghouses 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

Crushing and Screening System #2 consists of a primary, secondary, and tertiary crushing system and screening 

operations used to size the ferroalloy according to buyer specifications prior to shipment. Emissions from this 

operation are controlled by two baghouses operating in parallel. 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

NA 

Installation date: 

NA 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): 33 tph 

 

 

Maximum Hourly Throughput: 

33 tph 

Maximum Annual Throughput: 

68,742.1 tpy 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 56 of 85 

Emission Unit Form (emission_unit.doc) 

Page 56 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 0.51 2.24 

Particulate Matter (PM10) 0.51 2.24 

Total Particulate Matter (TSP) 0.51 2.24 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 – Crushing System No. 2 which consists of four stages: primary crushing, secondary crushing, tertiary 

crushing, and screening. An emission factor was obtained for each of the two types of processes from the Ohio EPA 

Feasibility Study, “Reasonably Available Control Measures for Fugitive Dust Sources” (September 1980), Ohio 

Environmental Protection Agency, Division of Air Pollution Control. Emission factors are as follows: 

7.2 lb/ton processed for each of the crushing operations 

4.5 lb/ton for the screening operation 

Total EF = (7.2 lb/ton) x 3 + 4.5 lb/ton = 26.1 lb/ton processed. Conservatively assume all PM is PM10 and PM2.5. 

Particulate matter from this system is controlled by two baghouses in parallel. This stream represents half of the 

total emissions from this unit. Therefore, emission factor = (1/2) x 16.1 = 13.05 lb/ton. 

TSP - Crushing System No. 2 which consists of four stages: primary crushing, secondary crushing, tertiary 

crushing, and screening. An emission factor was obtained for each of the two types of processes from the Ohio EPA 

Feasibility Study, “Reasonably Available Control Measures for Fugitive Dust Sources” (September 1980), Ohio 

Environmental Protection Agency, Division of Air Pollution Control. Emission factors are as follows: 

7.2 lb/ton processed for each of the crushing operations 

4.5 lb/ton for the screening operation 

Total EF = (7.2 lb/ton) x 3 + 4.5 lb/ton = 26.1 lb/ton processed. Conservatively assume all PM is PM10. 

Particulate matter from this system is controlled by two baghouses in parallel. This stream represents one-third of 

the total emissions from this unit. Therefore, emission factor = (1/2) x 26.1 = 13.05 lb/ton. 
Page 57 of 85 

Emission Unit Form (emission_unit.doc) 

Page 57 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

See Pages 67 and 68 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

See Page 69 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 58 of 85 

Emission Unit Form (emission_unit.doc) 

Page 58 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

009-03 

Emission unit name: 

Crushing and Screening System #4 

List any control devices associated 

with this emission unit: 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

Crushing and Screening System #4 consists of a primary, secondary, and tertiary crushing system and screening 

operations used to size the ferroalloy according to buyer specifications prior to shipment. Emissions from this 

operation are controlled by the MagSil Scrubber. 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

NA 

Installation date: 

NA 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): 20 tph 

 

 

Maximum Hourly Throughput: 

20 tph 

Maximum Annual Throughput: 

66,098.2 tpy 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 59 of 85 

Emission Unit Form (emission_unit.doc) 

Page 59 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 9.85 43.13 

Particulate Matter (PM10) 9.85 43.13 

Total Particulate Matter (TSP) 9.85 43.13 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 – Crushing System No. 4 which consists of four stages: primary crushing, secondary crushing, tertiary 

crushing, and screening. An emission factor was obtained for each of the two types of processes from the Ohio EPA 

Feasibility Study, “Reasonably Available Control Measures for Fugitive Dust Sources” (September 1980), Ohio 

Environmental Protection Agency, Division of Air Pollution Control. Emission factors are as follows: 

7.2 lb/ton processed for each of the crushing operations 

4.5 lb/ton for the screening operation 

Total EF = (7.2 lb/ton) x 3 + 4.5 lb/ton = 26.1 lb/ton processed. Conservatively assume all PM is PM10 and PM2.5. 

TSP - Crushing System No. 4 which consists of four stages: primary crushing, secondary crushing, tertiary 

crushing, and screening. An emission factor was obtained for each of the two types of processes from the Ohio EPA 

Feasibility Study, “Reasonably Available Control Measures for Fugitive Dust Sources” (September 1980), Ohio 

Environmental Protection Agency, Division of Air Pollution Control. Emission factors are as follows: 

7.2 lb/ton processed for each of the crushing operations 

4.5 lb/ton for the screening operation 

Total EF = (7.2 lb/ton) x 3 + 4.5 lb/ton = 26.1 lb/ton processed. Conservatively assume all PM is PM10. 

 

 
Page 60 of 85 

Emission Unit Form (emission_unit.doc) 

Page 60 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

See Pages 67 and 68 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

See Page 69 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 61 of 85 

Emission Unit Form (emission_unit.doc) 

Page 61 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

009-04 

Emission unit name: 

Crushing and Screening System #5 

List any control devices associated 

with this emission unit: 

 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

Crushing and Screening System #5 consists of a primary, secondary, and tertiary crushing system and screening 

operations used to size the ferroalloy according to buyer specifications prior to shipment. Emissions from this 

operation are controlled by the MagSil Scrubber. 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

NA 

Installation date: 

NA 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): 20 tph 

 

 

Maximum Hourly Throughput: 

20 tph 

Maximum Annual Throughput: 

5,870.3 tpy 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 62 of 85 

Emission Unit Form (emission_unit.doc) 

Page 62 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 0.88 3.84 

Particulate Matter (PM10) 0.88 3.84 

Total Particulate Matter (TSP) 0.88 3.84 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 – Crushing System No. 5 which consists of four stages: primary crushing, secondary crushing, tertiary 

crushing, and screening. An emission factor was obtained for each of the two types of processes from the Ohio EPA 

Feasibility Study, “Reasonably Available Control Measures for Fugitive Dust Sources” (September 1980), Ohio 

Environmental Protection Agency, Division of Air Pollution Control. Emission factors are as follows: 

7.2 lb/ton processed for each of the crushing operations 

4.5 lb/ton for the screening operation 

Total EF = (7.2 lb/ton) x 3 + 4.5 lb/ton = 26.1 lb/ton processed. Conservatively assume all PM is PM10 and PM2.5. 

TSP - Crushing System No. 5 which consists of four stages: primary crushing, secondary crushing, tertiary 

crushing, and screening. An emission factor was obtained for each of the two types of processes from the Ohio EPA 

Feasibility Study, “Reasonably Available Control Measures for Fugitive Dust Sources” (September 1980), Ohio 

Environmental Protection Agency, Division of Air Pollution Control. Emission factors are as follows: 

7.2 lb/ton processed for each of the crushing operations 

4.5 lb/ton for the screening operation 

Total EF = (7.2 lb/ton) x 3 + 4.5 lb/ton = 26.1 lb/ton processed. Conservatively assume all PM is PM10. 
Page 63 of 85 

Emission Unit Form (emission_unit.doc) 

Page 63 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

See Pages 67 and 68 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

See Page 69 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 64 of 85 

Emission Unit Form (emission_unit.doc) 

Page 64 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

009-06 

 

Emission unit name: 

Transfer Points 

List any control devices associated 

with this emission unit: 

NA 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

Emissions from raw material batch drops occurring both outside in the raw material storage area and inside for 

materials transferred into the building. Emissions were quantified for quartz gravel, coal, wood chips, and 

limestone. 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

NA 

Installation date: 

NA 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): 28 tph 

 

 

Maximum Hourly Throughput: 

28 tph 

Maximum Annual Throughput: 

NA 

Maximum Operating Schedule: 

8,760 hr/yr 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 65 of 85 

Emission Unit Form (emission_unit.doc) 

Page 65 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 1.58 6.93 

Particulate Matter (PM10) 1.58 6.93 

Total Particulate Matter (TSP) 1.58 6.93 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

PM10 – Emissions from raw material batch drops occurring both outside in the raw material storage area and inside 

for materials transferred into the building. Emissions were quantified for quartz gravel, coal, wood chips, and 

limestone using the method described in AP-42 5th Edition, Chapter 13.2.2. Emission factors were developed for 

each material (refer to attached spreadsheets). Conservatively assume all PM is PM10 and PM2.5. 

TSP – Emissions from raw material batch drops occurring both outside in the raw material storage area and inside 

for materials transferred into the building. Emissions were quantified for quartz gravel, coal, wood chips, and 

limestone using the method described in AP-42 5th Edition, Chapter 13.2.2. Emission factors were developed for 

each material (refer to attached spreadsheets). 
Page 66 of 85 

Emission Unit Form (emission_unit.doc) 

Page 66 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

See Pages 67 and 68 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 X Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

See Page 69 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 67 of 85 

List all applicable requirements for this emission unit. For each applicable requirement, include the underlying rule/regulatioconstruction permit with the condition number. (Note: Title V permit condition numbers alone are not the underlying applicable req

emission limit is calculated based on the type of source and design capacity or if a standard is based on a design parameter, this inform

be included.

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Requirement 

1 45CSR§§7-3.1 and 3.2 5.1.1. Opacity No person shall cause, suffer, allow or permit emission of smoke and/or particulate matter into 

process source operation which is greater than twenty (20) percent opacity, except for smoke a

emitted from any process source operation which is less than forty (40) percent opacity for 

aggregating no more than five (5) minutes in any sixty (60) minute period. 

2 45CSR§§7-4.1.(009-06) 5.1.2. PM Limits No person shall cause, suffer, allow, or permit PM to be vented into the open air from any type sour

source operation, or from all air pollution control equipment installed on any type source opera

operation in excess of the quantities specified in this permit. Emission Unit ID 009-06; Equipment Description, Transfer Points; Max. Allowable PM Emission L

3 45CSR§7-4.7.a.(009-01, 

009-02, 009-03, 009-04 and 

00A01). 

5.1.3. Opacity Type 'b' duplicate source operations whose air pollution control equipment efficiency is a minimu

(99%) by weight and whose total process weight rate is less than two hundred fifty thousand (25shall be exempted from the requirements of 45CSR§7-4.1 provided that smoke emitted into the duplicate source operation is less than twenty percent (20%) opacity. 

4 CO-R7-95-13, Condition 

7.a.10.A. and CO-R7, 13, 

16-93-1, Condition IV.9. 

5.1.4. Water Pressure 

Monitoring 

The permittee shall maintain instrumentation to continuously monitor water pressures at or near eacsuppression systems for slag crushing systems. The permittee shall repair or replace any nozzle fa

flow characteristics at anytime that the slag crushing is in operation. 

5 CO-R7-95-13, Condition 

7.a.11.B. 

5.1.5. Soderburg Paste 

Prohibition 

The permittee shall not employ soderburg paste to provide refractory lining for any ladle. 

6 CO-R7-95-13, Condition 

7.a.6.E. 

5.1.6. Repouring All ladle to ladle repouring of molten material shall be conducted with a system to minimize fugitiv

7 CO-R7-95-13, Condition 

7.a.9.A. 

5.1.7. Maintenance The permittee shall maintain the product crushing and sizing operations in good operating condition

8 CO-R7-E-2004-13, 

Condition III.3. 

5.1.8. Casting Station 

Operations 

Within sixty (60) days after restarting the facility, at least one casting station must be fully operati

be used during all casting at the facility. 

9 

40CFR§63.1652(e)(2) and 

45CSR34. 

5.1.9. 

Crushing and 

Screening 

Equipment.

Crushing and screening equipment. No owner or operator shall cause to be discharged into the atmopiece of equipment associated with crushing and screening exhaust gases containing particulate 

gr/dscf. 

10 CO-R7-95-13, 

Conditions 7.b.1.A. and B. 

5.2.1. VE The permittee shall conduct visual emission (VE) observations in accordance with Sections 3.2.1. an
Page 68 of 85 

List all applicable requirements for this emission unit. For each applicable requirement, include the underlying rule/regulation citation construction permit with the condition number. (Note: Title V permit condition numbers alone are not the underlying applicable requirem

emission limit is calculated based on the type of source and design capacity or if a standard is based on a design parameter, this informa

be included.

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Requirement 

11 40CFR§§63.1656(c)(1), (3)(i) 

and 45CSR34 

5.3.1. Compliance 

Demonstration 

with the Emission 

Standards 

Compliance demonstration with the emission standards. 

a. The owner or operator must conduct an initial performance test for air pollution control devices o

Section 5.1.9. of this permit to demonstrate compliance with the applicable emission standards. b. Following development, and approval, if required, of the site-specific test plan, the owner or oper

performance test for each air pollution control device or vent stack to measure particulate matter and with the applicable standard. An owner or operator of sources subject to the particulate matter concentration standards in Sectmust determine the particulate matter concentration using Method 5 or 5D, as applicable. Complianaverage concentration for the three runs comprising the performance test does not exceed the standa

12 CO-R7-95-13, 

Conditions 7.b.3. 

5.4.1. VE Records of the visible emission checks conducted in accordance with Section 5.2.1. of this perm

accordance with Section 3.2.2. of this permit. 

13 CO-R7-95-13, 

Condition 7.b.2.c. 

5.4.2. Recordkeeping The permittee shall record on a daily basis the hours of operation and gallons of water used in opera

plant. 
Page 69 of 85 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall be used to demonstrate method is based on a permit or rule, include the condition number or citation. (Note: Each requirement listed above must have an as

demonstrating compliance. If there is not already a required method in place, then a method must be proposed.)

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Method of Compliance 

1 45CSR§§7-3.1 and 3.2 5.1.1. Opacity Conduct opacity testing as required. 2 45CSR§§7-4.1.(009-06) 5.1.2. PM Limits Stack testing or opacity testing as required. 3 45CSR§7-4.7.a.(009-01, 

009-02, 009-03, 009-04 and 

00A01). 

5.1.3. Opacity Stack testing or opacity testing as required. 

4 CO-R7-95-13, Condition 

7.a.10.A. and CO-R7, 13, 

16-93-1, Condition IV.9. 

5.1.4. Water Pressure 

Monitoring 

Maintain instrumentation to continuously monitor water pressure for wet suppression system. 

5 CO-R7-95-13, Condition 

7.a.11.B. 

5.1.5. Soderburg Paste 

Prohibition 

NA 

6 CO-R7-95-13, Condition 

7.a.6.E. 

5.1.6. Repouring NA 

7 CO-R7-95-13, Condition 

7.a.9.A. 

5.1.7. Maintenance NA 

8 CO-R7-E-2004-13, 

Condition III.3. 

5.1.8. Casting Station 

Operations 

NA 

9 

40CFR§63.1652(e)(2) and 

45CSR34. 

5.1.9. 

Crushing and 

Screening 

Equipment 

Conduct testing as required. 

10 CO-R7-95-13, 

Conditions 7.b.1.A. and B. 

5.2.1. VE Conduct VE observations as required. 

11 40CFR§§63.1656(c)(1), (3)(i) 

and 45CSR34 

5.3.1. Compliance 

Demonstration 

with the Emission 

Standards 

Conduct testing as required. 

12 CO-R7-95-13, 

Conditions 7.b.3. 

5.4.1. VE Maintain records of VE observations. 

13 CO-R7-95-13, 

Condition 7.b.2.c. 

5.4.2. Recordkeeping Record hours of operation and gallons of water used in slag crushing operations. 
Page 70 of 85 

Emission Unit Form (emission_unit.doc) 

Page 70 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

Various (See Below Description) 

Emission unit name: 

Portable Screener/Crusher 

List any control devices associated 

with this emission unit: 

Various 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

Track mounted portable screener/crusher with emission units I.D. (Emission Point I.D.) SC-1C (SC-1CE) Grizzly 

Feeder, BC-1C (T3C) Screen Reject Belt Conveyor, CR-1C (009-03) Jaw Crusher, BC-2C (T6C) Belt Conveyor, 

OS-1C (OS-1CE) Unsized Stockpile, and OS-2C (OS-2CE) Sized Stockpile. 

 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

Proposed 

Installation date: 

Proposed

Modification date(s): 

NA

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): 400 tph 

Maximum Hourly Throughput: 

400 tph 

Maximum Annual Throughput: 

90,000 tpy 

Maximum Operating Schedule: 

8,760 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? X Yes ____ No 

 Engine 

If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

No. 2 Fuel 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 71 of 85 

Emission Unit Form (emission_unit.doc) 

Page 71 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 34.89 3.95 

Particulate Matter (PM10) 34.89 3.95 

Total Particulate Matter (TSP) 73.7 8.37 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

Emission factor of 0.5 lb/ton for crushing and screening and AP-42 for transfer points and open stockpiles. 

Conservatively assume PM2.5 is equal to PM10. 
Page 72 of 85 

Emission Unit Form (emission_unit.doc) 

Page 72 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

See Pages 79 to 82 

 

 

 

 

 

 

 

 Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

See Pages 83 to 85 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 73 of 85 

Emission Unit Form (emission_unit.doc) 

Page 73 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

EX-1 with OS-1X 

Emission unit name: 

Extruder Unit 

List any control devices associated 

with this emission unit: 

FE/N 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

Extruder Unit EX-1 (EX-1E) with Briguette Stockpile OS-1X (OS-1XE) of 5,000 sq. ft. 

 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

Proposed 

Installation date: 

Proposed

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): 20 tph 

Maximum Hourly Throughput: 

20 tph 

Maximum Annual Throughput: 

10,000 

Maximum Operating Schedule: 

8,760 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 74 of 85 

Emission Unit Form (emission_unit.doc) 

Page 74 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 0.88 0.17 

Particulate Matter (PM10) 0.88 0.17 

Total Particulate Matter (TSP) 1.85 0.36 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

AP-42 for transfer points and stockpiles. 

Conservatively assume PM2.5 is equal to PM10. 
Page 75 of 85 

Emission Unit Form (emission_unit.doc) 

Page 75 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

See Pages 79 to 82 

 

 

 

 

 

 

 

 Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

See Pages 83 to 85 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 76 of 85 

Emission Unit Form (emission_unit.doc) 

Page 76 of 85 

Revised – 07/31/07

ATTACHMENT E - Emission Unit Form

Emission Unit Description

Emission unit ID number: 

PT-1 with OS-1P 

Emission unit name: 

Pelletizing Unit 

List any control devices associated 

with this emission unit: 

FE/N 

Provide a description of the emission unit (type, method of operation, design parameters, etc.): 

Pelletizing Unit PT-1 (PT-1E) with Pellet Stockpile OS-1P (OS-1PE) of 5,000 sq. ft. 

Manufacturer: 

NA 

Model number: 

NA 

Serial number: 

NA 

Construction date: 

2010 

Installation date: 

2010 

Modification date(s): 

NA 

Design Capacity (examples: furnaces - tons/hr, tanks - gallons): 6 tph 

Maximum Hourly Throughput: 

6 tph 

Maximum Annual Throughput: 

10,000 tpy 

Maximum Operating Schedule: 

8,760 

Fuel Usage Data (fill out all applicable fields)

Does this emission unit combust fuel? ___Yes X No If yes, is it? 

___ Indirect Fired ___Direct Fired 

Maximum design heat input and/or maximum horsepower rating: 

 

 

Type and Btu/hr rating of burners: 

 

 

 

List the primary fuel type(s) and if applicable, the secondary fuel type(s). For each fuel type listed, provide 

the maximum hourly and annual fuel usage for each. 

 

 

 

 

 

Describe each fuel expected to be used during the term of the permit.

Fuel Type Max. Sulfur Content Max. Ash Content BTU Value 

 

 

 

 
Page 77 of 85 

Emission Unit Form (emission_unit.doc) 

Page 77 of 85 

Revised – 07/31/07

Emissions Data

Criteria Pollutants Potential Emissions 

PPH TPY 

Carbon Monoxide (CO) 

Nitrogen Oxides (NOX) 

Lead (Pb) 

Particulate Matter (PM2.5) 0.191 0.032 

Particulate Matter (PM10) 0.191 0.032 

Total Particulate Matter (TSP) 0.404 0.074 

Sulfur Dioxide (SO2) 

Volatile Organic Compounds (VOC) 

Hazardous Air Pollutants Potential Emissions 

PPH TPY 

 

 

 

Regulated Pollutants other than Potential Emissions 

Criteria and HAP 

PPH TPY 

 

 

List the method(s) used to calculate the potential emissions (include dates of any stack tests conducted, 

versions of software used, source and dates of emission factors, etc.). 

AP-42 for transfer points and stockpiles. 

Conservatively assume PM2.5 is equal to PM10. 
Page 78 of 85 

Emission Unit Form (emission_unit.doc) 

Page 78 of 85 

Revised – 07/31/07

Applicable Requirements

List all applicable requirements for this emission unit. For each applicable requirement, include the 

underlying rule/regulation citation and/or construction permit with the condition number. (Note: Title V 

permit condition numbers alone are not the underlying applicable requirements). If an emission limit is 

calculated based on the type of source and design capacity or if a standard is based on a design parameter, 

this information should also be included. 

See Pages 79 to 82 

 

 

 

 

 

 

 

 Permit Shield 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall 

be used to demonstrate compliance. If the method is based on a permit or rule, include the condition number 

or citation. (Note: Each requirement listed above must have an associated method of demonstrating 

compliance. If there is not already a required method in place, then a method must be proposed.) 

See Pages 83 to 85 

Are you in compliance with all applicable requirements for this emission unit? X Yes ___No 

If no, complete the Schedule of Compliance Form as ATTACHMENT F. 
Page 79 of 85 

List all applicable requirements for this emission unit. For each applicable requirement, include the underlying rule/regulatioconstruction permit with the condition number. (Note: Title V permit condition numbers alone are not the underlying applicable req

emission limit is calculated based on the type of source and design capacity or if a standard is based on a design parameter, this inform

be included.

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Requirement 

1 45CSR13, R13-2857, 

Condition 4.1.1. 

6.1.1. PM Limits Emissions from the operations covered under this permit shall not exceed the following: 

 PM/Mn Compounds PM10/Mn Compo

 lb/hr TPY lb/hr Crushing 21.8 2.45 10.31 Screening 21.8 2.45 10.31 Pelletizer 0.01 0.01 0.01 Extruder 0.39 0.10 0.18 Transfer Points 29.0 3.32 13.71 Stockpiles 3.36 0.61 1.59 Total 76.36 8.94 36.11 

2 45CSR13, R13-2857, 

Condition 4.1.2. 

6.1.2. Operating Rate 

Limit 

Total combined throughput of material into the Crusher CR-1C shall not exceed 400 tons per hour Compliance with this limit shall be based on a 12 month rolling total. For the purposes of this pe

total means the sum of material throughput at the end of any given month for the previous 12 month

3 45CSR13, R13-2857, 

Condition 4.1.3. 

6.1.3. Operating Rate 

Limit 

Total combined throughput of material into the Screen SC-1C shall not exceed 400 tons per hour n

Compliance with this limit shall be based on a 12 month rolling total. 

4 45CSR13, R13-2857, 

Condition 4.1.4. 

6.1.4. Operating Rate 

Limit 

Total combined throughput of material into the Extruder EX-1 shall not exceed 20 tons per hour nCompliance with this limit shall be based on a 12 month rolling total. 

5 45CSR13, R13-2857, 

Condition 4.1.5. 

6.1.5. Operating Rate 

Limit 

Total combined throughput of material into the Pelletizer PT-1 shall not exceed 6 tons per hour nCompliance with this limit shall be based on a 12 month rolling total. 

6 45CSR13, R13-2857, 

Condition 4.1.6. 

6.1.6. Stockpile Size 

Limit 

The base area of stockpile OS-1C shall not exceed 5,000 sq. ft. 

7 45CSR13, R13-2857, 

Condition 4.1.7. 

6.1.7. Stockpile Size 

Limit 

The base area of stockpile OS-2C shall not exceed 5,000 sq. ft. 

8 45CSR13, R13-2857, 

Condition 4.1.8. 

6.1.8. Stockpile Size 

Limit 

The base area of stockpile OS-1X shall not exceed 5,000 sq. ft. 

9 45CSR13, R13-2857, 

Condition 4.1.9. 

6.1.9. Stockpile Size Limit The base area of stockpile OS-1P shall not exceed 5,000 sq. ft. 

10 45CSR13, R13-2857, 

Condition 4.1.10. 

6.1.10. Control 

Requirement 

Emissions from Crusher CR-1C and Screen SC-1C shall be controlled by use of a baghouse. 

designed, installed, operated and maintained so as to achieve a minimum overall efficiency of at lea

11 45CSR13, R13-2857, 

Condition 4.1.11. 

6.1.11. Control 

Requirement 

The following transfer points shall be controlled by enclosures:T1C, T2C, T4C, T7C, T1P, T3P, T1X 

12 45CSR13, R13-2857, 

Condition 4.1.12. 

6.1.12. Control 

Requirement 

Transfer points T3C and T6C shall be controlled by water sprays 
Page 80 of 85 

List all applicable requirements for this emission unit. For each applicable requirement, include the underlying rule/regulatioconstruction permit with the condition number. (Note: Title V permit condition numbers alone are not the underlying applicable req

emission limit is calculated based on the type of source and design capacity or if a standard is based on a design parameter, this inform

be included.

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Requirement 

13 45CSR13, R13-2857, 

Condition 4.1.13. 

6.1.13. Control 

Requirement 

Transfer point T5C shall be controlled by both an enclosure and water sprays. 

14 45CSR§7-3.1, 45CSR§7-3.2, 

and 45CSR13, R13-2857, 

Condition 4.1.14. 

6.1.14. Opacity Opacity from any process source operation shall not exceed 20% except for opacity which is less 

periods aggregating no more than 5 minutes in any 60 minute period. 

15 45CSR16, 40CFR§§60.672(a) 

and (b), and 45CSR13-2857, 

Condition 4.1.16. 

6.1.15. 40CFR60 

Subpart OOO 

When processing limestone, the permittee shall comply with all applicable standards of 40 CFR Parincluding but not limited to the following: a. The Crusher CR-1C and Screen SC-1C must both meet a PM limit of 0.014 grain/dscf. b. The transfer points associated with belts BC-1C and BC-2C must meet an opacity limit of 7%. 

16 45CSR34, 

40CFR§63.1652(e)(1) and 

45CSR13, R13-2857, 

Condition 4.1.17. 

6.1.16. 40CFR63 

Subpart XXX 

When not processing limestone, the permittee shall comply with all applicable standards of 40 CFR including Sections 3.1.14., 3.1.15. 3.1.16. of this permit and the following: No owner or operator shall cause to be discharged into the atmosphere from any new or reconstru

associated with crushing and screening exhaust gases containing particulate matter in excess of 50 m

17 45CSR§13-5.11. and 

45CSR13, R13-2857, 

Condition 4.1.18. (Baghouses 

to SC-1C and CR-1C; Water 

sprays to BC-1C, BC-2C, 

OS-1C, and OS-2C, Full 

enclosures on EX-1 and PT-1) 

6.1.17. Operation and 

Maintenance of 

Air Pollution 

Control 

Equipment 

Operation and Maintenance of Air Pollution Control Equipment. The permittee shall, to the exmaintain, and operate all pollution control equipment permitted by R13-2857, and associated mo

manner consistent with safety and good air pollution control practices for minimizing emissions, ostringent limits set forth in this permit or as set forth by any State rule, Federal regulation, or approved by the Secretary. 

18 45CSR16, 40CFR§§ 

60.675(b)(1) and (b)(2) and 

45CSR13, R13-2857, 

Condition 4.2.1. 

6.2.1. Testing 

Requirement 

The permittee shall comply with all applicable testing requirements of 40 CFR Part 60, Subpart OO

limited to the following: The owner or operator shall determine compliance with the PM standards in Section 6.1.15.a. as folla. Except as specified in 40 CFR §§ 60.675(e)(3) and (4), Method 5 of Appendix A3 of this part or M

A6 of this part shall be used to determine the particulate matter concentration. The sample volume sdscm (60 dscf). For Method 5 (40 CFR part 60, Appendix A3), if the gas stream being sampled is at 

the sampling probe and filter may be operated without heaters. If the gas stream is above ambient teprobe and filter may be operated at a temperature high enough, but no higher than 121EC (250EF), 

condensation on the filter. b. Method 9 of Appendix A4 of this part and the procedures in 40 CFR § 60.11 shall be used to dete

19 

45CSR34, 40CFR§ 

63.1656(c)(1) and 45CSR13, 

R13-2857, Condition 4.2.2. 

6.2.2. Testing Requirement 

The permittee shall comply with all applicable standards of 40 CFR Part 63, Subpart XXX including 

following: The owner or operator must conduct an initial performance test for air pollution control devices Section 6.1.16. of this permit to demonstrate compliance with the applicable emission standards. 
Page 81 of 85 

List all applicable requirements for this emission unit. For each applicable requirement, include the underlying rule/regulatioconstruction permit with the condition number. (Note: Title V permit condition numbers alone are not the underlying applicable req

emission limit is calculated based on the type of source and design capacity or if a standard is based on a design parameter, this inform

be included.

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Requirement 

20 45CSR13, R13-2857, 

Condition 4.3.2. (Baghouses to SC-1C and CR-1C; Water sprays to BC-1C, BC-2C, 

OS-1C, and OS-2C, Full 

enclosures on EX-1 and PT-1) 

6.3.1. Record of 

Maintenance of 

Air Pollution 

Control 

Equipment 

Record of Maintenance of Air Pollution Control Equipment. For all pollution control equipment per

permittee shall maintain accurate records of all required pollution control equipment inspect

maintenance procedures. 

21 45CSR13, R13-2857, 

Condition 4.3.3. (Baghouses to 

SC-1C and CR-1C; Water 

sprays to BC-1C, BC-2C, 

OS-1C, and OS-2C, Full 

enclosures on EX-1 and PT-1) 

6.3.2. Record of 

Malfunctions of 

Air Pollution 

Control 

Equipment 

Record of Malfunctions of Air Pollution Control Equipment. For all air pollution control equipment the permittee shall maintain records of the occurrence and duration of any malfunction or operationa

pollution control equipment during which excess emissions occur. For each such case, the following 

recorded: a. The equipment involved. b. Steps taken to minimize emissions during the event. c. The duration of the event. d. The estimated increase in emissions during the event. For each such case associated with an equipment malfunction, the additional information shall also b

e. The cause of the malfunction. f. Steps taken to correct the malfunction. g. Any changes or modifications to equipment or procedures that would help prevent future recurren

22 45CSR16, 40CFR§§ 60.674(b) 

and (c), and 45CSR13, 

R13-2857, Condition 4.3.4. 

6.3.3. 40CFR60 

Subpart OOO 

Monitoring and 

Recordkeeping 

The permittee shall comply with all applicable monitoring and recordkeeping requirements of 40 CFOOO including but not limited to the following: The owner or operator of any affected facility for which construction, modification, or reconstru

after April 22, 2008, that uses wet suppression to control emissions from the affected facility must pinspections to check that water is flowing to discharge spray nozzles in the wet suppression system

must initiate corrective action within 24 hours and complete corrective action as expediently as operator finds that water is not flowing properly during an inspection of the water spray nozzlesmust record each inspection of the water spray nozzles, including the date of each inspection an

taken, in the logbook required under Section 6.4.1. Except as specified in 40 CFR §§ 60.674(d) or (of any affected facility for which construction, modification, or reconstruction commenced on or a

uses a baghouse to control emissions must conduct quarterly 30-minute visible emissions inspection(40 CFR part 60, Appendix A7). The Method 22 (40 CFR part 60, Appendix A7) test shall be conduis operating. The test is successful if no visible emissions are observed. If any visible emissions aroperator of the affected facility must initiate corrective action within 24 hours to return the baghoThe owner or operator must record each Method 22 (40 CFR part 60, Appendix A7) test, inccorrective actions taken, in the logbook required under Section 6.4.1. The owner or operator of 

establish a different baghouse-specific success level for the visible emissions test (other than nconducting a PM performance test according to 40 CFR § 60.675(b) simultaneously with a Meth

Appendix A7) to determine what constitutes normal visible emissions from that affected facility'compliance with the applicable PM concentration limit in Table 2 of this subpart. The revised vlevel must be incorporated into the permit for the affected facility.
Page 82 of 85 

List all applicable requirements for this emission unit. For each applicable requirement, include the underlying rule/regulation citation construction permit with the condition number. (Note: Title V permit condition numbers alone are not the underlying applicable requirem

emission limit is calculated based on the type of source and design capacity or if a standard is based on a design parameter, this informa

be included.

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Requirement 

23 45CSR34, 40CFR§ 

63.1657(a)(1) and 45CSR13, 

R13-2857, Condition 4.3.5. 

6.3.4. 40CFR63 

Subpart XXX 

Monitoring and 

Recordkeeping 

The permittee shall comply with all applicable monitoring and recordkeeping requirements of 40 CFXXX including Sections 3.2.1., 3.2.3., 3.4.5. and the following: For the baghouses serving the submerged arc furnaces, the metal oxygen refining process, and operations, the owner or operator must observe on a daily basis for the presence of any visible emiss

24 45CSR13, R13-2857, 

Condition 4.3.6. 

6.3.5. Monitoring and 

Recordkeeping 

In order to determine compliance with sections 6.1.2. and 6.1.3. of this permit the permittee shalamount of material processed through the screen SC-1C on a monthly basis.

25 45CSR13, R13-2857, 

Condition 4.3.7. 

6.3.6. Monitoring and 

Recordkeeping 

In order to determine compliance with section 6.1.4. of this permit the permittee shall monitor amaterial processed through the Extruder EX-1 on a monthly basis.

26 45CSR13, R13-2857, 

Condition 4.3.8. 

6.3.7. Monitoring and 

Recordkeeping 

In order to determine compliance with section 6.1.5. of this permit the permittee shall monitor amaterial processed through the Pelletizer PT-1 on a monthly basis.

27 45CSR16, 40CFR§ 

60.676(b)(1), and 45CSR13, 

R13-2857, Condition 4.4.1. 

6.4.1. 40CFR60 

Subpart OOO 

Monitoring and 

Recordkeeping 

The permittee shall comply with all applicable monitoring and recordkeeping requirements of 4OOO. Owners or operators of affected facilities for which construction, modification, or reconstru

after April 22, 2008, must record each periodic inspection required under Section 6.3.3., including actions taken, in a logbook (in written or electronic format). The owner or operator must keep the l

hard or electronic copies (whichever is requested) of the logbook available to the Administrator upo

28 45CSR13, R13-2857, 

Condition 4.4.2. 

6.4.2. 40CFR63 

Subpart XXX 

The permittee shall comply with all applicable monitoring and recordkeeping requirements of 40CFincluding Sections 3.5.13., 3.5.14., and 3.5.15. of this permit.
Page 83 of 85 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall be used to demonstrate method is based on a permit or rule, include the condition number or citation. (Note: Each requirement listed above must have an as

demonstrating compliance. If there is not already a required method in place, then a method must be proposed.)

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Method of Compliance 

1 45CSR13, R13-2857, 

Condition 4.1.1. 

6.1.1. PM Limits NA 

2 45CSR13, R13-2857, 

Condition 4.1.2. 

6.1.2. Operating Rate 

Limit 

12 Month Rolling Total Recordkeeping 

3 45CSR13, R13-2857, 

Condition 4.1.3. 

6.1.3. Operating Rate 

Limit 

12 Month Rolling Total Recordkeeping 

4 45CSR13, R13-2857, 

Condition 4.1.4. 

6.1.4. Operating Rate 

Limit 

12 Month Rolling Total Recordkeeping 

5 45CSR13, R13-2857, 

Condition 4.1.5. 

6.1.5. Operating Rate 

Limit 

12 Month Rolling Total Recordkeeping 

6 45CSR13, R13-2857, 

Condition 4.1.6. 

6.1.6. Stockpile Size 

Limit 

NA 

7 45CSR13, R13-2857, 

Condition 4.1.7. 

6.1.7. Stockpile Size 

Limit 

NA 

8 45CSR13, R13-2857, 

Condition 4.1.8. 

6.1.8. Stockpile Size 

Limit 

NA 

9 45CSR13, R13-2857, 

Condition 4.1.9. 

6.1.9. Stockpile Size Limit NA 

10 45CSR13, R13-2857, 

Condition 4.1.10. 

6.1.10. Control 

Requirement 

NA 

11 45CSR13, R13-2857, 

Condition 4.1.11. 

6.1.11. Control 

Requirement 

NA 

12 45CSR13, R13-2857, 

Condition 4.1.12. 

6.1.12. Control 

Requirement 

NA 

13 45CSR13, R13-2857, 

Condition 4.1.13. 

6.1.13. Control 

Requirement 

NA 

14 45CSR§7-3.1, 45CSR§7-3.2, 

and 45CSR13, R13-2857, 

Condition 4.1.14. 

6.1.14. Opacity Conduct opacity testing as required and maintain records. 

15 45CSR16, 40CFR§§60.672(a) 

and (b), and 45CSR13-2857, 

Condition 4.1.16. 

6.1.15. 40CFR60 

Subpart OOO 

Conduct testing and opacity testing as required and maintain records. 
Page 84 of 85 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall be used to demonstrate method is based on a permit or rule, include the condition number or citation. (Note: Each requirement listed above must have an as

demonstrating compliance. If there is not already a required method in place, then a method must be proposed.)

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Method of Compliance 

16 45CSR34, 

40CFR§63.1652(e)(1) and 

45CSR13, R13-2857, 

Condition 4.1.17. 

6.1.16. 40CFR63 

Subpart XXX 

Conduct testing and opacity testing as required and maintain records. 

17 45CSR§13-5.11. and 

45CSR13, R13-2857, 

Condition 4.1.18. (Baghouses 

to SC-1C and CR-1C; Water 

sprays to BC-1C, BC-2C, 

OS-1C, and OS-2C, Full 

enclosures on EX-1 and PT-1) 

6.1.17. Operation and 

Maintenance of 

Air Pollution 

Control 

Equipment 

NA 

18 45CSR16, 40CFR§§ 

60.675(b)(1) and (b)(2) and 

45CSR13, R13-2857, 

Condition 4.2.1. 

6.2.1. Testing 

Requirement 

Conduct 40CFR60, Subpart OOO testing as required and maintain records. 

19 45CSR34, 40CFR§ 

63.1656(c)(1) and 45CSR13, 

R13-2857, Condition 4.2.2. 

6.2.2. Testing Requirement Conduct 40CFR63, Subpart XXX testing as required and maintain records. 

20 45CSR13, R13-2857, 

Condition 4.3.2. (Baghouses to SC-1C and CR-1C; Water sprays to BC-1C, BC-2C, 

OS-1C, and OS-2C, Full 

enclosures on EX-1 and PT-1) 

6.3.1. Record of 

Maintenance of 

Air Pollution 

Control 

Equipment 

Maintain record of maintenance on air pollution control equipment. 

21 45CSR13, R13-2857, 

Condition 4.3.3. (Baghouses to 

SC-1C and CR-1C; Water 

sprays to BC-1C, BC-2C, 

OS-1C, and OS-2C, Full 

enclosures on EX-1 and PT-1) 

6.3.2. Record of 

Malfunctions of 

Air Pollution 

Control 

Equipment 

Maintain a record of malfunctions of air pollution control equipment. 

22 45CSR16, 40CFR§§ 60.674(b) 

and (c), and 45CSR13, 

R13-2857, Condition 4.3.4. 

6.3.3. 40CFR60 

Subpart OOO 

Monitoring and 

Recordkeeping 

40CFR60, Subpart OOO monitoring and recordkeeping. 

23 45CSR34, 40CFR§ 

63.1657(a)(1) and 45CSR13, 

R13-2857, Condition 4.3.5. 

6.3.4. 40CFR63 

Subpart XXX 

Monitoring and 

Recordkeeping 

40CFR63, Subpart XXX monitoring and recordkeeping. 
Page 85 of 85 

For all applicable requirements listed above, provide monitoring/testing/recordkeeping/reporting which shall be used to demonstrate method is based on a permit or rule, include the condition number or citation. (Note: Each requirement listed above must have an as

demonstrating compliance. If there is not already a required method in place, then a method must be proposed.)

No. Rule/ Regulation/ R13 Permit 

Existing 

R30 

Permit 

Condition 

Name Method of Compliance 

24 45CSR13, R13-2857, 

Condition 4.3.6. 

6.3.5. Monitoring and 

Recordkeeping 

Monitor and record monthly throughput of SC-1C. 

25 45CSR13, R13-2857, 

Condition 4.3.7. 

6.3.6. Monitoring and 

Recordkeeping 

Monitor and record monthly throughput of EX-1.

26 45CSR13, R13-2857, 

Condition 4.3.8. 

6.3.7. Monitoring and 

Recordkeeping 

Monitor and record monthly throughput of PT-1.

27 45CSR16, 40CFR§ 

60.676(b)(1), and 45CSR13, 

R13-2857, Condition 4.4.1. 

6.4.1. 40CFR60 

Subpart OOO 

Monitoring and 

Recordkeeping 

40CFR60, Subpart OOO monitoring and recordkeeping. 

28 45CSR13, R13-2857, 

Condition 4.4.2. 

6.4.2. 40CFR63 

Subpart XXX 

40CFR63, Subpart XXX monitoring and recordkeeping. 
ATTACHMENT F 

SCHEDULE OF COMPLIANCE 
Schedule of Compliance Form (compliance_schedule.doc) 

Page 1 of 1 

Revised – 8/18/04

F1 of F1 

ATTACHMENT F - Schedule of Compliance Form

Complete this section if you indicated noncompliance with any of the applicable requirements identified in the 

permit application. For each emission unit which is not in compliance, identify the applicable requirement, the 

reason(s) for noncompliance, a description of how the source will achieve compliance, and a detailed schedule of 

compliance. If there is a consent order that applies to this requirement, attach a copy to this form. 

1. Applicable Requirement 5.1.8 (Use Casting Station), 3.2.3 (Monitor Pressure Drop in Baghouse) 

Unit(s): Casting Station and Baghouses 

 

 

Applicable Requirement: 5.1.8 and 3.2.3 

 

 

2. Reason for Noncompliance: 

 

Casting without using the casting station due to operational issues with the casting station. 

Pressure gauges not on baghouse for Crushing System No. 1. 

 

3. How will Compliance be Achieved? 

 

See CO-R34-E-2011-05 Appendix A – Schedule for Compliance (Attached) 

 

4. Consent Order Number (if applicable): CO-R34-E-2011-05

 

5. Schedule of Compliance. Provide a schedule of remedial measures, including an enforceable sequence of 

actions with milestones, leading to compliance, including a date for final compliance.

Remedial Measure or Action Date to be Achieved 

See Attached 

 

 

 

6. Submittal of Progress Reports. None

Content of Progress Report: 

 

 None 

Report starting date: None 

Submittal frequency: None 


ATTACHMENT G 

AIR POLLUTION CONTROL DEVICE FORMS 
Air Pollution Control Device Form (control_device.doc) 

Page 1 of 9 

Revised – 01/31/07

Page 1 of 9 

ATTACHMENT G - Air Pollution Control Device Form

Control device ID number: 

 000A 

List all emission units associated with this control device. 

Crushing Operations 

 

Manufacturer: 

Joy Manufacturing Company 

 

Model number: 

 NA 

Installation date: 

1982 

Type of Air Pollution Control Device: 

___ Baghouse/Fabric Filter ___ Venturi Scrubber ___ Multiclone 

___ Carbon Bed Adsorber ___ Packed Tower Scrubber ___ Single Cyclone 

___ Carbon Drum(s) X Other Wet Scrubber ___ Cyclone Bank 

___ Catalytic Incinerator ___ Condenser ___ Settling Chamber 

___ Thermal Incinerator ___ Flare ___ Other (describe) ________________ 

___ Wet Plate Electrostatic Precipitator ___ Dry Plate Electrostatic Precipitator 

List the pollutants for which this device is intended to control and the capture and control efficiencies. 

Pollutant Capture Efficiency Control Efficiency 

PM10 100 95 

TSP 100 95 

Metals 100 95 

 

Explain the characteristic design parameters of this control device (flow rates, pressure drops, number of 

bags, size, temperatures, etc.). 

Scrubber is a low-pressure impingement-type scrubber used to control the dust generated from the magnesiumsilicon (magsil) ferroalloy crushing operations. Plant personnel estimate the control efficiency to be 99 percent. 

A control efficiency of 95 percent has conservatively been assumed. 

The liquid recirculation of the scrubber is 90 gpm and the wastewater blowdown rate is 10 gpm. 

Pressure Drop – 6 to 10 inches of H2), Gas temp – 68 degrees F 

 

Is this device subject to the CAM requirements of 40 C.F.R. 64? ___ Yes X No 

If Yes, Complete ATTACHMENT H 

If No, Provide justification. 

 

Describe the parameters monitored and/or methods used to indicate performance of this control device. 

 

Recirculation rate 

 

 

 

 

 

 
Air Pollution Control Device Form (control_device.wpd) 

Page 2 of 9 

Revised - 3/1/04

Page 2 of 9 

ATTACHMENT G - Air Pollution Control Device Form

Control device ID number: 

000D 

List all emission units associated with this control device. 

Crusher System No. 1 

 

Manufacturer: 

Wheelabrator 

 

Model number: 

 NA 

Installation date: 

1952 

Type of Air Pollution Control Device: 

 X Baghouse/Fabric Filter ___ Venturi Scrubber ___ Multiclone 

___ Carbon Bed Adsorber ___ Packed Tower Scrubber ___ Single Cyclone 

___ Carbon Drum(s) ___ Other Wet Scrubber ___ Cyclone Bank 

___ Catalytic Incinerator ___ Condenser ___ Settling Chamber 

___ Thermal Incinerator ___ Flare ___ Other (describe) ________________ 

___ Wet Plate Electrostatic Precipitator ___ Dry Plate Electrostatic Precipitator 

List the pollutants for which this device is intended to control and the capture and control efficiencies. 

Pollutant Capture Efficiency Control Efficiency 

PM10 100 99.5 

TSP 100 99.5 

Metals 100 99.5 

 

Explain the characteristic design parameters of this control device (flow rates, pressure drops, number of 

bags, size, temperatures, etc.). 

This control device represents one of three baghouses operating parallel to one another. 

Pressure Drop – 3 to 7 inches of H20 

Flow rate – 8,000 scfm 

Gas temp – 70 degrees F 

 

 

Is this device subject to the CAM requirements of 40 C.F.R. 64? ___ Yes X No 

If Yes, Complete ATTACHMENT H 

If No, Provide justification. 

 

Describe the parameters monitored and/or methods used to indicate performance of this control device. 

 

Pressure Drop 

 

 

 

 

 

 
Air Pollution Control Device Form (control_device.doc) 

Page 3 of 9 

Revised – 01/31/07

 Page 3 of 9 

ATTACHMENT G - Air Pollution Control Device Form

Control device ID number: 

000E 

List all emission units associated with this control device. 

Crusher System No. 1 

 

Manufacturer: 

American Air Filter 

 

Model number: 

 NA 

Installation date: 

1952 

Type of Air Pollution Control Device: 

 X Baghouse/Fabric Filter ___ Venturi Scrubber ___ Multiclone 

___ Carbon Bed Adsorber ___ Packed Tower Scrubber ___ Single Cyclone 

___ Carbon Drum(s) ___ Other Wet Scrubber ___ Cyclone Bank 

___ Catalytic Incinerator ___ Condenser ___ Settling Chamber 

___ Thermal Incinerator ___ Flare ___ Other (describe) ________________ 

___ Wet Plate Electrostatic Precipitator ___ Dry Plate Electrostatic Precipitator 

List the pollutants for which this device is intended to control and the capture and control efficiencies. 

Pollutant Capture Efficiency Control Efficiency 

PM10 100 99.5 

TSP 100 99.5 

Metals 100 99.5 

 

Explain the characteristic design parameters of this control device (flow rates, pressure drops, number of 

bags, size, temperatures, etc.). 

This control device represents one of three baghouses operating parallel to one another. 

 

 

 

 

 

Is this device subject to the CAM requirements of 40 C.F.R. 64? ___ Yes X No 

If Yes, Complete ATTACHMENT H 

If No, Provide justification. 

 

Describe the parameters monitored and/or methods used to indicate performance of this control device. 

Pressure Drop 

 

 

 

 

 

 

 
Air Pollution Control Device Form (control_device.wpd) 

Page 4 of 9 

Revised - 3/1/04

Page 4 of 9 

ATTACHMENT G - Air Pollution Control Device Form

Control device ID number: 

000F 

List all emission units associated with this control device. 

Crusher System No. 2 

 

Manufacturer: 

 American Air Filter 

 

Model number: 

 NA 

Installation date: 

1980 

Type of Air Pollution Control Device: 

 X Baghouse/Fabric Filter ___ Venturi Scrubber ___ Multiclone 

___ Carbon Bed Adsorber ___ Packed Tower Scrubber ___ Single Cyclone 

___ Carbon Drum(s) ___ Other Wet Scrubber ___ Cyclone Bank 

___ Catalytic Incinerator ___ Condenser ___ Settling Chamber 

___ Thermal Incinerator ___ Flare ___ Other (describe) ________________ 

___ Wet Plate Electrostatic Precipitator ___ Dry Plate Electrostatic Precipitator 

List the pollutants for which this device is intended to control and the capture and control efficiencies. 

Pollutant Capture Efficiency Control Efficiency 

PM10 100 99.5 

TSP 100 99.5 

Metals 100 99.5 

 

Explain the characteristic design parameters of this control device (flow rates, pressure drops, number of 

bags, size, temperatures, etc.). 

This control devise represents one of two baghouses operating parallel to one another. 

Pressure Drop – 3 to 7 inches of H20 

Gas Flow Rate – 6,000 scfm 

Gas temp – 70 degrees F 

 

 

Is this device subject to the CAM requirements of 40 C.F.R. 64? ___ Yes X No 

If Yes, Complete ATTACHMENT H 

If No, Provide justification. 

 

Describe the parameters monitored and/or methods used to indicate performance of this control device. 

Pressure Drop 

 

 

 

 

 

 

 
Air Pollution Control Device Form (control_device.doc) 

Page 5 of 9 

Revised – 01/31/07

Page 5 of 9 

ATTACHMENT G - Air Pollution Control Device Form

Control device ID number: 

0002 

List all emission units associated with this control device. 

Furnace No. 2 

 

Manufacturer: 

NA 

Model number: 

NA 

Installation date: 

1973 

Type of Air Pollution Control Device: 

 X Baghouse/Fabric Filter ___ Venturi Scrubber ___ Multiclone 

___ Carbon Bed Adsorber ___ Packed Tower Scrubber ___ Single Cyclone 

___ Carbon Drum(s) ___ Other Wet Scrubber ___ Cyclone Bank 

___ Catalytic Incinerator ___ Condenser ___ Settling Chamber 

___ Thermal Incinerator ___ Flare ___ Other (describe) ________________ 

___ Wet Plate Electrostatic Precipitator ___ Dry Plate Electrostatic Precipitator 

List the pollutants for which this device is intended to control and the capture and control efficiencies. 

Pollutant Capture Efficiency Control Efficiency 

PM10 100 99.5 

TSP 100 99.5 

Metals 100 99.5 

 

Explain the characteristic design parameters of this control device (flow rates, pressure drops, number of 

bags, size, temperatures, etc.). 

Baghouse contains 11 compartments, each with 256 bags for a total 2,816 bags. Each compartment can be 

isolated for cleaning (approximate cleaning time 33 minutes per compartment). Air to cloth ratio is 2.05. 

Pressure Drop – 8 to 12 inches of H20 

Flow rate – 45,000 scfm 

Gas temp – 330 degrees F 

 

Is this device subject to the CAM requirements of 40 C.F.R. 64? ___ Yes X No 

If Yes, Complete ATTACHMENT H 

If No, Provide justification. 

 

Describe the parameters monitored and/or methods used to indicate performance of this control device. 

 

Pressure Drop 

 

 

 

 

 

 
Air Pollution Control Device Form (control_device.wpd) 

Page 6 of 9 

Revised - 3/1/04

Page 6 of 9 

ATTACHMENT G - Air Pollution Control Device Form

Control device ID number: 

0003 

List all emission units associated with this control device. 

No. 5 Furnace 

 

Manufacturer: 

American Air Filter 

 

Model number: 

NA 

Installation date: 

1973 

Type of Air Pollution Control Device: 

 X Baghouse/Fabric Filter ___ Venturi Scrubber ___ Multiclone 

___ Carbon Bed Adsorber ___ Packed Tower Scrubber ___ Single Cyclone 

___ Carbon Drum(s) ___ Other Wet Scrubber ___ Cyclone Bank 

___ Catalytic Incinerator ___ Condenser ___ Settling Chamber 

___ Thermal Incinerator ___ Flare ___ Other (describe) ________________ 

___ Wet Plate Electrostatic Precipitator ___ Dry Plate Electrostatic Precipitator 

List the pollutants for which this device is intended to control and the capture and control efficiencies. 

Pollutant Capture Efficiency Control Efficiency 

PM10 100 99.5 

TSP 100 99.5 

Metals 100 99.5 

 

Explain the characteristic design parameters of this control device (flow rates, pressure drops, number of 

bags, size, temperatures, etc.). 

Baghouse contains 7 compartments, each with 256 bags for a total 1792 bags. Each compartment can be isolated. 

Bags are cleaned with reverse air provided by a 300 hp fan (cleaning time is approximately 21 minutes per 

compartment). Air to cloth ratio is 2.05. 

Pressure Drop – 8 to 12 inches of H20, flow rate – 24,000 scfm, Gas temp – 330 degrees F 

Designed for 99.5% removal efficiency. Efficiency is noted as zero since emissions were estimated based on 

stack tests performed on baghouse outlet. 

Is this device subject to the CAM requirements of 40 C.F.R. 64? ___ Yes X No 

If Yes, Complete ATTACHMENT H 

If No, Provide justification. 

 

Describe the parameters monitored and/or methods used to indicate performance of this control device. 

Pressure Drop. 

 

 

 

 

 

 

 
Air Pollution Control Device Form (control_device.doc) 

Page 7 of 9 

Revised – 01/31/07

Page 7 of 9 

ATTACHMENT G - Air Pollution Control Device Form

Control device ID number: 

0004 

List all emission units associated with this control device. 

No. 7 Furnace 

 

Manufacturer: 

American Air Filter 

 

Model number: 

NA 

Installation date: 

1973 

Type of Air Pollution Control Device: 

 X Baghouse/Fabric Filter ___ Venturi Scrubber ___ Multiclone 

___ Carbon Bed Adsorber ___ Packed Tower Scrubber ___ Single Cyclone 

___ Carbon Drum(s) ___ Other Wet Scrubber ___ Cyclone Bank 

___ Catalytic Incinerator ___ Condenser ___ Settling Chamber 

___ Thermal Incinerator ___ Flare ___ Other (describe) ________________ 

___ Wet Plate Electrostatic Precipitator ___ Dry Plate Electrostatic Precipitator 

List the pollutants for which this device is intended to control and the capture and control efficiencies. 

Pollutant Capture Efficiency Control Efficiency 

PM10 100 99.5 

TSP 100 99.5 

Metals 100 99.5 

 

Explain the characteristic design parameters of this control device (flow rates, pressure drops, number of 

bags, size, temperatures, etc.). 

Baghouse contains 7 compartments, each with 256 bags for a total 1792 bags. Each compartment can be isolated. 

Bags are cleaned with reverse air provided by a 300 hp fan (cleaning time is approximately 21 minutes per 

compartment). Air to cloth ratio is 2.05. 

Pressure Drop – 8 to 12 inches of H20, flow rate – 24,000 scfm, Gas temp – 330 degrees F 

Designed for 99.5% removal efficiency. Efficiency is noted as zero since emissions were estimated based on 

stack tests performed on baghouse outlet. 

Is this device subject to the CAM requirements of 40 C.F.R. 64? ___ Yes X No 

If Yes, Complete ATTACHMENT H 

If No, Provide justification. 

 

Describe the parameters monitored and/or methods used to indicate performance of this control device. 

Pressure Drop 

 

 

 

 

 

 

 
Air Pollution Control Device Form (control_device.wpd) 

Page 8 of 9 

Revised - 3/1/04

Page 8 of 9 

ATTACHMENT G - Air Pollution Control Device Form

Control device ID number: 

0006 

List all emission units associated with this control device. 

Crushing System No. 1 

 

Manufacturer: 

Wheelabrator 

 

Model number: 

NA 

Installation date: 

1952 

Type of Air Pollution Control Device: 

 X Baghouse/Fabric Filter ___ Venturi Scrubber ___ Multiclone 

___ Carbon Bed Adsorber ___ Packed Tower Scrubber ___ Single Cyclone 

___ Carbon Drum(s) ___ Other Wet Scrubber ___ Cyclone Bank 

___ Catalytic Incinerator ___ Condenser ___ Settling Chamber 

___ Thermal Incinerator ___ Flare ___ Other (describe) ________________ 

___ Wet Plate Electrostatic Precipitator ___ Dry Plate Electrostatic Precipitator 

List the pollutants for which this device is intended to control and the capture and control efficiencies. 

Pollutant Capture Efficiency Control Efficiency 

PM10 100 99.5 

TSP 100 99.5 

Metals 100 99.5 

 

Explain the characteristic design parameters of this control device (flow rates, pressure drops, number of 

bags, size, temperatures, etc.). 

This control device represents one of two baghouses operating parallel to one another. 

Pressure Drop – 3 to 7 inches of H20 

Flow rate – 8,000 scfm 

Gas temp – 70 degrees F 

 

 

Is this device subject to the CAM requirements of 40 C.F.R. 64? ___ Yes X No 

If Yes, Complete ATTACHMENT H 

If No, Provide justification. 

 

Describe the parameters monitored and/or methods used to indicate performance of this control device. 

Pressure Drop 

 

 

 

 

 

 

 
Air Pollution Control Device Form (control_device.doc) 

Page 9 of 9 

Revised – 01/31/07

Page 9 of 9 

ATTACHMENT G - Air Pollution Control Device Form

Control device ID number: 

0008 

List all emission units associated with this control device. 

Crushing System No. 2 

 

Manufacturer: 

Norblo 

 

Model number: 

 NA 

Installation date: 

1968 

Type of Air Pollution Control Device: 

 X Baghouse/Fabric Filter ___ Venturi Scrubber ___ Multiclone 

___ Carbon Bed Adsorber ___ Packed Tower Scrubber ___ Single Cyclone 

___ Carbon Drum(s) ___ Other Wet Scrubber ___ Cyclone Bank 

___ Catalytic Incinerator ___ Condenser ___ Settling Chamber 

___ Thermal Incinerator ___ Flare ___ Other (describe) ________________ 

___ Wet Plate Electrostatic Precipitator ___ Dry Plate Electrostatic Precipitator 

List the pollutants for which this device is intended to control and the capture and control efficiencies. 

Pollutant Capture Efficiency Control Efficiency 

PM10 100 99.5 

TSP 100 99.5 

Metals 100 99.5 

 

Explain the characteristic design parameters of this control device (flow rates, pressure drops, number of 

bags, size, temperatures, etc.). 

This control device represents one of two baghouses operating parallel to one another. 

Pressure Drop – 3 to 7 inches of H20 

Flow rate – 10,000 scfm 

Gas temp – 70 degrees F 

 

 

Is this device subject to the CAM requirements of 40 C.F.R. 64? ___ Yes X No 

If Yes, Complete ATTACHMENT H 

If No, Provide justification. 

 

Describe the parameters monitored and/or methods used to indicate performance of this control device. 

 

Pressure Drop 

 

 

 

 

 

 
ATTACHMENT H 

COMPLIANCE ASSURANCE MONITORING (CAM) FORMS 
Compliance Assurance Monitoring Plan Form (CAM Plan.doc) 

Page 1 of 2 

Revised – 10/05/06 

Page 1 of 2

ATTACHMENT H - Compliance Assurance Monitoring (CAM) Plan Form

For definitions and information about the CAM rule, please refer to 40 CFR Part 64. Additional information (including 

guidance documents) may also be found at http://www.epa.gov/ttn/emc/cam.html

CAM APPLICABILITY DETERMINATION

1) Does the facility have a PSEU (Pollutant-Specific Emissions Unit considered 

separately with respect to EACH regulated air pollutant) that is subject to CAM (40 

CFR Part 64), which must be addressed in this CAM plan submittal? To determine 

applicability, a PSEU must meet all of the following criteria (If No, then the 

remainder of this form need not be completed):

 YES NO 

a. The PSEU is located at a major source that is required to obtain a Title V permit; 

b. The PSEU is subject to an emission limitation or standard for the applicable regulated 

air pollutant that is NOT exempt; 

LIST OF EXEMPT EMISSION LIMITATIONS OR STANDARDS:

• NSPS (40 CFR Part 60) or NESHAP (40 CFR Parts 61 and 63) proposed after 11/15/1990. 

• Stratospheric Ozone Protection Requirements. 

• Acid Rain Program Requirements. 

• Emission Limitations or Standards for which a WVDEP Division of Air Quality Title V permit specifies a 

continuous compliance determination method, as defined in 40 CFR §64.1. 

• An emission cap that meets the requirements specified in 40 CFR §70.4(b)(12). 

c. The PSEU uses an add-on control device (as defined in 40 CFR §64.1) to achieve compliance with an emission 

limitation or standard; 

d. The PSEU has potential pre-control device emissions of the applicable regulated air pollutant that are equal to or 

greater than the Title V Major Source Threshold Levels; AND 

e. The PSEU is NOT an exempt backup utility power emissions unit that is municipally-owned. 

BASIS OF CAM SUBMITTAL

2) Mark the appropriate box below as to why this CAM plan is being submitted as part of an application for a Title V 

permit: 

RENEWAL APPLICATION. ALL PSEUs for which a CAM plan has NOT yet been approved need to be 

addressed in this CAM plan submittal. 

INITIAL APPLICATION (submitted after 4/20/98). ONLY large PSEUs (i. e., PSEUs with potential postcontrol device emissions of an applicable regulated air pollutant that are equal to or greater than Major Source 

Threshold Levels) need to be addressed in this CAM plan submittal. 

SIGNIFICANT MODIFICATION TO LARGE PSEUs. ONLY large PSEUs being modified after 4/20/98 need 

to be addressed in this cam plan submittal. For large PSEUs with an approved CAM plan, Only address the 

appropriate monitoring requirements affected by the significant modification. 

See following page 

for explanation
Compliance Assurance Monitoring Plan Form (CAM Plan.doc) 

Page 2 of 2 

Revised – 10/05/06 

Page 2 of 2

40CFR64 – Compliance Assurance Monitoring (CAM). The Electric Arc Furnaces are subject to 

SO2 limits in accordance with 45CSR10, however there are no control devices used to comply with the 

limit, thus the Furnaces are not pollutant specific emissions units (PSEUs) for SO2 in accordance with 

40 CFR §64.2(a)(2). The Electric Arc Furnaces, the crushing and screening equipment, and fugitive 

dust sources are subject to the Ferroalloys Production MACT which regulates PM emissions, therefore 

these sources are not subject to CAM for PM in accordance with 40 CFR §64.2(b)(1)(i).
Attachment 3

Material Safety Data Sheets

(MSDS)
Material Safety Data Sheet Prepared by Chem Alert

Product Name MANGANESE ORE (PILBARA MANGANESE)

1. IDENTIFICATION OF THE MATERIAL AND SUPPLIER

Supplier Name PILBARA MANGANESE PTY LTD

Address 28 Ventnor Avenue, West Perth WA, 6005, AUSTRALIA

Telephone (08) 9321 3633

Fax (08) 9321 3644

Emergency (08) 9321 3633

Email / Web cml@consminerals.com.au

Synonyms MANGANESE FINES ORE, MANGANESE LUMP ORE.

Uses ALLOY MANUFACTURE, CHEMICAL PRODUCTION.

2. HAZARDS IDENTIFICATION

CLASSIFIED AS HAZARDOUS ACCORDING TO NOHSC CRITERIA

NOT CLASSIFIED AS A DANGEROUS GOOD BY THE CRITERIA OF THE ADG CODE

Risk And

Safety Phrases

Risk and Safety Phrases are standardised phrases allocated to Hazardous Substances. Risk phrases convey a

general description of the physicochemical, environmental and health hazards of a substance. Safety phrases

provide information on safe storage, handling, disposal, personal protection and first aid.

RISK PHRASES

R20/22 Harmful by inhalation and if swallowed.

SAFETY PHRASES

S2 Keep out of reach of children.

S25 Avoid contact with eyes.

3. COMPOSITION / INFORMATION ON INGREDIENTS

Ingredient Formula Conc. CAS No.

BRAUNITE 4MnO.3MnO2.SiO2 30 - 60% Not Available

HAUSMANITE Mn.Mn2O4 30 - 60% Not Available

PSILOMELANE Ba.Mn.Mn8O16(OH) <1% Not Available

BIXBYITE (MnFe)2-O3 Not Available Not Available

PYROLUSITE (MNO2) MnO2 30 - 60% Not Available

4. FIRST AID MEASURES

Eye Flush gently with running water. Seek medical attention if irritation persists.

Inhalation If over exposure occurs leave exposure area immediately. If irritation persists, seek medical attention.

Skin Gently flush affected areas with water.

Ingestion For advice, contact a Poisons Information Centre on 13 11 26 (Australia Wide) or a doctor. If swallowed, do not

induce vomiting. Ingestion is considered unlikely due to product form.

Advice To

Doctor

Treat symptomatically.

First Aid

Facilities

Eye wash facilities should be provided.

Colour

Rating

AMBER

Printed by : RMT Page 1 of 5

Copyright © 2006 RMT. The data contained herein is protected by copyright and may not be reproduced for any reason.
Material Safety Data Sheet Prepared by Chem Alert

Product Name MANGANESE ORE (PILBARA MANGANESE)

5. FIRE FIGHTING MEASURES

Flammability Non flammable. May ignite in contact with incompatible materials. May evolve toxic gases (manganese oxides) when

heated to decomposition.

Fire and

Explosion

Non flammable. Evacuate area and contact emergency services. Remain upwind and notify those downwind of

hazard. Wear full protective equipment including Self Contained Breathing Apparatus (SCBA) when combating fire.

Use waterfog to cool intact containers and nearby storage areas.

Extinguishing Non flammable. Use fire fighting measures as applicable to the surrounding fire.

Hazchem Code None Allocated

6. ACCIDENTAL RELEASE MEASURES

Spillage If spilt (bulk), contact emergency services if appropriate. Wear dust-proof goggles, PVC/rubber gloves, a Class P1

(Particulate) respirator (where an inhalation risk exists), coveralls and rubber boots. Clear area of all unprotected

personnel. Collect and place in sealable containers for disposal. Avoid generating dust. If no contamination or

immediate hazard exists (eg. presence of incompatible materials), ore may be collected and returned to bulk store for

reuse or disposal.

7. HANDLING AND STORAGE

Handling Use of safe work practices are recommended to avoid eye or skin contact and inhalation. Observe good personal

hygiene, including washing hands before eating. Prohibit eating, drinking and smoking in contaminated areas.

Storage Store in cool, dry, well ventilated area, removed from organics, oxidising agents, hydrogen sulfide, heat sources and

foodstuffs. Ensure containers are adequately labelled, protected from physical damage and sealed when not in use.

8. EXPOSURE CONTROLS / PERSONAL PROTECTION

Ventilation Do not inhale dust/ powder. Use with adequate natural ventilation. Where a dust inhalation hazard exists, mechanical

extraction ventilation is recommended. Maintain dust levels below the recommended exposure standard. Water

suppression may be used to control dust.

Exposure

Standards

BRAUNITE (Not Available)

ES-TWA : 1 mg/m3 Manganese compounds

HAUSMANITE (Not Available)

ES-TWA : 1 mg/m3 Manganese compounds

PSILOMELANE (Not Available)

ES-TWA : 1 mg/m3 Manganese compounds

BIXBYITE (Not Available)

ES-TWA : 1 mg/m3 Manganese compounds

PPE Wear dust-proof goggles and PVC or rubber gloves. When using large quantities or where heavy contamination is

likely, wear coveralls. Where an inhalation risk exists, wear a Class P1 (Particulate) Respirator.

Colour

Rating

AMBER

Printed by : RMT Page 2 of 5

Copyright © 2006 RMT. The data contained herein is protected by copyright and may not be reproduced for any reason.
Material Safety Data Sheet Prepared by Chem Alert

Product Name MANGANESE ORE (PILBARA MANGANESE)

9. PHYSICAL AND CHEMICAL PROPERTIES

Appearance: DARK GREY TO BLACK SOLID

Odour: ODOURLESS

pH: NOT AVAILABLE

Vapour Pressure: NOT AVAILABLE

Vapour Density: NOT AVAILABLE

Boiling Point: NOT AVAILABLE

Melting Point: 1564 C

Evaporation Rate: NOT RELEVANT

Solubility (water): INSOLUBLE

Specific Gravity: > 3.2

% Volatiles: NOT AVAILABLE

Flammability: NON FLAMMABLE

Flash Point: NOT AVAILABLE

Upper Explosion Limit: NOT RELEVANT

Lower Explosion Limit: NOT RELEVANT

Autoignition Temperature: NOT AVAILABLE

10. STABILITY AND REACTIVITY

Reactivity Oxidising agent. May ignite in contact with incompatible materials, including organics, oxidising agents (peroxides)

and hydrogen sulfide. Specific incompatibilities reported for manganese dioxide include: violent reaction when heated

with aluminium; potentially explosive reaction with hydrogen peroxide, peroxomonosulfuric acid, chlorates (if heated)

or anilinium perchlorate; may ignite with hydrogen sulfide; reacts violently with potassium azide (when warmed);

diboron tetrafluoride; incandescent reaction with chlorine trifluoride; vigorous reaction with hydroxylaminium chloride

(Sax). This ore is stable under normal conditions of storage and use.

Decomposition

Products

May evolve toxic gases (manganese oxides) when heated to decomposition.

11. TOXICOLOGICAL INFORMATION

Health Hazard

Summary

Low to moderate toxicity. Use safe work practices to avoid dust inhalation. Chronic over exposure to manganese dust

at high levels may result in manganese poisoning (manganism), a progressively disabling brain disease, which in its

latter stages resembles Parkinsons disease. Symptoms may include lack of appetite, fatigue and changes in speech,

balance and personality. Further symptoms may include a mask-like facial expression and tremors.

Eye Low irritant. Exposure may result in irritation and lacrimation.

Inhalation Low irritant - toxic. Over exposure may result in mild respiratory irritation. Dusts enter the respiratory tract and

become deposited in the major body organs. Chronic exposure may result in manganese poisoning, a disabling,

usually progressive disorder of the central nervous system with symptoms resembling Parkinsonism.

Skin Low irritant. Prolonged and repeated contact with the skin may result in mild irritation.

Ingestion Low toxicity. Due to product form, ingestion is considered unlikely, however contamination via hand mouth transfer

may result in gastrointestinal irritation. Maintain good personal hygiene standards.

12. ECOLOGICAL INFORMATION

Environment Manganese ore is a naturally occuring component of the earth's crust. Not expected to have adverse effects on the

environment. Avoid discharge into sewers or waterways.

13. DISPOSAL CONSIDERATIONS

Waste

Disposal

Collect and place in sealable containers and dispose of to an approved landfill site. Contact the manufacturer for

additional information.

Colour

Rating

AMBER

Printed by : RMT Page 3 of 5

Copyright © 2006 RMT. The data contained herein is protected by copyright and may not be reproduced for any reason.
Material Safety Data Sheet Prepared by Chem Alert

Product Name MANGANESE ORE (PILBARA MANGANESE)

13. DISPOSAL CONSIDERATIONS cont.

Legislation Dispose of in accordance with relevant local legislation.

14. TRANSPORT INFORMATION

Transport Not classified as a Dangerous Good according to the Australian Code for the Transport of Dangerous Goods by Road

and Rail.

UN Number None Allocated

DG Class None Allocated

Subsidiary

Risk(s)

None Allocated

Packing Group None Allocated

Hazchem Code None Allocated

15. REGULATORY INFORMATION

AICS All chemicals listed on the Australian Inventory of Chemical Substances (AICS).

Poison

Schedule

A poison schedule number has not been allocated to this product using the criteria in the Standard for the Uniform

Scheduling of Drugs and Poisons (SUSDP).

16. OTHER INFORMATION

Additional

Information

RESPIRATORS: In general the use of respirators should be limited and engineering controls employed to avoid

exposure. If respiratory equipment must be worn ensure correct respirator selection and training is undertaken.

Remember that some respirators may be extremely uncomfortable when used for long periods. The use of air

powered or air supplied respirators should be considered where prolonged or repeated use is necessary.

ABBREVIATIONS:

mg/m3 - Milligrams per cubic metre

ppm - Parts Per Million

TWA/ES - Time Weighted Average or Exposure Standard.

CNS - Central Nervous System

NOS - Not Otherwise Specified

pH - relates to hydrogen ion concentration - this value will relate to a scale of 0 - 14, where 0 is highly acidic and 14 is

highly alkaline.

CAS# - Chemical Abstract Service number - used to uniquely identify chemical compounds.

M - moles per litre, a unit of concentration.

IARC - International Agency for Research on Cancer.

PERSONAL PROTECTIVE EQUIPMENT GUIDELINES:

The recommendation for protective equipment contained within this Chem Alert report is provided as a guide only.

Factors such as method of application, working environment, quantity used, product concentration and the availability

of engineering controls should be considered before final selection of personal protective equipment is made.

HEALTH EFFECTS FROM EXPOSURE:

It should be noted that the effects from exposure to this product will depend on several factors including: frequency

and duration of use; quantity used; effectiveness of control measures; protective equipment used and method of

application. Given that it is impractical to prepare a Chem Alert report which would encompass all possible scenarios,

it is anticipated that users will assess the risks and apply control methods where appropriate.

COLOUR RATING SYSTEM: Chem Alert reports are assigned a colour rating of Green, Amber or Red for the

purpose of providing users with a quick and easy means of determining the hazardous nature of a product. Safe

handling recommendations are provided in all Chem Alert reports so as to clearly identify how users can control the

hazards and thereby reduce the risk (or likelihood) of adverse effects. As a general guideline a Green colour rating

indicates a low hazard, an Amber colour rating indicates a moderate hazard and a Red colour rating indicates a high

Colour

Rating

AMBER

Printed by : RMT Page 4 of 5

Copyright © 2006 RMT. The data contained herein is protected by copyright and may not be reproduced for any reason.
Material Safety Data Sheet Prepared by Chem Alert

Product Name MANGANESE ORE (PILBARA MANGANESE)

16. OTHER INFORMATION cont.

hazard.

Report

Reviewed

1st January 2006

Date Printed 11th April 2006

Report Status Chem Alert reports are compiled as an independent source of information by RMT's scientific department. The

information is based on the latest chemical and toxicological research, and in compliance with relevant standards,

guidance notes and legislation (where applicable). The Chem Alert report is not intended as a replacement to the

manufacturer's original MSDS that is provided to Chem Alert subscribers for convenience. In many instances, Chem

Alert reports are compiled on behalf of manufacturers, in which case they serve as the "Manufacturer's MSDS" and

are clearly identified as such on the relevant reports.

Prepared By Risk Management Technologies

5 Ventnor Avenue, West Perth

Western Australia 6005

Phone: +61 8 9322 1711

Fax: +61 8 9322 1794

Web: www.rmt.com.au

Colour

Rating

AMBER

Printed by : RMT Page 5 of 5

Copyright © 2006 RMT. The data contained herein is protected by copyright and may not be reproduced for any reason.
Clark Coal and Coke Laboratory

1801 Route 51 South Jefferson Hills. PA 15025

FORM REVISION NO. 1 REV. DATE:11/17/09

APPD. BY: JAA

EFFECTIVE DATE: 6-10-09 ORIGINATOR: JAA

Phone: 412-387-1001 

Fax: 412-387-1028

Material Safety Data Sheet for Bituminoius Coal

Secton1-Material Identification and Information

 Identify: Coal, bituminous coal, (Coal is a naturally occurring black or dark-brown combustible 

material typically used as a fuel, and composed of a number of solid and gaseous organic materials 

including carbon, hydrogen, oxygen, and sulfur.)

 Manufacture: Naturally occurring material.

Section II- Hazardous Ingredients

 Hazardous Components: Coal dust,

- OSHA PEL: 2.4 mg/m3 TWA (<5% (Sio2) for respirable fraction

- MSHA PEL: 2.0 mg/m3 TWA (<=5% SiO2) for resirable fraction

- NIOSH REL: 1.0 MG/m3 TWA for respriable fraction

- ACGIH TLB: 0.9 mg/m3 TWA for resirable fraction

Section III-Physical/ Chemical Properties

 Appearance and odor: Black odor dark-brown solid with little or no odor

 Specific gravity (H2O=1): 1.2 to 1.7

 Solubility in water: Negligible

Section IV-Fire and Explosion Hazard Data

 Flash point (Method Used): Not applicable.

 Flammable limits in air: LEL for coal dust in air is 0.05 oz/ft3.

 Extinguishing media: For small fires, use dry chemical, sand, earth, water spray, or foam. For 

larger fires involving coal stockpiles in bunker, silos, or bins, heated coal foam. For larger fires 

involving coal stockpiles in bunkers, silos, or bins, heated coal or fire condition may be resolved 

by drawing down the bin and removing the heated deposits. Once removed, water, dry chemical, 

etc. at be applied to smother the fire or fire may be left to smother coal fires in confined spaces.

 Special Fire Fighting Procedures: Extreme caution should be practiced when using water on large 

areas of hot coal in confined area to prevent the accumulation of hazardous amounts of water gas 

that contain varying amounts of explosive hydrogen and carbon monoxide. Note that coal 

stockpiles should be properly compacted to prevent heating and subsequent spontaneous 

combustion of coal within the stockpile.

 Unusual Fire Explosion Hazards: Accumulation of methane gas from coal in confined or poorly 

ventilated areas may create an explosion hazard when an ignition source is present. In addition, 

coal dust suspended in air, may create a dust explosion, or contribute to the propagation or severity 

of an explosion when an ignition source is present

Section V- Reactivity Data

 Stability: Stable: under normal conditions of use. (see “Section IV-Fire and Explosion Hazard 

Data”)

 Conditions to avoid: Oxidizing agents including heat, sparks, and open flame.

 Incompatibility: None noted.
Clark Coal and Coke Laboratory

1801 Route 51 South Jefferson Hills. PA 15025

FORM REVISION NO. 1 REV. DATE:11/17/09

APPD. BY: JAA

EFFECTIVE DATE: 6-10-09 ORIGINATOR: JAA

Phone: 412-387-1001 

Fax: 412-387-1028

 Hazardous decomposition or byproducts: Burning of coal may produce carbon monoxide, carbon 

dioxide, sulfur oxides, and other byproducts of combustion. Explosive methane gas may be 

released from the types of cal during normal conditions of use and storage.

 Hazardous polymerization: Will not occur.

Section VI- Health Hazard Data

 Route (s) of entry: Primarily inhalation for respirable coal dust.

 Signs and symptoms of exposure:

- Health hazards (acute): coal dust may be irritating it the eyes, skin, and respiratory tract.

Health hazards (chronic): Continued exposure to respirable coal dust over prolonged 

periods of time above exposure limits, may lead to emphysema bronchitis, and 

pneumoconiosis

- Preexisting respiratory conditions may be aggravated by overexposure to coal dust.

 Carcinogenicity classification: None noted.

 Emergency and first aid procedures:

- Eyes: Flush repeatedly with water and avoid rubbing. If irritation persists, consult a 

physician

- Skin: Wash with soap and water.

- Inhalation: If overexposed, remove to fresh air.

Section VII- Precautions for Save Handling and Use

 Steps to be taken in case material is released or spilled: Where possible, recover for reuse. Wear 

appropriate personal protective equipment and avoid generation and inhalation of airborne dust 

during cleanup efforts

 Waste disposal method: Dispose of in accordance with applicable federal, state, and local 

regulations.

 Precautions to be taken in handling and storing: Use of water sprays and ventilation may be used 

to minimize generation and control airborne dust during handling and storing. Stockpiles of coal 

should be properly compacted to prevent heating and the subsequent spontaneous combustion of 

coal within the stockpile.

Section VIII- Control Measures

 Respiratory protection: NIOSH approved particulate respirator if exposure limits for respirable 

coal dust are exceeded.

 Ventilation: Local exhaust ventilation and water sprays are preferred methods of dust control.

 Protective gloves: Gloves made of leather, rubber, or other materials designed for the handling of a 

protection from granular materials, are recommended.

 Eye Protector: Safety glasses at a minimum are recommended.

 Other protective clothing or equipment: Additional protection such as steel-toed or metatarsal 

footwear and metacarpal footwear and metacarpal gloves may be needed for the handling of larger 

coal sizes.

 Work/ hygienic practices: Observe good personal hygiene habits while working with or around 

coal and coal dust.

Secton IX- Label Information

 Identify: Coal, bituminous coal.

 Appropriate Hazard Warnings:
Clark Coal and Coke Laboratory

1801 Route 51 South Jefferson Hills. PA 15025

FORM REVISION NO. 1 REV. DATE:11/17/09

APPD. BY: JAA

EFFECTIVE DATE: 6-10-09 ORIGINATOR: JAA

Phone: 412-387-1001 

Fax: 412-387-1028

- Physical Hazard: Coal is a combustible material. Coal dust, when suspended in air, may 

create a dust explosion or contribute to the propagation or severity of an explosion when 

ignition source is present.

- Health Hazard: Coal dust may be irritating to the eyes, skin and respiratory tract.

Continued exposure to respirable coal dust over prolonged periods of time above 

exposure limits, may lead to emphysema, bronchitis, and pneumoconiosis.

 Prepared by: CONSOl Energy Inc.

 1800 Washington Road

 Pittsburg, PA 15241-1421

 (412-) 831-4000

Section X- Other Information

Disclaimer of Expressed and Implied Warranties:

Although reasonable care has been taken in the preparation of this document, we extend 

no warranties and make no representation as to the accuracy or completeness of the 

information contained herein, and assume no responsibility regarding the suitability of 

this information for the user’s intended purposes or for the consequences of its use. Each 

individual should make a determination as to the suitability of the information for their 

particular purpose (s).

Distributed by: Technical Marketing Services

 CONSOL Energy Inc.

 1800 Washington Road

 Pittsburgh, PA 15241-1421

 (412) 831-4000
PUT OUR ENERGY TO WORK FOR YOU.

Two International Drive, Suite 200, Portsmouth, NH 03801

Tel (603) 431-1000 FAX (603) 430-7290 

An Axel Johnson, Inc. Company

MATERIAL SAFETY DATA SHEET 

BITUMINOUS 

COAL 

Content Last Revised 1/94; 10/12/00; 

07/26/02; 06/05 

4 pages. 

SECTION 1 - MATERIAL IDENTIFICATION 24 HOUR EMERGENCY 

INFORMATION 

PRODUCT / 

CHEMICAL NAME: BITUMINOUS COAL 

Sprague: 

Chemtrec: 

603-431-1000 

800-424-9300 

PRODUCT / 

CHEMICAL SYNONYMS: 

CHEMICAL FAMILY / 

FORMULA:

MATERIAL USE OR 

OCCURRENCE: 

WASHED COAL, CLEAN COAL, SOFT

COAL 

ALIPHATIC AND AROMATIC 

HYDROCARBONS / VARIABLE 

- 

HMIS / NFPA

HAZARD RATING 

4=EXTREME 

3=SERIOUS 

2=MODERATE 

1=SLIGHT 

0=MINIMAL

 HEALTH 

 FIRE 

REACTIVITY

 OTHER

1

1 0

SECTION 2 – INGREDIENTS & RECOMMENDED OCCUPATIONAL EXPOSURE LIMITS

COMPOSITION % WEIGHT

AS 

RECEIVED 

OSHA PEL ACGIH TLV 

(Typical) None established. None established. 

MOISTURE 1.0 – 10.0 

ASH 4.0-20.0 15 mg/M3 as nuisance dust 

less than 1% quartz 

10 mg/M3 as nuisance dust 

less than 1% quartz 

TOTAL SULFUR 0.5-2.2 5.0 ppm as SO2 2.00 ppm as SO2

FIXED CARBON 50.0-72.0 None established None established

VOLATILE MATTER* INCLUDING 

ELEMENTAL AND COMPOUNDS OF: 

17.0-37.0

HYDROGEN 4.8-5.3 None established None established 

NITROGEN 1.2-1.6 None established None established 

CHLORINE .08-.19 1.0 ppm 1.0 ppm 

COAL DUST 2.4 mg/ M3 respirable fraction, 

< 5% SiO2 

10 mg/ M3 > 5% SiO2 

% SiO2 + 2

2 mg/M3 respirable fraction, 

< 5% SiO2 

10 mg/ M3 > 5% SiO2 

% SiO2 + 2

SECTION 3 - PHYSICAL DATA

IGNITION TEMPERATURE: 260°-365°F % VOLATILITY BY VOLUME: Negligible 

MELTING POINT: 750° F VAPOR DENSITY (AIR = 1): N/A 

AVERAGE SPECIFIC GRAVITY (H2O = 1): 1.43 SOLUBILITY IN WATER: Non-soluble 

HETEROGENOUS - CARBONACEOUS

APPEARANCE & ODOR: Irregular, rectangular-shaped chunks or particles, dense, grayish-black to black color with 

slight, minimal dank odor. 
BITUMINOUS 

COAL 

Content Last Revised 1/94: 10/12/00: 07/26/02; 

06/05 4 pages 

MATERIAL SAFETY DATA SHEET 

U:\MSDS\BITUMINOUS COAL.doc; Last printed 7/27/2005 10:17 AM. 2

SECTION 4 - FIRE AND EXPLOSION HAZARD DATA

FLASH POINT: When exposed to flame of temperatures in excess of 260o F.

EXTINGUISHING MEDIUM: Foam, carbon dioxide, dry chemical, halon, and water fog. 

SPECIAL FIRE FIGHTING PROCEDURES: Use washdown and spread out method. 

UNUSUAL FIRE AND EXPLOSION HAZARDS: Susceptible to spontaneous combustion. Highly combustible and/or explosive 

when in dust or powder form. 

SECTION 5 - HEALTH DATA 

TOXICOLOGICAL TEST DATA: Coal may liberate various polycyclic aromatic hydrocarbons (PAH’s) upon thermal 

decomposition. There is no clear evidence that coal is carcinogenic to man or experimental animals because of their 

polycyclic aromatic hydrocarbon content. However, there is evidence that these PAH’s may play an active role in the 

generation of lung cancer seen in cigarette smokers or tar-roofing workers. 

Coal may release small quantities of methane gas over a period of time. Progression of tuberculosis is greatly 

increased in pneumoconiosis but susceptibility is apparently not increased. 

ACUTE HEALTH EFFECTS CHRONIC HEALTH EFFECTS 

INHALATION The principal health hazard associated with coal occurs 

during its mining and transport. Coal workers’ 

pneumoconiosis (CWP) can occur in miners after as 

little as 15 years of excessive inhalation of respirable 

coalmine dust. Respirable quartz particles and free 

silica may be co-implicated. Coal dust is deposited in 

the lungs where its site of action is the lung 

parenchyma, lymph nodes and hila. The severity of the 

disease is directly related to the amount of coal dust in 

the lungs. In the simple stages, the disease is 

detectable by x-ray as round, irregular "macules"of 1-5 

mm. This stage typically does not change lung function 

or shorten life. 

The chronic stage of CWP, however, 

involves massive pulmonary fibrosis 

that does impair pulmonary function 

and shorten life. 

Chronic Bronchitis (lung 

inflammation, coughing attacks, 

difficult breathing, etc.) and 

emphysema can result from 

excessive coal dust inhalation. 

Rheumatoid arthritis can be 

exacerbated by pneumonias leading 

to rapidly developing lung damage 

(Caplan’s Syndrome). 

INGESTION May cause irritation. No data available 

SKIN CONTACT May cause irritation. No data available. 

EYE CONTACT Irritation of the eye. No data available 

FIRST AID PROCEDURES

First aid procedures generally don’t apply to this product. Maintain exposure to coal dust according to 

applicable regulatory standards. 
BITUMINOUS 

COAL 

Content Last Revised 1/94: 10/12/00: 07/26/02; 

06/05 4 pages 

MATERIAL SAFETY DATA SHEET 

U:\MSDS\BITUMINOUS COAL.doc; Last printed 7/27/2005 10:17 AM. 3

SECTION 6 - REACTIVITY DATA

STABILITY: Stable if properly stored to inhibit oxidation. 

HAZARDOUS POLYMERIZATION: Hazardous polymerization has not been known to occur under normal 

temperatures and pressures. However, coal dust may react slowly with oxygen 

at room temperature. Heat accelerates the process, which could lead to 

spontaneous ignition in piles of coal dust. 

CONDITIONS TO AVOID: 1. Allowing coal to stand in water. 

2. Storing coal on loose or porous ground. 

3. Piling coal around upright steel or wooden posts, crane supports, 

underground drains, steam or hot water lines or areas where there is refuse 

such as wood, straw, growing vegetation or other organic material. 

4. Storage in closed hampers, bins, receptacles, etc. without positive 

ventilation. 

INCOMPATIBLES: 

TYPICAL DECOMPOSITION 

PRODUCTS: 

May liberate hydrogen, methane, carbon monoxide, oxides of sulfur and 

hydrogen, coal tar pitch volatiles upon thermal decomposition. 

SECTION 7 - SPECIAL PROTECTION

RESPIRATORY PROTECTION: Use with adequate ventilation. 

VENTILATION LOCAL EXHAUST: MSHA/NIOSH approved dust respirator. Appropriate respirator 

depends upon type and magnitude of exposure. 

MECHANICAL 

(General): 

Recommended for use in enclosed or semi-enclosed work 

areas. 

EYE PROTECTION: Splash goggles or shields with safety glasses 

PROTECTIVE GLOVES: Neoprene, PVC 

OTHER PROTECTIVE CLOTHING OR 

EQUIPMENT: 

Employee must wear appropriate impervious clothing and 

equipment to prevent repeated or prolonged skin contact with 

this substance. 

SECTION 8 - SPECIAL PRECAUTIONS

PRECAUTIONS FOR SAFE HANDLING & 

STORAGE: 

Do not permit accumulation of dust or spillage. See also conditions to 

avoid, above. 

SPILL AND LEAK PROCEDURES: Cleanup by excavation, vacuum collection or washdown. 

WASTE DISPOSAL METHOD: 1. Incinerate in combustion device or system. 

2. Dispose in approved, regulated landfill. 

SECTION 9 - DOT HAZARDOUS MATERIAL INFORMATION

PROPER SHIPPING NAME: 

BITUMINOUS COAL 

REQUIRED PLACARDING: NONE

HAZARD CLASS: 

Non-Hazardous

PACKING GROUP 

(P.G.): III 

N.A/U.N. NUMBER: NONE 
BITUMINOUS 

COAL 

Content Last Revised 1/94: 10/12/00: 07/26/02; 

06/05 4 pages 

MATERIAL SAFETY DATA SHEET 

U:\MSDS\BITUMINOUS COAL.doc; Last printed 7/27/2005 10:17 AM. 4

SECTION 10 - EPA SARA TITLE III INFORMATION

SECTION 311/312 ACUTE: N/A CHRONIC: N/A

HAZARD CLASSIFICATION: NonHazardous FIRE: N/A PRESSURE: N/A REACTIVE: N/A

SECTION 11 – REMARKS

This material contains fused polycyclic hydrocarbons. The OSHA interpretation of coal tar pitch volatiles (Section 1910, 

1002) is as follows: “Coal tar pitch volatiles include the fused polycyclic hydrocarbons which volatize from the 

distillation residues of coal, petroleum, wood, and other organic matter.” The OSHA PEL and ACGIH TLV for coal tar 

pitch volatiles is 0.2 mg/M3 (basis one soluble fraction). 

SECTION 12 - ADDITIONAL REGULATORY DATA

REPORTABLE COMPONENTS: FEDERAL EPA % SARA RQ CERCLA 

RQ 

RCRA 

NO. 

BITUMINOUS COAL 100 ----- ----- ----- 

NOTE: OSHA Regulations 29 CFR 1910.1200 (Hazard Communication) do not consider coal as a “hazardous 

material” and a Material Safety Data Sheet (MSDS) is not required. The information contained herein is based on data 

available at this time and is believed to be accurate. However, no warranty is expressed or implied regarding the 

accuracy of these data or the results to be obtained from the use thereof. Since information contained herein may be 

applied under conditions beyond our control and with which we may be unfamiliar, no responsibility is assumed for the 

results of its use. The person receiving this information shall make his own determination of the suitability of the 

material for his particular purpose. 













 Material Safety Data Sheet

WHMIS Protective Clothing TDG Road/Rail

Section I - Product Identification and Uses

Common/Trade Name METALLURGICAL COKE MSDS # 9941

Synonyms Coke, Buckwheat Coke, Nut Coke, Pea Coke, Blast Furnace Coke, Dry Coke Fines, Coke 

Breeze

Chemical Name Not applicable

Chemical Formula Not applicable

Chemical Family Not available

Supplier ARCELORMITTAL DOFASCO INC.

P.O. BOX 2460

HAMILTON, ON.

CANADA L8N 3J5

(905) 548-7200 EXT. 4051 (By-Product Sales)

Material Uses Carbon/fuel source for metal production. Internally generated by-product material. 

Section IA - First Aid Measures

Eye Contact Flush eyes with water to remove foreign body. Seek medical attention if irritation persists.

Skin Contact Wash with soap and water to remove from skin. Seek medical attention if irritation persists.

Inhalation Remove person to fresh air. Seek medical attention if symptoms persist.

Ingestion Not applicable.
Metallurgical Coke (MSDS 9941) Page 2

Section II - Composition and Information on Ingredients

Name CAS# % by Weight TLV/PEL LC50/LD50

1. CARBON

2. WATER

3. QUARTZ

4. SULPHUR

5. SODIUM MONOXIDE

6. CALCIUM OXIDE

7. MAGNESIUM OXIDE

8. POTASSIUM OXIDE

9. TITANIUM DIOXIDE

10. ALUMINA

11. IRON OXIDE

12. PHOSPHOROUS 

PENTOXIDE

13. MANGANESE OXIDE

7440-44-0

7732-18-5

14808-60-7

7704-34-9

12401-86-4

1305-78-8

1309-48-4

12136-45-7

13463-67-7

1344-28-1

1332-37-2

1314-56-3

1317-35-7

86-91

3-29

<1

0.6-0.8

0.01-0.7

0.01-0.3

0.01-0.3

0.01-0.2

0.01-0.2

0.2-3

0-2

0-0.10

0-0.02

TWA: 3.5 (mg/m3) from 

ACGIH (TLV) 

Not available.

TWA: 0.05 (mg/m3) from 

ONT. MOL

TWA: 10 (mg/m3) from 

ACGIH (TLV) (PNOS)

Not available.

TWA: 2 (mg/m3) from 

ACGIH (TLV) 

TWA: 10 (mg/m3) from 

ACGIH (TLV) 

Not available.

TWA: 10 (mg/m3) from 

ACGIH (TLV)

TWA: 10 (mg/m3) from 

ACGIH (TLV) (PNOS–

Inhalable; 3 (mg/m3) from 

ACGIH (TLV) (PNOSRespirable)

TWA: 5 (mg/m3) from 

ACGIH (TLV)

Not available.

TWA: 1 (mg/m3) from ONT. 

MOL

Not available.

Not available.

ORAL (LD50): Acute: 90 

mg/kg [Rat]. >15000 mg/kg 

[Mouse].

Not available.

Not available.

Not available.

ORAL (LD50): Acute: 810

mg/kg [Mouse

Not available.

ORAL (LD50): Acute: 

10000 mg/kg [Rat]. VAPOR

(LC50): Acute: 2087 ppm 4 

hour(s) [Rat].

Not available.

Not available.

GAS (LC50): Acute: 104.8 

ppm 4 hour(s) [Rat].

Not available.

Section III - Toxicological Properties

Routes of entry Skin contact. Eye contact. Inhalation.

TLV Permissible exposure limits have not been established for this product.

Toxicity for animals Acute oral toxicity (LD50): 440 mg/kg [Mouse]. (CARBON)

Chronic effects on humans Long-term inhalation overexposure may cause lung disorders. IARC has classified 

Crystalline Silica as a Class 1 carcinogen. Their study concluded that sufficient evidence for 

carcinogenicity exists in experimental animals and that sufficient evidence exists in humans 

for the carcinogenicity of inhaled crystalline silica in the forms of quartz or cristoballite from 

occupational sources.

Acute effects on humans Overexposure by inhalation may cause irritation of nose, throat and mucous membranes. 

Abrasive irritation of skin or eyes.
Metallurgical Coke (MSDS 9941) Page 3

Section IV - Physical Data

Physical State and Appearance Solid (solid lumps). Vapor Pressure Not applicable.

pH Not applicable. Evaporation Rate Not applicable.

Odor Threshold Not applicable. Viscosity Not applicable.

Volatility Not applicable. Water/Oil Dist. Coeff. Not applicable.

Melting/Sublimation Point Not applicable. Critical temperature Not applicable.

Boiling/Condensation Point Not applicable. Instability temperature Not applicable.

Specific Gravity 1.75 (Water = 1) Conditions of instability No additional remark.

Vapor Density Not available. Solubility Not available.

Dispersion Properties See solubility in water. Odor No characteristic odour.

Color Black.

Section V – Fire and Explosion Data

The product is Will burn at elevated temperatures.

Auto-ignition temperature Not applicable.

Fire degradation products Combustion products such as carbon oxides.

Flash Points Not applicable.

Flammable Limits Not applicable.

Fire Extinguishing Procedures Use water. Use SCBA during fire fighting.

Flammability Will burn at elevated temperatures.

Risks of explosion Risks of explosion of the product in presence of mechanical impact: No.

Risks of explosion of the product in presence of static discharge: No

No specific information is available in our database regarding the product’s risks of

explosion in the presence of various materials.

Section VI – Reactivity Data

Stability The product is stable.

Hazardous Decomp. Products Oxides of carbon.

Degradability Not applicable.

Products of Degradation Possibly hazardous short term degradation products are not likely.

Corrosivity No specific information is available in our database regarding the corrosivity of this 

product in presence of various materials.

Reactivity No specific information is available in our database regarding the reactivity of this 

material in presence of various other materials.
Metallurgical Coke (MSDS 9941) Page 4

Section VII – Preventive Measures

Waste Information Dispose of in accordance with local, provincial and federal regulations. 

Storage Not applicable.

Precaution Avoid dust generation during handling. Do not breathe dust or fume. Wear suitable 

protective clothing. In case of insufficient ventilation, wear suitable respiratory 

equipment.

This material contains a small amount (0.1-0.9% by weight) of quartz (free crystalline 

silica). Free crystalline silica is listed by IARC as a group 1 “proven human carcinogen”. 

This material does not contain any components listed under SARA 313.

Small spill and leak Contain spill, reclaim spilled material to suitable container. Use appropriate personal 

protective equipment during clean-up.

Large spill and leak If spills may impact the natural environment (e.g. entering to storm sewer, bay, 

waterway, etc.) contact your Environment department.

Section VIII – Protective Measures

Protective Clothing Safety glasses with side shields. Leather faced gloves. 

Use NIOSH/MSHA approved respirator.

Engineering Controls Use general ventilation under normal conditions. Use mechanical ventilation if dust or fume 

is generated.

Section IX – Classification

TDG Road/Rail Not controlled under TDG (Canada).

Maritime Transportation Not available.

WHMIS WHMIS CLASS D-2A: Material causing other toxic effects (VERY 

TOXIC).

Federal and Provincial 

Regulations

CEPA DSL: CALCIUM OXIDE; MAGNESIUM OXIDE; 

PHOSPHORUS OXIDE; MANGANESE OXIDE; IRON OXIDE; 

SULPHUR; POTASSIUM OXIDE; SODIUM MONOXIDE; 

TITANIUM DIOXIDE; QUARTZ

Section X – Other Information

References Dofasco’s Material Safety Data Sheet

If the use of this material is other than that specified by the supplier, additional precautions may be required.

Effective Date: October 21, 2008 

EMERGENCY CONTACT: 1-760-476-3962

3E COMPANY CODE: 333211 

To the best of our knowledge, the information contained herein is accurate. However, neither the above named supplier nor any of its subsidiaries assumes any liability 

whatsoever for the accuracy or completeness of the information contained herein. Final determination of suitability of any material is the sole responsibility of the 

user. All materials may present unknown hazards and should be used with caution. Although certain hazards are described herein, we cannot guarantee that these are 

the only hazards that exist.













MAIi]ERNAL SAFM/ DAIIA SHEE]I

FOR MANGAiI ESE SIITTER

PRODUCED B Y

STOCK COMPANY

zBAGAcfIUVALNIY KOMaINAt'

:,IdentfiGtion ol subst nG:

1.1, l,langan@ slnter (AM 2) code

1.2. r4aterjal ofda*ly greycolour,

Physi6l tuatures of cargo

3,1. Specific loading volume:

CODE BC - Group C.

10. stability and r€ctivity:

- not decompos€dj

11, Other information: no one.

s02

21.0-30.090 0.2 4.4 o/o

2602000000.

on lumps w.th defin e si2e (up to 200 mm)/

TN VED

3.

4.1. Cla$ification of cargo dle to presence of adhesion ofCODE BC - materialhas an adhesion;

Not liable to auto-ignition and self-heatingj

NotRammab e;

- Can absod the oxygen from air spae or warehouse;

- Not alowed to store AM-2 together with dustsnsiuve @rqo;

Not allowed to store and handle toqether with acids, aLkalis, food cargo/ fodderi

- Not radioactiv€;

InsignlRGnt water absorber.

6. Fi6taid measurs: no one.

7. Acidental release measures:

7.1. Petson related safety precution:

- PeEons wiblr hypeensibvity to mangan€se dust are not allowed to wo* dnecly with

- PeEons who work wi$ AM-2 should be provided widl anti-dust g€r;

L t4easufes for envibnnental protedion:

Provided al handllng and storage rules a€ oberyed Al4-2 d€ not influence environrnent;

- ar.4-2 ha.dli.g and storage ar€ allowed in bulk or packed ln : "blg-bags", steel drums, wood

, whiLe stori.g lncovered Al{ 2 du.inq long period advieble to @wr it with talpaulin or

n, {bi