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[SMC] ¦ CPFP¦7801012¦0***2015¦14421¦10A270P1¦

Iowa Department of Natural Resources

Air Quality Construction Permit

Permit Holder

Firm: Griffin Pipe Products Co.

Contact: Responsible Party:

Ray Ostrowski Ray Ostrowski

Environmental Manager Environmental Manager

(630) 719-6506

1011 Warrenville Road, Suite 550

Lisle, IL 60532

Permitted Equipment

Emission Unit(s): Cupola, EU-1 

Maximum Nameplate Capacity = 60 tons/hr 

Control Equipment: Combustion Chamber [CE-1; four (4) burners each rated @ 16.0 MMBtu/hr]

Followed by a Baghouse [CE-10]

Emission Point: EP-2A

Equipment Location: 2601 Ninth Avenue

Council Bluffs, IA 51501

Plant Number: 78-01-012

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with 

applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, 

and federal law.

Permit No. Proj. No. Description Date Stack Testing

10-A-270-P1 14-421 Modify Permit as per ACO **/**/15 Yes

_______________________________________________

Under the Direction of the Director of

the Department of Natural Resources
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Council Bluffs, Iowa 10-A-270-P1

PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or 

misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. In 

addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has 

been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal 

Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the 

potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or 

indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, 

installation, maintenance or operation of the proposed equipment.

2. Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point 

as described in this permit and in the application for this permit. The permit holder, owner, and operator of the facility 

shall assure that the installation of the equipment listed in this permit conforms to the design in the application (i.e. 

type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this emission unit(s), 

control equipment, or emission point without the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person 

who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring 

that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the 

provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and control 

equipment at all times in a manner consistent with good practice for minimizing emissions, as required by paragraph 

567 IAC 24.2(1) "Maintenance and Repair”.

3. Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transferable from one location to another or from one piece of 

equipment to another, unless the equipment is portable. When portable equipment for which a permit has been issued 

is to be transferred from one location to another, the Department shall be notified in writing at least seven (7) days 

prior to transferring to the new location unless the equipment will be located in an area which is classified as 

nonattainment for the National Ambient Air Quality Standards (NAAQS) or is a maintenance area for the NAAQS in 

which case notification shall be given fourteen (14) days prior to the relocation of equipment(1) (See Permit Condition 

8.A.2). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if the relocation 

will cause a violation of the (NAAQS). In such case, a supplemental permit shall be required prior to the initiation of 

construction of additional control equipment or modifications to equipment needed to meet the standards.

(1) A list of nonattainment areas and maintenance areas for the NAAQS can be obtained from the Department.

4. Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as 

submitted, and that adequate operation and maintenance is provided to ensure that no condition of air 

pollution is created. 
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Council Bluffs, Iowa 10-A-270-P1

4. Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are 

specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or 

operator shall seek a permit amendment in order to revert back to the most recent previous version of the 

permit. The previous, unchanged permit provisions are included in the amendment for your convenience

only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not initiated within eighteen (18) months after the permit issuance date; or

(2) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within thirty-six (36) months after the permit issuance date; or

(3) the construction or implementation of the proposed project, as it affects the emission point permitted 

herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shall amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted 

equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the previous permit for the affected 

emission unit(s) and emission point, together with any previous amendment to the permit, until one of the 

following conditions occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and 

emission point permitted herein; or

(2) This current amendment becomes void.

5. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part §60.11(g), where applicable, any credible evidence may be used 

for the purpose of establishing whether a person has violated or is in violation of any provisions specified in this permit 

or any provisions of 567 IAC Chapters 20 through 35.

6. Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not 

a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice 

for minimizing emissions except when another regulation applicable to the unit or process provides otherwise. 

Cleaning of control equipment, which does not require the shutdown of process equipment, shall be limited to one (1)

six-minute period per one (1) hour period. 

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according 

to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the excess shall be 

repaired in an expeditious manner, or the process generating the emissions shall be shutdown within a reasonable 

period of time, as specified in 567 IAC 24.1. 

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate

field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident (See 

Permit Condition 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all 

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2).
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7. Permit Violations

Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two 

(2) years in jail according to Iowa Code Section 455B.146A.

8. Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)”b”:

(a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days 

following initiation of construction, installation, or alteration;

(b) The actual date of startup, postmarked within fifteen (15) days following the start of operation;

(2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be transferred 

from one location to another, the Department shall be notified:

(a) at least fourteen (14) days before equipment relocation if the equipment will be located in a 

nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance 

area for the NAAQS; 

(b) at least seven (7) days before equipment relocation.

(3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership

within thirty (30) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

and include the following information:

 The date of ownership change,

 The name, address, and telephone number of the responsible official, the contact person, and the 

owner of the equipment both before and after the ownership change; and

 The construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, notification of each compliance test required by Permit 

Condition 12 shall be done not less than thirty (30) days before the required test or performance 

evaluation of a continuous emission monitor [567 IAC 25.1(7)]. The notification shall include:

 the time, 

 the place, 

 the name of the person who will conduct the tests, 

 and other information as required by the Department;

If the owner or operator does not provide timely notice to the Department, the Department shall not 

consider the test results or performance evaluation results to be a valid demonstration of compliance 

with the applicable rules or permit conditions. Upon written request, the Department may allow a 

notification period of less than thirty (30) days.

B. The owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported within 

eight (8) hours or at the start of the first working day following the onset of the incident. The report may 

be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2 shall 

be submitted as a follow-up to all required initial reports to the Department within seven (7) days of the 

onset of the upset condition.

(3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified 

in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring 

system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days 

following the end of the calendar quarter, on forms provided by the Director.
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8. Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, 

whether successful or not, postmarked not later than six (6) weeks after the completion of the test period 

unless other regulations provide for other notification requirements. In that case, the more stringent 

reporting requirement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit shall 

be available at the plant during normal business hours for inspection and copying by federal, state, or local 

air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years from 

the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. The owner or operator shall send correspondence regarding this permit to the following address:

Construction Permit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9549

Fax: (515) 725-9501

E. The owner or operator shall send correspondence concerning stack testing to:

Stack Testing Coordinator

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9545

Fax: (515) 725-9502

F. The owner or operator shall send reports and notifications to:

Compliance Unit Supervisor

Air Quality Bureau

Iowa Department of Natural Resources

7900 Hickman Road, Suite 1

Windsor Heights, IA 50324

Telephone: (515) 725-9550

Fax: (515) 725-9502

IDNR Field Office 4

1401 Sunnyside Lane

Atlantic, IA 50022

Telephone: (712) 243-1934

Fax: (712) 243-6251 

9. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. 

Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 IAC 

Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless they are 

specifically changed by the permit amendment. The previous, unchanged permit provisions are included in the 

amendment for your convenience only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of 

the issued permit. The written notice of appeal shall be filed with the Director of the Department with a copy to the 

Legal Services Bureau Chief at the following addresses:

Director

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319

Bureau Chief

Legal Services Bureau

Iowa Department of Natural Resources

502 East 9th Street

Des Moines, IA 50319
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10a. BACT Emission Limits

Pollutant lb/hr(1) tons/yr(2) Additional Limits

Lead (Pb) NA 0.55 0.0047 lb/ton of metal charged(1)

(1) Standard is expressed as the average of 3 runs. 

(2) Standard is a 12-month rolling total. 

10b. Other Emission Limits

Pollutant lb/hr(1) tons/yr(2) Additional Limits Reference

(567 IAC)

Particulate Matter (PM) 33.8(3) NA See Footnote 4 23.1(4)”dz”

(5)

PM10 33.8(6) NA NA NAAQS

PM2.5 NA NA NA NA

Opacity NA NA See Footnote 7 23.3(2)”d”

Sulfur Dioxide (SO2) 2.00(6)(8) NA 500 ppmv 23.3(3)”e”

Nitrogen Oxides (NOX) 30.0(6) NA NA PSD ‘Synthetic Minor’

Volatile Organic Compounds 5.77(6) NA NA PSD ‘Synthetic Minor’

Carbon Monoxide (CO) 6.00(6) NA NA PSD ‘Synthetic Minor’

Lead (Pb) 0.046(9) NA NA See Footnote 9

0.282(10) NA NA RACT

Metal HAP(11) NA NA See Footnote 4 23.1(4)”dz” (5)

Individual HAP NA 9.4(12) NA NESHAP Area Source

Total HAP NA 24.4(12) NA NESHAP Area Source

(1) Standard is expressed as the average of 3 runs. 

(2) Standard is a 12-month rolling total. 

(3) Emission limit requested by the facility (plant number 78-01-012). It should be noted this emission point is subject to 567 IAC 

23.4(4) which would have allowed an emission rate of 46.3 lb/hr.

(4) Per 40 CFR §63.10895(c)(1), emissions discharged to the atmosphere shall not exceed either:

 0.8 lb of PM per ton of metal charged or

 0.06 lb of total metal HAP per ton of metal charged

(5)

IAC reference to Subpart ZZZZZ (National Emission Standards for Hazardous Air Pollutants for Iron and Steel Foundries Area

Sources; 40 CFR §63.10880 – 40 CFR §63.10906) of the National Emission Standards for Hazardous Air Pollutants (NESHAP).

(6) Limit imposed in order for original project number 97-652 to be a synthetic minor. This project includes the following emission 

units: EU 27 (annealing oven, original permits 98-A-142 and 99-A-372), EU 28 (core oven, original permit 98-A-143), EU 29 

(casting machine, original permits 98-A-144 and 99-A-386), EU 30 (sand silo, original permit 98-A-145), EU 31 (cement silo, 

original permit 98-A-146), EU 32 (original permit 98-A-147), EU 33 (core making, original permit 98-A-148) and EU 34 

(miscellaneous heaters, fugitive emissions). (NOTE: Project 04-670 lowered SO2 and CO emission rate).

(7)

 Opacity limits are:

 Per 567 IAC 23.3(2)”d” the limit on the stack is 40%.

o An exceedance of the indicator opacity of no visible emissions will require the owner/operator to promptly 

investigate the emission unit and make corrections to operations or equipment associated with the exceedance. If 

exceedances continue after the corrections, the DNR may require additional proof to demonstrate compliance (e.g., 

stack testing).

 Per 40 CFR §63.10895(e), fugitive emissions shall not be discharged to the atmosphere from the foundry operations that 

exhibit opacity greater than 20% on a six (6) minute average except for one (1) six (6) minute average per hour that does 

not exceed 30%.

(8) Emission rate used in facility-wide dispersion modeling to demonstrate no exceedances of the National Ambient Air Quality 

Standards (NAAQS) was 9.0 lb/hr.

(9) Lead emission limit is an applicable requirement established in a federally enforceable Consent Decree entered in United States 

v. Griffin Pipe Products Co,, LLC, (Civil Action No. 1: 14-cv-0027-JAJ-RAW).

(10) The lead emission limit established in Iowa Department of Natural Resources Administrative Consent Order No. 2015-AQ-02 

to address the nonattainment designation for a portion of Pottawattamie County published in the Federal Register (76 FR 72097) 

on November 22, 2011.

(11) By definition (40 CFR §63.10906) total metal HAP is the sum of the concentrations of compounds of antimony (Sb), arsenic 

(As), beryllium (Be), cadmium (Cd), chromium (Cr), cobalt (Co), lead (Pb), manganese (Mn), mercury (Hg), nickel (Ni), and 

selenium (Se) as measured by EPA Method 29 (40 CFR Part 60, Appendix A-8).

(12) Plant-wide emission limit to ensure the facility (plant number 78-01-012) is an area source for the National Emission Standards 

for Hazardous Air Pollutants (NESHAP).
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11. Emission Point Characteristics

This emission point shall conform to the specifications listed below:

Parameter Value

Stack Height, (ft, from the ground) 100

Discharge Style Vertical, Unobstructed

Stack Opening (inches, diameter) 80

Exhaust Temperature (F) 295

Exhaust Flowrate (scfm) 77,000

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted 

emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process 

and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values 

stated, the owner or operator shall submit a request to the Department within thirty (30) days of the discovery to 

determine if a permit amendment is required or submit a permit application requesting to amend the permit.

12. Compliance Demonstration(s) 

Pollutant Compliance 

Demonstration

Compliance Methodology Frequency

PM – Federal No NA NA

PM – State No NA NA

PM10 No NA NA

PM2.5 No NA NA

Opacity No NA NA

SO2 No NA NA

NOx No NA NA

VOC No NA NA

CO No NA NA

Pb Yes Stack Testing Annual(2)

Metal HAP Yes(1) Stack Testing One-time(3) 

Individual HAP Yes Recordkeeping(4) 12-month rolling total

Total HAP Yes Recordkeeping(4) 12-month rolling total

(1) Testing shall be conducted per 40 CFR §63.10898.

(2) Pb testing shall be conducted on this emission point at a minimum frequency of once per calendar year. Following a written 

request by Griffin Pipe Products Company and approval by the Department, the testing frequency may be decreased following 

initial or subsequent performance testing.

(3)

If the individual HAP emissions exceed 7.05 tons per 12-month rolling period or the total HAP emissions exceed 18.3 tons per 

12-month rolling period for the facility, then annual compliance testing is required for the Metal HAP emissions.

(4) See Permit Condition 15 for demonstrating compliance with the Individual HAP and Total HAP emission limits.

If an initial compliance demonstration specified above is testing, the owner or the owner’s authorized agent shall 

verify compliance with the emission limitations contained in Permit Condition 10 within sixty (60) days after 

achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of 

the proposed equipment. 

If subsequent testing is specified above, the owner or the owner’s authorized agent shall verify compliance with the 

emission limitations contained in Permit Condition 10 according to the frequency and timeframe noted above.
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12. Compliance Demonstration(s) (Continued)

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the 

table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

PM – Federal 1 hour 40 CFR 60, Appendix A, Method 5

PM – State 1 hour 40 CFR 60, Appendix A, Method 5 

40 CFR 51 Appendix M Method 202

PM10 1 hour 40 CFR 51, Appendix M, 201A with 202

PM2.5 1 hour 40 CFR 51, Appendix M, 201A with 202

Opacity 1 hour 40 CFR 60, Appendix A, Method 22

SO2 1 hour 40 CFR 60, Appendix A, Method 6C

NOx 1 hour 40 CFR 60, Appendix A, Method 7E

VOC 1 hour 40 CFR 60, Appendix A, Method 25A

CO 1 hour 40 CFR 60, Appendix A, Method 10

Pb 1 hour 40 CFR 60, Appendix A, Method 12 or Method 29

Metal HAP 1 hour 40 CFR 60, Appendix A, Method 29

HAP 1 hour 40 CFR 60, Appendix A, Method 18

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the Department, 

each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs shall apply for 

compliance, unless otherwise indicated by the Department. 

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days 

before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the 

Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. 

Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It 

shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the 

Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, 

different, or more detailed testing requirements.

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be 

operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate 

specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where 

compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is 

the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) 

has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, 

continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to 

determine whether this unit(s) is in compliance.

13. New Source Performance Standards (NSPS) and 

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability

This emission unit is not subject to any of the New Source Performance Standards (NSPS) as there is not an NSPS for 

its source category.

This facility (plant number 78-01-012) is of the source category for NESHAP Subpart EEEEE (National Emission 

Standards for Hazardous Air Pollutants for Iron and Steel Foundries; 40 CFR §63.7680 – 40 CFR §63.7765). The 

facility is not subject at this time as it is classified as an area source for NESHAP purposes.

Since this facility (plant number 78-01-012) is an area source it is subject to NESHAP Subparts A (General Provisions; 

40 CFR §63.1 – 40 CFR §63.15) and ZZZZZ (National Emission Standards for Hazardous Air Pollutants for Iron and 

Steel Foundries Area Sources; 40 CFR §63.10880 – 40 CFR §63.10906).

Failure to include any NSPS or NESHAP requirements as a part of this permit does not relieve the permittee from the 

requirement to comply with all applicable NSPS or NESHAP requirements.
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14. Operating Limits

Operating limits for this emission unit shall be:

A. The production rate shall not exceed 235,150 tons of metal charged per rolling twelve-month period.

B. Griffin Pipe Products shall follow the Operating Limits detailed in Iowa Department of Natural Resources 

Administrative Consent Order No. 2015-AQ-02 Condition A-5.B or install a baghouse (CE-12) as per Condition 

B-1 of the Iowa Department of Natural Resources Administrative Consent Order No. 2015-AQ-02.

C. In addition to coke, the cupola may be fired with the following fuels at the listed rates:

Alternative Fuel Maximum Rate (tons/hr)

Wood 1

Rubber tires 1

Paper 1

Used paint 1

Roofing paper** 1

Scrap plastic containers 1

Fuel oil 1

** Roofing paper that contains asbestos shall not be charged in the cupola.

D. The sulfur content of any fuel used in the cupola shall not exceed 1% by weight.

E. The pressure drop across the baghouse (CE-10) shall be between 3.5 to 10.0 inches of water column based 

on a 5-minute average.

F. Maintain Baghouse (CE-10) according to manufacturer specifications and maintenance schedule.

G. The minimum temperature of the combustion chamber shall be 1,300oF or greater. The minimum 

temperature applies under normal operating conditions and does not apply during startup, shutdown, or 

malfunction periods. The combustion chamber is limited to firing on natural gas or propane.

H. Griffin Pipe Products shall develop a “startup, shutdown, malfunction (SSM) plan. The SSM plan shall be 

submitted to the Department within thirty (30) days of the issuance of this permit for approval by the 

Department. At a minimum the following requirements shall be included in the SSM plan as BACT work 

practices for SSM operations of the cupola:

 Startup:

(a) Ensure oxygen and nitrogen are available.

(b) Ensure the baghouses are ready and conditioned for operation.

(c) Start the baghouse and induced draft (ID) fan operation, if not already running.

(d) Turn on and check cooling water to the cupola shell and tuyeres.

(e) Put coke bed in cupola and ignite.

(f) Start cupola blast blower.

(g) Burn coke bed until fire comes out of tap hole.

(h) Check each tuyere sight to ensure coke bed is burning evenly.

(i) Turn off cupola blast blower

(j) Charge metallics, coke, limestone, and alloys.

(k) When cupola is full, turn on blast and start melting.

 Shutdown:

(a) Ensure baghouse and ID fan are fully functional during the shutdown sequence.

(b) Close the cap when there are approximately four (4) charges remaining in the cupola.

(c) Continue melting until molten iron flow begins to slow down.

(d) Turn the blast off.

(e) Clean out the iron runner.

(f) Drain the cupola.

(g) Open the cupola cap.

(h) The baghouse and ID fan shall continue to operate until the cupola has been shutdown.

 Malfunction:

During malfunction, the work practice standards shall be followed for the emission unit and its air 

pollution control equipment as stated in 467 IAC 24.1(4).
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14. Operating Limits (Continued)

I. The owner or operator shall implement the scrap management plan as specified in Standard Operating 

Procedure (SOP) Melt220CB.

J. The amount of SO2 treatment chemical used in the gas stream to the baghouse shall not exceed 383 lbs/hr.

K. The amount of heavy metal treatment chemical used in the gas stream to the baghouse shall not exceed 360 

lbs/hr.

L. Griffin Pipe Products may use any SO2 treatment chemical or heavy metal treatment chemical as long as it 

obtains prior approval from the Department. In order to obtain approval Griffin Pipe Products shall submit 

to the Department, in writing, the following information at least thirty (30) days prior to the use of the 

chemical:

 A cover letter detailing the request

 The name of the chemical

 The supplier or manufacturer

 The minimum rate to be used

 The maximum rate to be used

 A copy of the Material Safety Data Sheet (MSDS)

M. In addition, Griffin Pipe Products shall:

 Do all operation and maintenance required by NESHAP Subpart ZZZZZ per 40 CFR §63.10896; and,

 Do all monitoring required by NESHAP Subpart ZZZZZ per 40 CFR §63.10897 by the compliance 

date(s) required in NESHAP Subpart ZZZZZ.

15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of 

five (5) years and shall be available for inspection by the Department. Records shall be legible and maintained in an 

orderly manner. These records shall show the following:

A. Griffin Pipe Products shall maintain a record of the sulfur content of the coke used in the cupola. The facility 

shall obtain a Certificate of Analysis with every shipment of coke or perform a sulfur content analysis for 

every shipment.

B. When the alternative fuels listed under Permit Condition 14.C are used in the cupola, Griffin Pipe Products

shall record the date, type of fuel used, amount of each fuel used and the sulfur content of each fuel used.

C. A copy of the MSDS for any roofing paper that is to be fired in the cupola.

D. The cumulative tons of metal charged on a rolling-12-month basis for each month of operation.

E. Griffin Pipe Products shall follow the Operating Condition Monitoring and Recordkeeping requirements 

detailed in Iowa Department of Natural Resources Administrative Consent Order No. 2015-AQ-02 Condition 

A-6.B or install a baghouse (CE-12) as per Condition B-1 of the Iowa Department of Natural Resources 

Administrative Consent Order No. 2015-AQ-02.

F. Calculate and record the average pressure drop across the baghouse (CE-10) in inches of water column. The 

average pressure drop across the baghouse shall be expressed and recorded as the average of all pressure drop 

data measured during each 5-minute period.

G. Maintain a record of all inspections and maintenance activities and any action resulting from the inspection 

and maintenance activities of the baghouse (CE-10). 

H. The continuous measurements of the combustion chamber temperature.

I. A copy of the approved SSM plan and all records required by the plan. 

J. Retain on-site a copy of the approved Standard Operating Procedures (SOP) Melt220CB and all records 

required by the plan.
Griffin Pipe Products Co. Cupola (EP-2A) Page 11 of 12

Council Bluffs, Iowa 10-A-270-P1

15. Operating Condition Monitoring and Recordkeeping (Continued)

K. The name of the SO2 treatment chemical and its hourly injection rate.

L. The name of the heavy metal treatment chemical and its hourly injection rate.

M. A copy of the MSDS for each SO2 treatment chemical and heavy metal treatment chemical along with a copy 

of the Departmental approval for that chemical.

N. Calculate the individual HAP emissions from all operations in tons for the facility (Plant Number 78-01-012) 

on a monthly basis and keep a 12-month rolling total. Records for individual HAP emissions shall be kept 

on a monthly basis until the individual HAP emissions exceed 7.05 tons/yr. At this point the owner or 

operator shall immediately begin keeping a 365-day rolling total amount of individual HAP emitted at the 

facility (Plant Number 78-01-012). Calculation requirements will revert back to a monthly basis if the 365-

day rolling total is returned to below 7.05 tons/yr for individual HAP.

O. Calculate the total HAP emissions from all operations in tons for the facility (Plant Number 78-01-012) on a 

monthly basis and keep a 12-month rolling total. Records for total HAP emissions shall be kept on a monthly 

basis until the total HAP emissions exceed 18.3 tons/yr. At this point the owner or operator shall immediately 

begin keeping a 365-day rolling total amount of total HAP emitted at the facility (Plant Number 78-01-012). 

Calculation requirements will revert back to a monthly basis if the 365-day rolling total is returned to below 

18.3 tons/yr for total HAP.

P. In addition, Griffin Pipe Products shall keep all records as required by NESHAP Subpart ZZZZZ per 40 CFR 

§63.10899 by the compliance date required in NESHAP Subpart ZZZZZ.

16. Continuous Emission Monitoring

Continuous emission monitoring is not required by this permit at this time.

17. Permit History

Permit No. Proj. No. Description Date Stack Testing

10-A-270-P 10-030 Original PSD Permit

(supersedes Permit 71-A-009-S8)

12/07/10 Yes
Griffin Pipe Products Co. Cupola (EP-2A) Page 12 of 12

Council Bluffs, Iowa 10-A-270-P1

18. Description of Terms and Acronyms

The descriptions below are meant only as a brief explanation of terms contained within the permit and may not be 

the exact definition of the term or acronym as contained within the regulations.

acfm Actual cubic feet per minute

Applicant The owner, company official or authorized agent

Btu British thermal unit

C Degrees Celsius

Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form 

particulate matter immediately after discharge from the stack

CO2e Carbon dioxide equivalent which is the aggregate emissions of greenhouse gas (GHG)

emissions based on global warming potentials

Department Iowa Department of Natural Resources

dia. Diameter

F Degrees Fahrenheit

ft Foot

GHG Greenhouse Gas which is defined as being the group of carbon dioxide (CO2), methane 

(CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC), perfluorocarbons (PFC) and sulfur 

hexafluoride (SF6)

g grams

g/dscm Grams per dry standard cubic meter

gr Grains

gr/dscf Grains per dry standard cubic foot

gr/scf Grains per standard cubic foot

HAP Hazardous Air Pollutant(s)

hp horsepower

hr Hour

lb Pound

lb/hr Pounds per hour

m Meter

mg Milligram

MM Million

MW Megawatt

NA Not Applicable

PM2.5 Particulate Matter with an aerodynamic diameter equal to or less than 2.5 microns

PM10 Particulate Matter with an aerodynamic diameter equal to or less than 10 microns

PM – Federal Particulate Matter that does not include the condensable PM

PM – State Particulate Matter that includes condensable PM

ppm parts per million

ppmv parts per million by volume

ppmw parts per million by weight

scfm Standard cubic feet per minute

SHAP Single hazardous air pollutant

THAP Total hazardous air pollutants

tons/yr Tons per year

yr Year

END OF PERMIT