ADE 

Alabama Department of Environmental Management 

MAJOR SOURCE OPERATING PERMIT 

PERMITTEE: SANDERS LEAD COMPANY 

FACILITY NAME: SANDERS LEAD COMPANY 

FACILITY/PERMIT NO.: 210-0005 

LOCATION: TROY, ALABAMA 

In accordance with and subject to the provisions of the Alabama Air Pollution Control Act of 1971, as 

amended, Ala, Code 1975, §§22-28-1 to 22-28-23 (2006 Rplc. Vol. and 2007 Cum. Supp.) (the "AAPCA") 

and the Alabama Environmental Management Act, as amended, Ala. Code 1975, §§22-22A-1 to 

22-22A-15, (2006 Rplc. Vol. and 2007 Cum. Supp.) and rules and regulations adopted thereunder, and 

subject further to the conditions set forth in this permit, the Permittee is hereby authorized to construct, 

install and use the equipment, device or other article described above. 

Pursuant to the Clean Air Act of 1990, all conditions of this permit are federally enforceable by EPA, 

the Alabama Department of Environmental Management, and citizens in general. Those provisions 

which are not required under the Clean Air Act of 1990 are considered to be state permit provisions and 

are not federally enforceable by EPA and citizens in general. Those provisions are contained in separate 

sections of this permit. 

Issuance Date: 

Effective Date: 

Expiration Date: 

November 9, 2012 

November 9, 2012 

November 8, 2017 

Alabama Department of Environmental Management 

1 
TABLE OF CONTENTS 

GENERA.L PERMIT PRO'VI'SOS ............................................................................. 5 

SUMMARY PAGE BLAST FURNACE 1 & 2, AND AGGLOMERATION FURNACE 

(STACK 1) ......................................................................................................... 21 

PRO'VI'SOS FOR BLAST FURNACE 1 & 2, AND AGGLOMERATION FURNACE 

(STACK 1) ......................................................................................................... 22 

Applicability ................................................................................................................ 22 

Emission Standards ................................................................................................... 22 

Compliance and Performance Test Methods and Procedures ...................................... 24 

Recordkeeping and Reporting Requirements ............................................................... 26 

SUMMARY PAGE BLAST FURNACES 3 & 4 (STACK 5) ........................................ 29 

PRO'VI'SOS FOR BLAST FURNACES 3 & 4 (STACK 5) .......................................... 30 

Applicability ................................................................................................................ 30 

Emission Standards ................................................................................................... 30 

Compliance and Performance Test Methods and Procedures ...................................... 32 

Recordkeeping and Reporting Requirements ............................................................... 34 

SUMMARY PAGE BLAST FURNACES 1, 2, 3 AND 4 SANITARY HOODS (STACK 4 & 

~A) .................................................................................................................... :3«i 

PRO'VI'SOS FOR BLAST FURNACES 1, 2, 3 AND 4 SANITARY HOODS (STACK 4 & 

~A) .................................................................................................................... ~~ 

Applicability ................................................................................................................ 3 7 

Emission Standards ................................................................................................... 3 7 

Compliance and Performance Test Methods and Procedures ...................................... 38 

Recordkeeping and Reporting Requirements ............................................................... 40 

SUMMARY PAGE FOR SODA ASH STORAGE SILO ............................................. 41 

PRO'VI'SOS FOR SODA ASH STORAGE SILO ....................................................... 42 

Applicability ................................................................................................................ 4 2 

Emission Standards ................................................................................................... 42 

Compliance and Performance Test Methods and Procedures ...................................... 42 

Emission Monitoring ................................................................................................... 4 2 

Recordkeeping and Reporting Requirements ............................................................... 42 

2 
SUMMARY PAGE FOR ALLOYING KETTLES AND ALLOYING KETTLES HEATING 

SYSTEM ............................................................................................................ 43 

PROVISOS FOR ALLOYING KETTLES AND ALLOYING KETTLES HEATING 

SYSTEM ............................................................................................................ 44 

Applicability ................................................................................................................ 44 

Emission Standards ................................................................................................... 44 

Compliance and Performance Test Methods and Procedures ...................................... 45 

Emission Monitoring ................................................................................................... 46 

Recordkeeping _and Reporting Requirements ............................................................... 4 7 

SUMMARY PAGE FOR SLAG TREATMENT BUILDING (STACK 10) ...................... 48 

PROVISOS FOR SLAG TREATMENT FACILITY (STACK 10) ................................ 49 

Applicability ................................................................................................................ 4 9 

Emission Standards ................................................................................................... 4 9 

Compliance and Performance Test Methods and Procedures ...................................... 50 

Emission Monitoring ................................................................................................... 51 

Recordkeeping and Reporting Requirements ............................................................... 52 

SUMMARY PAGE BLAST FURNACE CANOPY HOODS AND BUILDING 

VENTILATION (STACK 11) ................................................................................. 53 

PROVISOS FOR BLAST FURNACE CANOPY HOODS AND BUILDING VENTILATION 

(STACK 11) ....................................................................................................... 54 

Applicability ................................................................................................................ 54 

Emission Standards ................................................................................................... 54 

Compliance and Performance Test Methods and Procedures ...................................... 55 

Recordkeeping and Reporting Requirements ............................................................... 56 

SUMMARY PAGE BATTERY BREAKER/SHREDDER BUILDING (STACK 12) ........ 57 

PROVISOS FOR BATTERY BREAKER/SHREDDER BUILDING (STACK 12) .......... 58 

Applicability ................................................................................................................ 58 

Emission Standards ................................................................................................... 58 

Compliance and Performance Test Methods and Procedures ...................................... 59 

Recordkeeping and Reporting Requirements ............................................................... 60 

3 
SUMMARY PAGE RAW MATERIAL STORAGE BUILDING (STACK 13) .................. 61 

PROVISOS FOR RAW MATERIAL STORAGE BUILDING (STACK 13) •••••••••••••••••••. 62 

Applicability ................................................................................................................ 62 

Emission Standards ................................................................................................... 62 

Compliance and Performance Test Methods and Procedures ...................................... 63 

Recordkeeping and Reporting Requirements ............................................................... 64 

APPENDIX CAM •••••••••••••••.••••••.•••••••••••••••••••••••••••••••••••.•••••••••••••••••••••••••••••••••.••. 65 

CO AND VOC PLAN FOR BLAST FURNACES 1 & 2 AFTERBURNERS (STACK 1) .. 66 

PARTICULATE MATTER CAM PLAN FOR STACK 1 BAGHOUSE .......................... 67 

PARTICULATE MATTER CAM PLAN FOR SANITARY BAGHOUSES STACK 4 AND 

STACK 4A •••.•••••.•.•.••.•.•...•...••..••....•..•.•.•.••••••.•••••••.•••.••••••••••••••••••.••.•.•...••.•.•..•.• 68 

CO AND VOC CAM PLAN FOR BLAST FURNACES 3 AND 4 AFTERBURNERS 

(STACK 5) •••••••.•••••.•••••.•.••...••••••••••••••••••••••••••••.•.•.•••••••••••••••••••••••••••••••.••••••••••••. 69 

PARTICULATE MATTER CAM PLAN FOR STACK 5 BAGHOUSE .......................... 70 

PARTICULATE MATTER CAM PLAN FOR SLAG TREATMENT BUILDING 

BAGHOUSE (STACK 10) •••••••••••••••••••••.•••••••••••••••••••••••••••••••••••••••••••••••.•••.••••••••••• 71 

PARTICULATE MATTER CAM PLAN FOR CANOPY HOODS AND FURNACE 

BUILDING VENTILATION BAGHOUSE (STACK 11) .............................................. 72 

PARTICULATE MATTER CAM PLAN FOR ALLOYING KETTLES AND ALLOYING 

KETTLE HEATING SYSTEM BAGHOUSE (STACK 14) .......................................... 73 

4 
General Permit Provisos 

Federally Enforceable Provisos Regulations 

1. Transfer 

This permit is not transferable, whether by operation of law Rule 335-3-16-.02(6) 

or otherwise, either from one location to another, from one 

piece of equipment to another, or from one person to 

another, except as provided in Rule 335-3-16-.13( 1)(a)5. 

2. Renewals 

An application for permit renewal shall be submitted at least Rule 335-3-16-.12(2) 

six (6) months, but not more than eighteen ( 18) months, 

before the date of expiration of this permit. 

The source for which this permit is issued shall lose its right 

to operate upon the expiration of this permit unless a timely 

and complete renewal application has been submitted within 

the time constraints listed in the previous paragraph. 

3. Severability Clause 

The provisions of this permit are declared to be severable Rule 335-3-16-.05(e) 

and if any section, paragraph, subparagraph, subdivision, 

clause, or phrase of this permit shall be adjudged to be 

invalid or unconstitutional by any court of competent 

jurisdiction, the judgment shall not affect, impair, or 

invalidate the remainder of this permit, but shall be confined 

in its operation to the section, paragraph, subparagraph, 

subdivisions, clause, or phrase of this permit that shall be 

directly involved in the controversy in which such judgment 

shall have been rendered. 

4. Compliance 

(a) The permittee shall comply with all conditions of Rule 335-3-16-.05(f) 

ADEM Admin. Code 335-3. Noncompliance with this 

permit will constitute a violation of the Clean Air Act 

of 1990 and ADEM Admin. Code 335-3 and may 

result in an enforcement action; including but not 

limited to, permit termination, revocation and 

reissuance, or modification; or denial of a permit 

renewal application by the permittee. 

(b) The permittee shall not use as a defense in an Rule 335-3-16-.05(g) 

enforcement action that maintaining compliance with 

conditions of this permit would have required halting 

or reducing the permitted activity. 

5 
General Permit Provisos 

Federally Enforceable Provisos Regulations 

5. Termination for Cause 

This permit may be modified, revoked, reopened, and Rule 335-3-16-.05(h) 

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 will not stay any 

permit condition. 

6. Property Rights 

The issuance of this permit does not convey any property Rule 335-3-16-.05(i) 

rights of any sort, or any exclusive privilege. 

7. Submission of Information 

8. 

The permittee must submit to the Department, within 30 Rule 335-3-16-.05U) 

days or for such other reasonable time as the Department 

may set, any information that the Department may request 

in writing to determine whether cause exists for modifying, 

revoking and reissuing, or terminating this permit or to 

determine compliance with this permit. Upon receiving a 

specific request, the permittee shall also furnish to the 

Department copies of records required to be kept by this 

permit. 

Economic Incentives, Marketable Permits, and 

Emissions Trading 

No permit revision shall be required, under any approved Rule 335-3-16-.05(k) 

economic incentives, marketable permits, emissions trading 

and other similar programs or processes for changes that 

are provided for in this permit. 

9. Certification of Truth, Accuracy, and Completeness: 

Any application form, report, test data, monitoring data, or Rule 335-3-16-.07(a) 

compliance certification submitted pursuant to this permit 

shall contain certification by a responsible official of truth, 

accuracy, and completeness except as provided in Rule 335-

3-16-.04(9)(b). This certification shall state that, based on 

information and belief formed after reasonable inquiry, the 

statements and information in the document are true, 

accurate and complete. 

6 
General Permit Provisos 

Federally Enforceable Provisos Regulations 

10. Inspection and Entry 

Upon presentation of credentials and other documents as Rule 335-3-16-.07(b) 

may be required by law, the permittee shall allow authorized 

representatives of the Alabama Department of 

Environmental Management and EPA to conduct the 

following: 

(a) Enter upon the permittee's premises where a source 

is located or emissions-related activity is conducted, 

or where records must be kept pursuant to the 

conditions of this permit; 

(b) Review andjor copy, at reasonable times, any records 

that must be kept pursuant to the conditions of this 

permit; 

(c) Inspect, at reasonable times, this facility's equipment 

(including monitoring equipment and air pollution 

control equipment), practices, or operations regulated 

or required pursuant to this permit; 

(d) Sample or monitor, at reasonable times, substances 

or parameters for the purpose of assuring compliance 

with this permit or other applicable requirements. 

11. Compliance Provisions 

(a) The permittee shall continue to comply with the Rule 335-3-16-.07(c) 

applicable requirements with which the company has 

certified that it is already in compliance. 

(b) The permittee shall comply in a timely manner with 

applicable requirements that become effective during 

the term of this permit. 

12. Compliance Certification 

A compliance certification shall be submitted annually by Rule 335-3-16-.07(e) 

January 8th of each year. 

(a) The compliance certification shall include the 

following: 

( 1) The identification of each term or condition of 

this permit that is the basis of the certification; 

7 
General Permit Provisos 

Federally Enforceable Provisos 

(2) The compliance status; 

(3) The method(s) used for determining the 

compliance status of the source, currently and 

over the reporting period consistent with Rule 

335-3-16-.05(3) (Monitoring and Recording 

Keeping Requirements); 

(4) Whether the method(s) or other means used to 

assure compliance provided continuous or 

intermittent data; 

(5) Such other facts as the Department may require 

to determine the compliance status of the 

source; 

(b) The compliance certification shall be submitted to : 

Alabama Department of Environmental Management 

Air Division 

P.O. Box 301463 

Montgomery, AL 36130-1463 

and to: 

Air and EPCRA Enforcement Branch 

EPA Region IV 

61 Forsyth Street, SW 

Atlanta, GA 30303 

13. Reopening for Cause 

Regulations 

Under any of the following circumstances, this permit will be Rule 335-3-16-.13(5) 

reopened prior to the expiration of the permit: 

(a) Additional applicable requirements under the Clean 

Air Act of 1990 become applicable to the permittee 

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 this permit is due to 

exp1re. 

(b) Additional requirements (including excess emissions 

requirements) become applicable to an affected 

source under the acid rain program. Upon approval 

by the Administrator, excess emissions offset plans 

8 
General Permit Provisos 

Federally Enforceable Provisos 

shall be deemed to be incorporated into this permit. 

(c) The Department or EPA determines that this permit 

contains a material mistake or that inaccurate 

statements were made in establishing the emissions 

standards or other terms or conditions of this permit. 

(d) The Administrator or the Department determines that 

this permit must be revised or revoked to assure 

compliance with the applicable requirements. 

14. Additional Rules and Regulations 

Regulations 

This permit is issued on the basis of Rules and Regulations §22-28-16(d), Code of 

existing on the date of issuance. In the event additional Alabama 1975, as 

Rules and Regulations are adopted, it shall be the permit amended 

holder's responsibility to comply with such rules. 

15. Equipment Maintenance or Breakdown 

(a) In case of shutdown of air pollution control Rule 335-3-1-.07(1),(2) 

equipment for scheduled maintenance, the intent to 

shut down shall be reported to the Department at 

least 24 hours prior to the planned shutdown, unless 

such shutdown is accompanied by the shutdown of 

the source which such equipment is intended to 

control. The Department shall be notified when 

maintenance on the air pollution control equipment is 

complete and the equipment is operating. 

(b) In the event that there is a breakdown of equipment 

or upset of process in such a manner as to cause, or 

is expected to cause, increased emissions of air 

contaminants which are above an applicable 

standard, the person responsible for such equipment 

shall notify the Director within 24 hours or the next 

working day and provide a statement giving all 

pertinent facts, including the estimated duration of 

the breakdown. The Director will be notified when the 

breakdown has been corrected. 

16. Operation of Capture and Control Devices 

All air pollution control devices and capture systems for §22-28-16(d), Code of 

which this permit is issued shall be maintained and Alabama 1975, as 

operated at all times in a manner so as to minimize the amended 

emissions of air contaminants. Procedures for ensuring that 

the above equipment is properly operated and maintained so 

as to minimize the emission of air contaminants shall be 

established. 

9 
General Permit Provisos 

Federally Enforceable Provisos Regulations 

17. Obnoxious Odors 

This permit is issued with the condition that, should Rule 335-3-1-.08 

obnoxious odors arising from the plant operations be verified 

by Air Division inspectors, measures to abate the odorous 

emissions shall be taken upon a determination by the 

Alabama Department of Environmental Management that 

these measures are technically and economically feasible. 

18. Fugitive Dust 

(a) Precautions shall be taken to prevent fugitive dust Rule 335-3-4-.02 

emanating from plant roads, grounds, stockpiles, 

screens, dryers, hoppers, ductwork, etc. 

(b) Plant or haul roads and grounds will be maintained 

in the following manner so that dust will not become 

airborne: 

(I) By the application of water any time the surface 

of the road is sufficiently dry to allow the 

creation of dust emissions by the act of wind or 

vehicular traffic; 

(2) By reducing the speed of vehicular traffic to a 

point below that at which dust emissions are 

created; 

(3) By paving; 

( 4) By the application of binders to the road surface 

at any time the road surface is found to allow 

the creation of dust emissions; or 

(5) By any combination of the above methods 

which results in the prevention of dust 

becoming airborne from the road surface. 

19. Additions and Revisions 

Any modifications to this source shall comply with the Rule 335-3-16-.13 and 

modification procedures in Rules 335-3-16-.13 or 335-3-16- .14 

.14. 

20. Recordkeeping Requirements 

(a) Records of required monitoring information of the Rule 335-3-16-. OS( c)(2) 

source shall include the following: 

10 
General Permit Provisos 

Federally Enforceable Provisos 

(1) The date, place, and time of all sampling or 

measurements; 

(2) The date analyses were performed; 

(3) The company or entity that performed the 

analyses; 

(4) The analytical techniques or methods used; 

(5) The results of all analyses; and 

(6) The operating conditions that existed at the 

time of sampling or measurement. 

(b) Retention of records of all required monitoring data 

and support information of the source for a period of 

at least 5 years from the date of the monitoring 

sample, measurement, report, or application. 

Support information includes all calibration and 

maintenance records and all original strip-chart 

recordings for continuous monitoring 

instrumentation and copies of all reports required by 

the permit. 

21. Reporting Requirements 

Regulations 

(a) Reports to the Department of any required monitoring Rule 335-3-16-.05(c)(3) 

shall be submitted at least every 6 months. All 

instances of deviations from permit requirements 

must be clearly identified in said reports. All required 

reports must be certified by a responsible official 

consistent with Rule 335-3-16-.04(9). 

(b) Deviations from permit requirements shall be 

reported within 48 hours or 2 working days of such 

deviations, including those attributable to upset 

conditions as defined in the permit. The report will 

include the probable cause of said deviations, and 

any corrective actions or preventive measures that 

were taken. 

22. Emission Testing Requirements 

Each point of emission which requires testing will be Rule 335-3-1-.05(3) 

provided with sampling ports, ladders, platforms, and other and Rule 335-3-1-

safety equipment to facilitate testing performed in .04( 1) 

accordance with procedures established by Part 60 of Title 

11 
General Permit Provisos 

Federally Enforceable Provisos 

40 of the Code of Federal Regulations, as the same may be 

amended or revised. 

The Air Division must be notified in writing at least 10 days 

in advance of all emission tests to be conducted and 

submitted as proof of compliance with the Department's air 

pollution control rules and regulations. 

To avoid problems concerning testing methods and 

procedures, the following shall be included with the 

notification letter: 

Regulations 

1. The date the test crew is expected to arrive, the date Rule 335-3-1-.04 

and time anticipated of the start of the first run, hoe 

many and which sources are to be tested, and the 

names of the persons and/ or testing company that 

will conduct the tests. 

2. A complete description of each sampling train to be 

used, including type of media used in determining 

gas stream components, type of probe lining, type of 

filter media, and probe cleaning method and solvent 

to be used (if test procedures requires probe 

cleaning). 

3. A description of the process(es) to be tested including 

the feed rate, any operating parameters used to 

control or influence the operations, and the rated 

capacity. 

4. A sketch or sketches showing sampling point 

locations and their relative positions to the nearest 

upstream and downstream gas flow disturbances. 

A pretest meeting may be held at the request of the source Rule 335-3-1-.04 

owner or the Air Division. The necessity for such a meeting 

and the required attendees will be determined on a case-bycase basis. 

All test reports must be submitted to the Air Division within 

30 days of the actual completion of the test unless an 

extension of time is specifically approved by the Air Division. 

23. Payment of Emission Fees 

Annual emission fees shall be remitted each year according Rule 335-1-7-.04 

to the fee schedule in ADEM Admin. CodeR. 335-1-7-.04. 

12 
General Permit Provisos 

Federally Enforceable Provisos Regulations 

24. Other Reporting and Testing Requirements 

Submission of other reports regarding monitoring records, Rule 335-3-1-.04(1) 

fuel analyses, operating rates, and equipment malfunctions 

may be required as authorized in the Department's air 

pollution control rules and regulations. The Department 

may require emission testing at any time. 

25. Title VI Requirements (Refrigerants) 

Any facility having appliances or refrigeration equipment, 40 CFR Part 82 

including air conditioning equipment, which use Class I or 

Class II ozone-depleting substances as listed in 40 CFR Part 

82, Subpart A, Appendices A and B, shall service, repair, 

and maintain such equipment according to the work 

practices personnel certification requirements, and 

certified recycling and recovery equipment specified in 40 

CFR Part 82, Subpart F. 

No person shall knowingly vent or otherwise release any 

Class I or Class II substance into the environment during 

the repair, servicing, maintenance, or disposal of any device 

except as provided in 40 CFR Part 82, Subpart F. 

The responsible official shall comply with all reporting and 

recordkeeping requirements of 40 CFR 82.166. Reports 

shall be submitted to the US EPA and the Department as 

required. 

26. Chemical Accidental Prevention Provisions 

If a chemical listed in Table 1 of 40 CFR Part 68.130 is 40 CFR Part 68 

present in a process in quantities greater than the threshold 

quantity listed in Table 1, then: 

(a) The owner or operator shall comply with the 

provisions in 40 CFR Part 68. 

(b) The owner or operator shall submit one of the 

following: 

( 1) A compliance schedule for meeting the 

requirements of 40 CFR Part 68 by the date 

provided in 40 CFR Part 68 § 68.10(a) or, 

(2) A certification statement that the source is in 

compliance with all requirements of 40 CFR 

Part 68, including the registration and 

submission of the Risk Management Plan. 

13 
General Permit Provisos 

Federally Enforceable Provisos Regulations 

27. Display of Permit 

This permit shall be kept under file or on display at all times Rule 335-3-14-.0l(l)(d) 

at the site where the facility for which the permit is issued is 

located and will make the permit readily available for 

inspection by any or all persons who may request to see it. 

28. Circumvention 

No person shall cause or permit the installation or use of Rule 335-3-1-.10 

any device or any means which, without resulting in the 

reduction in the total amount of air contaminant emitted, 

conceals or dilutes any emission of air contaminant which 

would otherwise violate the Division 3 rules and regulations. 

29. Visible Emissions 

Unless otherwise specified in the Unit Specific provisos of Rule 335-3-4-.01 ( 1) 

this permit, any source of particulate emissions shall not 

discharge more than one 6-minute average opacity greater 

than 20% in any 60-minute period. At no time shall any 

source discharge a 6-minute average opacity of particulate 

emissions greater than 40%. Opacity will be determined by 

40 CFR Part 60, Appendix A, Method 9, unless otherwise 

specified in the Unit Specific provisos of this permit. 

30. Fuel-Burning Equipment 

Unless otherwise specified in the Unit Specific provisos of Rule 335-3-4-.03 

this permit, no fuel-burning equipment may discharge 

particulate emissions in excess of the emissions specified in 

Part 335-3-4-.03. 

Unless otherwise specified in the Unit Specific provisos of 

this permit, no fuel- burning equipment may discharge 

sulfur dioxide emissions in excess of the emissions specified 

in Part 335-3-5-.01. Rule 335-3-5-.01 

31. Process Industries - General 

Unless otherwise specified in the Unit Specific provisos of Rule 335-3-4-.04 

this permit, no process may discharge particulate emissions 

in excess of the emissions specified in Part 335-3-4-.04. 

32. Averaging Time for Emission Limits 

Unless otherwise specified in the permit, the averaging time Rule 335-3-1-.05 

for the emission limits listed in this permit shall be the 

nominal time required by the specific test method. 

14 
General Permit Provisos 

Federally Enforceable Provisos 

33. Compliance Assurance Monitoring (CAM) 

Conditions (a) through (d) that follow are general conditions 

applicable to emissions units that are subject to the CAM 

requirements. Specific requirements related to each 

emissions unit are contained in the unit specific provisos 

and the attached CAM appendices. 

(a) Operation of Approved Monitoring 

( 1) Commencement of operation. The owner or operator 

shall conduct the monitoring required under this 

section and detailed in the unit specific provisos and 

CAM appendix of this permit (if required) upon 

issuance of the permit, or by such later date 

specified in the permit pursuant to §64.6(d). 

(2) Proper maintenance. At all times, the owner or operator 

shall maintain the monitoring, including but not 

limited to, maintaining necessary parts for routine 

repairs of the monitoring equipment. 

(3) Continued operation. Except for, as applicable, 

monitoring malfunctions, associated repairs, and 

required quality assurance or control activities 

(including, as applicable, calibration checks and 

required zero and span adjustments), the owner or 

operator shall conduct all monitoring in continuous 

operation (or shall collect data at all required 

intervals) at all times that the pollutant-specific 

emissions unit is operating. Data recorded during 

monitoring malfunctions, associated repairs, and 

required quality assurance or control activities shall 

not be used for purposes of this part, including data 

averages and calculations, or fulfilling a minimum 

data availability requirement, if applicable. The owner 

or operator shall use all the data collected during all 

other periods in assessing the operation of the control 

device and associated control system. A monitoring 

malfunction is any sudden, infrequent, not 

reasonably preventable failure of the monitoring to 

provide valid data. Monitoring failures that are caused 

in part by poor maintenance or careless operation are 

not malfunctions. 

(4) Response to excursions or exceedances. (a) Upon 

detecting an excursion or exceedance, the owner or 

operator shall restore operation of the pollutantspecific emissions unit (including the control device 

and associated capture system) to its normal or 

usual manner of operation as expeditiously as 

15 

Regulations 

40 CFR 64.7 
General Permit Provisos 

Federally Enforceable Provisos 

practicable in accordance with good air pollution 

control practices for minimizing emissions. The 

response shall include minimizing the period of any 

startup, shutdown or malfunction and taking any 

necessary corrective actions to restore normal 

operation and prevent the likely recurrence of the 

cause of an excursion or exceedance (other than 

those caused by excused startup or shutdown 

conditions). Such actions may include initial 

inspection and evaluation, recording that operations 

returned to normal without operator action (such as 

through response by a computerized distribution 

control system), or any necessary follow-up actions 

to return operation to within the indicator range, 

designated condition, or below the applicable 

emission limitation or standard, as applicable. 

(b) Determination of whether the owner or operator 

has used acceptable procedures in response to an 

excursion or exceedance will be based on 

information available, which may include but is 

not limited to, monitoring results, review of 

operation and maintenance procedures and 

records, and inspection of the control device, 

associated capture system, and the process. 

(a) Documentation of need for improved monitoring. 

After approval of monitoring under this part, if 

the owner or operator identifies a failure to 

achieve compliance with an emission limitation 

or standard for which the approved monitoring 

did not provide an indication of an excursion or 

exceedance while providing valid data, or the 

results of compliance or performance testing 

document a need to modify the existing indicator 

ranges or designated conditions, the owner or 

operator shall promptly notify the Department 

and, if necessary, submit a proposed 

modification to the permit to address the 

necessary monitoring changes. Such a 

modification may include, but is not limited to, 

reestablishing indicator ranges or designated 

conditions, modifying the frequency of 

conducting monitoring and collecting data, or 

the monitoring of additional parameters. 

16 

Regulations 
General Permit Provisos 

Federally Enforceable Provisos 

(b) Quality Improvement Plan (QIP) Requirements 

( 1) Based on the results of a determination made under 

Section 33(a)(4)(b) above, the Administrator or the 

permitting authority may require the owner or 

operator to develop and implement a QIP. Consistent 

with 40 CFR §64.6(c)(3), the permit may specify an 

appropriate threshold, such as an accumulation of 

exceedances or excursions exceeding 5 percent 

duration of a pollutant-specific emissions unit's 

operating time for a reporting period, for requiring 

the implementation of a QIP. The threshold may be 

set at a higher or lower percent or may rely on other 

criteria for purposes of indicating whether a 

pollutant-specific emissions unit is being maintained 

and operated in a manner consistent with good air 

pollution control practices. 

(2) Elements of a QIP: 

1. The owner or operator shall maintain a written QIP, if required, 

and have it available for inspection. 

2. The plan initially shall include procedures for evaluating the 

control performance problems and, based on the results of the 

evaluation procedures, the owner or operator shall modify the 

plan to include procedures for conducting one or more of the 

following actions, as appropriate: 

(i) Improved preventive maintenance practices. 

(ii) Process operation changes. " 

(iii) Appropriate improvements to control methods. 

(iv) Other steps appropriate to correct control 

performance. 

(v) More frequent or improved monitoring (only in 

conjunction with one or more steps under 

paragraphs (2)(b)(i) through (iv) above). 

(3) If a QIP is required, the owner or operator shall 

develop and implement a QIP as expeditiously as 

practicable and shall notify the Department if the 

period for completing the improvements contained in 

the QIP exceeds 180 days from the date on which the 

need to implement the QIP was determined. 

(4) Following implementation of a QIP, upon any 

subsequent determination pursuant to Section 

33(a)(4)(b) above, the Department may require that an 

17 

Regulations 

40 CFR 64.8 
General Permit Provisos 

Federally Enforceable Provisos 

owner or operator make reasonable changes to the 

QIP if the QIP is found to have: 

(a) Failed to address the cause of the control device 

performance problems; or 

(b) Failed to provide adequate procedures for 

correcting control device performance problems as 

expeditiously as practicable in accordance with 

good air pollution control practices for minimizing 

emissions. 

(5) Implementation of a QIP shall not excuse the owner or 

operator of a source from compliance with any 

existing emission limitation or standard, or any 

existing monitoring, testing, reporting or 

recordkeeping requirement that may apply under 

federal, state, or local law, or any other applicable 

requirements under the Act. 

(c) Reporting and Recordkeeping Requirements 

( 1) General reporting requirements 

On and after the date specified in Section 33(a)(1) 

above by which the owner or operator must use 

monitoring that meets the requirements of this part, 

the owner or operator shall submit monitoring 

reports to the permitting authority in accordance 

with ADEM Admin. CodeR. 335-3-16-.05(c)3. 

A report for monitoring under this part shall include, 

at a minimum, the information required under 

ADEM Admin. Code R. 335-3-16-.05(c)3. and the 

following information, as applicable: 

(i) Summary information on the number, duration 

and cause (including unknown cause, if 

applicable) of excursions or exceedances, as 

applicable, and the corrective actions taken; 

(ii) Summary information on the number, duration 

and cause (including unknown cause, if 

applicable) for monitor downtime incidents (other 

than downtime associated with zero and span or 

other daily calibration checks, if applicable); and 

(iii) A description of the actions taken to implement a 

QIP during the reporting period as specified in 

Section 33(b) above. Upon completion of a QIP, 

the owner or operator shall include in the next 

summary report documentation that the 

18 

Regulations 

40 CFR 64.9 
General Permit Provisos 

Federally Enforceable Provisos 

implementation of the plan has been completed 

and reduced the likelihood of similar levels of 

excursions or exceedances occurring. 

(2) General recordkeeping requirements. 

(a) The owner or operator shall comply with the 

recordkeeping requirements specified in ADEM 

Admin. Code R. 335-3-16-.05(c)2 .. The owner or 

operator shall maintain records of monitoring 

data, monitor performance data, corrective actions 

taken, any written quality improvement plan 

required pursuant to Section 33(b) above and any 

activities undertaken to implement a quality 

improvement plan, and other supporting 

information required to be maintained under this 

part (such as data used to document the 

adequacy of monitoring, or records of monitoring 

maintenance or corrective actions). 

(b) Instead of paper records, the owner or operator 

may maintain records on alternative media, such 

as microfilm, computer files, magnetic tape disks, 

or microfiche, provided that the use of such 

alternative media allows for expeditious inspection 

and review, and does not conflict with other 

applicable recordkeeping requirements. 

(d) Savings Provisions 

(1) Nothing in this part shall: 

(a) Excuse the owner or operator of a source from 

compliance with any existing emission limitation or 

standard, or any existing monitoring, testing, reporting 

or recordkeeping requirement that may apply under 

federal, state, or local law, or any other applicable 

requirements under the Act. The requirements of this 

part shall not be used to justify the approval of 

monitoring less stringent than the monitoring which is 

required under separate legal authority and are not 

intended to establish minimum requirements for the 

purpose of determining the monitoring to be imposed 

under separate authority under the Act, including 

monitoring in permits issued pursuant to title I of the 

Act. The purpose of this part is to require, as part of the 

issuance of a permit under title V of the Act, improved 

or new monitoring at those emissions units where 

monitoring requirements do not exist or are inadequate 

19 

Regulations 

40 CFR 64.10 
General Permit Provisos 

Federally Enforceable Provisos 

to meet the requirements of this part. 

(b)Restrict or abrogate the authority of the 

Department to impose additional or more 

stringent monitoring, recordkeeping, testing, or 

reporting requirements on any owner or operator 

of a source under any provision of the Act, 

including but not limited to sections 114(a)(l) and 

504(b), or state law, as applicable. 

(c)Restrict or abrogate the authority of the 

Department to take any enforcement action under 

the Act for any violation of an applicable 

requirement or of any person to take action under 

section 304 of the Act. 

20 

Regulations 
Summary Page Blast Furnace 1 & 2, and Agglomeration Furnace (Stack 1) 

Permitted 

Operating Schedule: 24 Hrs/ day x 7 Days/week x 52 Weeksjyr = 8760 Hrsjyr 

Emission limitations: 

Emission···Point '. ···~···~~·····o ··········oo·········- ·········oe&crtption ·····························~···-·········-~··r········-·····Pollutant-- ·······}····~.~-~~.~~~:!=:·-~~~~··· ··~··)····· Regulation Stack 1 ' Blast Furnaces No. 1 wl Afterburner, 1 PM 0.010 grldscf 1 Rule 335-3-14-.04 

Stack 1 

Stack 1 

Blast Furnace No. 2 wl Afterburner, 1 ! (5.65 lbslhr) (PSDIBACT) 

' 

1 and Agglomeration Furnace vented to 

1 common Baghouse Stack 1 

Blast Furnaces No. 1 w I Afterburner, PM* 

Blast Furnace No. 2 w I Afterburner, 

and Agglomeration Furnace vented to 

common Baghouse Stack 1 

Blast Furnaces No. 1 w I Afterburner, S02 

Blast Furnace No. 2 w I Afterburner, 

and Agglomeration Furnace vented to . 

common Baghouse Stack 1 · 

"\. 

2.64 lbslhr 

1462 lblhr 

computed from a 

rolling 24 hour 

average 

650 lbslhr or 325 

' lbslhr if only one 

blast furnace 

operating 

Rule 335-3-14-.04 

(Anti-PSD) 

Stack 1 ' 

Stack 1 

Stack 1 

Stack 1 

Blast Furnaces No. 1 w I Afterburner, 

Blast Furnace No. 2 w I Afterburner, 

and Agglomeration Furnace vented to 

common Baghouse Stack) .. 

Blast Furnaces No. 1 w I Afterburner, Pb 

Blast Furnace No. 2 w I Afterburner, 

and Agglomeration Furnace vented to , 

common Baghouse Stack 1 

Blast Furnaces No. 1 w I Afterburner, VOC (TGNMO) 

Blast Furnace No. 2 w I Afterburner, 

and Agglomeration Furnace vented to 

common Baghouse Stack 1 

Furnaces No. 1 w I Afterburner, THC 

Blast Furnace No. 2 w I Afterburner, 

and Agglomeration Furnace vented to 

common BagJ:1ou~t: $ta.c;l<J 

afterburner exit, 

based on a 3 hour 

average 

Less than 20% 

0.00087 grldscf 

,& 

or 17 

lbslhr if only one 

blast furnace 

operating 

40 CFR 63 Subpart X 

*Permitee shall be in compliance with emission limits no later than July 1, 2013 

21 
Provisos for Blast Furnace 1 & 2, and Agglomeration Furnace (Stack 1) 

Federally Enforceable Provisos Regulations 

Applicability 

1. These sources are subject to the applicable requirements of Rule 335-3-16-.03 

ADEM Admin. CodeR. 335-3-16-.03, "Major Source Operating 

Permits." 

2. These sources are subject to the applicable requirements of 40 40 CFR 63 Subpart X 

CFR Part 63 Subpart X, "National Emission Standards for Rule 335-3-11-.06 (23) 

Hazardous Air Pollutants from Secondary Lead Smelting." 

3. These sources are subject to the applicable requirements of 40 CFR 63 Subpart A 

Subpart A of 40 CFR Part 63, "General Provisions" as listed in 

Table 1 of Subpart X. 

4. These sources are subject to the applicable requirements of 40 40 CFR 60 Subpart L 

CFR Part 60 Subpart L, "Standards of Performance for Rule 335-3-10-.02 (12) 

Secondary Lead Smelters." 

5. These sources are subject to the applicable requirements of 40 CFR Part 60 Subpart 

Subpart A of 40 CFR Part 60, "General Provisions". A 

6. These sources are subject to the applicable requirements of Rule 335-3-4-.15 

ADEM Admin. Code R. 335-3-4-.15, "Secondary Lead 

Smelters." 

7. These sources are subject to the applicable requirements of Rule 335-3-14-.04 

ADEM Admin. CodeR. 335-3-14-.04, "Air Permits Authorizing 

Construction in Clean Air Areas [Prevention of Significant 

Deterioration Permitting (PSD)]." 

8. This source has enforceable limits in place in order to prevent Rule 335-3-14-.04 

it from being subject to the provisions of ADEM Admin. Code 

R. 335-3-14-.04, "Air Permits Authorizing Construction in 

Clean Air Areas (Prevention of Significant Deterioration]". 

9. This source has enforceable limits in place in order to provide Rule 335-3-1-.03 

for the attainment of the National Ambient Air Quality 

Standards. 

10. For particulate matter, Carbon Monoxide, and Volatile Organic 40 CFR Part 64 

Compounds this source is subject to the applicable 

requirements of 40 CFR Part 64, "Compliance Assurance 

Monitoring", to include General Proviso No. 33. 

Emission Standards 

1. Particulate Matter emissions from Stack 1 (Blast Furnaces 1 & Rule 335-3-14-.04 

2, and Agglomeration Furnace) shall not exceed 0.010 grjdscf (PSD/BACT) 

and 5.65 lbsjhr as determined by EPA Reference Method 5 as 

found in Appendix A of 40 CFR 60 (latest edition). 

22 
Federally Enforceable Provisos 

2. 

3. 

4. 

5. 

No later than July 1, 2013, the Particulate Matter emissions 

from Stack 1 (Blast Fumaces 1 & 2, and Agglomeration 

Fumace) shall not exceed 2.64 lbsjhr as determined by EPA 

Reference Method 5 as found in Appendix A of 40 CFR 60 

(latest edition). 

Lead emissions from Stack 1 (Blast Fumaces 1 & 2, and 

Agglomeration Furnace) shall not exceed 0.00087 gr j dscf and 

2.82 lbs/hr as determined by EPA Reference Method 12 or 

Method 29 as found in Appendix A of 40 CFR 60 (latest 

edition). 

No later than July 1, 2013, Lead emissions from Stack 1 

(Blast Furnaces 1 & 2, and Agglomeration Furnace) shall not 

exceed 0.258 lbjhr as determined by EPA Reference Method 

12 or Method 29 as found in Appendix A of 40 CFR 60 (latest 

edition). 

Sulfur Dioxide emissions from Stack 1 (Blast Fumaces 1 & 2, 

and Agglomeration Furnace) shall not exceed 1462 lbs/hr 

(computed from a rolling 24 hour average), as determined by 

the continuous emissions monitor or EPA Reference Method 6 

as found in Appendix A of 40 CFR 60 (latest edition). 

Regulations 

Rule 335-3-1-.03 

40 CFR 63.543(a) 

40 CFR 63.544(d) 

Rule 335-3-14-.04 

(PSD/BACT) 

Rule 33 5-3-1-.03 

Rule 335-3-14-.04 

(PSD/BACT) 

6. The opacity of emissions from these sources shall not exceed 40 CFR 60.122(a)(2) 

that designated as 20% opacity as determined by EPA 

Reference Method 9 as found in Appendix A of 40 CFR 60 

(latest edition). 

7. The emissions of Volatile Organic Compounds, as total Rule 335-3-14-.04 

gaseous non methane organics (TGNMO), from Stack 1 (Blast (Anti-PSD) 

Furnaces 1 & 2, and Agglomeration Furnace) shall not exceed 

34 lbsjhr (17 lbsjhr if only one blast furnace is operating) as 

determined by EPA Reference Method 25 of 40 CFR Part 60 

(las test edition). 

8. The emissions of Total Hydrocarbons (THC) from Stack 1 shall 40 CFR 63.543 

not exceed 360 ppmv, expressed as propane corrected to 4 % 

C02, as determined by EPA Reference Method 25A as found in 

Appendix A of 40 CFR 60 (latest edition). 

9. The afterbumer exit temperatures for the blast furnaces must Rule 335-3-14-.04 

be maintained at or above 1300°F, based on a rolling three (Anti-PSD) 

hour average. 

10. Carbon Monoxide emissions from Stack 1(Blast Furnaces 1 & Rule 335-3-14-.04 

2, and Agglomeration Furnace) shall not exceed 650 lbsjhr (Anti-PSD) 

(325 lbs/hr if only one blast fumace is operating) as 

determined by EPA Reference Method 10 as found in Appendix 

A of 40 CFR 60 (latest edition). 

23 
Federally Enforceable Provisos Regulations 

11. No later than July 1, 2013, these sources shall be operated in Rule 335-3-1-.03 

a total enclosure that is maintained at negative pressure at all 

times and vented to a control device designed to capture lead 

emissions. 

12. No later than July 1, 2013, the dust handling systems Rule 335-3-1-.03 

associated with Baghouse Stack 1 shall be enclosed to prevent 

fugitive emissions from these handling systems. 

13. No later than July 1, 2013, Sanders Lead Company shall Rule 335-3-1-.03 

implement all proposed control measures required by this 

permit. If an exceedence of the 2008 Lead National Ambient 

Air Quality Standard occurs during any three month period 

following July 1, 2013, Sanders Lead Company shall, within 

180 days, complete and submit a plan to identify which stack 

or stacks will be raised and to what extent. Sanders Lead 

Company shall have the plan implemented within 18 months 

of the exceedence. 

Compliance and Performance Test Methods and Procedures 

1. This source is subject to the applicable requirements of 40 40 CFR 63.547 

CFR 40 CFR Part 63 Subpart X, "National Emission Standards 

for Hazardous Air Pollutants from Secondary Lead Smelting" 

to include the Test Methods in §63.547. 

2. The 24 hour rolling average S02 emission rate shall be Rule 335-3-14-.04 

determined by the continuous emissions monitor or by EPA 

method 6 

3. Method 12 or 29 of 40 CFR Part 60, Appendix A shall be used 40 CFR 63.547 

in the determination of lead compound emissions from the 

stack. 

4. Method 25 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-14-.04 

determination of VOC (TGNMO) emissions from the stack. 

5. Method 25A of 40 CFR Part 60, Appendix A shall be used in 40 CFR 63.547 

the determination of total hydrocarbons (THC) emissions from 

the stack. 

6. For purposes of determining compliance with the THC limits, 40 CFR 63.547 

the procedures in 40 CFR Part 63 Subpart X §63.547 (c) shall 

be used. 

7. Method 5 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of particulate matter emissions from the stack. 

8. Method 9 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of opacity of the stack emissions. 

24 
Federally Enforceable Provisos Regulations 

9. Method 10 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of carbon monoxide emissions from the stack. 

10. Method 9 of 40 CFR Part 60, Appendix A, excluding Section Rule 335-3-4-.15(6) 

2.5 shall be used in the determination of opacity from 

emissions escaping the capture system from the charge doors, 

slag taps, and lead taps. 

Emission Monitoring 

1. This source is subject to the applicable requirements of 40 40 CFR 63.548 

CFR 40 CFR Part 63 Subpart X, "National Emission Standards 

for Hazardous Air Pollutants from Secondary Lead Smelting" to 

include the Monitoring Requirements in §63.548. 

2. Sanders Lead shall conduct lead compliance tests on Stack 1 40 CFR 63.543 

according to the schedule specified in §63.543 of 40 CFR Part 

63 Subpart X, "National Emission Standards for Hazardous Air 

Pollutants from Secondary Lead Smelting". Results will be 

reported to the Director within 60 days of completion of 

testing. The Director must be notified at least ten days in 

advance of all emissions tests that will be conducted and 

submitted as proof of compliance with 40 CFR Part 63 Subpart 

X and ADEM Rules and Regulations. 

3. Reference the Appendix for the monitoring reqirements for 40 40 CFR Part 64 

CFR Part 64, "Compliance Assurance Monitoring". 

4. The installed Continuous Opacity Monitoring System (COMS) Rule 335-3-14-.04 

for stack 1 will be operated and maintained using procedures 

in 40 CFR Part 60, Appendix B, Performance Specification 1. 

COMS data will be used to monitor compliance with the 

opacity standard. 

5. The installed Continuous Sulfur Dioxide Emissions Monitor for Rule 335-3-14-.04 

Stack 1 will be operated and maintained using procedures in 

40 CFR Part 60, Appendix B, Performance Specification 2. 

CEMS data will be used to monitor compliance with the S02 

standard. 

25 
Federally Enforceable Provisos Regulations 

6. A monitoring device for the continuous measurement and 40 CFR 63.548 

recording of the temperature of the gas stream at the exit of 

each afterburner. The monitoring device must operate in 

accordance with the provisions described in the monitoring 

requirements of 40 CFR Part 63 Subpart X, "National Emission 

Standards for Hazardous Air Pollutants from Secondary Lead 

Smelting" to include §63.548. 

7. A standard operating procedures manual shall be prepared 40 CFR 63.548 

and shall be adhered to as described in the monitoring 

requirements of 40 CFR Part 63 Subpart X, "National Emission 

Standards for Hazardous Air Pollutants from Secondary Lead 

Smelting" to include §63.548. 

8. Ambient air monitoring for sulfur dioxide must be conducted Rule 335-3-14-.04 

for the plant for which this permit is issued. The type, 

number, and location of these instruments must be approved 

by the Director. Collected data is to be submitted to this 

agency in a format and at a frequency specified by the 

Director. 

9. No later than July 1, 2013, the Permittee must install, operate Rule 335-3-1-.03 

and maintain a digital differential pressure monitoring system 

to continuously monitor each total enclosure. 

Recordkeeping and Reporting Requirements 

1. All upsets, accidents, or other events that create or cause Rule 335-3-14-.04 

higher than expected lead-bearing emissions that may impact 

ambient air quality will be reported to the Department by 

telephone no later than the next normal work day after the 

event. A monthly summary report of these events will be 

mailed to the Department no later than the fifth day of the 

following month. Negative reports will be submitted. 

26 
Federally Enforceable Provisos Regulations 

2. A written report of excess emissions for Stack 1, as defined Rule 335-3-14-.04 

below, will be submitted to the Department for each calendar 

quarter within the month following the quarter. The reports 

will include the following information: 

a. (1) Opacity. The magnitude of excess emissions of 20% 

or computed from six-minute averages. 

(2) S02. Emission rates over 1,462 lbs per hour as 

computed from a rolling 24-hour average. 

(3) Afterburner Exit Temperature. Each value below 

1,300° F computed from a rolling three-hour average. 

Note: Data recorded during periods of monitor system 

breakdowns, maintenance, adjustments, and 

calibration checks shall not be included in any of the 

above data averages. 

b. The date and time of commencement and completion of 

each time period of excess emissions. 

c. The nature and cause of the excess emissions (if known) 

and the corrective action taken or preventative measures 

adopted. 

d. The date and time identified each period during which 

either of the monitoring system were inoperative (except for 

zero and span checks) and the nature of the repairs or 

adjustments. 

e. Equations used to convert S02 emission data as monitored 

to the required reporting standards (lbsjhr) will be 

included in the report(s). 

f. When no excess emissions have occurred and the 

monitoring system(s) was not inoperative or did not require 

repair or adjustment, such information will be stated in 

the report. 

3. Should the emissions from Stack 1 exceed a six-minute average Rule 335-3-14-.04 

opacity of 20%, as determined by the COMS, the Department 

will be notified immediately. A decision will then be made on 

whether operations can continue or must be suspended until 

corrective measures are taken. 

27 
Federally Enforceable Provisos Regulations 

4. All the original data charts, performance evaluations, Rule 335-3-14-.04 

calibrations checks, adjustments, and maintenance records 

and other information regarding and generated by the 

afterburner temperature, opacity, S02 , and ambient air 

monitoring systems will be maintained in a permanent form 

suitable for inspection. The file shall be retained for at least 

five (5) years following the date of such measurements, 

maintenance, reports, and records. 

5. This facility will keep a record of when each furnace is Rule 335-3-14-.04 

operating and noting when both furnaces are operating 

simultaneously. 

6. The recordkeeping requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, records of the 

information that is specified in §63.550 shall be kept. 

7. The reporting requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, the reporting 

requirements listed in §63.550 shall be complied with. 

28 
Summary Page Blast Furnaces 3 & 4 (Stack 5) 

Permitted 

Operating Schedule: 24 Hrsjday x 7 Daysjweek x 52 Weeks/yr = 8760 Hrsjyr 

Emission limitations: 

Emission Point * I ............. Description . . ... ... .. ... . .. ..... .. . .. r . PoUutaii" . T . .EmiSsion limit r· . Regulation 

. .(.. "'' .,. ....... """"''' .. """"' .... ,. ..... , .. J .t . ' ... ''"' '"""'''''"~···· .............. ,.,.;, ... "". 

Stack 5 

Stack 5 

Stack 5 

Stack 5 

Stack 5 

Stack 5 

Stack 5 

Stack 5 

Stack 5 

Stack 5 

Blast Furnace No.3 wl Afterburner, 1 PM 1 0.010 grldscf , Rule 335-3-14-.04 

Blast Furnace No.4 wl Afterburner (6.00 lbslhr) I (PSDIBACT) 

f vented to common Baghouse Stack 5 I 

I 

Blast Furnace No. 3 w 1 Afterburner, 

J 

] PM* I 

1 

Blast Furnace No. 4 w I Afterburner 

···f·yer1t~ci tc) C:()rn_l11()r1 ?~g}1()\l13e.$tac:l:c? .. 1 1 Blast Furnace No. 3 w I Afterburner, i S02 

Blast Furnace No. 4 w I Afterburner 1 

i vented to common Baghouse Stack 5 

Blast Furnace No. 3 w I Afterburner, 

Blast Furnace No. 4 w I Afterburner 

: vented to common Baghouse Stack 5 

Blast Furnace No. 3 w I Afterburner, 1 CO 

f Blast Furnace No. 4 w I Afterburner 

, vented to common Baghouse Stack 5 

Blast Furnace No. 3 w I Afterburner, 

. Blast Furnace No. 4 w I Afterburner 

· vented to common Baghouse Stack 5 

Blast Furnace No.3 wl Afterburner, 

Blast Furnace No. 4 w I Afterburner 

vented to common Baghouse Stack 5 

Blast Furnace No. 3 w I Afterburner, 

Blast Furnace No. 4 w I Afterburner 1 vented to common Baghouse Stack 5 

Pb 

Pb* 

I 

i 1,253 lblhr 

: computed from a 1 rolling 24 hour 

I 

1 average 

650 lbslhr or 325 

lbslhr if only one 

blast furnace 

1 operating 

1300oF at the 

afterburner exit, 

, based on a 3 hour 

0.00087 grldscf 

& 

3.00 lbslhr 

0.258 lbslhr 

, , , , •••••n•••••••••••••nomo•""""'"''' ••""''"''"''"'''''""'''"''""''"""'"''''"-'"''''"''-'"t' "'"'"'"''''''''''"'''''-'''''"'' •--' 

Blast Furnace No. 3 w I Afterburner, I VOC (TGNMO) : 32 lbslhr or 16 

1 Blast Furnace No. 4 w I Afterburner 

1 vented to common Baghouse Stack 5 

I I lbslhr if only one 

! blast f;rrnace 

i operatmg 

i 

Blast Furna~e N~. ·3-;TA.it~;bur~e-r, r voc(TGNM6).Ti3.oooFaithe 

Blast Furnace No. 4 w I Afterburner [ afterburner exit, 

vented to common Baghouse Stack 5 based on a 3 hour 

average 

Rule 335-3-14-.04 

(Anti-PSD) 

, Rule 335-3-14-.04(9) 1 (PSDIBACT) 

1 40 CFR 63 Subpart X 

Rule 335-3- J 4-.04(9) 

(PSD/BACT) 

Rule 335-3-1-.03 

(SIP) 

1 ..... 

1 Rule 335-3-14-.04 

• (Anti-PSD) I 

Rule 335-3-14-.04 

(Anti-PSD) 

Blast Furnace No.3 wl Afterburner, 360 PPMV 40 CFR 63 Subpart X 

Blast Furnace No. 4 w I Afterburner 

· yer1teci to. c:ornrn()r! ?~glt()11S~ __ §t~_c_l:c _§ 

*Permitee shall be in compliance with the emission limits no later than July 1, 2013 

29 
Provisos for Blast Furnaces 3 & 4 (Stack 5) 

Federally Enforceable Provisos Regulations 

Applicability 

1. These sources are subject to the applicable requirements of Rule 335-3-16-.03 

ADEM Admin. Code R. 335-3-16-.03, "Major Source Operating 

Permits." 

2. These sources are subject to the applicable requirements of 40 40 CFR 63 Subpart X 

CFR Part 63 Subpart X, "National Emission Standards for Rule 335-3-11-.06 (23) 

Hazardous Air Pollutants from Secondary Lead Smelting." 

3. These sources are subject to the applicable requirements of 40 CFR 63 Subpart A 

Subpart A of 40 CFR Part 63, "General Provisions" as listed in 

Table 1 of Subpart X. 

4. These sources are subject to the applicable requirements of 40 40 CFR P 60 Subpart L 

CFR Part 60 Subpart L, "Standards of Performance for Rule 335-3-10-.02 ( 12) 

Secondary Lead Smelters." 

5. These sources are subject to the applicable requirements of 40 CFR 60 Subpart A 

Subpart A of 40 CFR Part 60, "General Provisions". 

6. These sources are subject to the applicable requirements of Rule 335-3-4-.15 

ADEM Admin. Code R. 335-3-4-.15, "Secondary Lead 

Smelters." 

7. These sources are subject to the applicable requirements of Rule 335-3-14-.04 

ADEM Admin. CodeR. 335-3-14-.04, "Air Permits Authorizing 

Construction in Clean Air Areas [Prevention of Significant 

Deterioration Permitting (PSD)]." 

8. This source has enforceable limits in place in order to prevent Rule 335-3-14-.04 

it from being subject to the provisions of ADEM Admin. Code 

R. 335-3-14-.04, "Air Permits Authorizing Construction m 

Clean Air Areas [Prevention of Significant Deterioration]". 

9. This source has enforceable limits in place in order to provide Rule 335-3-1-.03 

for the attainment of the National Ambient Air Quality 

Standards. 

10. For particulate matter, Carbon Monoxide, and Volatile Organic 40 CFR Part 64 

Compounds this source is subject to the applicable 

requirements of 40 CFR Part 64, "Compliance Assurance 

Monitoring", to include General Proviso No. 33. 

Emission Standards 

1. Particulate Matter emissions from Stack 5 shall not exceed Rule 335-3-14-.04 

0.010 grjdscf and 6.00 lbsjhr as determined by EPA (PSD/BACT) 

Reference Method 5 as found in Appendix A of 40 CFR 60 

(latest edition). 

30 
Federally Enforceable Provisos 

2. 

3. 

4. 

5. 

No later than July 1, 2013, Particulate Matter emissions from 

Stack 5 (Blast Furnaces 3 & 4) shall not exceed 2.64 lbsjhr as 

determined by EPA Reference Method 5 as found in Appendix 

A of 40 CFR 60 (latest edition 

Lead emissions from Stack 5 shall not exceed 0.00087 gr / dscf 

and 3.00 lbsjhr as deterrriined by EPA Reference Method 12 

or Method 29 as found in Appendix A of 40 CFR 60 (latest 

edition). 

No later than July 1, 2013, Lead emissions from Stack 5 

(Blast Furnaces 3 & 4) shall not exceed 0.258 lb/hr as 

determined by EPA Reference Method 12 or Method 29 as 

found in Appendix A of 40 CFR 60 (latest edition). 

Sulfur Dioxide emissions from Stack 5 (Blast Furnaces 3 & 4) 

shall not exceed 1,253 lbs/hr (computed from a rolling 24 

hour average), as determined by the continuous emissions 

monitor or EPA Reference Method 6 as found in Appendix A of 

40 CFR 60 (latest edition). 

Regulations 

Rule 335-3-1-.03 

40 CFR 63.543(a) 

Rule 335-3-14-.04 

(PSD/BACT) 

Rule 335-3-1-.03 

Rule 335-3-14-.04 

(PSD/BACT) 

6. The opacity of emissions from these sources shall not exceed Rule 335-3-14-.04 

that designated as 10% opacity as determined by EPA (PSD/BACT) 

Reference Method 9 as found in Appendix A of 40 CFR 60 

(latest edition). 

7. The emissions of Volatile Organic Compounds, as total Rule 335-3-14-.04 

gaseous non methane organics (TGNMO), from Stack 5 shall (Anti-PSD) 

not exceed 32 lbsjhr ( 16 lbs/hr if only one blast furnace is 

operating) as determined by EPA Reference Method 25 of 40 

CFR Part 60 (latest edition). 

8. The emissions of Total Hydrocarbons (THC) from Stack 5 shall 40 CFR 63.543 

not exceed 360 ppmv, expressed as propane corrected to 4 % 

C02. as determined by EPA Reference Method 25A as found in 

Appendix A of 40 CFR 60 (latest edition). 

9. The afterburner exit temperatures for the blast furnaces must Rule 335-3-14-.04 

be maintained at or above 1300°F, based on a rolling three (Anti-PSD) 

hour average. 

10. Carbon Monoxide emissions from Stack 5 (Blast Furnaces 3 & Rule 335-3-14-.04 

4) shall not exceed 650 lbsjhr (325 lbsjhr if only one blast (Anti-PSD) 

furnace is operating) as determined by EPA Reference Method 

10 as found in Appendix A of 40 CFR 60 (latest edition). 

11. No later than July 1, 2013, these sources shall be operated in Rule 335-3-1-.03 

a total enclosure that is maintained at negative pressure at all 

times and vented to a control device designed to capture lead 

emissions. 

31 
Federally Enforceable Provisos Regulations 

12. No later than July 1, 2013, the dust handling systems Rule 335-3-1-.03 

associated with Baghouse Stack 5 shall be enclosed to prevent 

fugitive emissions from these handling systems. 

13. No later than July 1, 2013, Sanders Lead Company shall Rule 335-3-1-.03 

implement all proposed control measures required by this 

permit. If an exceedence of the 2008 Lead National Ambient 

Air Quality Standard occurs during any three month period 

following July 1, 2013, Sanders Lead Company shall, within 

180 days, complete and submit a plan to identify which stack 

or stacks will be raised and to what extent. Sanders Lead 

Company shall have the plan implemented within 18 months 

of the exceedence. 

Compliance and Performance Test Methods and Procedures 

1. This source is subject to the applicable requirements of 40 40 CFR 63.547 

CFR 40 CFR Part 63 Subpart X, "National Emission Standards 

for Hazardous Air Pollutants from Secondary Lead Smelting" 

to include the Test Methods in §63.547. 

2. The 24 hour rolling average S02 emission rate shall be Rule 335-3-14-.04 

determined by the continuous emissions monitor or by EPA 

method 6 

3. Method 12 or 29 of 40 CFR Part 60, Appendix A shall be used 40 CFR 63.547 

in the determination of lead compound emissions from the 

stack. 

4. Method 25 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-14-.04 

determination of VOC (TGNMO) emissions from the stack. 

5. Method 25A of 40 CFR Part 60, Appendix A shall be used in 40 CFR 63.547 

the determination of total hydrocarbons (THC) emissions from 

the stack. 

6. For purposes of determining compliance with the THC limits, 40 CFR 63.547 

the procedures in 40 CFR Part 63 Subpart X §63.547 (c) shall 

be used. 

7. Method 5 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of particulate matter emissions from the stack. 

8. Method 9 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of opacity of the stack emissions. 

9. Method 10 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of carbon monoxide emissions from the stack 

32 
Federally Enforceable Provisos Regulations 

10. Method 9 of 40 CFR Part 60, Appendix A, excluding Section Rule 335-3-4-.15(6) 

2.5 shall be used in the determination of opacity from 

emissions escaping the capture system from the charge doors, 

slag taps, and lead taps. 

Emission Monitoring 

1. This source is subject to the applicable requirements of 40 40 CFR 63.548 

CFR 40 CFR Part 63 Subpart X, "National Emission Standards 

for Hazardous Air Pollutants from Secondary Lead Smelting" to 

include the Monitoring Requirements in §63.548. 

2. Sanders Lead shall conduct lead compliance tests on Stack 5 40 CFR 63.543 

according to the schedule specified in §63.543 of 40 CFR Part 

63 Subpart X, "National Emission Standards for Hazardous Air 

Pollutants from Secondary Lead Smelting". Results will be 

reported to the Director within 60 days of completion of 

testing. The Director must be notified at least ten days in 

advance of all emissions tests that will be conducted and 

submitted as proof of compliance with 40 CFR Part 63 Subpart 

X and ADEM Rules and Regulations. 

3. Reference the Appendix for the monitoring reqirements for 40 40 CFR Part 64 

CFR Part 64, "Compliance Assurance Monitoring". 

4. The installed Continuous Opacity Monitoring System (COMS) Rule 335-3-14-.04 

for stack 1 will be operated and maintained using procedures 

in 40 CFR Part 60, Appendix B, Performance Specification 1. 

COMS data will be used to monitor compliance with the 

opacity standard. 

5. The installed Continuous Sulfur Dioxide Emissions Monitor for Rule 335-3-14-.04 

Stack 1 will be operated and maintained using procedures in 

40 CFR Part 60, Appendix B, Performance Specification 2. 

CEMS data will be used to monitor compliance with the S02 

standard. 

6. A monitoring device for the continuous measurement and 40 CFR 63.548 

recording of the temperature of the gas stream at the exit of 

each afterburner. The monitoring device must operate in 

accordance with the provisions described in the monitoring 

requirements of 40 CFR Part 63 Subpart X, "National Emission 

Standards for Hazardous Air Pollutants from Secondary Lead 

Smelting" to include §63.548. 

33 
Federally Enforceable Provisos Regulations 

7. A standard operating procedures manual shall be prepared 40 CFR 63.548 

and shall be adhered to as described in the monitoring 

requirements of 40 CFR Part 63 Subpart X, "National Emission 

Standards for Hazardous Air Pollutants from Secondary Lead 

Smelting" to include §63.548. 

8. Ambient air monitoring for sulfur dioxide must be conducted Rule 335-3-14-.04 

for the plant for which this permit is issued. The type, 

number, and location of these instruments must be approved 

by the Director. Collected data is to be submitted to this 

agency in a format and at a frequency specified by the 

Director. 

9. No later than July 1, 2013, the Permittee must install, operate Rule 335-3-1-.03 

and maintain a digital differential pressure monitoring system 

to continuously monitor each total enclosure. 

Recordkeeping and Reporting Requirements 

1. All upsets, accidents, or other events that create or cause Rule 335-3-14-.04 

higher than expected lead-bearing emissions that may impact 

ambient air quality will be reported to the Department by 

telephone no later than the next normal work day after the 

event. A monthly summary report of these events will be 

mailed to the Department no later than the fifth day of the 

following month. Negative reports will be submitted. 

2. A written report of excess emissions, for Stack 5, as defined Rule 335-3-14-.04 

below, will be submitted to the Department for each calendar 

quarter within the month following the quarter. The reports 

will include the following information: 

a. (1) Opacity. The magnitude of excess emissions of 10% 

or computed from six-minute averages. 

(2) S02. Emission rates over 1,253 lbs per hour as 

computed from a rolling 24-hour average. 

(3) Afterburner Exit Temperature. Each value below 

1,300° F computed from a rolling three-hour average. 

Note: Data recorded during periods of monitor system 

breakdowns, maintenance, adjustments, and 

calibration checks shall not be included in any of the 

above data averages. 

34 
Federally Enforceable Provisos 

b. The date and time of commencement and completion of 

each time period of excess emissions. 

c. The nature and cause of the excess emissions (if known) 

and the corrective action taken or preventative measures 

adopted. 

d. The date and time identified each period during which 

either of the monitoring system were inoperative (except for 

zero and span checks) and the nature of the repairs or 

adjustments. 

e. Equations used to convert S02 emission data as monitored 

to the required reporting standards (lbs/hr) will be 

included in the report(s). 

f. When no excess emissions have occurred and the 

monitoring system(s) was not inoperative or did not require 

repair or adjustment, such information will be stated in 

the report. 

Regulations 

3. Should the emissions from Stack 5 exceed a six-minute average Rule 335-3-14-.04 

opacity of 10%, as determined by the COMS, the Department 

will be notified immediately. A decision will then be made on 

whether operations can continue or must be suspended until 

corrective measures are taken. 

4. All the original data charts, performance evaluations, Rule 335-3-14-.04 

calibrations checks, adjustments, and maintenance records 

and other information regarding and generated by the 

afterburner temperature, opacity, S02 , and ambient air 

monitoring systems will be maintained in a permanent form 

suitable for inspection. The file shall be retained for at least 

five (5) years following the date of such measurements, 

maintenance, reports, and records. 

5. This facility will keep a record of when each furnace is Rule 335-3-14-.04 

operating and noting when both furnaces are operating 

simultaneously. 

6. The recordkeeping requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, records of the 

information that is specified in §63.550 shall be kept. 

7. The reporting requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, the reporting 

requirements listed in §63.550 shall be complied with. 

35 
Summary Page Blast Furnaces 1, 2, 3 and 4 Sanitary Hoods (Stack 4 & 4a) 

Permitted 

Operating Schedule: 24 Hrsjday x 7 Days/week x 52 Weeks/yr"" 8760 Hrsjyr 

Emission limitations: 

··· ----·- ~-----T·--itouut&ilt ___ T _____ iliiSsion.umif·---r···--·--iegliia'tton: · -···· · ··~ 

I I i 

~ '' •. , ... ~·" •'. ·~ '•-« ' ......... ~ ....... ~ •. ·..,-···-····~·-·· 

Emission Point Description 

. . ! , .... , ... J.......... ·t·· .... ... , ... L . .. * 

Stack 4 

Stack 4 

Stack 4 

Stack 4a 

Sanitary Baghouse Stack 4: 

• Furnace No. 1 Sanitary Hoods 

• Furnf!..c~.No. 2 §<tf1itary Hoods 

Sanitary Baghouse Stack 4: 

• Furnace No. 1 Sanitary Hoods 

• Furnace No. 2 Sanitary Hoods 

i Sanitary Baghouse Stack 4: 

• Furnace No. 1 Sanitary Hoods 

• Furnace No. 2 SanitaryHoods 

Sanitary Baghouse Stack 4: 

• Furnace No. 1 Sanitary Hoods 

• Furnace No. 2 Sanitary Hoods 

Sanitary Baghouse Stack 4: 

PM* 

Pb* 

THC 

' Opacity I 

• Furnace No. 1 Sanitary Hoods 

~urnace.No. 2$.:tnitaryHo()cl~ .... + 

Sanitary Baghouse Stack 4a Including: 1 PM* 

Furnace No. 3 Sanitary Hoods · 

Furnace No. 4 Sanitary Hoods 

Threej~J .. f?}l.le_].)_ll~t §toE;;tg~ I3irls -\- _ _ __ 

Sanitary Baghouse Stack 4a Including: 1 Pb* 

• Furnace No. 3 Sanitary Hoods 

• Furnace No. 4 Sanitary Hoods 

• Three (3) Flue Dust Storage Bins 

t· .. 

Stack 4a Sanitary Baghouse Stack 4a Including: ! Pb** 

• Furnace No. 3 Sanitary Hoods 

• Furnace No. 4 Sanitary Hoods 

1 • 'filree {~) Flue l)_llst $t()ra,ge. f3ir1s 

Stack 4a Sanitary Baghouse Stack 4a Including: THC 

• Furnace No. 3 Sanitary Hoods 

• Furnace No. 4 Sanitary Hoods 

• .... 'fil_re~ (:3Jf?111~ l)_llst §tora,g~ f3ir1s ... j.. _ ··-······ . 

Sanitary Baghouse Stack 4a Including: 1 Opacity 

r • Furnace No. 3 Sanitary Hoods 

• Furnace No. 4 Sanitary Hoods 

Three (}) ~l11e l)_ll::;t_§tcrr(lg~ .J?irls. 

*Combined PM Emission Limit from Stack 4 and Stack 4a 

0.0039 grjdscf 

, (1.62 lbsjhr) 

0.00087 gr/dscf I 

I& 

20 PPMV 

(see general provisos) 

i t .. 

i 0.0039 grjdscfnot to 

i exceed 1.62 lbs/hr 

.. ( ..... ---·-·--··········· ···············-··· i 0.00087 gr/dscf 

& 

I 0.41 lbs/hr 

0.022 lbsjhr 

I 

I ··+··· ............................................ _ .................. , ....................... _ .... ···: : (see general provisos) 

I 

I 

I ·'. 

**Permitee shall be in compliance with the emission limits no later than July 1, 2013 

36 

Rule 335-3-14-.04(9) 

(PSD/BACT) 

40 CFR 63 Subpart X 

Rule 335-3-14-.04(9) 

(PSD/BACT) 

Rule 335-3-1-.03 

(SIP) 

I • 

• 40 CFR 63 Subpart X 

Rule 335-3-4-.01(1) 

40 CFR 63 Subpart X 

I Rule 335-3-14-.04(9) 

(PSDjBACT) 

Rule 335-3-1-.03 

(SIP) 

Rule 335-3-4-.01(1) 
Provisos for Blast Furnaces 1, 2, 3 and 4 Sanitary Hoods (Stack 4 & 4a) 

Federally Enforceable Provisos Regulations 

Atmlicability 

1. These sources are subject to the applicable requirements of Rule 335-3-16-.03 

ADEM Admin. CodeR. 335-3-16-.03, "Major Source Operating 

Permits." 

2. These sources are subject to the applicable requirements of 40 40 CFR 63 Subpart X 

CFR Part 63 Subpart X, "National Emission Standards for Rule 335-3-11-.06 (23) 

Hazardous Air Pollutants from Secondary Lead Smelting." 

3. These sources are subject to the applicable requirements of 40 CFR 63 Subpart A 

Subpart A of 40 CFR Part 63, "General Provisions" as listed in 

Table 1 of Subpart X. 

4. These sources are subject to the applicable requirements of Rule 335-3-4-.15 

ADEM Admin. Code R. 335-3-4-.15, "Secondary Lead 

Smelters." 

5. These sources are subject to the applicable requirements of Rule 335-3-14-.04 

ADEM Admin. CodeR. 335-3-14-.04, "Air Permits Authorizing 

Construction in Clean Air Areas [Prevention of Significant 

Deterioration Permitting (PSD)]." 

6. This source has enforeceable limits in place in order to provide Rule 335-3-1-.03 

for the attainment of the National Ambient Air Quality 

Standards. 

7. For particulate matter this source is subject to the applicable 40 CFR Part 64 

requirements of 40 CFR Part 64, "Compliance Assurance 

Monitoring", to include General Proviso No. 33. 

Emission Standards 

1. This source shall not emit particulate matter of an opacity Rule 335-3-4-.01 

more than one 6-minute average greater than 20% in any 60-

minute period. At no time shall any source discharge a 6-

minute average opacity of particulate matter emissions greater 

than 40%. 

2. The combined particulate matter emissions from Stack 4 and Rule 335-3-14-.04 

Stack 4a shall not exceed 0.0039 gr / dscf and 1.62 lbs/hr as (PSD /BACT) 

determined by EPA Reference Method 5 as found in Appendix 

A of 40 CFR 60 (latest edition). 

3. The combined Lead emissions from Stack 4 and Stack 4a 40 CFR 63.543 

shall not exceed 0.00087 grjdscf and 0.41 lb/hr as 

determined by EPA Reference Method 12 or Method 29 as 

found in Appendix A of 40 CFR 60 (latest edition). 

37 

Rule 335-3-14-.04 

(PSD/BACT) 
Federally Enforceable Provisos Regulations 

4. No later than July 1, 2013, lead emissions from Stack 4 shall Rule 335-3-1-.03 

not exceed 0.022 lb/hr as determined by EPA Reference 

Method 12 or Method 29 as found in Appendix A of 40 CFR 60 

(latest edition). 

5. No later than July 1, 2013, lead emissions from Stack 4a shall Rule 335-3-1-.03 

not exceed 0.022 lbjhr as determined by EPA Reference 

Method 12 or Method 29 as found in Appendix A of 40 CFR 60 

(latest edition). 

6. The emissions of total hydrocarbons from the blast furnace 40 CFR 63.543 

charging process shall not exceed 20 ppmv. 

7. Visible emissions escaping the capture system (Blast Furnace Rule 335-3-4-.15 (6)(a) 

Canopy Hoods and Sanitary Hoods) for the charging door shall 

not exceed 10% opacity when charging the blast fumace. 

8. Visible emissions escaping the capture system (Blast Furnace Rule 335-3-4-.15 (6)(a) 

Canopy Hoods and Sanitary Hoods) for the closed charging 

door on the blast fumace shall not exceed 5% opacity during 

furnace operation. 

9. Visible emissions escaping the capture system (Blast Fumace Rule 335-3-4-.15 (6)(b) 

Canopy Hoods and Sanitary Hoods) for the slag tap and lead 

tap on the blast fumace shall not exceed 1% opacity. 

10. No later than July 1, 2013, these sources shall be operated in Rule 335-3-1-.03 

a total enclosure that is maintained at negative pressure at all 

times and vented to a control device designed to capture lead 

emissions. 

11. No later than July 1, 2013, Sanders Lead Company shall Rule 335-3-1-.03 

implement all proposed control measures required by this 

permit. If an exceedence of the 2008 Lead National Ambient 

Air Quality Standard occurs during any three month period 

following July 1, 2013, Sanders Lead Company shall, within 

180 days, complete and submit a plan to identify which stack 

or stacks will be raised and to what extent. Sanders Lead 

Company shall have the plan implemented within 18 months 

of the exceedence. 

Compliance and Performance Test Methods and Procedures 

1. Method 12 or 29 of 40 CFR Part 60, Appendix A shall be used 40 CFR 63.547 

in the determination of lead compound emissions from the 

stack. 

2. Method 25 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-14-.04 

determination of VOC (TGNMO) emissions from the stack. 

38 
Federally Enforceable Provisos Regulations 

3. Method 25A of 40 CFR Part 60, Appendix A shall be used in 40 CFR 63.547 

the determination of total hydrocarbons (THC) emissions from 

the stack. 

4. For purposes of determining compliance with the THC limits, 40 CFR 63.54 7 

the procedures in 40 CFR Part 63 Subpart X §63.547 (c) shall 

be used. 

5. Method 5 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of particulate matter emissions from the stack. 

6. Method 9 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of opacity of the stack emissions. 

Emission Monitoring 

1. This source is subject to the applicable requirements of 40 40 CFR 63.548 

CFR Part 63 Subpart X, "National Emission Standards for 

Hazardous Air Pollutants from Secondary Lead Smelting" to 

include the Monitoring Requirements in §63.548. 

2. If the Baghouses (Stack 4 and Stack 4a) are equipped with 40 CFR 63.548 

HEPA filters in accordance with 40 CFR 63 Subpart X, the 

Permittee shall monitor and record the pressure drop across 

the HEPA filter system daily. If the pressure drop is outside the 

limit specified by the filter manufacturer, maintenance 

inspections and/or corrective action are to be initiated. 

3. Sanders Lead shall conduct lead compliance tests on Stack 4 40 CFR 63.543 

and Stack 4a according to the schedule specified in §63.543 of 

40 CFR Part 63 Subpart X, "National Emission Standards for 

Hazardous Air Pollutants from Secondary Lead Smelting". 

Results will be reported to the Director within 60 days of 

completion of testing. The Director must be notified at least 

ten days in advance of all emissions tests that will be 

conducted and submitted as proof of compliance with 40 CFR 

Part 63 Subpart X and ADEM Rules and Regulations. 

4. Reference the Appendix for the monitoring reqirements for 40 40 CFR Part 64 

CFR Part 64, "Compliance Assurance Monitoring". 

5. A standard operating procedures manual shall be prepared 40 CFR 63.548 

and shall be adheared to as described in the monitoring 

requirements of 40 CFR Part 63 Subpart X, "National Emission 

Standards for Hazardous Air Pollutants from Secondary Lead 

Smelting" to include §63.548. 

39 
Federally Enforceable Provisos Regulations 

6. A bag leak detection system shall be operated in accordance 40 CFR 63.548 

with the provisions described irt the monitoring requirements 

of 40 CFR Part 63 Subpart X, "National Emission Standards 

for Hazardous Air Pollutants from Secondary Lead Smelting" to 

include §63.548, unless the Baghouses (Stack 4 and Stack 4a) 

are equipped with HEPA filters in accordance with 40 CFR 63 

Subpart X. 

7. No later than July 1, 2013, the Permittee must install, operate Rule 335-3-1-.03 

and maintain a digital differential pressure monitoring system 

to continuously monitor each total enclosure. 

Recordkeeping and Reporting Requirements 

1. The recordkeeping requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, records of the 

information that is specified in §63.550 shall be kept. 

2. The reporting requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, the reporting 

requirements listed in §63.550 shall be complied with. 

3. The Permittee shall maintain a record of all monitoring required Rule 335-3-16-.05 

by this permit. This shall include all problems observed and 

any corrective action taken. The records shall be maintained in 

a form suitable for inspection and shall be kept on site for a 

period of five (5) years. 

40 
Summary Page for Soda Ash Storage Silo 

Permitted 

Operating Schedule: 24 Hrs/day x 7 Days/week x 52 Weeks/yr = 8760 Hrsjyr 

Emission limitations: 

Emi&&ion···Point~,····r·········· ·············~~·········~·········Description ·····~·······~······~···~····m~-•• ~ •. ~ .. ~····[······~~~~=~~~:~·······~·······[·~·····~·~~~==~i:=··~~=tt·····~···~·······~·············~··~····Reguiation EP 018 1 Soda Ash Storage Silo with Bagfilter 1 PM 1 3.59 (P)062 · Rule 334-3-4-.04 I 

EP 018 

41 
Provisos for Soda Ash Storage Silo 

Federally Enforceable Provisos 

A pplica bili ty 

Regulations 

1. This source is subject to the applicable requirements of ADEM Rule 335-3-16-.03 

Admin. Code R. 335-3-16-.03, "Major Source Operating 

Permits." 

Emission Standards 

1. This source is subject to no additional specific requirements Nj A 

other than those listed in the General Permit Provisos. 

Compliance and Performance Test Methods and Procedures 

1. Method 5 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of particulate matter emissions from the stack. 

2. Method 9 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of opacity of the stack emissions. 

Emission Monitoring 

1. This source is subject to no additional specific requirements N j A 

other than those listed in the General Permit Provisos. 

Recordkeeping and Reporting Requirements 

1. This source is subject to no additional specific requirements Nj A 

other than those listed in the General Permit Provisos. 

42 
Summary Page for Alloying Kettles and Alloying Kettles Heating System 

Permitted 

Operating Schedule: 24 Hrsjday x 7 Daysjweek x 52 Weeksjyr = 

Emission limitations: 

Emission Point 1·r· "'*''"· .. ~·-·~" ...• ~ .... 

Description · ···· ............... ·- ···· l

1

····· ·· ·P'ouuta:lli ··· ···· ! ·····imi&&ion. um.it i 

l L.. 

Stack 5 

Stack 5 

Stack 5 

Stack 4 

Stack 4 

Stack 4 

Stack 4 

Stack 4 

Stack 4 

Stack 14 

Stack 14 

Stack 14 

Stack 14 

Stack 14 

Stack 14 

1 Eight Alloying Kettles vented to 

Baghouse Stack 5 f PM 

Eight Alloying Kettles vented to Opacity 

Baghouse Stack 5 

Eight Alloying Kettles vented to Pb 

Baghouse Stack 5 

Alloying Kettle Heating System vented PM* 1 to Baghouse Stack 4 

: Alloying Kettle Heating System vented Opacity 

: to Baghouse Stack 4 

i Alloying Kettle Heating System vented S02 

; to Baghouse Stack 4 

' Alloying Kettles & Heating System 

, vented to Baghouse Stack 14 j. '' •.........• 

: Alloying Kettles & Heating System 

' vented to Baghouse Stack 14 

*Combined Emission Limit from Stack 4 and Stack 4a 

, 0.010 grjdscf 1 (6.00 lbs/hr) 

Less than 1 0% 

. 0.00087 grjdscf I i& 

3.00 lbsjhr 

0.0039 grjdscf 

(1.62 lbsjhr) 

(see general 

provisos) 

N/A 

i 0.038 lbsjhr 

**Permitee shall be in compliance with the emission limits no later than July 1, 2013 

43 

8760 Hrsjyr 

··r· ... Regulation I 

I 

! 

Rule 335-3-14-.04(9) 

I (PSD/BACT) 

Rule 335-3-14-.04(9) 

(PSD/BACT) 

' 40 CFR 63 Subpart X 

i Rule335-3-14-.04(9) 

(PSD/BACT) 

Rule 335-3-14-.04(9) 

(PSD/BACT) 

Rule 335-3-4-.01(1) 

N/A 

Rule 335-3-1-.03 

(SIP) 
Provisos for Alloying Kettles and Alloying Kettles Heating System 

Federally Enforceable Provisos Regulations 

Applicability 

1. These sources are subject to the applicable requirements of Rule 335-3-16-.03 

ADEM Admin. Code R. 335-3-16-.03, "Major Source Operating 

Permits." 

2. These sources are subject to the applicable requirements of 40 40 CFR 63 Subpart X 

CFR Part 63 Subpart X, "National Emission Standards for Rule 335-3-11-.06 (23) 

Hazardous Air Pollutants from Secondary Lead Smelting." 

3. These sources are subject to the applicable requirements of 40 CFR 63 Subpart A 

Subpart A of 40 CFR Part 63, "General Provisions" as listed in 

Table 1 of Subpart X. 

4. These sources are subject to the applicable requirements of Rule 335-3-4-.15 

ADEM Admin. CodeR. 335-3-4-.15, "Secondary Lead Smelters." 

5. This source has enforeceable limits in place in order to provide Rule 335-3-1-.03 

for the attainment of the National Ambient Air Quality 

Standards. 

6. These sources are subject to the applicable requirements of Rule 335-3-14-.04 

ADEM Admin. CodeR. 335-3-14-.04, "Air Permits Authorizing 

Construction in Clean Air Areas [Prevention of Significant 

Deterioration Permitting (PSD)]." 

7. For particulate matter this source is subject to the applicable 40 CFR Part 64 

requirements of 40 CFR Part 64, "Compliance Assurance 

Monitoring", to include General Proviso No. 33. 

Emission Standards 

1. Particulate Matter emissions from Stack 5 shall not exceed Rule 335-3-14-.04 

0.010 grjdscfand 6.00 lbsjhr as determined by EPA Reference (PSD/BACT) 

Method 5 as found in Appendix A of 40 CFR 60 (latest edition. 

2. Sanders Lead shall not alloy in more than four (4) alloying Rule 335-3-14-.04 

kettles at any one time. (PSD /BACT) 

3. Lead emissions from Stack 5 shall not exceed 0.00087 gr j dscf 40 CFR 63.543(a) 

and 3.00 lbsjhr as determined by EPA Reference Method 12 or Rule 335_

3 _14_. 04 

Method 29 as found in Appendix A of 40 CFR 60 (latest (PSD /BACT) 

edition). 

4. The opacity of emissions from Stack 5 shall not exceed that Rule 335-3-14-.04 

designated as 10% opacity as determined by EPA Reference (PSD /BACT) 

Method 9 as found in Appendix A of 40 CFR 60 (latest edition). 

44 
Federally Enforceable Provisos 

5. The combined particulate matter emissions from Stack 4 and 

Stack 4a shall not exceed 0.0039 gr / dscf and 1.62 lbsjhr as 

determined by EPA Reference Method 5 as found in Appendix 

A of 40 CFR 60 (latest edition). 

6. The combined Lead emissions from Stack 4 and Stack 4a shall 

not exceed 0.00087 grjdscf and 0.41 lb/hr as determined by 

EPA Reference Method 12 or Method 29 as found in Appendix 

A of 40 CFR 60 (latest edition). 

7. No later than July 1, 2013, the Particulate Matter emissions 

from Stack 14 (Alloying Kettle and Heating System) shall not 

exceed 1.78 lbsjhr as determined by EPA Reference Method 5 

as found in Appendix A of 40 CFR 60 (latest edition). 

8. No later than July 1, 2013, the Lead emissions from Stack 14 

(Alloying Kettle and Heating System) shall not exceed 0.038 

lbjhr as determined by EPA Reference Method 12 or Method 

29 as found in Appendix A of 40 CFR 60 (latest edition). 

Regulations 

Rule 335-3-14-.04 

(PSD/BACT) 

40 CFR 63.543 

Rule 335-3-14-.04 

(PSD/BACT) 

Rule 335-3-1-.03 

Rule 335-3-1-.03 

9. No later than July 1, 2013, this source shall be equipped with Rule 335-3-1-.03 

a secondary HEPA filter system downstream of the Baghouse 

associated with Stack 14. 

10. No later than July 1, 2013, these sources shall be operated in Rule 335-3-1-.03 

a total enclosure that is maintained at negative pressure at all 

times and vented to a control device designed to capture lead 

emissions. 

11.No later than July 1, 2013, Sanders Lead shall conduct all Rule 335-3-1-.03 

maintenance activities associated with contaminated 

equipment within enclosed areas. Sanders Lead shall install 

transfer points at the refining, smelting, and raw material 

storage building exits to contain leaded vehicles within the 

buildings. Contaminated equipment leaving the enclosure shall 

be decontaminated prior to exiting the enclosure. 

12.No later than July 1, 2013, Sanders Lead Company shall Rule 335-3-1-.03 

implement all proposed control measures required by this 

permit. If an exceedence of the 2008 Lead National Ambient Air 

Quality Standard occurs during any three month period 

following July 1, 2013, Sanders Lead Company shall, within 

180 days, complete and submit a plan to identify which stack 

or stacks will be raised and to what extent. Sanders Lead 

Company shall have the plan implemented within 18 months 

of the exceedence. 

Compliance and Performance Test Methods and Procedures 

1. Method 12 of 40 CFR Part 60, Appendix A shall be used in the 40 CFR Part 63 Subpart 

determination of lead compound emissions from the stack. X §63.547 (a) & Rule 

335-3-11-.06 (23) 

45 
Federally Enforceable Provisos Regulations 

2. Method 5 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of particulate matter emissions from the stack. 

3. Method 9 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of opacity of the stack emissions. 

4. For purposes of determining compliance with the face velocity 40 CFR Part 63 Subpart 

requirements, the procedures in 40 CFR Part 63 Subpart X X §63.547 (d) & Rule 

§63.547 (d) shall be used. 335-3-11-.06 (23) 

5. Particulate matter and lead emissions may be determined 40 CFR Part 63 Subpart 

simultaneously by following the Alternative Test Methods for X §63.547 (a) & Rule 

Inorganic Lead described in 40 CFR Part 60, Method 12. 335-3-11-.06 (23) 

Emission Monitoring 

1. This source is subject to the applicable requirements of 40 40 CFR 63.548 

CFR Part 63 Subpart X, "National Emission Standards for 

Hazardous Air Pollutants from Secondary Lead Smelting" to 

include the Monitoring Requirements in §63.548. 

2. Reference the Appendix for the monitoring reqirements for 40 40 CFR Part 64 

CFR Part 64, "Compliance Assurance Monitoring". 

3. No later than July 1, 2013, the Permittee shall monitor and 40 CFR 63.548 

record the pressure drop across the HEPA filter system (Stack 

14), daily. If the pressure drop is outside the limit specified by 

the filter manufacturer, maintenance inspections and/ or 

corrective action are to be initiated according to the 

requirements described in 40 CFR Part 63 Subpart X, 

"National Emission Standards for Hazardous Air Pollutants 

from Secondary Lead Smelting" to include §63.548. 

4. A standard operating procedures manual shall be prepared 40 CFR 63.548 

and shall be adhered to as described in the monitoring 

requirements of 40 CFR Part 63 Subpart X, "National Emission 

Standards for Hazardous Air Pollutants from Secondary Lead 

Smelting" to include §63.548. 

5. A bag leak detection system shall be operated in accordance 40 CFR 63.548 

with the provisions described in the monitoring requirements 

of 40 CFR Part 63 Subpart X, "National Emission Standards 

for Hazardous Air Pollutants from Secondary Lead Smelting" to 

include §63.548, unless the Baghouses, associated with these 

sources, are equipped with HEPA filters in accordance with 40 

CFR 63 Subpart X. 

46 
Federally Enforceable Provisos 

6. Sanders Lead shall conduct lead compliance tests on the 

Stacks associated with these sources according to the schedule 

specified in §63.543 and §63.544 of 40 CFR Part 63 Subpart X, 

"National Emission Standards for Hazardous Air Pollutants 

from Secondary Lead Smelting". Results will be reported to the 

Director within 60 days of completion of testing. The Director 

must be notified at least ten days in advance of all emissions 

tests that will be conducted and submitted as proof of 

compliance with 40 CFR Part 63 Subpart X and ADEM Rules 

and Regulations. 

Regulations 

40 CFR 63.543 

40 CFR 63.544 

7. No later than July 1, 2013, the Permittee must install, operate Rule 335-3-1-.03 

and maintain a digital differential pressure monitoring system 

to continuously monitor each total enclosure. 

Recordkeeping and Reporting Requirements 

1. The recordkeeping requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, records of the 

information that is specified in §63.550 shall be kept. 

2. The reporting requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, the reporting 

requirements listed in §63.550 shall be complied with. 

3. The facility shall maintain a record of how many kettles are Rule 335-3-14-.04 

alloying at one time. The following records must be kept: 

(a) Date and time of alloying. 

(b) Which kettles are alloying 

These records shall be maintained in a form suitable for 

inspection for a period of (5) five years. 

4. The Permittee shall maintain a record of all monitoring Rule 335-3-16-.05 

required by this permit. This shall include all problems 

observed and any corrective action taken. The records shall be 

maintained in a form suitable for inspection and shall be kept 

on site for a period of five (5) years. 

47 
Summary Page for Slag Treatment Building (Stack 10) 

Permitted 

Operating Schedule: 24 Hrs/ day x 7 Daysjweek x 

Emission limitations: 

Stack 10 

Stack 10 

Stack 10 

Stack 10 

I 

. r Sl~g Treatment Facility with 

1 Baghouse 

I 

, Slag Treatment Facility with 

' Baghouse 

' 

! Slag Treatment Facility with 

Baghouse 

1 Slag Treatment Facility with 

Baghouse 

. Pb 

, PM** 

**Permitee shall be in compliance with the emission limits no 

Page 48 

52 Weeksjyr = 

: 0.00034 grjdscf 

(0.115 lbsjhr) 

1.70 lbs/hr 

8760 Hrsjyr 

Rule 335-3-14-.04 

(Anti-PSD) 

' Rule 335-3-1-.03 

i (SIP) 

i .,. 

Rule 335-3-1-.03 

'(SIP) 
Provisos for Slag Treatment Facility (Stack 10) 

Federally Enforceable Provisos Regulations 

Applicability 

1. This source is subject to the applicable requirements of ADEM Rule 335-3-16-.03 

Admin. Code R. 335-3-16-.03, "Major Source Operating 

Permits." 

2. This source is subject to the applicable requirements of 40 40 CFR 63 Subpart X 

CFR Part 63 Subpart X, "National Emission Standards for Rule 335-3-11-.06 (23) 

Hazardous Air Pollutants from Secondary Lead Smelting." 

3. This source is subject to the applicable requirements of 40 CFR 63 Subpart A 

Subpart A of 40 CFR Part 63, "General Provisions" as listed in 

Table 1 of Subpart X. 

4. This source is subject to the applicable requirements of ADEM Rule 335-3-4-.15 

Admin. CodeR. 335-3-4-.15, "Secondary Lead Smelters." 

5. This unit has an enforceable limit in order to prevent it from Rule 335-3-14-.04 

being subject to the provisions of ADEM Admin. Code R. 335-

3-14-.04, "Air Permits Authorizing Construction in Clean Air 

Areas [Prevention of Significant Deterioration]." 

6. This source has enforeceable limits in place in order to Rule 335-3-1-.03 

provide for the attainment of the National Ambient Air Quality 

Standards 

7. For particulate matter this source is subject to the applicable 40 CFR Part 64 

requirements of 40 CFR Part 64, "Compliance Assurance 

Monitoring", to include General Proviso No. 33. 

Emission Standards 

1. The Particulate Matter emissions from Stack 10 shall not Rule 335-3-14-.04 

exceed 0.01 gr/dscf and 3.38 lbs/hr as determined by EPA (Anti-PSD) 

Reference Method 5 as found in Appendix A of 40 CFR 60 

(latest edition). 

2. Lead emissions from Stack 10 shall not exceed 0.00034 Rule 335-3-14-.04 

gr/dscf and 0.115 lbs/hr as determined by EPA Reference (Anti-PSD) 

Method 12 or Method 29 as found in Appendix A of 40 CFR 

60 (latest edition). 

3. Untreated slag used for charging to the blast furnaces and Rule 335-3-14-.04 

untreated slag generated during periods when the slag (Anti-PSD) 

treatment facility is inoperative, may be stored in the Existing 

Raw Material Storage (ERMS) building. 

Page 49 
Federally Enforceable Provisos Regulations 

4. Except for personnel access, all exterior doors with the Rule 335-3-14-.04 

exception of the vehicle entrance door and the access to the (Anti-PSD) 

three slag delivery and pickup bins will be kept closed at all 

times. The vehicle entrance door and the three slag delivery 

and pickup bins will be covered with PVC strips. 

5. Necessary maintenance measures will be implemented to Rule 335-3-14-.04 

ensure that PVC strip door coverings provide at least 90% (Anti-PSD) 

coverage of the open areas. 

6. Slag awaiting analysis, stored in trucks outside the treatment Rule 335-3-14-.04 

facility will be covered to prevent entrainment. (Anti-PSD) 

7. No later than July 1, 2013, The Particulate Matter emissions Rule 335-3-1-.03 

from Stack 10 shall not exceed 1.70 lbsjhr as determined by 

EPA Reference Method 5 as found in Appendix A of 40 CFR 60 

(latest edition). 

8. No later than July 1, 2013, Lead emissions from Stack 10 Rule 335-3-1-.03 

shall not exceed 0.023 lbjhr as determined by EPA Reference 

Method 12 or Method 29 as found in Appendix A of 40 CFR 

60 (latest edition). 

9. The slag treatment operations shall be operated in a total 40 CFR 63.544 

enclosure that is maintained at negative pressure at all times 

and vented to a control device designed to capture lead 

emissions. 

10.No later than July 1, 2013, Sanders Lead Company shall Rule 335-3-1-.03 

implement all proposed control measures required by this 

permit. If an exceedence of the 2008 Lead National Ambient 

Air Quality Standard occurs during any three month period 

following July 1, 2013, Sanders Lead Company shall, within 

180 days, complete and submit a plan to identify which stack 

or stacks will be raised and to what extent. Sanders Lead 

Company shall have the plan implemented within 18 months 

of the exceedence. 

Compliance and Performance Test Methods and Procedures 

1. Method 12 or Method 29 of 40 CFR Part 60, Appendix A shall Rule 335-3-14-.04 

be used in the determination of lead compound emissions 

from the stack. 

2. Method 5 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of particulate matter emissions from the stack. 

3. Method 9 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of opacity of the stack emissions. 

Page 50 
Federally Enforceable Provisos Regulations 

4. Particulate matter and lead emissions may be determined Rule 335-3-14-.04 

simultaneously by following the Alternative Test Methods for 

Inorganic Lead described in 40 CFR Part 60, Method 12. 

Emission Monitoring 

1. Sanders Lead shall conduct lead emissions compliance tests 40 CFR 63.543 

on Stack 10 according to the schedule specified in §63.543 of 

40 CFR Part 63 Subpart X, "National Emission Standards for 

Hazardous Air Pollutants from Secondary Lead Smelting". 

Results will be reported to the Director within 60 days of 

completion of testing. The Director must be notified at least 

ten days in advance of all emissions tests that will be 

conducted and submitted as proof of compliance with 40 CFR 

Part 63 Subpart X and ADEM Rules and Regulations. 

2. Reference the Appendix for the monitoring reqirements for 40 40 CFR Part 64 

CFR Part 64, "Compliance Assurance Monitoring". 

3. This source is subject to the applicable requirements of 40 40 CFR 63.548 

CFR Part 63 Subpart X, "National Emission Standards for 

Hazardous Air Pollutants from Secondary Lead Smelting" to 

include the Monitoring Requirements in §63.548. 

4. If the Baghouse (Stack 10) is equipped with HEPA filters in 40 CFR 63.548 

accordance with 40 CFR 63 Subpart X, the Permittee shall 

monitor and record the pressure drop across the HEPA filter 

system daily. If the pressure drop is outside the limit specified 

by the filter manufacturer, maintenance inspections and/ or 

corrective action are to be initiated. 

5. A standard operating procedures manual shall be prepared 40 CFR 63.548 

and shall be adheared to as described in the monitoring 

requirements of 40 CFR Part 63 Subpart X, "National 

Emission Standards for Hazardous Air Pollutants from 

Secondary Lead Smelting" to include §63.548. 

6. A bag leak detection system shall be operated in accordance 40 CFR 63.548 

with the provisions described in the monitoring requirements 

of 40 CFR Part 63 Subpart X, "National Emission Standards 

for Hazardous Air Pollutants from Secondary Lead Smelting" 

to include §63.548, unless the Baghouse (Stack 10) is 

equipped with HEPA filters in accordance with 40 CFR 63 

Subpart X. 

7. No later than July 1, 2013, the Permittee must install, operate Rule 335-3-1-.03 

and maintain a digital differential pressure monitoring system 

to continuously monitor each total enclosure. 

Page 51 
Federally Enforceable Provisos Regulations 

Recordkeeping and Reporting Requirements 

1. The recordkeeping requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, records of the 

information that is specified in §63.550 shall be kept. 

2. The reporting requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, the reporting 

requirements listed in §63.550 shall be complied with. 

3. The Permittee shall maintain a record of all monitoring Rule 335-3-16-.05 

required by this permit. This shall include all problems 

observed and any corrective action taken. The records shall 

be maintained in a form suitable for inspection and shall be 

kept on site for a period of five (5) years. 

Page 52 
Summary Page Blast Furnace Canopy Hoods and Building Ventilation (Stack 11) 

Permitted 

Operating Schedule: 24 Hrsjday x 7 Days/week x 52 Weeksjyr = 8760 Hrsjyr 

Emission limitations: 

Emission Point# r Description -. - -"1 "pc)ftutaD.t" -T ----Emission Hn1if- -, - --Regulation 

I l ' I 

Stack 11 

Stack 11 

__ ,_ si~st-I?U;~a~~--c.;i1-0p)r-ii00ci; &-----------~-P-M···-----------·-- +·-2:i54-it;8"}1lr · ·-- ·1 Rule 335-3-1-.03 

I Furnace Building Ventilation w/ ! 1 (SIP) 

· Baghouse : · 

. Blast Furnace Canopy Hoods & - Tpt) I 1 Furnace Building Ventilation wj 1 

; Baghouse 1 

I 

Blast Furnace Canopy Hoods & 

Furnace Building Ventilation w/ 

' Baghouse 

Page 53 

+ 0.191 lbs/hr ''' ~· •i ... 

I !"""""""""" ................................ .. 

~ (see general provisos) 

' ... i .... ~ .. 
Provisos for Blast Furnace Canopy Hoods and Building Ventilation (Stack 11) 

Federally Enforceable Provisos Regulations 

Applicability 

1. These sources are subject to the applicable requirements of Rule 335-3-16-.03 

ADEM Admin. Code R. 335-3-16-.03, "Major Source Operating 

Permits." 

2. These sources are subject to the applicable requirements of 40 40 CFR Part 63 Subpart X 

CFR Part 63 Subpart X, "National Emission Standards for & Rule 335-3-11-.06 (23) 

Hazardous Air Pollutants from Secondary Lead Smelting." & 

3. These sources are subject to the applicable requirements of 40 CFR Part 63 Subpart A 

Subpart A of 40 CFR Part 63, "General Provisions" as listed in and X. 

Table 1 of Subpart X. 

4. This source has enforeceable limits in place in order to provide Rule 335-3-1-.03 

for the attainment of the National Ambient Air Quality 

Standards. 

5. These sources are subject to the applicable requirements of Rule 335-3-4-.15 

ADEM Admin. Code R. 335-3-4-.15, "Secondary Lead 

Smelters." 

6. For particulate matter this source is subject to the applicable 40 CFR Part 64 

requirements of 40 CFR Part 64, "Compliance Assurance 

Monitoring", to include General Proviso No. 33. 

Emission Standards 

1. No later than July 1, 2013, the Particulate Matter emissions Rule 335-3-1-.03 

from Stack 11 shall not exceed 2.04 lbs/hr as determined by 

EPA Reference Method 5 as found in Appendix A of 40 CFR 60 

(latest edition). 

2. No later than July 1, 2013, Lead emissions from Stack 11 shall Rule 335-3-1-.03 

not exceed 0.191lb/hr as determined by EPA Reference Method 

12 or Method 29 as found in Appendix A of 40 CFR 60 (latest 

edition). 

3. No later than July 1, 2013, this source shall be equipped with a Rule 335-3-1-.03 

secondary HEPA filter system downstream of the Baghouse 

associated with Stack 11. 

4. No later than July 1, 2013, these sources shall be operated in a Rule 335-3-1-.03 

total enclosure that is maintained at negative pressure at all 

times and vented to a control device designed to capture lead 

emiSSIOnS. 

Page 54 
Federally Enforceable Provisos Regulations 

5. No later than July 1, 2013, Sanders Lead shall conduct all Rule 335-3-1-.03 

maintenance activities associated with contaminated equipment 

within enclosed areas. Sanders Lead shall install transfer 

points at the refining, smelting, and raw material storage 

building exits to contain leaded vehicles within the buildings. 

Contaminated equipment leaving the enclosure shall be 

decontaminated prior to exiting the enclosure maintenance to a 

newly enclosed area and install transfer points at the refining, 

smelting, and raw material storage building exits to contain 

leaded vehicles within the buildings. 

6. No later than July 1, 2013, Sanders Lead Company shall Rule 335-3-1-.03 

implement all proposed control measures required by this 

permit. If an exceedence of the 2008 Lead National Ambient Air 

Quality Standard occurs during any three month period 

following July 1, 2013, Sanders Lead Company shall, within 

180 days, complete and submit a plan to identify which stack 

or stacks will be raised and to what extent. Sanders Lead 

Company shall have the plan implemented within 18 months of 

the exceedence. 

Compliance and Performance Test Methods and Procedures 

1. Method 12 or 29 of 40 CFR Part 60, Appendix A shall be used 40 CFR 63.547 

in the determination of lead compound emissions from the 

stack. 

2. Method 5 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of particulate matter emissions from the stack. 

3. Method 9 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of opacity of the stack emissions. 

Emission Monitoring 

1. This source is subject to the applicable requirements of 40 40 CFR 63.548 

CFR Part 63 Subpart X, "National Emission Standards for 

Hazardous Air Pollutants from Secondary Lead Smelting" to 

include the Monitoring Requirements in §63.548 

2. Reference the Appendix for the monitoring reqirements for 40 40 CFR Part 64 

CFR Part 64, "Compliance Assurance Monitoring". 

Page 55 
Federally Enforceable Provisos Regulations 

3. 'The Permittee shall monitor and record the pressure drop 40 CFR 63.548 

across the HEPA filter system, daily. If the pressure drop is 

outside the limit specified by the filter manufacturer, 

maintenance inspections and/ or corrective action are to be 

initiated according to the requirements described in 40 CFR 

Part 63 Subpart X, "National Emission Standards for 

Hazardous Air Pollutants from Secondary Lead Smelting" to 

include §63.548. 

4. Sanders Lead shall conduct lead compliance tests on Stack 11 40 CFR 63.543 

according to the schedule specified in §63.543 of 40 CFR Part 

63 Subpart X, "National Emission Standards for Hazardous Air 

Pollutants from Secondary Lead Smelting". Results will be 

reported to the Director within 60 days of completion of 

testing. The Director must be notified at least ten days in 

advance of all emissions tests that will be conducted and 

submitted as proof of compliance with 40 CFR Part 63 Subpart 

X and ADEM Rules and Regulations. 

5. A standard operating procedures manual shall be prepared 40 CFR 63.548 

and shall be adhered to as described in the monitoring 

requirements of 40 CFR Part 63 Subpart X, "National Emission 

Standards for Hazardous Air Pollutants from Secondary Lead 

Smelting" to include §63.548. 

6. No later than July 1, 2013, the Permittee must install, operate Rule 335-3-1-.03 

and maintain a digital differential pressure monitoring system 

to continuously monitor each total enclosure. 

Recordkeeping and Reporting Requirements 

1. The recordkeeping requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, records of the 

information that is specified in §63.550 shall be kept. 

2. The reporting requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, the reporting 

requirements listed in §63.550 shall be complied with. 

3. The Permittee shall maintain a record of all monitoring required Rule 335-3-16-.05 

by this permit. This shall include all problems observed and 

any corrective action taken. The records shall be maintained in 

a form suitable for inspection and shall be kept on site for a 

period of five (5) years. 

Page 56 
Summary Page Battery Breaker/Shredder Building (Stack 12) 

Permitted 

Operating Schedule: 24 Hrsjday x 7 Daysjweek x 52 Weeksjyr = 8760 Hrsjyr 

Emission limitations: 

. EmaS~D POint ·r· -. . DOSCripi!OD . ---- ·r PO~t··J-EuliBdOaHDiit r .. RiiUiit~O 

Stack 12 1 Batter Breaker/Shredder Building wj I PM j 1.78 lbs/hr l Rule 335-3-1-.03 

Stack 12 

Stack 12 

1 Baghouse I 1 i (SIP) I . 

I 

I Batter Breaker I Shredder Building w I 1 Pb 

· Baghouse 

Batter Breaker /Shredder Building 

Baghouse 

Page 57 

0.044 lbs/hr . Rule 335-3-1-.03 

: (SIP) 

Rule 335-3-4-.01(1) 
Provisos for Battery Breaker/Shredder Building (Stack 12) 

Federally Enforceable Provisos Regulations 

Applicability 

1. These sources are subject to the applicable requirements of Rule 335-3-16-.03 

ADEM Admin. CodeR. 335-3-16-.03, "Major Source Operating 

Permits." 

2. These sources are subject to the applicable requirements of 40 40 CFR Part 63 Subpart X 

CFR Part 63 Subpart X, "National Emission Standards for & Rule 335-3-11-.06 (23) 

Hazardous Air Pollutants from Secondary Lead Smelting." & 

3. These sources are subject to the applicable requirements of 40 CFR Part 63 Subpart A 

Subpart A of 40 CFR Part 63, "General Provisions" as listed in and X. 

Table 1 of Subpart X. 

4. This source has enforeceable limits in place in order to provide Rule 335-3-1-.03 

for the attainment of the National Ambient Air Quality 

Standards. 

5. These sources are subject to the applicable requirements of Rule 335-3-4-.15 

ADEM Admin. Code R. 335-3-4-.15, "Secondary Lead 

Smelters." 

Emission Standards 

1. No later than July 1, 2013, Particulate Matter emissions from Rule 335-3-1-.03 

Stack 12 (Battery Breaker I Shredder Building) shall not exceed 

1. 78 lbslhr as determined by EPA Reference Method 5 as found 

in Appendix A of 40 CFR 60 (latest edition). 

2. No later than July 1, 2013, Lead emissions from Stack 12 Rule 335-3-1-.03 

(Battery Breaker I Shredder Building) shall not exceed and 

0.044 lblhr as determined by EPA Reference Method 12 or 

Method 29 as found in Appendix A of 40 CFR 60 (latest edition). 

3. No later than July 1, 2013, this source shall be equipped with a Rule 335-3-1-.03 

secondary HEPA filter system downstream of the Baghouse 

associated with Stack 12. 

4. No later than July 1, 2013, these sources shall be operated in a Rule 335-3-1-.03 

total enclosure that is maintained at negative pressure at all 

times and vented to a control device designed to capture lead 

ermsswns. 

5. No later than July 1, 2013, the Permittee shall install a building Rule 335-3-1-.03 

connection tunnel for the transport of Group from the Battery 

Breaker-Shredder Building to the Raw Material Storage 

Building. 

Page 58 
Federally Enforceable Provisos Regulations 

6. No later than July 1, 2013, Sanders Lead Company shall Rule 335-3-1-.03 

implement all proposed control measures required by this 

permit. If an exceedence of the 2008 Lead National Ambient Air 

Quality Standard occurs during any three month period 

following July 1, 2013, Sanders Lead Company shall, within 

180 days, complete and submit a plan to identify which stack 

or stacks will be raised and to what extent. Sanders Lead 

Company shall have the plan implemented within 18 months of 

the exceedence. 

Compliance and Performance Test Methods and Procedures 

1. Method 12 or 29 of 40 CFR Part 60, Appendix A shall be used 40 CFR 63.547 

in the determination of lead compound emissions from the 

stack 

2. Method 5 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of particulate matter emissions from the stack 

3. Method 9 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of opacity of the stack emissions. 

Emission Monitoring 

1. This source is subject to the applicable requirements of 40 40 CFR 63.548 

CFR Part 63 Subpart X, "National Emission Standards for 

Hazardous Air Pollutants from Secondary Lead Smelting" to 

include the Monitoring Requirements in §63.548 

2. No later than July 1, 2013, the Permittee shall monitor and 40 CFR 63.548 

record the pressure drop across the HEPA filter system daily. If 

the pressure drop is outside the limit specified by the filter 

manufacturer, maintenance inspections and/ or corrective 

action are to be initiated according to the requirements 

described in 40 CFR Part 63 Subpart X, "National Emission 

Standards for Hazardous Air Pollutants from Secondary Lead 

Smelting" to include §63.548. 

Page 59 
Federally Enforceable Provisos Regulations 

3. Sanders Lead shall conduct lead compliance tests on Stack 12 40 CFR 63.543 

according to the schedule specified in §63.543 of 40 CFR Part 

63 Subpart X, "National Emission Standards for Hazardous Air 

Pollutants from Secondary Lead Smelting". Results will be 

reported to the Director within 60 days of completion of 

testing. The Director must be notified at least ten days in 

advance of all emissions tests that will be conducted and 

submitted as proof of compliance with 40 CFR Part 63 Subpart 

X and ADEM Rules and Regulations. 

4. A standard operating procedures manual shall be prepared 40 CFR 63.548 

and shall be adheared to as described in the monitoring 

requirements of 40 CFR Part 63 Subpart X, "National Emission 

Standards for Hazardous Air Pollutants from Secondary Lead 

Smelting" to include §63.548. 

5. No later than July 1, 2013, the Permittee must install, operate Rule 335-3-1-.03 

and maintain a digital differential pressure monitoring system 

to continuously monitor each total enclosure. 

Recordkeeping and Reporting Requirements 

1. The recordkeeping requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, records of the 

information that is specified in §63.550 shall be kept. 

2. The reporting requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, the reporting 

requirements listed in §63.550 shall be complied with. 

3. The Permittee shall maintain a record of all monitoring required Rule 335-3-16-.05 

by this permit. This shall include all problems observed and 

any corrective action taken. The records shall be maintained in 

a form suitable for inspection and shall be kept on site for a 

period of five (5) years. 

Page 60 
Summary Page Raw Material Storage Building (Stack 13) 

Permitted 

Operating Schedule: 24 Hrs/day x 7 Daysjweek x 52 Weeksjyr = 8760 Hrsjyr 

Emission limitations: 

E:miaaion Pohii~* T --- --- --· --neSCriJ)tiOil-~ -- --- ---~--T- --Ponutaif ____ T __ , imiSsion-mnit ---r-- ---iegiltat:ion 

1 J L I 

Stack 13 

Stack 13 

Stack 13 

Raw Material Storage Building wl ' PM ; 1.78 lbslhr Rule 335-3-1-.03 

, Baghouse : (SIP) 

I ... .. ····· .. 

Raw Material Storage Building w I 

; Baghouse 

1 Raw Material Storage Building w I ~ Baghouse 

I 

Pb 1 0.030 lbslhr Rule 335-3-1-.03 

, (SIP) 

, Opacity (see general provisos) Rule 335-3-4-.01 ( 1) 

Page 61 
Provisos for Raw Material Storage Building (Stack 13) 

Federally Enforceable Provisos Regulations 

Applicability 

1. These sources are subject to the applicable requirements of Rule 335-3-16-.03 

ADEM Admin. Code R. 335-3-16-.03, "Major Source Operating 

Permits." 

2. These sources are subject to the applicable requirements of 40 40 CFR Part 63 Subpart X 

CFR Part 63 Subpart X, "National Emission Standards for & Rule 335-3-11-.06 (23) 

Hazardous Air Poilu tan ts from Secondary Lead Smelting." & 

3. These sources are subject to the applicable requirements of 40 CFR Part 63 Subpart A 

Subpart A of 40 CFR Part 63, "General Provisions" as listed in and X. 

Table 1 of Subpart X. 

4. This source has enforeceable limits in place in order to provide Rule 335-3-1-.03 

for the attainment of the National Ambient Air Quality 

Standards. 

5. These sources are subject to the applicable requirements of Rule 335-3-4-.15 

ADEM Admin. Code R. 335-3-4-.15, "Secondary Lead 

Smelters." 

Emission Standards 

1. No later than July 1, 2013, the Particulate Matter emissions Rule 335-3-1-.03 

from Stack 13 (Raw Material Storage Building) shall not exceed 

1.78 lbs/hr as determined by EPA Reference Method 5 as found 

in Appendix A of 40 CFR 60 (latest edition). 

2. No later than July 1, 2013, the Lead emissions from Stack 13 Rule 335-3-1-.03 

(Raw Material Storage Building) shall not exceed 0.030 lbjhr 

as determined by EPA Reference Method 12 or Method 29 as 

found in Appendix A of 40 CFR 60 (latest edition). 

3. No later than July 1, 2013, this source shall be equipped with a Rule 335-3-1-.03 

secondary HEPA filter system downstream of the Baghouse 

associated with Stack 13. 

4. No later than July 1, 2013, these sources shall be operated in a Rule 335-3-1-.03 

total enclosure that is maintained at negative pressure at all 

times and vented to a control device designed to capture lead 

emissions . 

. 5. No later than July 1, 2013, the Permittee shall install a building Rule 335-3-1-.03 

connection tunnel for the transport of Group from the Battery 

Breaker-Shredder Building to the Raw Material Storage 

Building. 

Page 62 
Federally Enforceable Provisos Regulations 

6. No later than July 1, 2013, Sanders Lead shall conduct all Rule 335-3-1-.03 

maintenance activities associated with contaminated equipment 

within enclosed areas. Sanders Lead shall install transfer 

points at the refining, smelting, and raw material storage 

building exits to contain leaded vehicles within the buildings. 

Contaminated equipment leaving the enclosure shall be 

decontaminated prior to exiting the enclosure. 

7. No later than July 1, 2013, Sanders Lead Company shall Rule 335-3-1-.03 

implement all proposed control measures required by this 

permit. If an exceedence of the 2008 Lead National Ambient Air 

Quality Standard occurs during any three month period 

following July 1, 2013, Sanders Lead Company shall, within 

180 days, complete and submit a plan to identify which stack 

or stacks will be raised and to what extent. Sanders Lead 

Company shall have the plan implemented within 18 months of 

the exceedence 

Compliance and Performance Test Methods and Procedures 

1. Method 12 or 29 of 40 CFR Part 60, Appendix A shall be used 40 CFR 63.547 

in the determination of lead compound emissions from the 

stack. 

2. Method 5 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of particulate matter emissions from the stack. 

3. Method 9 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 

determination of opacity of the stack emissions. 

Emission Monitoring 

1. This source is subject to the applicable requirements of 40 40 CFR 63.548 

CFR Part 63 Subpart X, "National Emission Standards for 

Hazardous Air Pollutants from Secondary Lead Smelting" to 

include the Monitoring Requirements in §63.548 

2. No later than July 1, 2013, the Permittee shall monitor and Rule 335-3-1-.03 

record the pressure drop across the HEPA filter system, daily. 

If the pressure drop is outside the limit specified by the filter 

manufacturer, maintenance inspections and/ or corrective 

action are to be initiated according to the requirements 

described in 40 CFR Part 63 Subpart X, "National Emission 

Standards for Hazardous Air Pollutants from Secondary Lead 

Smelting" to include §63.548 

Page 63 
Federally Enforceable Provisos Regulations 

3. Sanders Lead shall conduct lead compliance tests on Stack 13 40 CFR 63.543 

according to the schedule specified in §63.543 of 40 CFR Part 

63 Subpart X, "National Emission Standards for Hazardous Air 

Pollutants from Secondary Lead Smelting". Results will be 

reported to the Director within 60 days of completion of 

testing. The Director must be notified at least ten days in 

advance of all emissions tests that will be conducted and 

submitted as proof of compliance with 40 CFR Part 63 Subpart 

X and ADEM Rules and Regulations. 

4. A standard operating procedures manual shall be prepared 40 CFR 63.548 

and shall be adheared to as described in the monitoring 

requirements of 40 CFR Part 63 Subpart X, "National Emission 

Standards for Hazardous Air Pollutants from Secondary Lead 

Smelting" to include §63.548. 

5. No later than July 1, 2013, the Permittee must install, operate Rule 335-3-1-.03 

and maintain a digital differential pressure monitoring system 

to continuously monitor each total enclosure. 

Recordkeeping and Reporting Requirements 

1. The recordkeeping requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, records of the 

information that is specified in §63.550 shall be kept. 

2. The reporting requirements under §63.10 of the General 40 CFR 63.550 

Provisions shall be adhered to. In addition, the reporting 

requirements listed in §63.550 shall be complied with. 

3. The Permittee shall maintain a record of all monitoring required Rule 335-3-16-.05 

by this permit. This shall include all problems observed and 

any corrective action taken. The records shall be maintained in 

a form suitable for inspection and shall be kept on site for a 

period of five (5) years. 

Page 64 
Appendix CAM 

Page 65 
CO and VOC Plan for Blast Furnaces 1 & 2 Afterburners (Stack 1) ---- Indicator I Indicator 2 

------- I. Indicator Afterburner exit temperature Work Practice 

- Measurement Approach The exit temperature is monitored with Inspection and tuning of the burner 

a thermocouple system, inspection ofthe data recorder. 

---

II. Indicator Range An excursion is defined as more than An excursion is defined as failure to 

50°F drop below the average perform or document annual burner 

temperature recorded during the most inspection or daily thermocouple system 

recent compliance test, based on a inspection. 

running three hour average 

--- Ill. Performance Criteria 

A. Data Representativeness The thermocouple is located in the Not Applicable 

afterburner chamber at the afterburner 

exit. The accuracy of the thermocouple 

is ±2.5°F or 0.1% of the range. The 

range is 0 to 2500 °F. The recorded 

sensitivity is 0.1 °F. 

-- Not Applicable Not Applicable 

B. Verification of Operation 

Status -----

Accuracy of the thermocouple will be Not Applicable 

c. QA/QC Practices and 

verified by a second redundant NISTtraceable thermocouple inserted 

Criteria adjacent to the primary thermocouple, 

once each day. (The two readings must 

agree within 15 °F.) 

D. Monitoring Frequency Measured continuously. Annual inspection and tuning ofthe 

burner system, daily thermocouple system 

inspection 

E. Data Collection Chart recorder records data Record results of annual inspection and 

Procedures continuously and data logger records tuning of the burner system and the daily 

instantaneous readings every 15- thermocouple system inspection 

minutes along with 15-minute and 3-

hour averages every 15 minutes. 

--

F. Averaging Period Fifteen minute and 3-hour average Not Applicable 

Page 66 
Particulate Matter CAM Plan for Stack 1 Baghouse 

Indicator I Indicator 2 Indicator 3 

- I. Indicator Opacity COMs as a Bag Leak Inspection/Maintenance 

Detector 

Measurement Approach COMs operated on COMs operated on Various baghouse system 

primary scale as an secondary scale as a bag operation and 

opacity monitor. leak detector. Secondary maintenance inspections 

Primary scale: 0 - I 00% scale: 0- 20% opacity, are conducted within 

opacity for permit limit with alarm set point at prescribed intervals, per 

compliance. 50% of scale MACT SOP manual. 

II. Indicator Range An excursion is defined An excursion is defined as An excursion is defined as 

as an opacity an alarm at 50% of the failure to perform 

measurement exceeding scale. Excursion triggers inspections per MACT 

10.0% on a 6-minute review of chart record to SOP manual or to take 

average (50% of visible determine extent of need action following report of 

emission limit). for inspection, corrective necessary maintenance. 

Excursions trigger an action, and recordkeeping 

inspection, corrective per MACT SOP manual. 

action, and a reporting 

requirement. ··-

Ill. Performance Criteria 

A. Data Representativeness COMs located at the COMs located at the PerMACT SOP 

baghouse outlet. baghouse outlet. 

B. Verification of Operation Not Applicable Not Applicable Not Applicable 

Status 

c. QAIQC Practices and Calibrate, maintain in Initial adjustments for Trained personnel to 

accordance with averaging period, alarm perform maintenance and 

Criteria manufacturer's set point, and alarm delay inspections. 

specifications, 40 CFR time conducted using 

60.13, and Appendix B, concepts of EPA;s written 

guidance for triboelectric 

monitors. --

D. Monitoring Frequency Measured continuously. Measured continuously. Per MACT SOP 

. 

Opacity output signal Bag leak detector output Per MACT SOP 

and alarm times are signal and alarm times are 

continuously recorded on continuously recorded on 

E. Data Collection Procedures a strip chart. a strip chart. 

Six minute averages Instantaneous Not Applicable 

F. Averaging Period 

Page 67 
Particulate Matter CAM Plan for Sanitary Baghouses Stack 4 and Stack 4a --------~ ---- Indicator I (BLD) Indicator I (HEPA) Indicator 2 

---~- -~----

I. Indicator Triboelectric Signal HEPA Pressure Drop Inspection/Maintenance 

----- Measurement Triboelectric Monitor. Pressure Drop across the Various baghouse system 

Approach HEPA filter is measured operation and maintenance 

An Audible alarm sounds with a Magnehelic inspections are conducted within 

when the signal exceeds a Pressure Guage prescribed intervals, per MACT 

preset point, indicating a SOP manual. 

possible bag leak or 

malfunction. 

----- II. Indicator Range An excursion is defined as a While the unit is operating, An excursion is defined as failure 

triboelectric signal greater an excursion is defined as a to perform inspections per MACT 

than 75 percent of scale for 7.5 pressure differential below SOP manual or failure to take 

seconds. Excursions triggers 0.5 inches of H20 and action following report of 

review of chart record to greater than 5.0 inches of necessary maintenance. 

determine extent of need for H20. Excursions trigger 

inspection, corrective action, an inspection, corrective 

and recordkeeping per MACT action, and a reporting 

SOP manual. requirement. 

-------------~-

III. Performance Criteria 

A. Data The probe sensor is located in The magnehelic measures Per MACT SOP 

Representativeness the baghouse exit stack. The the pressure differential 

triboelectric signal is between the inlet and outlet 

proportional to particulate ofthe HEPA filter system. 

mass flow if factors such as 

humidity, exhaust gas 

velocity, and particle size 

remain constant. 

-~-~-

B. Verification of Not Applicable Not Applicable Not Applicable 

Operation Status ------~--

c. QAIQC Practices and 

Initial adjustments for alarm Quarterly inspection of the Trained personnel to perform 

set point and alarm delay time pressure taps located at the maintenance and inspections. 

Criteria conducted using concepts of HEPA inlet and outlet. 

EPA's written guidance for 

triboelectric monitors. 

D. Monitoring Frequency Measured continuously. At least once daily Per MACT SOP 

Triboelectic signal and record The pressure drop will be Per MACT SOP 

E. Data Collection of alarm times are recorded with date and 

Procedures continuously recorded on a time. 

strip chart, with any notes on 

alarms transcribed manually. 

- --------~ 

F. Averaging Period Instantaneous Instantaneous Not Applicable 

----

Page 68 
CO and VOC CAM Plan for Blast Furnaces 3 and 4 Afterburners (Stack 5) 

Indicator I Indicator 2 

-- I. Indicator Afterburner exit temperature Work Practice 

-- Measurement Approach The exit temperature is monitored with Inspection and tuning of the burner 

a them10couple system, inspection of the data recorder. 

II. Indicator Range An excursion is defined as more than An excursion is defined as failure to 

50°F drop below the average perform or document annual burner 

temperature recorded during the most inspection or daily thermocouple system 

recent compliance test, based on a inspection. 

running three hour average 

--- Ill. Performance Criteria 

A. Data Representativeness The thermocouple is located in the Not Applicable 

afterburner chamber at the afterburner 

exit. The accuracy of the thermocouple 

is ±2.5°F or 0.1% of the range. The 

range is 0 to 2500 °F. The recorded 

sensitivity is 0.1 °F. 

Not Applicable Not Applicable 

B. Verification ofOperation 

Status Accuracy of the thermocouple will be Not Applicable 

c. QA/QC Practices and 

verified by a second redundant NISTtraceable thermocouple inserted 

Criteria adjacent to the primary thermocouple, 

once each day. (The two readings must 

agree within 15 °F.) 

D. Monitoring Frequency Measured continuously. Annual inspection and tuning ofthc 

burner system, daily thermocouple system 

inspection 

E. Data Collection Chart recorder records data Record results of annual inspection and 

Procedures continuously and data logger records tuning of the burner system and the daily 

instantaneous readings every 15- thermocouple system inspection 

minutes along with 15-minute and 3-

hour averages every 15 minutes. 

F. Averaging Period Fifteen minute and 3-hour average Not Applicable 

Page 69 
Particulate Matter CAM Plan for Stack 5 Baghouse ---- Indicator I Indicator 2 Indicator 3 

----- I. Indicator Opacity COMs as a Bag Leak Inspection/Maintenance 

Detector ---

Measurement Approach COMs operated on COMs operated on Various baghouse system 

primary scale as an secondary scale as a bag operation and 

opacity monitor. leak detector. Secondary maintenance inspections 

Primary scale: 0 - I 00% scale: 0- 20% opacity, are conducted within 

opacity for permit limit with alarm set point at prescribed intervals, per 

compliance. 50% of scale MACT SOP manual. 

II. Indicator Range An excursion is defined An excursion is defined as An excursion is defined as 

as an opacity an alarm at 50% of the failure to perform 

measurement exceeding scale. Excursion triggers inspections per MACT 

10.0% on a 6-minute review of chart record to SOP manual or to take 

average (50% of visible determine extent of need action following report of 

emission limit). for inspection, corrective necessary maintenance. 

Excursions trigger an action, and recordkeeping 

inspection, corrective per MACT SOP manual. 

action, and a reporting 

requirement. --~ 

III. Performance Criteria 

A. Data Representativeness COMs located at the COMs located at the Per MACT SOP 

baghouse outlet. baghouse outlet. 

--

B. Verification of Operation Not Applicable Not Applicable Not Applicable 

Status 

----~"-~--"·--

C. QAIQC Practices and Calibrate, maintain in Initial adjustments for Trained personnel to 

accordance with averaging period, alarm perform maintenance and Criteria manufacturer's set point, and alarm delay inspections. 

specifications, 40 CFR time conducted using 

60.13, and Appendix B, concepts of EPA;s written 

guidance for triboelectric 

monitors. 

D. Monitoring Frequency Measured continuously. Measured continuously. Per MACT SOP 

Opacity output signal Bag leak detector output Per MACT SOP 

E. Data Collection Procedures and alarm times are signal and alarm times are 

continuously recorded on continuously recorded on 

a strip chart. a strip chart. 

-~ 

F. Averaging Period Six minute averages Instantaneous Not Applicable 

--

Page 70 
Particulate Matter CAM Plan for Slag Treatment Building Baghouse (Stack 10) 

Indicator I (BLD) Indicator I (HEPA) Indicator 2 

-- I. Indicator Triboelectric Signal HEPA Pressure Drop Inspection/Maintenance 

----~-

Measurement Triboelectric Monitor. Pressure Drop across the Various baghouse system 

Approach HEPA filter is measured operation and maintenance 

An Audible alarm sounds with a Magnehelic inspections are conducted within 

when the signal exceeds a Pressure Guage prescribed intervals, per MACT 

preset point, indicating a SOP manual. 

possible bag leak or 

malfunction. 

II. Indicator Range An excursion is defined as a While the unit is operating, An excursion is defined as failure 

triboelectric signal greater an excursion is defined as a to perform inspections per MACT 

than 75 percent of scale for 7.5 pressure differential below SOP manual or failure to take 

seconds. Excursions triggers 0.5 inches of H20 and action following report of 

review of chart record to greater than 5.0 inches of necessary maintenance. 

determine extent of need for H20. Excursions trigger 

inspection, corrective action, an inspection, corrective 

and recordkeeping per MACT action, and a reporting 

SOP manual. requirement. 

"--~--~---

Ill. Performance Criteria 

A. Data The probe sensor is located in The magnehelic measures Per MACT SOP 

Representativeness the baghouse exit stack. The the pressure differential 

triboelectric signal is between the inlet and outlet 

proportional to particulate of the HEPA filter system. 

mass flow if factors such as 

humidity, exhaust gas 

velocity, and particle size 

remain constant. 

B. Verification of Not Applicable Not Applicable Not Applicable 

Operation Status 

c. QAIQC Practices and 

Initial adjustments for alarm Quarterly inspection ofthe Trained personnel to perform 

set point and alarm delay time pressure taps located at the maintenance and inspections. Criteria conducted using concepts of HEPA inlet and outlet. 

EPA's written guidance for 

triboelectric monitors. 

D. Monitoring Frequency Measured continuously. At least once daily Per MACT SOP 

Triboelectic signal and record The pressure drop will be Per MACT SOP 

E. Data Collection of alarm times are recorded with date and 

Procedures continuously recorded on a time. 

strip chart, with any notes on 

alarms transcribed manually. 

F. Averaging Period Instantaneous Instantaneous Not Applicable 

Page 71 
I. 

Particulate Matter CAM Plan for Canopy Hoods and Furnace Building Ventilation 

Baghouse (Stack 11) 

Indicator I Indicator 2 

---- Indicator HEPA Pressure Drop Inspection/Maintenance 

Measurement Approach Pressure Drop across the HEPA filter is Various baghouse system operation and 

measured with a Magnehelic Pressure maintenance inspections are conducted 

Guage within prescribed intervals, per MACT 

SOP manual. 

II. Indicator Range While the unit is operating, an excursion is An excursion is defined as failure to 

defined as a pressure differential below 0.5 perform inspections per MACT SOP 

inches of H20 and greater than 5.0 inches of manual or failure to take action 

H20. Excursions trigger an inspection, following report of necessary 

corrective action, and a reporting maintenance. 

requirement. 

III. Performance Criteria 

The magnehelic measures the pressure 

A. Data differential between the inlet and outlet of Per MACT SOP 

Representativeness the HEPA filter system. 

B. Verification of Not Applicable Not Applicable 

Operation Status 

c. QA/QC Practices and 

Quarterly inspection of the pressure taps Trained personnel to perform 

located at the HEPA inlet and outlet. maintenance and inspections. 

Criteria 

At least once daily Per MACT SOP 

D. Monitoring Frequency 

The pressure drop will be recorded with Per MACT SOP 

E. Data Collection date and time. 

Procedures 

F. Averaging Period 

Instantaneous Not Applicable 

Page 72 
I. 

Particulate Matter CAM Plan for Alloying Kettles and Alloying Kettle Heating 

System Baghouse (Stack 14) 

Indicator I Indicator 2 

Indicator HEPA Pressure Drop Inspection/Maintenance 

Measurement Approach Pressure Drop across the HEP A fi Iter is Various baghouse system operation and 

measured with a Magnehelic Pressure maintenance inspections are conducted 

Guage within prescribed intervals, per MACT 

SOP manual. 

II. Indicator Range While the unit is operating, an excursion is An excursion is defined as failure to 

defined as a pressure differential below 0.5 perform inspections per MACT SOP 

inches of H20 and greater than 5.0 inches of manual or failure to take action 

H20. Excursions trigger an inspection, following report of necessary 

corrective action, and a reporting maintenance. 

requirement. 

Ill. Performance Criteria 

The magnehelic measures the pressure 

A. Data differential between the inlet and outlet of Per MACT SOP 

Representativeness the HEPA filter system. 

B. Verification of Not Applicable Not Applicable 

Operation Status 

c. QA/QC Practices and 

Quarterly inspection of the pressure taps Trained personnel to perform 

located at the HEPA inlet and outlet. maintenance and inspections. Criteria 

At least once daily PerMACT SOP 

D. Monitoring Frequency 

The pressure drop will be recorded with Per MACT SOP 

E. Data Collection date and time. 

Procedures 

F. Averaging Period 

Instantaneous Not Applicable 

Page 73