# ADE

Alabama Departmentof Environmental Management



# MAJORSOURCE OPERATINGPERMIT

PERMITTEE: SANDERS LEAD COMPANY 

### FACILITYNAME: SANDERS LEAD COMPANY 

### FACILITY/PERMITNO.: 210-0005 LOCATION: TROY, ALABAMA

In accordance withandsubjectto theprovisions of theAlabamaAirPollution ControlActof 1971, as amended, Ala, Code 1975, §§22-28-1 to 22-28-23 (2006Rplc. Vol. and2007 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. and2007 Cum. Supp.) andrules andregulations adoptedthereunder, and subjectfurther to the conditions setforth in thispermit, the Permittee is hereby authorizedto construct, installanduse the equipment, device orotherarticledescribedabove. Pursuant to the CleanAirActof 1990, allconditions of thispermitarefederally enforceable byEPA, the Alabama Department ofEnvironmental Management, and citizens in general. Those provisions which are notrequiredunderthe CleanAirActof 1990are consideredto be statepermitprovisions and are not federally enforceable byEPA andcitizens in general. Thoseprovisionsare containedin separate sections of thispermit.



### IssuanceDate: EffectiveDate: ExpirationDate: November

### 9, 2012 November

### 9, 2012 November

### 8, 2017

AlabamaDepartmentofEnvironmentalManagement

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 andPerformance TestMethods andProcedures
......................................24 RecordkeepingandReportingRequirements
...............................................................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 andPerformance TestMethods andProcedures
......................................32 RecordkeepingandReportingRequirements
...............................................................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
................................................................................................................37 

### Emission Standards
...................................................................................................37 

### ComplianceandPerformance TestMethods andProcedures
......................................38 RecordkeepingandReportingRequirements
...............................................................40 SUMMARY PAGE FOR SODAASH STORAGE SILO .............................................41 PRO'VI'SOS FOR SODAASH STORAGE SILO.......................................................42



### Applicability
................................................................................................................4 2 Emission Standards
...................................................................................................42 Compliance andPerformance TestMethods andProcedures
......................................42 EmissionMonitoring
...................................................................................................4 2 RecordkeepingandReportingRequirements
...............................................................42 2SUMMARY PAGE FORALLOYING KETTLES AND ALLOYING KETTLES HEATING SYSTEM............................................................................................................43

PROVISOS FORALLOYING KETTLES AND ALLOYING KETTLES HEATING SYSTEM............................................................................................................44



### Applicability
................................................................................................................44 Emission Standards
...................................................................................................44 Compliance andPerformance TestMethods andProcedures
......................................45 EmissionMonitoring
...................................................................................................46 Recordkeeping_andReportingRequirements
...............................................................47 SUMMARY PAGE FOR SLAG TREATMENT BUILDING (STACK 10)

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

................................49



### Applicability
................................................................................................................4 9 Emission Standards
...................................................................................................49 

### ComplianceandPerformance TestMethods andProcedures
......................................50 EmissionMonitoring
...................................................................................................51 RecordkeepingandReportingRequirements
...............................................................52 SUMMARY PAGE BLAST FURNACE CANOPY HOODSAND BUILDING VENTILATION (STACK 11).................................................................................53 PROVISOS FOR BLAST FURNACE CANOPY HOODSAND BUILDING VENTILATION (STACK 11) .......................................................................................................54



### Applicability
................................................................................................................54 Emission Standards
...................................................................................................54 Compliance andPerformance TestMethods andProcedures
......................................55 RecordkeepingandReportingRequirements
...............................................................56 SUMMARY PAGE BATTERY BREAKER/SHREDDERBUILDING (STACK 12)
........57 PROVISOS FOR BATTERY BREAKER/SHREDDERBUILDING (STACK 12)
..........58



### Applicability ................................................................................................................58 Emission Standards
................................................................................................... 58 ComplianceandPerformance TestMethods andProcedures
......................................59 RecordkeepingandReportingRequirements
............................................................... 60 

### 3SUMMARY PAGE RAW MATERIAL STORAGE BUILDING (STACK 13)

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



### Applicability
................................................................................................................ 62 Emission Standards
................................................................................................... 62 ComplianceandPerformance TestMethods andProcedures
...................................... 63 RecordkeepingandReportingRequirements
............................................................... 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 SLAGTREATMENT BUILDING BAGHOUSE (STACK 10)•••••••••••••••••••••.•••••••••••••••••••••••••••••••••••••••••••••••.•••.••••••••••• 71 PARTICULATE MATTER CAM PLAN FOR CANOPY HOODSAND FURNACE BUILDINGVENTILATION BAGHOUSE (STACK 11)

..............................................72 PARTICULATE MATTER CAM PLAN FORALLOYING KETTLES AND ALLOYING KETTLE HEATING SYSTEM BAGHOUSE (STACK 14)

..........................................73

4

### GeneralPermitProvisos FederallyEnforceable Provisos Regulations 1. Transfer This permit is not transferable, whether by operation oflaw 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 permitrenewal shall be submitted at least Rule 335-3-16-.12(2) six (6) months, but not more than eighteen (18) months, before the date ofexpiration ofthis permit. The source for which this permit is issued shall lose its right to operate upon the expiration ofthis permitunless a timely and complete renewal application has been submitted within the time constraints listedin the previous paragraph. 

### 3. SeverabilityClause 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 ofthis 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 suchjudgment shallhave beenrendered. 

### 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 ofthe 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 applicationbythe 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 ofthis permit would have required halting orreducingthe permitted activity.



### 5

### General Permit Provisos FederallyEnforceable 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 ofa 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 ofany sort, or anyexclusive privilege. 

### 7. Submission ofInformation



### 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 providedfor in this permit. 

### 9. Certification ofTruth, 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

### GeneralPermit Provisos FederallyEnforceable 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 ofthis 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 orrequired pursuantto this permit; (d) Sample or monitor, at reasonable times, substances or parameters for the purpose ofassuring compliance with this permitor 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 certifiedthatitis alreadyin compliance. (b) The permittee shall comply in a timely manner with applicable requirements that become effective during the term ofthis permit. 

### 12. Compliance Certification A compliance certification shall be submitted annually by Rule 335-3-16-.07(e) January 8th ofeachyear. (a) The compliance certification shall include the following: (1) The identification of each term or condition of this permitthatis the basis ofthe certification;

7

### GeneralPermit Provisos FederallyEnforceable 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 DepartmentofEnvironmental 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 ofthe following circumstances, this permitwill be Rule 335-3-16-.13(5) reopened priorto the expiration ofthe 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 FederallyEnforceable Provisos shallbe deemed to beincorporatedinto 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 orotherterms or conditions ofthis 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 ofRules 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 responsibilityto complywith suchrules. 

### 15. Equipment Maintenance orBreakdown (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 airpollution control equipmentis complete and the equipmentis operating. (b) In the event that there is a breakdown of equipment or upset ofprocess 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 breakdownhas been corrected. 

### 16. Operation ofCapture and ControlDevices 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 ofaircontaminants. Procedures for ensuringthat the above equipmentis properly operated and maintained so as to minimize the emission of air contaminants shall be established. 9

### GeneralPermit Provisos FederallyEnforceable 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 economicallyfeasible. 

### 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 ofwater any time the surface of the road is sufficiently dry to allow the creation ofdust emissions by the act ofwind or vehiculartraffic; (2) By reducing the speed of vehicular traffic to a point below that at which dust emissions are created; (3) Bypaving; (4) Bythe application ofbinders to the road surface at any time the road surface is found to allow the creation ofdustemissions; 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

### GeneralPermit Provisos FederallyEnforceable 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 ofall analyses; and (6) The operating conditions that existed at the time ofsampling ormeasurement. (b) Retention of records of all required monitoring data and support information ofthe 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 ofany required monitoring Rule 335-3-16-.05(c)(3) shall be submitted at least every 6 months. All instances of deviations from permit requirements mustbe clearlyidentified in saidreports. All required reports must be certified by a responsible official consistentwith 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

### GeneralPermit Provisos FederallyEnforceable Provisos 40 of the Code of Federal Regulations, as the same may be amended orrevised. 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 controlrules 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 ofthe start ofthe 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 ofthe 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 oftime is specifically approved bythe Air Division. 

### 23. Payment ofEmission Fees Annual emission fees shall be remitted each year according Rule 335-1-7-.04 to the fee schedule inADEM Admin. CodeR. 335-1-7-.04.

12

### GeneralPermit Provisos FederallyEnforceable Provisos Regulations 24. OtherReportingand TestingRequirements 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 mayrequire 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 ofany device except as providedin40 CFR Part 82, SubpartF. 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. ChemicalAccidental Prevention Provisions If a chemical listed in Table 1 of 40 CFR Part 68.130 is 40 CFR Part 68 presentin 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 Part68. (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 providedin40 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 ofthe RiskManagement Plan. 13

### GeneralPermit Provisos FederallyEnforceable Provisos Regulations 27. DisplayofPermit This permit shallbe 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 permitis issued is located and will make the permit readily available for inspection by anyor all persons who mayrequestto 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 Specificprovisos ofthis 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 ofthe 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 ofthe emissions specified in Part335-3-5-.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 inexcess ofthe emissions specifiedin Part 335-3-4-.04. 

### 32. AveragingTime 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 testmethod.

14

### GeneralPermit Provisos FederallyEnforceable 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 ofApprovedMonitoring (1) 

### Commencement ofoperation. 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 specifiedin the permitpursuantto §64.6(d). (2) 

### Propermaintenance. At all times, the owneror operator shall maintain the monitoring, including but not limited to, maintaining necessary parts for routine repairs ofthe 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 ofthis part, including data averages and calculations, 

### or fulfilling a minimum data availability requirement, ifapplicable. The owner 

### or operator shall use all the data collected during all otherperiods in assessing the operation ofthe control device and associated control system. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoringfailures 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

### GeneralPermit Provisos FederallyEnforceable 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 ofneedfor 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 ofadditional parameters.

16 

### Regulations

### GeneralPermitProvisos FederallyEnforceable Provisos (b) QualityImprovementPlan (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 ofa QIP: 1. The owner or operator shall maintain a written QIP, ifrequired, and have it available for inspection. 2. The plan initially shallinclude procedures for evaluatingthe control performance problems and, based on the results ofthe evaluationprocedures, the owneror operator shall modifythe plan to include procedures for conducting one ormore ofthe 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 QIPexceeds 180 days from the date onwhich the need to implement the QIPwas 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

### GeneralPermit Provisos FederallyEnforceable Provisos

owner or operator make reasonable changes to the QIPifthe QIPis 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 ofa 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 undertheAct. (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 ofthis part, the owner or operator shall submit monitoring reports to the permitting authority in accordance withADEM 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 dailycalibration checks, ifapplicable); and (iii) A description ofthe 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 PermitProvisos FederallyEnforceable Provisos implementation of the plan has been completed and reduced the likelihood of similar levels of excursions orexceedances 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 ofthis part is to require, as part ofthe issuance ofa permit under title V ofthe 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 PermitProvisos FederallyEnforceable Provisos to meet the requirements ofthis 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 ofany person to take action under section 304 ofthe Act.



### 20 Regulations

### SummaryPage Blast Furnace 1 & 

### 2, andAgglomeration Furnace (Stack 1) Permitted Operating Schedule: 24 Hrs/dayx 7 Days/weekx 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 ifonly 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 ifonly one blastfurnace operating 40 CFR 63 SubpartX

*Permitee shallbe in compliance with emission limits no later thanJuly 1, 2013
21

### Provisos for BlastFurnace 1 & 

### 2, andAgglomeration Furnace (Stack 1) FederallyEnforceable 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 subjectto the applicable requirements of40 40 CFR 63 SubpartX CFR Part 63 Subpart X, "National Emission Standards for Rule 335-3-11-.06 (23) HazardousAir Pollutantsfrom SecondaryLead Smelting." 3. These sources are subject to the applicable requirements of 40 CFR 63 SubpartA SubpartA of40 CFR Part 63, "General Provisions" as listed in Table 1 ofSubpartX. 4. These sources are subjectto the applicable requirements of40 40 CFR 60 Subpart L CFR Part 60 Subpart L, "Standards of Performance for Rule 335-3-10-.02 (12) SecondaryLead Smelters." 5. These sources are subject to the applicable requirements of 40 CFRPart 60 Subpart SubpartA of40 CFR Part60, "GeneralProvisions". 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 PermitsAuthorizing 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 ofADEM Admin. Code R. 335-3-14-.04, "Air Permits Authorizing Construction in CleanAirAreas (Prevention ofSignificantDeterioration]". 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. Forparticulate 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 Matteremissions 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 inAppendixA of40 CFR 60 (latestedition).
22

### FederallyEnforceable 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 (latestedition). Lead emissions from Stack 1 (Blast Fumaces 1 & 2, and Agglomeration Furnace) shall not exceed 0.00087 grjdscf 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 of40 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 inAppendixA of40 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 335-3-1-.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 ifonly one blast furnace is operating) as determined by EPA Reference Method 25 of 40 CFR Part 60 (lastest edition). 8. The emissions ofTotal 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 AppendixA of40 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 determinedbyEPA Reference Method 10 as found inAppendix A of40 CFR 60 (latestedition).

23

### FederallyEnforceable 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 ofthe exceedence.
Compliance and PerformanceTest Methods and Procedures 1. This source is subject to the applicable requirements of 40 40 CFR 63.547 CFR40 CFR Part 63 SubpartX, "National Emission Standards for Hazardous Air Pollutants from Secondary Lead Smelting" to include theTestMethods 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 of40 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 of40 CFR Part 60, AppendixA shall be used in the Rule 335-3-14-.04 determination ofVOC (TGNMO) emissions from the stack. 5. Method 25A of40 CFR Part 60, Appendix A shall be used in 40 CFR 63.547 the determination oftotal 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 of40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofparticulate matter emissions from the stack. 8. Method 9 of40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofopacity ofthe stackemissions.
24

### FederallyEnforceable Provisos Regulations 9. Method 10 of40 CFR Part 60, Appendix A shallbe used in the Rule 335-3-1-.05 determination ofcarbon monoxide emissionsfrom 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, slagtaps, 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 SubpartX, "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 SubpartX, "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 proofofcompliance 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, "ComplianceAssurance 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 SulfurDioxide 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

### FederallyEnforceable 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 of40 CFR Part 63 SubpartX, "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 of40 CFR Part 63 SubpartX, "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 continuouslymonitor each total enclosure.
Recordkeeping and ReportingRequirements 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

### FederallyEnforceable 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 ofexcess emissions of20% or computed from six-minute averages. (2) S02. Emissionrates over 1,462 lbs perhour as computed from a rolling 24-hour average. (3) Afterburner ExitTemperature. Eachvalue below 1,300° F computed from a rollingthree-hour average. Note: Datarecorded during periods ofmonitor system breakdowns, maintenance, adjustments, and calibration checks shall not be includedin any ofthe above data averages. b. The date and time ofcommencementand completion of each time period ofexcess emissions.
c. The nature and cause ofthe excess emissions (ifknown) and the corrective action taken orpreventative measures adopted. d. The date and time identified each period duringwhich either ofthe monitoring systemwere inoperative (except for zero and span checks) and the nature ofthe repairs or adjustments.
e. Equations used to convert S02emission 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, suchinformationwill 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

### FederallyEnforceable 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 informationthatis specifiedin §63.550 shallbe 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 listedin §63.550 shallbe compliedwith.



### 28

### SummaryPage Blast Furnaces 3 & 

### 4 (Stack5) Permitted OperatingSchedule: 24 Hrsjdayx 7 Daysjweekx 52 Weeks/yr = 

### 8760 Hrsjyr 

### Emission limitations: Emission Point

# *

# I

.............Description
. . ............ .......... .. 

# r.PoUutaii"
.T

. 

## .EmiSsionlimit 

# 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.3wl 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 w1Afterburner, 

# J ] PM* I 1 Blast Furnace No. 4 wI Afterburner**···f·yer1t~ci** tc) C:()rn_l11()r1**?~g}1()\l13e.$tac:l:c?** .. 1 1 Blast Furnace No. 3 wI Afterburner, i S02

Blast Furnace No. 4 wI Afterburner 1 i vented to common Baghouse Stack 5

Blast Furnace No. 3 wI Afterburner, Blast Furnace No. 4 wI Afterburner : vented to common Baghouse Stack 5

Blast Furnace No. 3 wI Afterburner,

1 CO

f Blast Furnace No. 4 wI 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 wI Afterburner, BlastFurnace No. 4 wI 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 lbslhrifonly one blast furnace

1 operating

1300oFat the afterburnerexit,

, based on a 3 hour

0.00087 grldscf & 3.00 lbslhr 0.258 lbslhr

, , , , •••••n•••••••••••••nomo•""""'"''' ••""''"''"''"'''''""'''"''""''"""'"''''"-'"''''"''-'"t' "'"'"'"''''''''''"'''''-'''''"'' •--' I VOC (TGNMO) : 32 lbslhror 16 Blast Furnace No. 3 w

### I Afterburner,

1 Blast Furnace No. 4 wI Afterburner

1 vented to common Baghouse Stack 5 I I lbslhrifonly one 

### ! blastf;rrnace i operatmg i Blast**Furna~e N~.** **·3-;TA.it~;bur~e-r,** 

# rvoc(TGNM6).Ti3.oooFaithe Blast Furnace No. 4 wI Afterburner [ afterburnerexit, 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 SubpartX

Rule 335-3-J4-.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)

BlastFurnace No.3 wl Afterburner, 360 PPMV 40 CFR 63 SubpartX Blast Furnace No. 4 wI Afterburner
· yer1teci to.c:ornrn()r!**?~glt()11S~**__**§t~_c_l:c**_§ *Permitee shallbe in compliance with the emissionlimits no laterthanJuly 1, 2013



### 29

### Provisos for Blast Furnaces 3 & 

### 4 (Stack 5) FederallyEnforceable 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 subjectto the applicable requirements of40 40 CFR 63 SubpartX CFR Part 63 Subpart X, "National Emission Standards for Rule 335-3-11-.06 (23) HazardousAir Pollutants from SecondaryLead Smelting." 3. These sources are subject to the applicable requirements of 40 CFR 63 SubpartA SubpartA of40 CFR Part 63, "General Provisions" as listed in Table 1 ofSubpartX. 4. These sources are subjectto the applicable requirements of40 40 CFR P 60 SubpartL CFR Part 60 Subpart L, "Standards of Performance for Rule 335-3-10-.02 (12) SecondaryLead Smelters." 5. These sources are subject to the applicable requirements of 40 CFR 60 SubpartA SubpartA of40 CFR Part60, "GeneralProvisions". 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 PermitsAuthorizing 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 ofADEM Admin. Code R. 335-3-14-.04, "Air Permits Authorizing Construction m CleanAirAreas [Prevention ofSignificantDeterioration]". 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. Forparticulatematter, CarbonMonoxide, 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 (latestedition).
30

### FederallyEnforceable 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 of40 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 inAppendixAof40 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 AppendixA of 40 CFR 60 (latestedition). 

### 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 ofemissions 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 (latestedition). 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 ofTotal 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 AppendixAof40 CFR 60 (latestedition). 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 inAppendixAof40 CFR 60 (latestedition). 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

### FederallyEnforceable 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 emissionsfrom 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 ofthe exceedence.
Compliance and PerformanceTest Methods and Procedures 1. This source is subject to the applicable requirements of 40 40 CFR 63.547 CFR40 CFR Part 63 SubpartX, "National Emission Standards for Hazardous Air Pollutants from Secondary Lead Smelting" to include theTest 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 of40 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 of40 CFR Part 60, AppendixA shall be used in the Rule 335-3-14-.04 determination ofVOC (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 oftotal 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 of40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofparticulate matter emissions from the stack. 8. Method 9 of40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofopacityofthe stack emissions. 9. Method 10 of40 CFR Part 60, AppendixA shallbe used in the Rule 335-3-1-.05 determination ofcarbon monoxide emissions from the stack

32

### FederallyEnforceable 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, slagtaps, 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 SubpartX, "National Emission Standards for Hazardous Air Pollutants from Secondary Lead Smelting" to include the MonitoringRequirements 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 SubpartX, "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 proofofcompliance 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, "ComplianceAssurance 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 of40 CFR Part 63 SubpartX, "National Emission Standards for Hazardous Air Pollutants from Secondary Lead Smelting" to include §63.548.

33

### FederallyEnforceable 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 of40 CFR Part 63 SubpartX, "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 continuouslymonitor each totalenclosure.
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 ofexcess emissions of 10% or computedfrom six-minute averages. (2) S02. Emissionrates over 1,253 lbs perhour as computedfrom a rolling 24-hour average. (3) Afterburner ExitTemperature. Eachvalue below 1,300° F computed from a rollingthree-hour average. Note: Datarecorded during periods ofmonitor system breakdowns, maintenance, adjustments, and calibration checks shallnot be included in any ofthe above data averages.

34

### FederallyEnforceable Provisos b. The date and time ofcommencement and completion of each time period ofexcess emissions.
c. The nature and cause ofthe excess emissions (ifknown) and the corrective action taken orpreventative measures adopted. d. The date and time identified each period duringwhich eitherofthe monitoring systemwere inoperative (except for zero and spanchecks) and the nature ofthe repairs or adjustments.
e. Equations used to convert S02emission 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 notinoperative ordid not require repair or adjustment, such information will be statedin the report. 

### Regulations

3. Should the emissionsfrom 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 specifiedin §63.550 shallbe 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 compliedwith.

35

### SummaryPage Blast Furnaces 1, 2, 3 and4 SanitaryHoods (Stack4 & 

### 4a) Permitted OperatingSchedule: 24 Hrsjdayx 7 Days/weekx 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
. .. 

# *

Stack4
Stack4
Stack4
Stack4a SanitaryBaghouse Stack4: • Furnace No. 1 Sanitary Hoods •**Furnf!..c~.No.** 2 §<tf1itaryHoods SanitaryBaghouse Stack4:

• Furnace No. 1 Sanitary Hoods • Furnace No. 2 Sanitary Hoods

i SanitaryBaghouse Stack4: • Furnace No. 1 Sanitary Hoods • Furnace No. 2 SanitaryHoods SanitaryBaghouse Stack4:

• Furnace No. 1 Sanitary Hoods • Furnace No. 2 Sanitary Hoods SanitaryBaghouse Stack4: PM*
Pb*

THC
' Opacity I • Furnace No. 1 Sanitary Hoods**~urnace.No. 2$.:tnitaryHo()cl~**  ....

## + SanitaryBaghouse Stack4a Including: 1 PM* Furnace No. 3 Sanitary Hoods · Furnace No. 4 SanitaryHoods**Threej~J**..**f?}l.le_].)_ll~t §toE;;tg~**  I3irls -\-
_ ___ SanitaryBaghouse Stack4aIncluding: 1 Pb*

• Furnace No. 3 Sanitary Hoods • Furnace No. 4 Sanitary Hoods • Three (3) Flue Dust Storage Bins

t·
.. Stack4a SanitaryBaghouse Stack4a Including: ! Pb** • Furnace No. 3 Sanitary Hoods • Furnace No. 4 SanitaryHoods

1 • 'filree**{~)** Flue l)_llst $t()ra,ge. f3ir1s Stack4a SanitaryBaghouse Stack4a Including: THC • Furnace No. 3 SanitaryHoods • Furnace No. 4 Sanitary Hoods • ....**'fil_re~ (:3Jf?111~** l)_llst**§tora,g~** f3ir1s
...j..

_ ··-······ . SanitaryBaghouse Stack4a Including: 1 Opacity

r • Furnace No. 3 Sanitary Hoods • Furnace No. 4 SanitaryHoods Three(})**~l11e l)_ll::;t_§tcrr(lg~** .J?irls. *Combined PM EmissionLimit from Stack4 and Stack4a 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 shallbe in compliancewith the emission limits no later thanJuly 1, 2013

36 Rule 335-3-14-.04(9) (PSD/BACT) 40 CFR 63 SubpartX
Rule 335-3-14-.04(9) (PSD/BACT) Rule 335-3-1-.03 (SIP)

I • • 40 CFR 63 SubpartX

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

40 CFR 63 SubpartX

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

(PSDjBACT) Rule 335-3-1-.03 (SIP)

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

### Provisos for BlastFurnaces 1, 2, 3 and4 SanitaryHoods (Stack4 & 

### 4a) FederallyEnforceable 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 subjectto the applicable requirements of40 40 CFR 63 SubpartX CFR Part 63 Subpart X, "National Emission Standards for Rule 335-3-11-.06 (23) HazardousAir Pollutants from SecondaryLead Smelting." 3. These sources are subject to the applicable requirements of 40 CFR 63 SubpartA SubpartA of40 CFR Part 63, "General Provisions" as listed in Table 1 ofSubpartX. 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 PermitsAuthorizing Construction in Clean Air Areas [Prevention of Significant Deterioration Permitting (PSD)]." 6. This source has enforeceable limits inplacein orderto 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 ofparticulate matter emissions greater than40%. 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 Aof40 CFR 60 (latestedition). 4a 40 CFR 63.543 3. The combined Lead emissions from Stack 4 and Stack shall not exceed 0.00087 grjdscf and 0.41 lb/hr as determined by EPA Reference Method 12 or Method 29 as found inAppendixAof40 CFR 60 (latest edition).

37 Rule 335-3-14-.04 (PSD/BACT)

### FederallyEnforceable 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 inAppendixA of40 CFR 60 (latest edition). 5. No laterthanJuly 1, 2013, lead emissions from Stack4a shall Rule 335-3-1-.03 not exceed 0.022 lbjhr as determined by EPA Reference Method 12 or Method 29 as found inAppendixA of40 CFR 60 (latestedition). 6. The emissions of total hydrocarbons from the blast furnace 40 CFR 63.543 chargingprocess shallnotexceed 20 ppmv. 7. Visible emissions escaping the capture system (Blast Furnace Rule 335-3-4-.15 (6)(a) Canopy Hoods and SanitaryHoods) for the charging door shall notexceed 10% opacitywhen chargingthe blastfumace. 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 onthe blastfumace shallnotexceed 1% opacity. 10. No later than July 1, 2013, these sources shall be operated in Rule 335-3-1-.03 a total enclosure thatis 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 ofthe exceedence.
Compliance and PerformanceTestMethods and Procedures 1. Method 12 or 29 of40 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 of40 CFR Part 60, AppendixA shall be used in the Rule 335-3-14-.04 determination ofVOC (TGNMO) emissionsfrom the stack.

38

### FederallyEnforceable Provisos Regulations 3. Method 25A of 40 CFR Part 60, Appendix A shall be used in 40 CFR 63.547 the determination oftotal hydrocarbons (THC) emissions from the stack. 4. For purposes of determining compliance with the THC limits, 40 CFR 63.547 the procedures in 40 CFR Part 63 SubpartX §63.547 (c) shall beused. 5. Method 5 of40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofparticulate matter emissions from the stack. 6. Method 9 of40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofopacity ofthe stackemissions.

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 MonitoringRequirements 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. Ifthe pressure drop is outside the limit specified by the filter manufacturer, maintenance inspections and/or corrective action are to beinitiated. 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 proofofcompliance with 40 CFR Part 63 SubpartX and ADEM Rules and Regulations.
4. Reference the Appendix for the monitoring reqirements for 40 40 CFR Part64 CFR Part64, "ComplianceAssurance 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 of40 CFR Part 63 SubpartX, "National Emission Standards for Hazardous Air Pollutants from Secondary Lead Smelting" to include §63.548.

39

### FederallyEnforceable 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 SubpartX.
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 continuouslymonitor 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 shallbe 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 shallbe complied with. 3. The Permittee shall maintain a record ofall 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 offive (5) years.

40

### SummaryPage for SodaAsh Storage Silo Permitted OperatingSchedule: 24 Hrs/dayx 7 Days/weekx 52 Weeks/yr = 

### 8760 Hrsjyr


### Emission limitations:

# Emi&&ion···Point~,····r··········**·············~~·········~·········Description ·····~·······~······~···~····m~-** ••

# ~•.

# ~..

# ~····[······~~~~=~~~:~·······~·······[·~·····~·~~~==~i:=··~~=tt·····~···~·······~·············~··~····Reguiation EP 018 1SodaAsh Storage Silo with Bagfilter 1 PM 13.59 (P)062 · Rule 334-3-4-.04 I EP 018

41

### Provisos for SodaAsh Storage Silo FederallyEnforceable Provisos Applica bili ty 

### Regulations

1. This source is subject to the applicable requirements ofADEM Rule335-3-16-.03 Admin. Code R. 335-3-16-.03, "Major Source Operating Permits." Emission Standards 1. This source is subject to no additional specific requirements NjA other than those listed in the General Permit Provisos. Compliance and PerformanceTest Methods and Procedures 1. Method 5 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofparticulate matteremissions from the stack. 2. Method 9 of40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofopacityofthe stackemissions. Emission Monitoring 1. This source is subject to no additional specific requirements NjA other than those listed in the General Permit Provisos. Recordkeeping and Reporting Requirements 

### 1. This source is subject to no additional specific requirements NjA otherthanthose listed in the General PermitProvisos.

42

### SummaryPage for AlloyingKettles andAlloyingKettles Heating System Permitted OperatingSchedule: 24 Hrsjdayx 7 Daysjweekx 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

Stack4
Stack4
Stack4
Stack 4
Stack 4
Stack 4
Stack 14 Stack 14
Stack 14
Stack 14 Stack 14 Stack 14 1 EightAlloying Kettles vented to Baghouse Stack 5 f PM EightAlloying Kettles vented to Opacity Baghouse Stack 5 EightAlloying Kettles vented to Pb Baghouse Stack 5 Alloying Kettle Heating System vented PM*

1 to Baghouse Stack4

: Alloying Kettle Heating System vented Opacity : to Baghouse Stack4 

## i Alloying Kettle Heating System vented S02 ; to Baghouse Stack4

' Alloying Kettles & Heating System

, vented to Baghouse Stack 14 j. '' •.........• : Alloying Kettles & Heating System ' vented to Baghouse Stack 14

*Combined Emission Limit from Stack4 and Stack4a , 0.010 grjdscf
1 (6.00 lbs/hr)

Less than 10%

. 0.00087 grjdscf I 

### i&

3.00 lbsjhr 0.0039 grjdscf (1.62 lbsjhr) (see general provisos) N/A

i 0.038 lbsjhr

**Permitee shallbe in compliance with the emission limits no later thanJuly 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 SubpartX 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 andAlloyingKettles Heating System FederallyEnforceable 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 of40 40 CFR 63 SubpartX CFR Part 63 Subpart X, "National Emission Standards for Rule 335-3-11-.06 (23) HazardousAir Pollutants from SecondaryLead Smelting." 3. These sources are subject to the applicable requirements of 40 CFR 63 SubpartA Subpart A of40 CFR Part 63, "General Provisions" as listed in Table 1 ofSubpartX. 4. These sources are subject to the applicable requirements of Rule 335-3-4-.15 ADEM Admin. CodeR. 335-3-4-.15, "SecondaryLead 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 byEPA Reference (PSD/BACT) Method 5 as found inAppendixAof40 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 grjdscf 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 inAppendixA of40 CFR 60 (latest edition).

44

### FederallyEnforceable 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 of40 CFR 60 (latestedition). 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 of40 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 AppendixA of40 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 inAppendixA of40 CFR 60 (latestedition). 

### 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 associatedwith 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 priorto 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. Ifan exceedence ofthe 2008 Lead NationalAmbientAir 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 ofthe exceedence. Compliance and PerformanceTestMethods and Procedures 1. Method 12 of40 CFR Part 60, Appendix A shall be used in the 40 CFR Part 63 Subpart determination oflead compound emissions from the stack. X §63.547 (a) & Rule 335-3-11-.06 (23) 45

### FederallyEnforceable Provisos Regulations 2. Method 5 of 40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofparticulate 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 ofopacity ofthe stackemissions. 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 in40 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 Part64, "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. Ifthe 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 SecondaryLead 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 of40 CFR Part 63 SubpartX, "NationalEmission 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 SecondaryLead Smelting" to include §63.548, unless the Baghouses, associated with these sources, are equipped with HEPA filters in accordance with 40 CFR 63 SubpartX.

46

### FederallyEnforceable Provisos 6. Sanders Lead shall conduct lead compliance tests on the Stacks associated withthese sources according to the schedule specified in §63.543 and §63.544 of40 CFR Part 63 SubpartX, "National Emission Standards for Hazardous Air Pollutants from Secondary Lead Smelting". Resultswill be reported to the Director within 60 days ofcompletion oftesting. 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 continuouslymonitor 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 shallbe 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 shallbe compliedwith. 3. The facility shall maintain a record of how many kettles are Rule 335-3-14-.04 alloying at one time. The following records mustbe kept: (a) Date and time ofalloying. (b) Which kettles are alloying These records shallbe maintainedin a form suitable for inspectionfor 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 offive (5) years.



### 47

### SummaryPage for SlagTreatment Building (Stack 10) Permitted Operating Schedule: 24 Hrs/day x 7 Daysjweekx


### Emission limitations:

Stack 10
Stack 10
Stack 10
Stack 10 I

. r**Sl~g** Treatment Facility with

1 Baghouse I

, SlagTreatment Facilitywith ' Baghouse ' ! SlagTreatment Facility with

Baghouse

1 SlagTreatment Facility with

Baghouse . Pb

, PM**

**Permitee shallbe in compliancewith 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 SlagTreatment Facility (Stack 10) FederallyEnforceable Provisos Regulations Applicability 1. This source is subjectto the applicable requirements ofADEM 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 SubpartX CFR Part 63 Subpart X, "National Emission Standards for Rule 335-3-11-.06 (23) HazardousAir Pollutants from SecondaryLead Smelting." 3. This source is subject to the applicable requirements of 40 CFR 63 SubpartA SubpartA of40 CFR Part 63, "General Provisions" as listed in Table 1 ofSubpartX. 4. This source is subjectto the applicable requirements ofADEM Rule 335-3-4-.15 Admin. CodeR. 335-3-4-.15, "SecondaryLead Smelters." 5. This unit has an enforceable limit in order to prevent it from Rule 335-3-14-.04 being subject to the provisions ofADEM Admin. Code R. 335- 3-14-.04, "Air Permits Authorizing Construction in Clean Air Areas [Prevention ofSignificantDeterioration]." 6. This source has enforeceable limits in place in order to Rule 335-3-1-.03 provide for the attainment ofthe NationalAmbient 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 RawMaterial Storage (ERMS) building.

Page 49

### FederallyEnforceable 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 coveredwith 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 ofthe 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 inAppendixA of40 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 (latestedition). 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 ofthe exceedence. Compliance and PerformanceTestMethods and Procedures 1. Method 12 or Method 29 of40 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 of40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofparticulate matteremissions from the stack. 3. Method 9 of40 CFR Part 60, AppendixA shall be used in the Rule 335-3-1-.05 determination ofopacity ofthe stackemissions.

Page 50

### FederallyEnforceable 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 proofofcompliance with 40 CFR Part63 SubpartX and ADEM Rules and Regulations. 2. Reference the Appendix for the monitoring reqirements for 40 40 CFR Part 64 CFR Part 64, "ComplianceAssurance 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 MonitoringRequirements 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. Ifthe 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 SecondaryLead 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 SubpartX. 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 continuouslymonitor each total enclosure.

Page 51

### FederallyEnforceable Provisos Regulations Recordkeeping and Reporting Requirements

1. The recordkeeping requirements under §63.10 ofthe General 40 CFR 63.550 Provisions shall be adhered to. In addition, records of the information that is specifiedin §63.550 shallbe 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 offive (5) years.

Page 52

### SummaryPage Blast Furnace CanopyHoods and BuildingVentilation (Stack 11) Permitted Operating Schedule: 24 Hrsjdayx 7 Days/weekx 

### 52 Weeksjyr = 8760 Hrsjyr


### Emission limitations: EmissionPoint#

# r Description -. - -

### "1 

## "pc)ftutaD.t"

# -T----EmissionHn1if- -, - --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 BuildingVentilation

### w/ 

### ! 1 (SIP)
· Baghouse : ·

. BlastFurnace Canopy Hoods

### &
- Tpt) I 1 Furnace BuildingVentilation wj 1 ; Baghouse 1 I Blast Furnace Canopy Hoods &

Furnace BuildingVentilation

### w/ ' Baghouse

Page 53 

# +0.191 lbs/hr '''**~·** •i
...

I !""""""""""

..................................**~** (see general provisos)

'
...i
....**~**..

### Provisos for Blast Furnace CanopyHoods and BuildingVentilation (Stack 11) FederallyEnforceable 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 subjectto the applicable requirements of40 40 CFR Part 63 SubpartX CFR Part 63 Subpart X, "National Emission Standards for & Rule 335-3-11-.06 (23) Hazardous Air Pollutants from SecondaryLead Smelting." & 3. These sources are subject to the applicable requirements of 40 CFR Part63 SubpartA Subpart A of40 CFR Part 63, "General Provisions" as listed in andX. Table 1 ofSubpartX. 4. This source has enforeceable limits in place in orderto 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 of40 CFR 60 (latestedition). 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 byEPA Reference Method 12 or Method 29 as found in Appendix A of40 CFR 60 (latest edition). 3. No later thanJuly 1, 2013, this source shall be equippedwith a Rule 335-3-1-.03 secondary HEPA filter system downstream of the Baghouse associatedwith 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 leadedvehicles 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. Ifan exceedence ofthe 2008 Lead National AmbientAir 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 PerformanceTestMethods and Procedures
1. Method 12 or 29 of40 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 of40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofparticulate matteremissions from the stack. 3. Method 9 of40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofopacityofthe stackemissions.

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, "ComplianceAssurance Monitoring".

Page 55

### FederallyEnforceable 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 of40 CFR Part 63 SubpartX, "National Emission Standards for HazardousAir 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 proofofcompliance 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 of40 CFR Part 63 SubpartX, "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 continuouslymonitor 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 specifiedin §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 ofallmonitoringrequired 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 offive (5) years.

Page 56

### SummaryPage BatteryBreaker/ShredderBuilding (Stack 12) Permitted OperatingSchedule: 24 Hrsjdayx 7 Daysjweekx 52 Weeksjyr = 8760 

### Hrsjyr


### Emission limitations:



## .**EmaS~D** 

### POint

# ·r·-..DOSCripi!OD
. ----

# ·r**PO~t··J-EuliBdOaHDiit**

# r..**RiiUiit~O** Stack 12 1BatterBreaker/ShredderBuilding 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 BatterBreaker

### IShredderBuilding w

### I 1 Pb
· Baghouse

BatterBreaker/Shredder Building Baghouse

Page 57 0.044 lbs/hr
. Rule 335-3-1-.03 : (SIP)

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

### Provisos for BatteryBreaker/ShredderBuilding (Stack 12) FederallyEnforceable 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 of40 40 CFR Part 63 SubpartX CFR Part 63 Subpart X, "National Emission Standards for & Rule 335-3-11-.06 (23) HazardousAir Pollutants from SecondaryLead Smelting." & 3. These sources are subject to the applicable requirements of 40 CFR Part 63 SubpartA SubpartA of40 CFR Part 63, "General Provisions" as listed in and X. Table 1 ofSubpartX. 4. This source has enforeceable limits in place in orderto 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

### IShredder Building) shall not exceed 1.78 lbslhr as determined by EPA Reference Method 5 as found inAppendixA of40 CFR 60 (latest edition). 2. No later than July 1, 2013, Lead emissions from Stack 12 Rule 335-3-1-.03 (Battery Breaker

### IShredder Building) shall not exceed and 0.044 lblhr as determined by EPA Reference Method 12 or Method 29 as found inAppendixA of40 CFR 60 (latestedition). 3. No laterthan July 1, 2013, this source shall be equippedwith 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 laterthan 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

### FederallyEnforceable 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. Ifan exceedence ofthe 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 PerformanceTestMethods and Procedures
1. Method 12 or 29 of40 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 of40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofparticulate matteremissions from the stack 3. Method 9 of40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofopacity ofthe stackemissions.

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 MonitoringRequirements 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

### FederallyEnforceable 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 of40 CFR Part 63 SubpartX, "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 proofofcompliance 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 of40 CFR Part 63 SubpartX, "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 continuouslymonitoreach total enclosure. Recordkeepingand 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 shallbe 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 shallbe complied with. 3. The Permittee shall maintain a record ofall 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 offive (5) years.

Page 60

### SummaryPage RawMaterial Storage Building (Stack 13) Permitted Operating Schedule: 24 

### Hrs/dayx 7 

### Daysjweekx 

### 52 Weeksjyr = 

### 8760 Hrsjyr


### Emissionlimitations: 

# 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 Buildingwl ' PM ; 1.78 lbslhr Rule 335-3-1-.03

, Baghouse : (SIP)

I

... .. ····· ..

Raw Material Storage Building wI ; Baghouse

1 Raw Material Storage BuildingwI**~** 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 

### RawMaterial Storage Building (Stack 13) FederallyEnforceable 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 of40 40 CFR Part 63 SubpartX CFR Part 63 Subpart X, "National Emission Standards for 

### &Rule 335-3-11-.06 (23) Hazardous Air Poilutants from SecondaryLead Smelting." & 3. These sources are subject to the applicable requirements of 40 CFR Part 63 SubpartA SubpartA of40 CFR Part 63, "General Provisions" as listed in and X. Table 1 ofSubpartX. 4. This source has enforeceable limits in place in orderto 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 byEPA Reference Method 5 as found inAppendixA of40 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 inAppendixAof40 CFR 60 (latestedition). 3. No laterthanJuly 1, 2013, this source shall be equippedwith a Rule 335-3-1-.03 secondary HEPA filter system downstream of the Baghouse associatedwith Stack 13. 4. No laterthan 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 laterthanJuly 1, 2013, the Permittee shallinstall 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

### FederallyEnforceable 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 priorto exitingthe 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. Ifan exceedence ofthe 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 PerformanceTestMethods and Procedures
1. Method 12 or 29 of40 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 of40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofparticulate matter emissions from the stack. 3. Method 9 of40 CFR Part 60, Appendix A shall be used in the Rule 335-3-1-.05 determination ofopacity ofthe stackemissions.

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

### FederallyEnforceable 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 SubpartX, "National Emission Standards for HazardousAir 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 proofofcompliance 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 of40 CFR Part63 SubpartX, "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 continuouslymonitor 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 compliedwith. 3. The Permittee shall maintain a record ofall monitoringrequired 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 offive (5) years.

Page 64Appendix CAM

Page 65

### CO andVOC Plan for Blast Furnaces 1 & 

### 2 Afterburners (Stack 1)

---- Indicator I Indicator2

------- I. Indicator Afterburnerexit temperature Work Practice

- Measurement Approach The exit temperature is monitored with Inspection and tuning ofthe burner athermocouple 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 ordocument annual burner temperaturerecorded during the most inspection ordaily thermocouple system recent compliancetest, based on a inspection. runningthree hour average

--- Ill. Performance Criteria A. Data Representativeness Thethermocouple is located in the NotApplicable afterburnerchamberat the afterburner exit. The accuracyofthe thermocouple is ±2.5°F or0.1% ofthe range. The range is 0 to 2500°F. The recorded sensitivity is 0.1 °F.

-- NotApplicable NotApplicable B. Verification ofOperation Status ----- Accuracy ofthe thermocouple will be NotApplicable 

## c. QA/QC Practices and verified by a second redundantNISTtraceable 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, dailythermocouple system inspection E. Data Collection Chartrecorderrecords data Record results ofannual inspection and Procedures continuously and data loggerrecords tuning ofthe burner system and the daily instantaneous readings every 15- thermocouple system inspection minutes along with 15-minute and 3- houraverages every 15 minutes.

-- F. AveragingPeriod Fifteen minute and 3-houraverage NotApplicable

Page 66

### Particulate Matter CAM Plan for Stack 1 Baghouse Indicator I Indicator2 Indicator 3

- I. Indicator Opacity COMsas a BagLeak Inspection/Maintenance Detector MeasurementApproach COMs operated on COMs operatedon Variousbaghouse system primary scale as an secondary scale as a bag operation and opacitymonitor. leak detector. Secondary maintenance inspections Primary scale: 0

- I00% scale: 0- 20%opacity, are conducted within opacity for permit limit with alarm setpoint at prescribed intervals, per compliance. 50%ofscale MACT SOP manual. II. IndicatorRange An excursion is defined An excursion is defined as An excursion is defined as as an opacity an alarm at 50%ofthe failure to perform measurementexceeding scale. Excursion triggers inspections perMACT 10.0%on a 6-minute review ofchartrecord to SOP manual orto take average (50% ofvisible determine extent ofneed action following report of emission limit). for inspection, corrective necessary maintenance. Excursionstriggeran action, and recordkeeping inspection, corrective perMACT SOP manual. action, and a reporting requirement.

··- Ill. Performance Criteria A. Data Representativeness COMs located atthe COMs located at the PerMACT SOP baghouse outlet. baghouse outlet.

B. Verification ofOperation NotApplicable NotApplicable NotApplicable Status


## c. QAIQC Practices and Calibrate, maintain in Initial adjustments for Trained personnel to accordance with averagingperiod, 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 ofEPA;s written guidance for triboelectric monitors.

-- D. Monitoring Frequency Measured continuously. Measured continuously. Per MACT SOP

. Opacityoutput signal Bag leak detectoroutput Per MACT SOP and alarm times are signal and alarmtimes are continuouslyrecorded on continuouslyrecorded on E. DataCollection Procedures a strip chart. a strip chart. Six minute averages Instantaneous NotApplicable F. Averaging Period

Page 67

### Particulate Matter CAM Plan for SanitaryBaghouses Stack4 and Stack 4a**--------~**---- Indicator I (BLD) Indicator I (HEPA) Indicator2**---~- -~----**  I. Indicator Triboelectric Signal HEPA Pressure Drop Inspection/Maintenance

----- Measurement Triboelectric Monitor. Pressure Drop across the Variousbaghouse 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. IndicatorRange 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 ofscale for 7.5 pressure differential below SOP manual orfailure to take seconds. Excursionstriggers 0.5 inches ofH20 and action following report of review ofchartrecord to greaterthan 5.0 inches of necessarymaintenance. determineextentofneed for H20. Excursionstrigger inspection, corrective action, an inspection, corrective and recordkeepingperMACT action, and a reporting SOP manual. requirement.**-------------~-** III. Performance Criteria A. Data The probe sensoris located in The magnehelic measures Per MACT SOP Representativeness the baghouse exit stack. The the pressuredifferential triboelectric signal is between the inlet and outlet proportional to particulate ofthe HEPA filter system. mass flow iffactors such as humidity, exhaustgas 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 Measuredcontinuously. At least once daily PerMACT SOP
Triboelectic signal and record Thepressure drop will be PerMACT SOP E. Data Collection ofalarm times are recorded with date and Procedures continuously recorded on a time. stripchart, with any notes on alarms transcribed manually.

-**--------~** F. Averaging Period Instantaneous Instantaneous NotApplicable

----

Page 68

### CO andVOC CAM Plan for Blast Furnaces 3 and 4 Afterburners (Stack 5) Indicator I Indicator2

-- I. Indicator Afterburnerexittemperature Work Practice

-- Measurement Approach The exit temperature is monitored with Inspection and tuning oftheburner a them10couple 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 belowthe average perform ordocument annual burner temperature recorded duringthe most inspection ordaily thermocouple system recent compliance test, based on a inspection. running three houraverage

--- Ill. PerformanceCriteria A. Data Representativeness The thermocouple is located in the NotApplicable afterburnerchamberat the afterburner exit. The accuracy ofthe thermocouple is ±2.5°F or0.1%ofthe range. The range is 0 to 2500°F. Therecorded sensitivity is 0.1 °F.

NotApplicable NotApplicable B. Verification ofOperation Status Accuracyofthe thermocouple will be NotApplicable 

### c. QA/QC Practices and verified by a second redundant NISTtraceable thermocouple inserted Criteria adjacent to the primary thermocouple, onceeachday. (Thetwo readings must agree within 15 °F.) D. Monitoring Frequency Measured continuously. Annual inspection and tuning ofthc burnersystem, daily thermocouple system inspection E. Data Collection Chartrecorderrecords data Record results ofannual inspection and Procedures continuously and data loggerrecords tuning ofthe burner system and the daily instantaneous readings every 15- thermocouple system inspection minutes along with 15-minute and 3- houraverages every 15 minutes.

F. AveragingPeriod Fifteen minute and 3-houraverage NotApplicable

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### Particulate Matter CAM Plan for Stack 5 Baghouse

---- Indicator I Indicator2 Indicator 3



### ----- I. Indicator Opacity COMs as a BagLeak Inspection/Maintenance Detector

--- Measurement Approach COMs operated on COMs operated on Various baghouse system primary scale as an secondaryscale as a bag operation and opacity monitor. leak detector. Secondary maintenance inspections Primary scale: 0

- I00% scale: 0- 20%opacity, are conducted within opacity for permit limit with alarm setpoint at prescribed intervals, per compliance. 50%ofscale MACTSOP 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% ofthe failure to perform measurementexceeding scale. Excursion triggers inspections perMACT 10.0%on a 6-minute review ofchartrecord to SOP manual orto take average (50%ofvisible determine extent ofneed action following report of emission limit). for inspection, corrective necessary maintenance. Excursions triggeran action, and recordkeeping inspection, corrective perMACT SOP manual. action, and a reporting requirement.**--~** III. Performance Criteria A. DataRepresentativeness COMs located atthe COMs located atthe PerMACT SOP baghouse outlet. baghouseoutlet.

-- B. Verification ofOperation NotApplicable NotApplicable NotApplicable Status**----~"-~--"·--** C. QAIQC Practices and Calibrate, maintain in Initial adjustments for Trained personnel to accordance with averagingperiod, alarm perform maintenance and Criteria manufacturer's setpoint, and alarm delay inspections. specifications, 40 CFR time conducted using 60.13, and Appendix B, concepts ofEPA;s written guidance for triboelectric monitors. D. MonitoringFrequency Measured continuously. Measured continuously. PerMACT SOP Opacityoutput signal Bag leak detectoroutput PerMACT 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 NotApplicable

--

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### Particulate Matter CAM Plan for SlagTreatment BuildingBaghouse (Stack 10) Indicator I (BLD) Indicator I (HEPA) Indicator2



### -- 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. possiblebag 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 percentofscale for 7.5 pressure differentialbelow SOP manual orfailure to take seconds. Excursions triggers 0.5 inches ofH20 and action following report of review ofchartrecord to greaterthan 5.0 inches of necessary maintenance. determine extent ofneed for H20. Excursions trigger inspection, corrective action, an inspection, corrective and recordkeeping per MACT action, and areporting SOP manual. requirement.**"--~--~---** Ill. Performance Criteria A. Data The probe sensoris 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 proportionalto particulate ofthe HEPA filter system. mass flow iffactors such as humidity, exhaustgas 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 atthe 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 leastonce daily Per MACT SOP Triboelectic signal and record The pressure dropwill be Per MACT SOP E. DataCollection ofalarm times are recorded with date and Procedures continuously recorded on a time. strip chart, with any notes on alarmstranscribed manually.
F. Averaging Period Instantaneous Instantaneous NotApplicable

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### Particulate Matter CAM Plan for CanopyHoods andFurnace BuildingVentilation Baghouse (Stack 11) Indicator I Indicator2

---- Indicator HEPA Pressure Drop Inspection/Maintenance MeasurementApproach 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 below0.5 perform inspections per MACT SOP inches ofH20 and greaterthan 5.0 inches of manual or failure to take action H20. Excursionstriggeran inspection, following report ofnecessary corrective action, and a reporting maintenance. requirement.
III. Performance Criteria The magnehelic measures the pressure A. Data differential between the inletand outlet of PerMACT SOP Representativeness the HEPA filter system. B. Verification of Not Applicable NotApplicable Operation Status 

## c. QA/QC Practices and Quarterly inspection ofthe pressuretaps Trainedpersonnel to perform located atthe HEPA inlet and outlet. maintenance and inspections. Criteria At least oncedaily 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 NotApplicable

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### Particulate Matter CAM Plan for Alloying Kettles andAlloying Kettle Heating System Baghouse (Stack 14) Indicator I Indicator2 Indicator HEPA Pressure Drop Inspection/Maintenance MeasurementApproach Pressure Drop across the HEPA fiIter 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 pressuredifferential below0.5 perform inspections per MACT SOP inches ofH20 and greaterthan 5.0 inches of manual or failure to take action H20. Excursionstriggeran inspection, following report ofnecessary corrective action, and a reporting maintenance
. requirement.
Ill. PerformanceCriteria The magnehelic measures the pressure A. Data differential between the inletand outlet of Per MACTSOP Representativeness the HEPA filter system. B. Verification of NotApplicable NotApplicable Operation Status 

## c. QA/QC Practices and Quarterly inspection ofthe pressuretaps Trained personnel to perform located atthe 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 NotApplicable

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