# State Implementation Plan

**Lead Non**

**- Attainment**  **Council Bluffs, Iowa**

**Iowa Department of Natural Resources**
**Environmental Services Division Air Quality Bureau** 
**7900 Hickman Rd Suite 1 Windsor Heights, IA 50324** 

**January 30** 
**, 2015** 
**Final**

# Executive **Summary**

Lead is an air pollutant linked to adverse health effects upon IQ, behavior, and learning, particularly among children. To help protect public health and welfare the U.S. Environmental Protection Agency (EPA) establishes and periodically revises N ational A mbient A ir Q uality S tandards (NAAQS) for six types of air pollutants, known as criteria pollutants. Lead is one of the criteria pollutants and EPA first established a lead NAAQS in 1978.

The 1978 lead NAAQS remained in place until 2008 when EPA tightened the standard s , lowering the acceptable ambient lead levels by an order of magnitude, to 0.15 μg/m 3 , never to be exceeded by any
three

- month rolling average. EPA’s revision of the lead NAAQS also required new efforts to evaluate
emissions from existing lead sources. An outcome of this process is that the Iowa D epartment of Natural Resources (D NR ) started operating a new lead monitor in Council Bluffs in November 2009. This
monitor recorded ambient lead concentrations in 2010 that did not mee t the revised standard. As a consequence a portion of Council Bluffs was designated a lead nonattainment area

, effective December 31, 2011

.

The Iowa DNR is required by the federal Clean Air Act and EPA’s associated nonattainment regulations to submit a pla n to eliminate the unhealthy ambient lead levels. This document, referred to as a lead nonattainment SIP, constitutes that plan and it is designed to fulfill all associated obligations. Required elements of a nonattainment plan include, for example, an a ssessment of the lead sources in the area,
the identification of control measures needed to bring the area back into attainment, and an attainment demonstration supporting the effectiveness of the control measures.

Two sources within the lead nonattainm ent area emit lead, Griffin Pipe Products Co., LLC (Griffin Pipe) and Alter Metal Recycling. Griffin Pipe manufactures ductile iron pipe for potable water transmission and other uses. Alter Metal Recycling is a scrap metal recycler. The two facilities a re located next to
one another near the lead monito r.

The control measures require lead emissions reductions from both facilities

. Although o perations at
Griffin P ipe are temporarily suspended the facility must implement one of two available control strategies wh en operations resume. B oth strateg ies require haul road sweeping and include new

emissions limits on existing lead sources. O ne option adds limits on the hours of operations while the second option requires the installation of a new baghouse to control existing source s

. The c ontrol measures for Alter Metal Recycling r equire roadway sweeping efforts designed to reduce haul road lead emissions by 95%

. The sweeping requirements went into effect September 9, 2014.

All lead control measures a re federally enforceable and have reduce d actual and potential lead

emissions within the nonattainment area . The most recent monitored lead NAAQS violation occurred in 2012 during the September through November 3

- month rolling average. No new l ead NAAQS violations are anticipated

. A ttainment is expected in an expeditious manner consistent with federal requirements

, no later than December 31, 2016

.

2

## Contents

1. Introduction

................................ ................................ ................................ ................................ .......... 5

1.1. National Ambient Air Quality Standards

................................ ................................ ....................... 5

1.2. Lead Nonattainment Designation

................................ ................................ ................................ . 5

1.3. Description of the Nonattainment Area

................................ ................................ ....................... 7

1.4. Summary of Air Quality Data

................................ ................................ ................................ ........ 9

1.5. Affected Sources

................................ ................................ ................................ ......................... 11

Griffin Pipe

................................ ................................ ................................ ................................ .......... 11

Alter Metal Recycling

................................ ................................ ................................ .......................... 11

2. Nonattainment SIP Requirements

................................ ................................ ................................ ...... 12

3. 2010 Baseyear Lead Emissions Inventory

................................ ................................ ........................... 13

3.1. Griffin Pipe

................................ ................................ ................................ ................................ .. 14

3.2. Alter Metal Recycling

................................ ................................ ................................ .................. 14

3.3. Haul Roads

................................ ................................ ................................ ................................ .. 14

3.4. Other Sources

................................ ................................ ................................ ............................. 14

4. RACT/RACM

................................ ................................ ................................ ................................ ........ 16

4.1. Griffin Pipe

................................ ................................ ................................ ................................ .. 17

Cupola

................................ ................................ ................................ ................................ ................. 18

Desulfurization and Magnesium Inoculation

................................ ................................ ...................... 19

Haul Roads, Casting, Scrap Handling, and Building Emissions

................................ ............................ 19

4.2. Alter Metal Recycling

................................ ................................ ................................ .................. 19

5. Control Strategy

................................ ................................ ................................ ................................ .. 20

5.1. Griffin Pipe

................................ ................................ ................................ ................................ .. 20

Control Strategy Option A

................................ ................................ ................................ ................... 20

Control Strategy Option B

................................ ................................ ................................ ................... 21

Standard Operating Procedures

................................ ................................ ................................ ......... 21

5.2. Alter Metal Recycling

................................ ................................ ................................ .................. 22

5.3. Implementation

................................ ................................ ................................ .......................... 23

6. Attainment Demonstration

................................ ................................ ................................ ................. 24

6.1. Source Characteristics

................................ ................................ ................................ ................. 24

6.2. Receptor Gr ids

................................ ................................ ................................ ............................ 27

6.3. Terrain Elevations

................................ ................................ ................................ ....................... 27

6.4. Building Downwash

................................ ................................ ................................ ..................... 27

6.5. Meteorological Data

................................ ................................ ................................ ................... 27

6.6. Background Value

................................ ................................ ................................ ....................... 27

36.7. Results

................................ ................................ ................................ ................................ ......... 28

7. Reasonable Further Progress

................................ ................................ ................................ .............. 30

8. Contingency Measures

................................ ................................ ................................ ........................ 31

9. Attainment Date

................................ ................................ ................................ ................................ . 32

10. Additional Nonattainment SIP Provisions

................................ ................................ ........................... 33

10.1. Identification & Quantification of Emissions

................................ ................................ .............. 33

10.2. Nonattainment New Source Review

................................ ................................ ........................... 33

10.3. CAA §110(a)(2) Requirements

................................ ................................ ................................ .... 33

10.4. Equivalent Techniques

................................ ................................ ................................ ................ 33

11. Administrative Materials & Responses to Public Comments

................................ ............................. 34

11.1. Submittal Letter

................................ ................................ ................................ .......................... 34

11.2. Evidence of State Adoption

................................ ................................ ................................ ......... 34

11.3. Necessary Legal Authority

................................ ................................ ................................ ........... 34

11.4. Evidence of Public Notice & Public Hearing Certification

................................ ........................... 34

11.5. Compilation of Public Comments and the State’s Responses

................................ .................... 35

Appendix A. Baseyear 2010 Haul Road Emissions Calculations

................................ .............................. 40

Appendix B. Griffin Pipe Administrative Consent Order

................................ ................................ ......... 51

Appendix C. Alter Metal Recycling Construction Permit

................................ ................................ ........ 79

Appendix D. Facility Changes at Alter Metal Re cycling

................................ ................................ ........... 90

Appendix E. Proof of Publication

................................ ................................ ................................ ............ 99

4

## 1. **Introduction**

On November 22, 2011, the U.S. Environmental Protection Agency ( EPA) issued a final rule ( 76 FR 72097 ) designating a portion of Pottawattamie County, Iowa, as a lead (Pb) nonattainment area. Th e feder al Clean Air Act (CAA) requires a state with a lead nonattainment area to submit to EPA a State Implementation Plan (SIP) revision that demonstrates how the area will attain the lead N ational

A mbient A ir Q uality S tandards (NAAQS). T he lead NAAQS must be achieved as quickly as possible and no later than 5 y ears after t he effective date of the designation. T he nonattainment designation for a n area in Council Bluffs became effective on December 31, 2011, and therefore the lead NAAQS must be
achieved no later than December 31, 2016. The Iowa Department of Nat ural Resources (DNR) developed this document and the associated control measures to fulfill those and all other applicable

nonattainment SIP requirements

.



### 1.1. **National Ambient Air Quality Standards** Lead is a naturally occurring metal that can be harmful to human health and is one of six common air pollutants regulated by the EPA using NAAQS. Primary N AAQS are criteria established by EPA that set limits on air pollution necessary to protect human health with an adequate margin of safety . Secondary NAAQS protect public welfare (public welfare protections consider, for example, effects on soils, water, crops, vegetation, man

- mad e materials, animals, wildlife, and visibility)

. The primary and secondary
NAAQS for lead are identical. The C AA requires EPA to review the NAAQS every five years and

, if

necessary, update the standards to ensure they provide adequate health and welfare protection s.

The EPA first established health standards for lead on October 5, 1978 (43 FR 46246). At that ti me the lead NAAQS were set at a level of 1.5 micrograms per cubic meter of air ( μ g/m 3 ), averaged over a calendar quarter. On October 15, 2008, EPA promulgated a revision to the standard, lowering the level by an order of magnitude, from 1.5 μg/m 3 to 0.15 μg/m 3

. The averaging period was also revised, from a calendar quarter to a three

- month rolling average. To meet EPA’s new health standard, no three

- month rolling average lead concentrations may exceed 0.15 μ g/m3 across a consecutive three

- year period. T he secondary standard was also revised, to be identical to the new primary standard. The 2008 lead
NAAQS are summarized in Table 1

- 1 . For additional information on the 2008 lead NAAQS revision see the preamble and rule language published in the Federal Register on November 12, 2008 ( 73 FR 66964 )

.

Table 1

- 1 . Summary of the 2008 lead NAAQS. The primary and secondary standards are identical.

Pollutant Averaging Time Level Form

Lead ( Pb) 3

- month rolling average 0.15 μg/m 3 Not to be exceeded



### 1.2. **Lead Nonattainment Designation**  Following a NAAQS revision, S ection 107(d) of the CAA requires the states and EPA to complete a designations process. An area that does not meet the standard, or an area that contributes to a nearby area not meeting the standard, is classified as a nonattainment are a. On November 3, 2009, a required

source

- oriented lead monitor began op eration in Council Bluffs, Iowa . In the following year (2010), 6
three

- month r olling averages greater than 0.15 μg/m 3 Pb NAAQS were measured. The highest value, 0.26 μ g/m 3 , occurred in the June

- August 2010 average. T he EPA designated a portion of Pottawattamie County as a nonattainment area in response to the measured lead concent rations

.

5At approximately 950 square miles, Pottawattamie County is the second largest county in Iowa by geographical area, the 8 th largest by population with 93

, 518 inhabitants 1

, and is part of the Omaha (Nebraska)

- Council Bluffs (Iowa) metropolitan st atistical area. The st atewide perspective of the location of Pottawattamie County is depicted in Figure 1

- 1

.

Figure 1

- 1

. Reference map illustrating the location of Pottawattamie County (in yellow) within Iowa

.

The nonattainment designation was published in the Federal Register on November 22, 2011 ( 76 FR

72097 ) and became effective December 31, 2011. The official definition of the nonattainment boundary
is contained in the C ode of Federal R egulations (CFR) at 40 CFR 81.316 a s the “Area bounded by Avenue G on the north, N 16th/S 16th street on the east, 23rd Avenue on the south, and N 35th/S 35th street on
the west.” This definition is summarized in Table 1

- 2

.

Table 1

- 2 . Roadway b oundaries used to define the lead nonattainment area.

Northern boundary Avenue G Eastern boundary N 16 th / S 16 th Street Southern boundary 23 rd A venue Western boundary N 35 th / S 35 th S treet

While it is not clear from the CFR the lead nonattainment area is located entirely within the city of Council Bluffs, Iowa. The nonattainment area encompasses about 3.43 square miles within the city and is approximately centered on the locations of the lead monitor and two lead emitting s ources , Griffin Pipe Products Co., LLC (Griffin Pipe) and Alter Metal Recycling, which are all near the intersections of 9 th

Ave and S 27 th St as shown in Figure 1

- 2

.

1 July 1, 2011, US Census Bureau data : http://www.census.gov/popest/data/counties/totals/2011/index.html

6Figure 1

- 2

. Depiction (in green) of the lead nonattainment area within t he city of Council Bluffs, Iowa,
and the relative locations of Griffin Pipe , Alter Metal Recycling, and the lead monitor

.



### 1.3. **Description of the Nonattainment Area**
Council Bluffs is located on the we stern edge of Pottawattamie County, along the Missouri River. T he topography of Pottawattamie C ounty consists of flat river bottoms in width from 3 to 10 miles along the Missouri River. Bluffs extending 100 to 300 feet above the river plain demark the ex tent of the generally
level bottomlands. Moving eastward beyond the bluffs the topography transitions into areas of steep ravines and hills, followed by gently rolling prairie

. 2 A topographic depiction of the region around the
nonattainment area is shown in Figure 1

- 3

.

2 http://en.wikisource.org/wiki/History_of_Iowa_From_the_Earliest_Times_to_the_Beginning_of_the_Twentieth_ Century/3/Counties/Pottawattamie

7Figure 1

- 3 . Topographic features within the vicinity of the nonattainment area.

The topography within the nonattainment area is comparable to flat river bottom s , displays ne gligible changes in elevation

, and does not exhibit features that would create a consistent barrier capable of segregating the area into distinct airsheds . While river influenced flows are probable in this region they are not expected to significantly influence lead emissions or concentrations not otherwise accounted for in the meteorological data (from Eppley Airfield

– the Omaha airport) used in the dispersion modeling.

Gri ffin Pipe is located ju st south of t he source oriented lead monitor. Lying immediately south of Griffin Pipe is Alter Metal Recycling. The area surrounding the monitor generally consists of a mix of industrial and residential properties. A rail yard occupies much of the land south of Alter Metal Recycling. Residential housing is found in the area immediately west and also near the northern border of Griffin Pipe. Figure 1

- 4 illustrates t he approximate property boundaries of Griffin Pipe and Alter Metal Recycling, relative to the lead monitor (boundary data obtained from: http://gis.pottcounty.com )

.

8Figure 1

- 4

. Approximate property b oundaries for Griffin Pipe (blue) and Alter Metal Recycling (green).
The lead monitor is at approximate latitude, longitude: 41.254223,

- 95.887297

.



### 1.4. **Summary of Air Quality Data**

In the 2008 lead NAAQS revisions ( 73 FR 66964 , November 12, 2008) EPA included provisions to expand the lead monitoring network. One phase of the expansion required the addition of sourc e oriented

monitors l ocated to measure the maximum lead concentration s near sources with lead emissions of 1.0

tons 3 per year or more. S ource

- oriented monitors not eligible for an exemption based on dispersion modeling were required to be operation al by J anuary 1, 2010

. The monitoring criteria resulted in one

ne w source

- oriented lead monitor being added in the state, sited near the Griffin Pipe facility. The

monitor (site ID 191550011 ) is located approximately 250 feet north of the Griffin Pipe facility, near the
intersections of 8 th Ave and S 27 th St in Council Bluffs. The m onitor started operation on November 3, 2009, measuring lead concentrations in total suspended particulate (TSP) and reporti ng concentrations

in local conditions

.

Although a lead desig n value is based on three years of three

- month rolling averages, a single three

mont h average over the standard constitutes a NAAQS violation because t he form of the standard does not allow any exceedances. Determining that an area does not attain the standard can therefore be
done with three months of data if that average is over 0.15 μg/m 3

. The EPA utilized this characteristic of the lead NAAQS to issue a second round of lead designations in 2011, based on 2010 data from newly
sited source

- oriented monitors. The lead nonattainment designation in Council Bluffs occurred on that
schedule.

3 EPA later reduced the lead emissions threshold from 1.0 to 0.5 t ons per year ( 75 FR 81126

, December 27, 2010 ).

9T he Council Bluffs lead mo nitor recorded 6 three

- month rolling averages violating the lead NAAQS in

2010. The highest of these 3

- month rolling averages occurred over the period June

– August and was

0.26 μg/m 3 (see Table 1

- 3 ). The latest available certified lead data i ncludes measurements through 2013. While no additional NAAQS violations were recorded in 2011, four occurred in 2012. No new NAAQS violations occurred in 2013. The three

- month rolling average lead data are charted in Figure 1

- 5

.

T able 1

- 3

. Three

- month rolling average lead concentrations at the Council Bluffs lead monitor. NAAQS

violations are indicated in red. The month provided indicates the ending month of the three month

rolling average (averages for January and February include data from the preceding year).

2010 3

- Month Rolling Average 2011 3

- Month Rolling Average 2012 3

- Month Rolling Average 2013 3

- Month Rolling Average

Jan 0.10 Jan 0.05 Jan 0.08 Jan 0.09
Feb 0.03 Feb 0.03 Feb 0.05 Feb 0.07

Mar 0.07 Mar 0.07 Mar 0.07 Mar 0.05 Apr 0.12 Apr 0.07 Apr 0.07 Apr 0.05 May 0.14 May 0.11 May 0.10 May 0.05

Jun 0.17 Jun 0.10 Jun 0.10 Jun 0.07
Jul 0.20 Jul 0.14 Jul 0.14 Jul 0.09

A ug 0.26 A ug 0.12 A ug 0.18 A ug 0.13 Sep 0.24 Sep 0.09 Sep 0.19 Sep 0.12

Oct 0.25 Oct 0.08 Oct 0.20 Oct 0.10

Nov 0.18 Nov 0.09 Nov 0.16 Nov 0.05

Dec 0.14 Dec 0.10 Dec 0.14 Dec 0.04

Figure 1

- 5 . Three

- month rolling average lead concentrations from the Council Bluffs lead monitor

, November 2009

– December 2013 certified data.

10

### 1.5. **Affected Sources**

T wo lead so urces were identified within the nonattainment area , Griffin Pipe Products Co., LLC, and
Alter Meta l Recycling. Griffin Pipe is considered a major source for Title V and P revention of Significant Deterioration (P SD ) purposes

. Alter Metal Recycling is a minor source.

**Griffin Pipe** Griffin Pipe manufactures ductile iron pressure pipe for potab le water transmission and wastewater
collection. Using North American Industry Classification System ( NAICS ) descriptions the facility is considered a gray iron foundry associated with NAICS code 331511. The facility in Co uncil Bluffs covers more than 10 5,000 square feet on a nineteen (19) acre site. The plant produces ductile iron pressure pipe in twenty (20) foot lengths and diameters ranging from 6” through 48”.

The hot iron required in the pipe manufacturing process is produced in a cupola. The cup ola uses coke, scrap iron, scrap steel, and fluxes as raw materials. After the hot iron leaves the cupola it is treated in a desulfurization process and a magnesium inoculation process . Desulfurization removes undesirable sulfur from the metal and magnes ium inoculation uses magnesium to give the metal the physical properties needed to produce the ductile iron pipe. 4 Lead present in the scrap is emitted as the m etals are melted in the cupola, treated in the desulfurization and magnesium inoculation proces ses , and cast

.

On February 4, 2014, U.S. Pipe and Foundry C ompany announced the acquisition of a majority interest in Griffin Pipe. O n March 3, 2014, the facility ceased operating the cupola (melt ing operations were suspended) with finishing opera tions ending on March 7, 2014. The plant was idled on May 3, 2014

. 5 Griffin Pipe does not consider the idling of the plant a permanent shutdown and will resume operations (pipe production) when economic conditions warrant

.
**Alter Metal Recycling** Alter Metal Recycling is a scrap material processing facility associated with Alter Trading Corporation

. Alter Trading is a privately owned company f ounded in 1898, with trading offices and processing plants
across the central United States. 6 The Council Bluffs facility is one of several scrap processing facilities in Iowa. The Council Bluffs facility receives waste metal, for example, used cars, and operates a shredder (hammer mill) that reduces the incoming material into more manageable sizes. The fac ility is considered
a minor source. Lead emissions from Alter Metal Recycling occur predominantly from fugitive emissions
associated with vehicle traffic on facility roadways when roadway silt containing lead becomes airborne.

4 From Griffin Pipe’s January 21, 2010 PSD application.

5 Some pipe storage and pipe shipping actives may occur after that date.

6 http://altertrading.com/company_history.shtml

11

## 2. **Nonattainment SIP Require ments** 

This SIP submittal is intended to fulfill the obligations of a lead nonattainment SIP. 7 As discussed in more detail in the preamble to the final lead NAAQS revisions ( 73 FR 66964

, November 12, 2008) , the nonattainment SIP must meet the requirements of subpart 1 of Part D of the Clean Air Act, including those specified in Section 172(c). The required plan elements in CAA § 172(c) are summarized ( simplified, clarified

, and paraphrased ) in Table 2

- 1

. Details are provided in later chapters.

Table 2

- 1 . Summary of Clean Air Act § 172(c) nonattainment SIP requirements.

CAA §172(c)(1) Provisions f or attainment and the timely implementation of all Reasonably Available Control Measures (RACM) & Reasonably Availab le Control Technologies (RACT)

. CAA §172(c)(2) R easonable further p rogress (RFP) requirements ( met by appropriate emission
reduction s and implementation timelines)

. CAA §172(c)(3) Compile a comprehensive , accurate, and current inventory of actual emissions

.

CAA §172(c)(4) Identify and quantify emissions which will be allowed, in accordance with CAA § 173(a)(1)(B), from the construction/ operation of major new or modified stationary

sources. Demonstrate such emissions will be consistent with RFP and the NAAQS

. CAA §172(c)(5) Include p rovisions to implement nonattainment new source review requirements

.

CAA §172(c)(6) Develop a control strategy with schedules and timetables for compliance and
enforceable emissions limits or other control meas ures necessary for the timely

attain ment of the NAAQS

. CAA §172(c)(7) Comply with the applicable provisions of CAA § 110(a)(2)

. CAA §172(c)(8) This element allows the use equivalent techniques for modeling, emissions inventory, or planning procedures (if no less stringent than any standard methods)

. CAA §172(c)(9) Provide for the implementation of contingency measures if the area does not make

RFP or if the area does not attain the standard by the required attainment date

.

Compilation of the emissions inventory typically occurs early in the SIP development process to help identify potentially imp ortant sources. The var ious control measures (which incorporate RACT/RACM)
included in the control strategy consider implementation timeframes t o ensure reasonable further progress (RFP) requirements are met and to ensure the NAAQS are attain ed a s expeditiously as practicable. By law, the area must attain the standard within 5 years of the date of the nonattainment designation. The nonattainment designation became effective December 31, 2011, and thus the attainment date can be no later than December 31, 2016.

An attainment de monstration provides evidence that the overall control strategy is sufficient to achieve the NAAQS within the regulatory timelines. The attainment demonstration is completed using air quality dispersion models in accordance with Appendix W of 40 CFR 51. The control strategy must also

contain a description o f enforcement methods, including procedures for monitoring compliance and handling violations. Addit ional information regarding control strategy related requirements can be found in 40 CFR 51 Subpart G

.

The s tate is demonstrating in this lead nonattainment SIP that it has met all applicable obligations, including applicable provisions reviewed in Table 2

- 1 , the necessary public participation requirements,
and all applicable admini strative requirements in 40 C FR 51.

7 While technically this document is a SIP revision, for simplicity it is often referred to as a lead nonattainment SIP.

12

## 3. **2010 Baseyear**  **Lead Emissions Inventory** 

A comprehensive, accurate, and current inventory of actual lead emissions within the nonattainment

area is a required comp onent of the nonattainment SIP per CAA § 172(c )( 3)

. Special provisions pertaining to the submittal of lead emissions inventory data are found in 40 CFR 51.117. Among the requirements is 40 CFR 51.117 (e) : “ Emissions data. (1) The point source inventory on which the summary of the baseline for lead emission s inventory is based must contain all sources that emit 0.5 or more tons of lead per year. ”

The baseyear inventory establishes a baseline and is used to evaluate emissions reductions achieved by the control strategy and to assess reasonable further progr ess requirements

. The DNR is selecting calendar year 2010 as the baseyear as it corresponds to the first year in which lead NAAQS violations
were measured at the lead monitor

. In 2010, t wo facilities within the nonattainment area emit ted more than one po und of lead per year

, Griffin Pipe and Alter Metal Recycling. 8 B a seyear lead emissions

estimates are provided in Table 3

- 1 and were calculated by the DNR using stack test results, information submitted by the facility, state review, and engineering estimates

.

Table 3

- 1

. A ctual lead emissions estimates for the 2010 baseyear

. Note, haul road

emissions estimates are indicative of worst

- case conditions . Due to rounding total emissions in lbs/year may not sum exactly as shown.

Facility

[ ID ] Source Type Emission Unit (ID) + Emission
Point ID Pb
Emissions (tons/ y r ) Pb
Emissions

(lb/yr )

Griffin Pipe ( GP) [ 78

- 01

- 012 ] Point Cupola (EU

- 1) EP

- 2 ++ 0.7447 1,489 Magnesium Inoculation (EU

- 4) Hot Iron Desulfurization (EU

- 2) EP

- 7A

0.2570 514 Uncaptured Magnesium Inoculation (EU

- 4) EP

- 7B

Small Diameter Casting (EU

- 6) EP

- 6A 0.0018 4 Building Emissions EP

- 6B

Large Diameter Casting (EU

- 29) EP

- 29 0.0018 4 EP

- 29A

Fugitive Scrap Handling (EU

- 17) FUG1 0.0043 9
Haul Roads n/a 0 .0286 57
GP Total 1.0382 2,07 6

Alter Metal Recycling (AMS) [ 78

- 01

- 043 ] Fugitive Haul Road s n/a 0.7182 1,436

+ F or simplicity, all emission units are not always listed if an emission point is associated with more than one unit. This does not affect the
lead emissions totals.

++ The Cupola Wet Scrubber Stack. AMS Total 0.7182 1,436

Total 1.7564 3,513

8 One lb/yr was not used as a specific threshold but instead represents a potential screening level to eliminate sources with very small (inconsequential), but non

- zero, lead emissions. For example, sources combusting fuel oil or natural gas (or other fuels) may report minute lead em issions due to trace quantities of lead present in the fuel.

13

### 3.1. **Griffin Pipe**

Point source l ead emissions from Griffin Pipe occur primarily from melting metal, a hot iron desulfurization process, a magnesium inoculation process

, and metal casting

. The melting process uses a cupola furnace that is charged with coke, scrap iron, scrap steel, and fluxes as raw materials. A s the
materials are heat ed, melted, and move through the casting process, l ead content present in the scrap is released and vented through stacks and roof vents

. The baseyear lead emissions from Griffin Pipe ’s poin t sources we re determined using information re viewed or calculated by the DNR . Data sources
include d stack test results, throughput information

, or other facility

- specific data. EPA’s online compilation of air p ollution (AP) emissions factors in AP

- 4 2 (Volume I , Fifth Edition) or industry

- based
emission factors were used only when no other information was available

.

The haul road and cupola charging (scrap handling) processes generate fugitive emissions external to the buildings at Griffin Pipe

. Lead present in the silt on facility haul road s is re

- entrained by facility traffic. Smaller amounts of lead are emitted by handling scrap material before and during the cupola charging process. While minute quantities of lead can be found in other mater ials used as the facility, such as in cement applied to the cast pipe and the natural gas used to fire the annealing furn aces, these trace quantities are negligible and were not considered in the development of control measures

.



### 3.2. **Alter Metal Recycling**

Alte r Metal Recycling is the other stationary facility within the nonattainment area with lead emissions contributing to monitored lead levels above the NAAQS. Inbound and outbound materials are transported primarily by truck to, from, and within Alter Metal Recycling. Haul road activities are the
dominant sou rce of lead emissions at Alter Metal Recycling

. Other activities at this facility such as torch cutting and hammer mill operations are estimated to be negligible and were not included in the development of control measures

.



### 3.3. **Haul Roads**

T he baseline haul road emissions estimates (for both facilities) provided in Table 3

- 1 likely represent

worst

- case conditions. The emission estimates are derived from the analysis of surface roadway
conditions prior to any watering or sweeping of the haul road s

. In reality, r oadway fugitive dust suppression activities in use in 2010 at Griffin Pipe or Alter Metal R ecycling would reduce haul road lead
emissions. The effects of this caveat are not readily quantifiable and it is possible t he baseyear haul
road emission estimates overstate the true values. Details of the baseyear haul road emissions calculation at both Alter Metal Recycling and Griffin Pipe are provided in Appendix A

.



### 3.4. **Other Sources** No other stationary sources within the nonattainment area are known to emit lead in quantities
relevant to monitored lead values in the nonattainment area. 9 On road m obile sources are no longer
associated with lead em issions. The latest tool for estimating emissions from onroad sources, the
MOtor Vehicle Em issions Simulator (MOVES2014 ) does not include lead as a pollutant. Similarly, lead is not included as a pollutant in the latest nonroad emissions model (NONROAD2008 ). The NONROAD
model c alculates emissions for all offroad sources except commercial marine, locomotives, and aircraft

.

9 Due to trace amounts of lead in many fossil fuels such as natural gas and fuel oil, small quantities can be emitted from various sources. For example, the 2011 NEI (version 1, September 30, 201 3) had ~19.5 pounds of lead emitted within all of Pottawattamie County from sources within the EIS Sector “ Fuel Comb

- Industrial Boilers, ICEs

– Oil .” This value represents less than 1% of the total from Alter Metal Recycling and Griffin Pipe. Such sour ces have been screened from further review.

14No commercial marine vehicles operat e within the nonattainment area . While piston

- engine aircraft

may use leaded aviation fuel (commercial jet aviation aircr aft do not use leaded fuel ) no airports are located within the nonattainment area

.

The most recent comprehensive triennial National Emis sions Inventory (NEI) ( 2011 Version 1, released September 30, 2013) estimates lead emissions from locomotive activiti es for all of Pottawattamie
county at 0.002 936 tons per year (tpy) of lead (~5.87 lbs/year)

. L ocomotive emissions are not pertinent
to the development of control measures for the lead nonattainment area. No other lead sources within
the nonattainment are a have been identified or quantified.

15

## 4. **RACT/RACM**

Section 172(c) (1) of Part D of the CAA requires that the nonattainment implementation plan “... provide for the implementation of all reasonably available control measures [RACM] as expeditiously as practicable (including such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimum, of reasonably available control technology [RACT] ) and shall provide for attainment of the nat ional primary ambient air quality standards. ”

Identification of lead RACM begins by identifying potential control measures for lead sources within the

nonattainment area

. 10 EPA’s March 2012 Guide to Developing Reasonably Available Control Measures (RACM) for Controlling Lead Emissions

, EPA

- 457/R

- 12

- 001

, identifies factors that should then be considered in determining whether a control measure is RACM:

1. The economic feasibility of the control measure,

2. The capital costs, annualized cost, and cost effe ctiveness of the control measure; and

3. The extent of adoption of the control measure by state regulations.

Control measures may be excluded from further consideration if it can be shown, both individually and as a group, that the emissions from the aff ected sources are insignificant ( 73 FR 66964 p. 6 7036). The remaining measures should be adopted as RACM if they are economically viable and technically feasible.

EPA’s historic description of RACT is the lowest emissions limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility ( 73 FR 66964 p. 67037). A RACT definition is provided in 40 CFR 51.100(o) : Reasonably available control technology (RACT) means devices, systems, process modifications, or other apparatus or techniques that are reasonably available taking into account: (1) The necessity of imposing such controls in order to attain and maintain a national ambient air quality standard; (2) The social, environmental, and economic impact of such controls

.

EPA is recommending a threshold for RACT analyse s such that at least all stationary sources emitting 0.5 tpy or more of lead should undergo a RACT review and that smaller sources should also be included if necessary to demonstrate attainment ( 73 FR 66964 p. 67038). RACT applies to existing sources of lead in the nonattainment area and encompasses stack e missions, fugitive emissions (such as haul roads), and industrial pr ocess fugitive emissions ( 73 FR 66964 p. 67037). The only two facilities with relevant
lead emi ssions within the nonattainment area are Griffin Pipe and Alter Metal Recycling . In the 2010 baseyear both facilities had estimated baseline actual emissions greater than EPA’s su ggested 0.5 tpy
RACT threshold.

From the above discussion it may appear a RACT/RACM determination requires a complex multifaceted analysis involving costs and other factors. In practice

, the RACT/RACM evaluation is generally less complex . RACT/RACM determinations are often simply the emission limits or other control measures necessary to achieve the NAAQS. The use of common, simple, or widely available control measures can effectively negate the need for an in

- depth analysis, particularly when such techniques are prerequisites for attainment of the NAAQS.

10 See 73 FR 66964 ( November 12, 2008 ), specifically page 67036.

16

### 4.1. **Griffin Pipe**
Griffi n Pipe i s the largest lead source within the nonattainment area according to t he 2010 baseline actual emissions estimates. While the facility idled me lting operations on May 3, 2014, Griffin Pipe does not consider the facility permanently shut down and th e facility’s potential emissions remain unchanged

. S ources at the facility must undergo a RACT/RACM review and n ew emissions limits must be established to ensure the lead NAAQS is attained and maintained when Griffin Pipe resumes operations. A discussion of the RACT/RACM analysis follows the summary in Table 4

- 1 and the depiction

in Figure 4

- 1 of the point source locations at Griffin Pipe.

Table 4

- 1 . Summary of RACT/RACM conclusions for Griffin Pipe.

Emission
Point ID Emission Point Description Associated Emissi on Units (Emission Unit ID) a ,b RACT/RACM Summary

EP

- 2 Cupola Wet Scrubber
Stack (point source) Cupola (EU

- 1) Magnesium Inoculation (EU

- 4) Wet scrubber and stack EP

2 no longer exist

EP

- 2A Cupola Baghouse Stack (point source) Cupola (EU

- 1) This replaces the cupola
wet scrubber stack. RACT
limit based on BACT from PSD project 10

- 030

.

EP

- 3 Hot Iron Desulfurization and Magnesium Inoculation Baghouse
Stack (point source) Hot Iron Desulfurization (EU

- 2) Magnesium Inoculation (EU

- 4) New baghouse from PSD project (10

- 030). Lower

emission limits added to meet Pb NAAQS

.

EP

- 7A Roof top p oin t s ource Magnesium Inoculation

Uncaptured (EU

- 4) New Pb e mission limit s to

meet NAAQS

.

EP

- 7B Rooftop point source Desulfurization

- Uncaptured (EU

- 2) New Pb emission limits to
meet NAAQS.

EP

- 6A Rooftop point source Small Diameter Casting (EU

- 6) New Pb emission limit to
meet NAAQS

.

EP

- 6B Rooftop point source Building Emissions New Pb emission limit s to meet NAAQS.

EP

- 29 Rooftop point source Large Diameter Casting (EU

- 29) New Pb emission limit to

meet NAAQS. EP

- 29 A Rooftop point source

FUG1 Fugitives Cupola Charge Handling (EU

17) Work practices to minimize

emissions.

Haul R oad s Fugitives Roadway fugitive e missions Sweeping of haul roads to reduce fugitive dust

emissions.

a In the 2010 baseyear

, magnesium inoculation and cupola emissions were controlled by the wet scrubber and t he
wet scrubber did not control hot

- iron desulfurization emissions. In 2011 two baghouses were added, one to control cupola emissions and a second to control both the mag nesium inoculation and hot iron desulfurization emissions. Uncaptured emissions still occur because the magnesium inoculation and hot

- iron desulfurization
capture equipment is not 100% effective.

b F or simplicity, all emission units are not always liste d if an emission point is associated with more than one unit

, this does not affect the RACT/RACM determination.

17Figure 4

- 1 . A pproximate location s of lead emitting point s ources at Griffin Pipe. EP

- 2 no longer exists.

**Cupola** In the 2010 baseyear the majority of the facility’s emissions, approximately 72%, were attributed to the cupola (and the magn esium inculcation process ). EPA’s March 2012 Guide to Developing Reasonable
Available Control Meas ures (RACM) for Controlling Lead Emissions (EPA

- 457/R

- 12

- 001) suggests there is substantial support for adding control devices (such as filters) to control cupol a emissions at iron
foundries.

The cupola was constructed prior to September 23, 1970

, and was initially grandfathered for the purposes of construction permitting . To reduce cupola emissions a wet scr ubber system was installed in 1971. Process modifications made in 1999 expanded the use of the wet scrubber system to control emissions from the plu nging (magnesium inoculation) process, which were previo usly uncontrolled.
Before 1971 emissions from the cupola were uncontrolled.

On December 7, 2010, the Iowa DNR issued permits to Griffin Pipe for a project (10

- 030) that was significant for lead und er the PSD program

. The PSD regulations and associated permits minimize lead emissions by requiring the installation of the top

- level control that satisfies the Best Available Control Technology (BACT) determination

. The PSD permit for the cupola (permit number 10

- A

- 270

- P ) required the addition of a baghouse and the implementation of a scrap management plan to reduce lead

emissions

. The scrap management plan required that lead containing components of scrap such as batteries, battery cables and wheel wei ghts be removed, to the extent practicable, prior to being

18charged (loaded ) in the cupola

. The DNR concludes a scrap management plan, baghouse, and the
associated emissions limits satisfy RACT/RACM for the cupola

.
**Desulfurization and Magnesium Inoculation** In the baseyear approximately 25% o f Griffin Pipe’s estimated actual lead emissions were associated
with hot

- iron desulfurization and uncaptured magnesium inoculation emissions. In early 2011 Griffin Pipe started operating the new cupola baghouse. At th e same time

, a second baghouse began operation to control emissions from the hot

- iron desulfurization and magnesium inoculation processes. The addition of this baghouse was also required a s part of the PSD project (10

- 030) mentioned above.
The desulfuriz ation and magnesium inoculation baghouse is separate from the cupola baghouse but otherwise comparable. The installation and operation of the baghouse essentially satisfies RACT/RACM requirements for the desulfurization and magnesium i noculation processes

. For purposes of the control
strategy, new emission rates were specified to ensure attainment and maintenance of the NAAQS

, including limits on roof vents EP

- 7A and EP

- 7B

.

**Haul Roads**

**, Cast**  **ing**
**, Scrap Handling**  **, and Building Emissions** The remaining baseyear lead emissions , which constitute only a few percen t of the total, are attributed

to haul road s, the large & small diameter casting processes , building emissions, and cupola charge handling. Despite a low emissions total the haul roa ds require con trol to provide for modeled

attainment in all areas considered ambient air. Sweeping of the haul road s to control at levels of 90% or

more compared to baseline conditions is considered RACM for the haul road s. All travelled roadways at
Grif fin Pipe are paved and are subject to sweeping requirements to minimize lead

- containing fugitive
dust emissions. Actual lead emissions from casting and scrap handling activities are expected to be relatively low, but the potenti al of the sources to emit l ead were not previously expressly limited.

Emi ssions limits were developed for attainment o f the lead NAAQS in the dispersion modeling
demonstration . The new limits are necessary for attainment demonstration purposes and are
considered RACT/RACM

.



### 4.2. **Alte r Metal Recycling**  Reducing lead emissions from the haul roads is the only reasonable control measure identified for Alter Metal Recycling. No other lead emissions at Alter Metal Recycling have been identified for RACT/RACM review. Control of the facility haul roads is necessary to demonstrate modeled attainment of the lead
NAAQS in ambient air . The facility is required to sweep all paved roadways to achieve a 95% reduction in fugitive dust emissions compared to the baseline, as summarized i n Table 4

- 2

.
Table 4

- 2 . Summary of RACT/RACM conclusions for Alter Metal Recycling.

Emission
Point ID Emission Point Description Associated Emissions Unit(s) (Emission Unit ID) a RACT/RACM Summary

Fugitives Haul R oad s Fugitive Haul Road Emissions Sweeping of haul roads to reduce fugitive dust emissions by 95%

.

19

## 5. **Control Strategy**

**5.1. Griffin Pipe**  The control strategy to attain the lead NAAQS builds upon the RACT/RACM analysis and incorporates
conditions relevant to the idling of plant operations. While actual lead emissions at the facility during
the idling are essentially zero , potential emissions remain unchanged unless new limits or other control

measures are established

. The DNR and Griffin Pipe voluntarily entered into an Administrative Consent
Order (ACO) containing enforceable control measures designed to ensure the lead NAAQS is attained
and mai ntained when Griffin Pipe resumes operations. The ACO defines two independent control strategies , d esignated Option A and Option B. Griffin P ipe must implement a strategy but may choose which strategy to implement. The ACO and its attachments contain the enforceable requirements, are submitted for inclusion in the SIP

, and are found in Appendix B

. Both strategies are summarized below

.
**Control Strategy Opt ion A**  The control strategy designated Option A contains , for example, new lead emissions limits, haul road

c ontrol measures, and restrictions on the hours of operations

. Requirements include:

• Limiting scrap melting operations to 1,250 hours in any 3

- month rolling period.

• Sweeping/cleaning the haul roads to achieve a 95% r eduction in Pb emissions.

• Shipping b ulk m aterial s and product only from 7 am to 5 pm daily.

• Implementing “g ood housekeeping” or best management practices (BMP), such as posting speed limit signs and cle aning in appropriate situations to minimize fugitive emissions

.

• Meeting new lead emission limits added to existing sources

, as shown in Table 5

- 1

.
Table 5

- 1

. Summary of Pb source emission limits for Griffin Pipe under control strategy Option A

.

Source Description (Unit ID) E mission Point

ID Pb Limit ( lb/hr ) Control Equipment

Cupola (EU

- 1) EP

- 2A 0.282 Baghouse (CE

- 10) Desulfurization (EU

- 2)

EP

- 3 0.0018 Baghouse (CE

- 11) Bull Ladle (EU

- 3) Magnesium Inoculation (EU

- 4) Magnesium Inoculation

- Uncaptured (EU

- 4)
Ladle Preheat

- Uncaptured (EU

- 19) EP

- 7A 0.0026 None

Desulfurization

- Uncaptured (EU

- 2)

EP

- 7B 0.0372 None Bull Ladle

- Uncaptured (EU

- 3)

Small Diameter Casting (EU

- 6)
Small Diameter Casting (EU

- 6) EP

- 6A 0.0043 None Building Emissions EP

- 6B 0.0025 None

L arge Diameter Casting (EU

- 29) a EP

- 29 & EP

- 29A 0.0025 None Cupola Charge Handling (EU

- 17) FUG 1 0.00143 None Traffic Pathways N / A b Sweeping

a The large

- diameter casting limits are bubbled (cumulative), covering both EP

- 29 and EP

- 2 9A simultaneously

. b The lea d limit is established at 0.00 2 tons of lead per rolling 3

- month total; that correlates to a lead silt content of 0.00016 g/m 2 and maximum potential operation. The lead limit is based on 95% reduction over baseline lead
levels

. The haul road surface total silt loading or lead silt loa ding shall not exceed 0.64 g/m 2 or 0.00016 g/m 2

, respectively, based on a 3

- month rolling average.

20**Control Strategy Option B** 
The contro l strategy designated option B requires the installation of a baghouse to control emissions
from roof vent EP

- 7B and tigh tens the emiss ion limit for EP

- 7B by nearly a factor of 15 compared to Option A. The new baghouse is located approximately 3 5 feet no rth of EP

- 3, as indicated in Figure 5

- 1

. The restrictions on the hours of operations are eliminated and offset by the addition of the baghouse

. T he frequency of sweeping is also adjusted b ased on similar considerations. Requirements include:

• Installing a new baghouse to control emission s from EP

- 7B an d meet ing a lead limit of 0.0025 lb/hr (see Table 5

- 2 )

.

• Sweeping/cleaning the haul roads to achieve a 90% reduction in Pb emissions.

• Implementing “g ood housekeeping” or BMP, such as posting speed limit signs and cleaning in appropriate situations to minimize fugitive emissions

.

• Meet ing n ew lead emission limits added to existing sources, as shown in Table 5

- 2

.

Table 5

- 2 . Summary of Pb source emission limits for Griffin Pipe under control strategy Option B

.

Source Description (Unit ID) E mission Point

ID Limit ( lb/hr ) Control Equipment

Cupola (EU

- 1) EP

- 2A 0.282 Baghouse (CE

- 10) Desulfurization (EU

- 2)

EP

- 3 0.02 Baghouse (CE

- 11) Bull Ladle (EU

- 3) Magnesium Inoculation (EU

- 4) Magnesium Inoculation

- Uncaptured (EU

- 4)
Ladle Preheat

- Uncaptured (EU

- 19) EP

- 7A 0.0075 None

Desulfurization

- Secondary Capture (EU

- 2)

EP

- 7B 0.0025 Baghouse (CE

- 12 ) Bull Ladle

- Secondary Capture (EU

- 3)

S mall D iameter Casting (EU

- 6)

S mall D iameter Casting (EU

- 6) EP

- 6A 0.0043 None Building Emissions EP

- 6B 0.0015 None
Large Diameter Casting (EU

- 29) a EP

- 29 & EP

- 29A 0.0025 None Cupola Charge Handling (EU

- 17) FUG 1 0.00143 None Traffic Pathways N / A b Sweeping

a The large diameter casting limits are bubbled (cumulative), covering both EP

- 29 and EP

- 29A

. b The lea d limit is established at 0.004 tons of lead per rolling 3

- month total; that correlates t o a lead silt content of

0.00032 g/m 2 and maximum potential operation . The lead limit is based on 90 % reduction over baseline lead
levels . The haul road surface total silt loading or lead silt loading shall not exceed 1.28 g/m 2 or 0.00 032 g/m 2

, respectively, based on a 3

- month rolling average.

**Standard Operating Procedures** Both of Griffin Pipe’s c ontrol strategies ( Op t ion A and Option B) require the implementation of work practice standards as specified in Standard Operating Procedure s (SOPs) Melt180CB and Melt220CB.
Melt180CB SOP prescribes methods to minimize emissions from cupola charge h andling activities and
Melt220CB SOP implement s a scrap management plan designed to minimize the amount of lead in the

scrap . T he se SOPs are provided in their entirety in sectio n B

- 1 of Appendix B

. While not all aspects of
thes e SOPs pertain to lead emissions or were relied upon as part of the attainment strategy modeling, they have been included in their entirety for simplicity and completeness purposes. Only those portions relevant to lead emissions are applicable to the SIP.

21Figure 5

- 1 . Depiction of the existing point sources at Griffin Pipe and the new location of source EP

- 7B (baghouse stack ) under control strategy Option B.



### 5.2. **Alter Metal Recycling** The control strategy requ ires Alter Metal Recycling to reduce their haul road emissions by sweeping paved roads. Unpaved roads must be paved or their use discontinued

. M aterial shipments are limited

to 946,000 tons per rolling 12

- month period

. Additional review of the control strategy is provide d
below . T he legally enforceable requirements are contained in construction permit number 14

- A

- 521

, submitted for inclusion in the SIP

, and located in Appendix C

.

• New limits restricting fugitive lead emissions from haul road traffic are based on a 95%
reduction from baseline levels. Emission reductions ar e accomplished by sweeping

. The lead limit is established at 0.01 tons of lead per rolling 3

- month average; that correlates to a lead silt content of 0.00281 g/m 2 and maximum potential operation

. A haul road surface silt loading content of 2.7 g/m 2 has been established as a surrogate for total lead silt content.

• All haul roads at Alter Metal Recycling must be paved. The facility shall complete the paving of unpaved haul road segments 7, 14, 15, and 16 by October 31, 2015, and stop using unpaved haul road segment 17 by the same date. A depiction of these unpaved road segments is

prov ided in Figure 5

- 2

.

• The shipping of inbound and outbound material s is restricted to between the hours of 5 am to 8

pm Monday through Frida y , and 8 am to 12 pm on Saturday, and cannot exceed 946,000 tons of material per rolling 12

- month period. Internal transfers are limited to M onday

- Friday.

22• Alter Metal Recycling must i mplement “good housekeeping” or BMP to minimize fugitive

emissions , such as posting speed limit signs and cleaning in appropriate situations.

T he control measures for Alter Metal Recycling also account for changes since the 2010 baseyear in haul road locations, road segment lengths, and new routes being implemented with the addition of a non

ferrous metal recovery operation at Alter Metal Recycling, discussed in Appendix D

.

Figure 5

- 2 . Approximate location of the unpaved road segments in the 2010 baseyear at Alter Metal Recycling. Segment 14 was originally paved but was treated as unpaved due to surface deterioration

.



### 5.3. **Implementation** The proposed RACT/RACM measures for the Council Bluffs lead nonattainment area and the associated control strategies are implemented through legally enforceable mechanism s. Griffin Pipe entered into an ACO (number 2015

- AQ

- 02 ) with the DNR

, permanently reducing emissions while the facility is operating. The ACO was signed on January 29, 2015, and requires control measures be implemented when the facility resumes operation. The ACO i s submitted as part of this SIP and is provided in Appendix B

.

C onstruction permit 14

- A

- 521 was issued to Alter Metal Recycling on September 2, 2014. Mandatory implementation of the haul road sweeping requirements became effective 7 days later, on September 9,

2014. The construction per mit is a legally enforceable mechanism, results in permanent lead emissions reductions, and i s submitted as part of this SIP in Appendix C

.

23

## 6. **Attainment Demonstration**

T he control measures developed for Griffin Pipe and Alter Metal Recycling will eliminate violations of
the 2008 lead NAAQS according to the dispersion modeling results

. The dispersion modeling analysis
used the current version of EPA’s preferred refined di spersion model, the American Meteorological Society/ Environmental Protection Agency Regulatory Model (AERMOD, dated 14134 ) . AERMOD was run in the default regulatory mode.



### 6.1. **Source Characteristics**  Sources at Griffin Pipe were modeled as point sources or volume sources. Potential emission rates for the point sources were developed from stack test results, process information, engineering assessment, and evaluation of the levels necessary to achieve the NAAQS through the RACT/RACM review. The stack

parame ters and maximum allowable hourly lead emission rates from point sources at Griffin Pipe are shown in Table 6

- 1

, Table 6

- 2 , and Table 6

- 3

. Table 6

- 1 includes those point sources with identical characteristics (notwithstanding restrictions on hours of operation) in control strategy Option A and Option B. Table 6

- 2 and Table 6

- 3 include the point source parameters which differ under control strategy Option A and Option B, respectively. All stacks are modeled with an unobstructed vertical discharge. Three volume sources were mo deled to account for cupola char ge handling emissions at Griffin Pipe. Cupola charging emissions are the same in both control strategy options and are shown in
Table 6

- 4

.

The h aul roa ds at Alter Metal Recycling and Griffin Pipe Recycling were characterized as volume sources consistent with EPA’s Haul Road Workgroup Final Report dated December 6, 2011. This includes appropriate adjustments of the volume source location and/or initial horizontal dimension (sigma y) for nearby receptors. Figure 6

- 1 indicates the locat ions of downwash structures (blue rectangles) , point

sources (light blue dots) , and volume sources (red dots) in th e model. Figure 6

- 2 and Figure 6

- 3 depict
the locations of the haul roads sources

. Modification s to the facility haul road s incurred due to the
addition of a process , referred to as the ZC Plant ( to allow the facility to recover non

- ferrous materials from shredder fluff previously landfille d or otherwise disposed as waste) are incorpo rated into the modeling layout and described in Appendix D

.

A detailed accounting of the haul road emissions at Griffin Pipe and Alter Metal Recycling is not suite d for reproduction in this document due to complexity from t emporal variation and th e number of haul
road segments. In summary, t he lead emissions from the haul roads are distributed spatially (by road
segment ) and in time (by day of week and by hour of d ay) according to the usage schedule of the haul
roads and any applicable restrictions in the control strategies

. 11 The haul road emission rates also

account for several road segments with shared use by Griffin Pipe and Alter Metal Recycling.

11 T emporal variations in the haul road emission rates at Alter Metal Recycling occur, for example, across the hours of the day because the inbound/outbound shipping of material is restricted to between 5 am and 8 pm (Monday through Friday; 9 am to noon on Saturdays). Day of week variations occur, for example, b ecause i nternal transfers are allowed only Monday

- Friday while inbound/outbound material may be shipped on Monday

- Saturday

.

24Table 6

- 1

. Hourly e mission limits and stack parameters for point sources at Griffin Pipe with identical
characteristics in control strategy option s A and B

.

AERMOD

Source ID Brief Source Description E mission

rate ( Pb )

(lb/hr) Stack Height

(ft) Gas exit
temp

( ° F) Gas exit velocity

(ft/s) Effective

D iam eter (inches)

GEP2A Cupola Baghouse 0.282 100 295 52.4 80

GEP6A Small Diameter Casting 0.0043 49 92 49.6 80

GEP29 Large Diameter Casting 0.0025 + 48 143 25.2 81 .24

GEP29A Large Diameter Casting 48 128 25.0 81 .24

+ Total emissions from both GEP29 and GEP29A (large diameter casting) cannot exceed 0.0025 lb/hr.

Table 6

- 2

. Hourly emission limits and stack parameters for point sources at Griffin Pipe under control strategy Option A

.

AERMOD

Source ID Brief Source Description E mission

rate ( Pb )

(lb/hr) Stack Height

(ft) Gas exit
temp

( ° F) Gas exit velocity

(ft/s) Effective

D iam eter (inches)

GEP3 Desulf./Inoc. Baghouse 0.0018 100 149 36.1 74

GEP7A Magnesium Inoculation

Uncaptured 0.0026 49 97 22.3 122.4

GEP7B Desulfurization

- Uncaptured 0.0372 49 110 22.6 122.4

GEP6B Building Emissions 0.0025 49 92 49.6 80

Table 6

- 3 . Hourly emission limits and stack parameters for point sources at Griffin Pipe under control strategy Option B.

AERMOD

Source ID Brief Source Description E mission

rate ( Pb )

(lb/hr) Stack Height

(ft) Gas exit
temp

( ° F) Gas exit velocity

(ft/s) Effective

D iam eter (inches)

GEP3 Desulf./Inoc. Baghouse 0.02 100 149 36.1 74

GEP7A Magnesium Inoculatio n

Uncaptured 0.0075 49 97 22.3 122.4

GEP7B Desulfurization

- Secondary Capture ( New Baghouse ) + 0.0025 100 110 39.8 96

GEP6B Building Emissions 0.0015 49 92 49.6 80

+ The new baghouse to control GEP7B is located 35 feet north of GEP3.

Table 6

- 4

. Volume source parameters at Griffin Pipe

. *

AERMOD

Source ID Source Description E mission

rate (Pb)

(lb/hr) Release height

(ft) Initial lateral
dimension (m) Initial vertical
dimension (ft)
FUG1B_W Cupola charge handling 0.000477 36 7.25 33.5

FUG1B Cupola charge handling 0.000477 36 7.25 33.5
FUG1B_E Cupola charge handling 0.000477 36 4.27 33.5

* For brevity, Griffin Pipe haul road sources have been excluded from this table.

25Figure 6

- 1 . Model layout for Griffin Pipe and Alter Metal Recycling in the control strategy modeling

.

Figure 6

- 2 . Griffin Pipe roadway segments.

Figure 6

- 3 . Alter Metal Recycling roadway segments (incorporates changes due to the ZC Plant)

.
26

### 6.2. **Receptor Grids** The two facilities are adjacent to each other and share a common boundary between them , as sh own previously in Figure 1

- 4 . The dispersion modeling evaluated total ambient impact of lead emissions from Griffin Pipe and Alter Metal Recycling combined, as well as their impacts on each other’s property to ensure that neither facility is causing NAAQS violations on their neighbor’s property.

Property owned by a facility but not secured to prevent public access is considered ambient air and subject to modeling. The identification of facility boundaries for purposes of receptor placement must therefore consider if public access is somehow restricted

. Property bo undaries at Griff in Pipe are secured by fencing and augmented by movable gates at driveways into the facility. Historically Griffin Pipe has employed 24

- hour guard service and video surveillance of the property as additional security

measure s

. B ecause cu rrent conditions sufficiently preclude public access t h e ACO with Griffin Pipe contains simple language pertaining to this topic. Since not all property boundaries at Alter Metal Recycling are fenced their construction permit (14

- A

- 521) is more specific a nd requires the posting of signs warning of restricted access and the use of surveillance to secure unfenced boundaries.

To determine total ambient impact, the two contiguous facilities were treated as a single entity with one encompassing property bounda ry (as shown by the purple lines in Figure 6

- 1 )

. Receptors were spaced 50 m apart on this property boundary. A Cartesian grid of discrete receptors extends out 1.5 km from the boundary. For the first 0.5 km the recepto rs are spaced at 50 m intervals and from 0.5 to 1.5 km the receptors are spaced at 100 m intervals. The receptor grid covers a combined area of 14 km 2 (3.5 km x 4 km) surrounding Griffin Pipe and Alter Metal Recycling. To determine the facilities’ impacts on each
oth er’s property, receptors at 50 m intervals were placed along the common boundary between the two facilities and at 50 m intervals on the property of the facility.



### 6.3. **Terrain Elevations** The terrain, source, and building elevations were obtained from the Natio nal Elevation Dataset (NED) for Pottawattamie County, Iowa. The domain used for importation of AERMAP data encompasses all terrain that may be at or above a 10% slope from each receptor.



### 6.4. **Building Downwash** All structures potentially contributing to plume downwash were included in the model. Downwash was evaluated using the latest version of the Building Profile Input Program (BPIP

- PRIME) after determining the source and building base elevations using the latest version of AERMAP.



### 6.5. **Meteorological Data**

The surface and upper air meteorological data are from the Omaha airport (KOMA) for years 2008

– 2012 . The base elevation is 299 m. These data are considered representative of the meteorological conditions in the area of Griffin Pipe and Alter Metal Recyclin g.



### 6.6. **Background Value** An analysis was conducted of the ambient lead concentrations measured during the time period
November 2009 through 2012 at the monitor located near the intersection of 8 th Avenue and 27 th Street in Council Bluffs. The review excluded all concentrations measured on days with an hourly wind direction with a southerly (greater than 90 degrees and less than 270 degrees) component, in an attempt to screen out concentrations potentially influen ced b y sources at Griffin Pipe or Alter Metal Recycling . Based on EPA’ s comments and recommendations the background level for lead is assumed to
be 0.01 μ g/m 3 for the nonattainment SIP modeling.

27

### 6.7. **Results**

Lead NAAQS compliance was evaluated for five cases. The first two cases evaluated cumulative impacts
of lead emissions from both facilities on ambient air

. One simulation was required for each of Griffin Pipe ’s two control strate gies. P otential (permitted /allowable ) e missions from Alter Metal Recycling are identical in both scenarios. The three remaining simulations included two runs to assess Griffin Pipe’s lead impacts for both control strategies on Alter Metal Recycling’s property and a final simulation to
assess the lead impacts from Alter Metal Rec ycling on Griffin Pipe ’s property. All five simulations modeled compliance with the lead NAAQS.

P ost file analyses were conducted to determine the paired spatial and temporal contributions from each facility at th e worse

- case receptor location

. The AERM OD results were post

- processed using the latest version of EPA’s executable file “leadpost_13262.exe.” When post

- processing involved multiple source groups, an equivalent DNR spreadsheet tool was used. The post

- processed results were compared with
the le ad NAAQS of 0.15 μg/m 3

.

Table 6

- 5 and Table 6

- 6 show that the results of the two cumulative control strategy modeling runs achieve atta inment with the lead NAAQS. The results for Gri ffin Pipe’s Option A strategy are provided in
Table 6

- 5 and the results for the Option B strategy follow in Table 6

- 6

. The modeled predictions are apportioned by source type for the receptor in ambient air with the highest modeled concentra tion

. No NAAQS violations are predicted by the dispersion modeling and each control strategy is expected to yield attainment with the 2008 lead NAAQS. Results for the remaining three cases involving individual facility impacts upon each other all showed attainm ent of the lead NAAQS. The dispersion modeling
data was transmitted to EPA Region 7 for review and approval

.

28Table 6

- 5 . Dispersion modeling results showing the receptor in ambient air with the h ighest modeled concentration attain s the lead NAAQS using Griffin Pipe’s Option A control strategy. All concentrations are in μ g/m 3 calculated using EPA’s Leadpost process or or similar techniques.

Location Total Impact * Alter Metal Recycling Griffin Pipe

Entire Facility ( Ha u l Roads ) Entire Facility Haul
Roads Cupola

BH (2A) D esulf

. BH (3) Vents
7A and 7B Small casting & Building (6A & 6B) Large casting (29 & 29A) Charge handling (FUG1 )

X= 258192

Y= 4570766 0.149 0.066 0.073 0.007 0.000 0.000 0.045 0.008 0.003 0.010

* Total impact includes a background concentration of 0.01 μg/m 3

. BH=Baghouse

Table 6

- 6

. Dispersion modeling results showing the receptor in ambient air with the highest modeled concentration attain s the lead NAA QS using Griffin Pipe’s Option B control strategy. All concentrations are in μg/m 3 calculated using EPA’s Leadpost processor or similar techniques.

Location Total Impact * Alter Metal Recycling Griffin Pipe

Entire Facility ( Ha u l Roads ) Entire Facility Haul
Roads Cupola

BH (2A) D esulf

. BH (3) Vent 7A and

New BH 7B Small casting & Building (6A & 6B) Large casting (29 & 29A) Charge handling (FUG1 )

X= 258182

Y = 4570767 0.149 0.069 0.070 0.023 0.000 0.001 0.018 0.010 0.005 0.014

* Total impact includes a background concentration of 0.01 μg/m 3

. Due to rounding the numbers may not sum exactly as shown. BH=Baghouse

29

## 7. **Reasonable Further Progress**

Section 172(c)(2) of the CAA requires nonattainment plans include provisions addressing reasonable further progress (RFP). The CAA defines RFP in Section 171 as “ such annual incremental reductions in emissions of the relevant air pollutant as are required by this part or may reasonably be required by the Administrator for the purpose of ensuring attainment of the applicable national ambient air quality standard by the applicable dat e. ”

EPA recognizes that a chieving generally linear progress can be difficult or impossible with a small
number of sources. According to the discussion in the preamble of the 2008 lead NAAQS revision ( 73 FR

66964 , November 12, 2008, see pages 6 7038

- 67039)

, the RFP requirements for lead no nattainment “should be met by ‘ adherence to an ambitious compliance schedule ’ which is expected to periodically yield significant emission reductions, and as appropriate, linear progress.”

In January of 2011 Griffin Pipe began operation of two new baghouses to control lead emissions from the cupola and the desulfurization and magnesium inoculation processes. Actual lead emissions from Griffin Pipe are expected to be essentially zero when th e facility is idle but this is not used to meet RFP requirements. As of September 9, 2014, Alter Metal Recycling is required to implement the haul road sweeping measures engineered to reduce approximately 95% of their roadway fugitive lead emissions.

A timeline of the recent and anticipated lead emissions from the facilities is provided in Table 7

- 1

. The RFP requirements in the Council Bluffs lead nonattainment area are met by a combination of early lead
reductions associated with the PSD permits issued to Griffin Pipe, the expeditious implementation of control measures at Alter Metal Recycling, and Griffin Pipe’s requirement to implement control measures when the facility resumes operations.

Table 7

- 1 . Summary of e mission s evaluations and components satisfying RFP.

Facility Actual Annual
Emissions Baseyear

– 2010 (tpy) Actual Annual Emissions

2012 (tpy) Control Measure
Reductions & Timeline

Griffin Pipe 1.0382 0.070 Control measures implemented when Griffin Pipe resumes operations.

Alter Metal Recycling 0.7182 (The inter

- annual variability in haul road emissions prior to the

implementation of controls is not readily calculable , may be negligible, and needs no further consideration. ) Control measures
reduce Pb emissions by 95% from baseline.
Reductions required by September 9, 2014.

30

## 8. **Contingency Measures**

To comply with CAA §172(c)(9) t he DNR developed contingency measures which can be implemented quickly by Griffin P ipe and Alter Metal Recycling if either the applicable attainment date or RFP 12
requirements are not met

. The contingency measures for both facilities are similar and can take effect promptly following a simple notification process.

The contingency measu res require each facility to essentially double their haul road sweeping /cleaning frequency within seven days after notification by the DNR that a monitored exceedance of the lead NAAQS occurred. Each facility must also submit sweeping data to the DNR and continue the increased cleaning/sweeping frequency until otherwise notified

.

If after three months of increased sweeping fr equency another NAAQS violation occurs, then each facility is required to submit an emissions evaluation meeting the criteria a nd timeline specified by the

DNR.

For Griffin Pipe the contingency requirements are enforceable through the ACO. Attachment A and Attachment B of the ACO contain slightly different language to tailor the frequency of increased sweeping to the respective control strategy. The contingency measures for Alter Metal Recycling are in place and enforceable through their construction permit.

Additionally, if contingency measures are triggered the DNR may request or conduct new or supplemental review s of lead emissions from sources and activities affecting the nonattainment area. This review may require data collection activities and a reexamination of previous assumptions or
conclusions.

12 Early lead reductions at Griffin Pipe from the addition of the baghouses and the timely compliance schedules in
the control strate gy satisfy RFP requirements.

31

## 9. **Attainment Date**

The effective date fo r the Council Bluffs lead nonattainment area was December 31, 2011. The CAA requires that the area achieve the lead standard s as expeditiously as practicable and no later than five years from the nonattainment designation. Lead nonattainment areas are not eligible for extensions of
the attainment date. 13

Significant lead reductions occurred shortly after the area was designated. These reductions alone were
not sufficient to achieve attainment. Three years of 3

- month rolling averages below the 0.15 μg/m 3 standard are required for attainment purposes. Additional lead emi ssions reductions are being implemented a s expeditiously as practicable. The s tate is identifying December 31, 2016, as the
attainment date.

13 A five

- year maximum attainment timeline is specified in CAA § 192 and therefore the use of attainment date extensions provisions provided in § 172(a)(C) are prohibited by § 172(a)(D).

32

## 10. **Additional Nonattainment SIP Provisions** 

Three remaining CAA Section 172 (c) nonattainment requirements not addressed above are discussed in this chapter

.



### 10.1. **Identification & Quantification of Emissions** According to CAA §172(4) the SIP must identify and quantify the emissions which will be allowed from the construction and operation of major new or modified stationary sources in the area. The state must
demonstrate that such emi ssions will be consistent with RFP requirements and will not interfere with attainment of the lead NAAQS. These requirements are met by Iowa’s preconstruction permitting program and implementation of nonattainme nt new source rules in 567

– Iowa Administrative Code (IAC) 31.1, 31.3

– 31.10.



### 10.2. **Nonattainment New Source Review**

Section 172(c)(5) of the CAA refers to permits for new or modified major sources located within the

nonattainmen t area. A special permitting process applies to such sources, referred to as a nonattainment new source review (NA NSR) program . NA NSR i s mandated by CAA §173 and a SIP approved NA NSR program must meet the minimum criteria defined in 40 CFR 51.165. On May 15, 2014 ( 79 FR 27763 ) EPA approved into Iowa’s SIP the NA NSR regulations in 567

– IAC 33

. The modified
administrate rules in Chapter 33 became effective on January 15, 2015, as published on December 11, 2013, in the Iowa Administrative Bulletin Volume X XXVI Number 12, pages 1455

- 1456.



### 10.3. **CAA § 110(a)(2) Requirements**  Section 172(c)(7) of the CAA require s nona ttainment SIPs to meet the applicable provisions of CAA
§ 110(a)(2). While the p rovisions of 110(a)(2) address various topics there is ample evidence 14 to suggest
that only the § 110(a)(2) criteria which are linked with a particular area’s designation and classification
are relevant to § 172(c)(7) . T his nonattainment SIP submittal satisfies all applicable CAA § 110(a)(2)

criteria , and evidenced by the state’s nonattainment new sourc e review progr am which addresses 110(a)(2)(I)

, the included control strategy

, and the associated emissions limits which are relevant to 110(a)(2)(A). In a ddition , on October 31, 2011, the DNR submitted to EPA an infrastructure SIP to
demonstrate that the DNR has the necessary plans, programs, and statutory authority to implement the requirements of Section 110 of the CAA as they pertain to the 2008 lead NAAQS.



### 10.4. **Equivalent Techniques** The DNR followed existing regulations, guidance, and standard practices when conducting dispersion modeling, preparing emissions inventories, and implementing planning procedures. The DNR did not

use or request approval of alternative or equivalent techni ques as allowed under § 172(c)(8) of the CAA.

14 As one example, see a proposal discussing this issue in 76 FR 79579 (December 22, 2011, specifically pages

79583

- 79584) and the promulgation of those associated positions in th e final rule 77 FR 34189 (June 12, 2012).

33

## 11. **Administrative Materials**  **& Response s**  **to Public**  **Comments**

State Implementation Plans addressing nonattainment areas must comply with general planning provisions in addition to the special provisions in § 172 of the Clean Air Act. For example, Sub part F of 40
CFR 51 identifies procedural requirements and Appendix V of 40 CFR 51 establishes minimum criteria
that must be met before a SIP revision can be considered an official submittal. T his SIP submittal

s atisfies all the procedural requirements and addresses all the administrative criteria. The order of
materials discussed below generally follows that of Section 2.1 of Appendix V of 40 CFR 51.



### 11.1. **Submittal Letter**
A formal letter of submittal from the de signee of the Governor of the State of Iowa, requesting EPA approval of the proposed revision to the SIP for the State of Iowa

, is included with the SIP submittal.



### 11.2. **Evidence of State Adoption**

T he Iowa Environmental Protection Commission (EPC) approved on January 21, 2015, this plan for
submitt al to EPA as a revision of the State I mplementation Pl an to address lead nonattainment in
Council Bluffs

. The DNR followed all applicable procedural requirements of the s tate’s laws and constitution in obtaining t he adoption of this plan.



### 11.3. **Necessary Legal Authority** The DNR is the regulatory agency with primary responsibility for outdoor air quality permitting and compliance activities in the state of Iowa. The DNR’s authority is set forth in chapter 455B of the Code
of Iow a and implemented through 567

– IAC chapters 10 and 20

- 35, and 561

– IAC chapters 2 and 7. The DNR’s permitting and compliance programs and associated rules have previously been approved by EPA as part of the State of Iowa’s SIP.

The State of Iowa has the n ecessary legal authority under s tate statute to adopt and implement this plan. Iowa Code section 455B.133(3) provides that the Iowa Environmental Protection Commission shall “adopt, amend, implement, or repeal emission limitations or standa rds for the atmosphere of this state on the basis of providing air quality necessary to protect the public health and welfare.” The federal
NAAQS for lead are adopted by reference at 567

– IAC 28. Iowa Code section 455B.134(9) states that
the duties of t he director include “issu[ing] orders consistent with rules to cause the abatement or control of air pollution, or to secure compliance with permit conditions.”

In combination with the DNR’s existing legal authority and associated administrative regulatio ns, the
control measures and other components included in this SIP revision are adequate to provide for the timely attainment and maintenance of the 2008 lead NAAQS.



### 11.4. **Evidence of Public Notice & Public Hearing Certification**  The DNR’s public participation process uses procedures to ensure the requirements in 40 CFR 51.102 and Appendix V are met

. The public n otice of the proposed action to issue Alter Metal Recycling’s construction permit included a 35

- day public comment period (from July 22 to August 25, 2014) with an
opportun ity to request a public hearing. The notice was published on July 20, 2014, in The Daily Nonpareil , a periodical based in Council Bluffs published Tuesday

- Sunday

. A copy of this notice is provided in Appendix E

. T he DNR also provided notice of the draft permit through our construction permit website (note, the permit is no l onger listed as the comment period has ended). The DNR did not receive a request to hold a public hearing nor were any public comments received on Alter Metal Recycling’s draft construction permit.

34Notice of the DNR ’s intention to revise the State Implementation Plan for the Council Bluffs lead

nonattainment area and notice providing a 33

- day public comment period with a public hearing was published on Thursday, November 20, 2014, in The Daily Nonpareil

. Proof of publication is included in Appendix E

. A list serve notice regarding the public comment period and public hearing was transmitted

on November 20, 2014

, to over 500 Iowa air quality list serve members.

An electronic copy of the nonattainment SIP document w as posted on the DNR’s Public Input Webpage

at http://www.iowadnr.gov/InsideDNR/RegulatoryAir/StakeholderInvolvement.aspx

. A copy of the
nonattainment SIP was made available to the public at the Council Bluffs Public Library, located at 400 Willow Ave, Council Bluffs, Iowa, 51503. The comment period started on November 20, 2014 , and
lasted through December 22, 2014

. In accordance with the information published in t he public notice, a public hearing was conducted at 10:30 am on December 22, 2014

, at the Council Bluffs Public Library

.



### 11.5. **Compilation of Public Comments and the State’s Responses** During the public hearing t he DNR received one oral comment. Seven written comments were submitted to DNR, three from business/industry and four from U.S. EPA. 15 Copies of all comments received, including a transcription of the oral comment, are available from the DNR upon request. A summary of the comments and the DNR’s responses are provided below.

Comment 1 (contingency measures) The commenter recommended adding a new paragraph to the end of Chapter 8 to create additional

cont ingency measures which would require the department to investigate, and address as appropriate, other potential lead sources in the area, including specifically v ehicle traffic on 9 th Avenue as well as scrap handling, torching, and shredding operations at Alter Metal Recycling . The commenter provided three areas of support for their recommendation. First, the commenter noted that the state conducted a preliminary review of possible lead emissions from 9 th Ave but did not include possible lead emissions
fr om 9 th Ave in the air quality modeling. The commenter then noted that traffic accesses Griffin Pipe’s and Alter Metal Recycling’s properties using 9 th Ave, and asserted that 9 th Avenue’s vehicle miles traveled (VMT) must be comparable to Griffin’s and Alt er’s traffic. Second, the commenter mentioned a study conducted by the Houston Department of Health and Human services of ambient air quality near metal recyclers in Houston, Texas, that would indicate sources other than haul roads at metal recycling
faci lities emit lead. The commenter believes the department should, as a contingency measure, investigate other potential sources of lead emissions from Alter Metal Recycling given the amount of scrap processed, the numerous transfer points, the auto shredder operations, and the cutting/torching operations. Third, the commenter noted that contingency measures in lead nonattainment SIPs from Missouri and Michigan include conditions pertaining to conducting additional lead emissions studies.

Department Respons e New language has been added in Chapter 8 to reflect a potential need for additional study of lead emissions if contingency measures are triggered. While impacts due to possible lead emissions from 9 th
Ave were accounted for in the lead background value that was used in the air quality analysis, the new language in Chapter 8 withholds presumptions of culpability for specific sources, such as those identified by the commenter, an d instead provides flexibility in a review of additional lead emissions, which may include evaluation of possible lead emissions from vehicle movement on 9 th Ave. The new language strengthens the contingency measures and preserves the requirement that bot h facilities submit an

15 Seven commen ts were compiled from three documents, one letter from EPA and two from business/industry.

35emissions evaluation meeting the criteria and timelines specified by the department if the contingency measures (increased sweeping frequencies) are triggered but prove insufficient to prevent another NAAQS violation. This existing mechanism, which is enforceable through Alter Metal Recycling’s construction permit and Griffin Pipe’s ACO, enables additional review of lead emissions from either facility if warranted. Potential lead emissions from those activities at Alter Metal Recycl ing mentioned by the commenter ( scrap handling and transfer points , torching, and shredding operations ) were reviewed by the department. The department has concluded, based on information supplied by both Alter Metal Recycling and Griffin Pipe, that the c ontrol measures account for the substantial lead sources and are sufficient to attain the 2008 lead NAAQS in an expeditious manner. If necessary, these assumptions can be reviewed within the context of the new language added at the end of Chapter 8

.

Comment 2 (receptor placement)
The c ommenter was of the opinion that the impacts ( Table 6

- 5 and Table 6

- 6 of the SIP document) that the department used to develop the control strategy were ov erly conservative because the modeling utilized fictional receptor locations on the property line between the facilities. The commenter stated that these receptors are either on Griffin Pipe’s property or on Alter Metal’s property and therefore,
there is no public property that separates the facilities. The result is that the fictional receptors, which cannot exist in space, cut in half the allowed emissions for each facility. For both Griffin Pipe and Alter Metal Recycling, the commenter believes that t he approach appears to require a higher level of control than what is needed to protect the general public under the NAAQS for lead.

Department Response Ignoring the combined impact at receptors along the property line that divides the two facilities reduces the maximum impacts from both facilities to 0.1 3 4 μg/m 3 (under the requirements in Attachment B of Griffin Pipe’s ACO) and 0.13 0 μg/m 3 (under the requirements in Attachment A of Grif fin Pipe’s ACO)

. These impacts include background and are only 1 0 to 1 3 percent lower than the total impacts at the receptors located on the property line that divides the two facilities. In both scenarios, Alter Metal Recycling becomes the main contribu tor (~90%) to the maximum concentration when the receptors along the property line that divides the two facilities are excluded. These results indicate that the approach used for receptor placement in the modeling analysis did not result in a hig her level of control
than what i s needed to meet the lead NAAQS.

Comment 3 (road silt sample averaging) The commenter sought clarification of differences in silt sample averaging requirements between the Alter Metal Recycling permit and the requirements in Griffi n Pipe’s ACO. Griffin Pipe’s ACO requires that compliance with the silt loading limit be based on a 3

- month rolling average. The commenter believed
the use of a 3

- month rolling average p rovide s compliance clarification that i s missing from their own

perm it. The commenter request ed that their silt loading sampling and compliance requirements be interp reted to have a similar meaning and that the DNR recognize this clarification in writing.

Department Response The current language in the Alter Metal Recycl ing construction permit specifies that compliance with the silt loading limit be based on data collected during a single month. The existing language in the Alter Metal Recycling permit will remain until the commenter submits a permit application with sup porting justification requesting a change in compliance measures associated with silt sampling and the department processes the application.

36Comment 4 ( t ermination l anguage) The commenter recommended deletion of the language in section VIII of the ACO with Griffin Pipe which allowed the department to terminate the ACO at any time. Section 110(a)(2)(A) of the CAA requires that implementation plans contain control measures which are enforceable. The commenter stated that an element of enforceability is whether the control measures are permanent in nature.

Department Response The department agrees with the comment and will remove the language “or terminated by DNR in writing” from Section VIII. TERMINATION OF THIS ADMINISTRATIVE CONSENT ORDER of the ACO with Griffin Pipe.

Comment 5 ( s tandard o perating p rocedures) The commenter noted that Attachments A and B of Griffin Pipe’s ACO both contain references to Standard Operating Procedures (SOPs) Metl180CB and Melt220CB but these SOPs are not, but should be, included in the SIP. The c ommenter stated that the department retains the discretion to submit only those portion of the SOPs relied upon as a part of the attainment strategy modeled to meet the 2008 lead NAAQS.

Department Response The department agrees that both SOPs (Metl180CB and Melt220CB) should be included with the SIP. They have therefore been discussed in Chapter 5 and added in Appendix B

- 1 . While not all aspects of
these SO Ps pertain to lead emissions or were relied upon as part of the attainment strategy modeling, they have been included in their entirety for simplicity and completeness purposes. Only those portions relevant to lead emissions are applicable to the SIP.

C omment 6 ( t emperature

- related c ontrol s trategy e xemptions : sweeping and silt load testing ) The commenter recommended that provisions in Griffin Pipe’s ACO related to paved haul road sweeping and silt testing at low ambient air temperatures be modified. Specific language in the ACO that is of concern is located at Paragraph J.ii and Paragraph K of Attachment A, Section A

- 5, and Paragraph K.iv and Paragraph L of Attachment B, Section B

- 5. That language 1) temporarily suspends haul road sweeping requiremen ts if ambient air temperatures measured at the facility during daylight operating
hours will be less than 3 5° F (1.7° C) or conditions due to weather could crea te hazardous driving conditions, and 2) does not require silt load testing in a month where swee ping could not be accomplished due to ambient temperatures or hazardous weather. The commenter was concerned that these provisions, taken together, could lead to exceedances of the slit load ing limits and could lead to a preventable violation of the lead NAAQS.

Additionally, the commenter was concerned that that if contingency measures are triggered, the associated requirements to increase the frequency of sweeping events could be delayed if daytime temperatures are below 35° F, which could cause a sign ificant delay in attainment of the lead NAAQS. The commenter recommended the language be revisited to require sweeping and silt load testing regardless of ambient air temperature. The commenter also mentioned that a Tymco DST

- 4 or equivalent sweeper can be operated without the use of water (and the functionality and safety of the equipment should not be compromised during colder temperatures). T he commenter noted the language could be modified to 1) allow sweeping, without the use of water, or 2) allow f or the suspension of sweeping if snow or ice are present on paved roadways at the facility. The commenter suggested modifying the Alter Metal Recycling construction permit in accordance with the above suggestions.

37Department Response
To address the comme nter’s concerns ( as clar ified in subsequent discussions) the department modified
conditions A

- 5.O.ii & B

- 5.O.ii and added new conditions A

- 5.O.iii & B

- 5.O.iii in the Attachments to Griffin Pipe’s ACO, as follows:

In Attachment A , conditions A

- 5

- O.ii and A

- 5.O.iii state:

ii. After November 30, 2014, the owner or operator shall implement good housekeeping practices on paved haul road surfaces within seven (7) days after notification by the Department that a monitored exceedance of the lead NAAQS occurred du ring months in which the inclement weather provision as specified in condition A

- 5.J.ii applied. The good housekeeping practices shall include but are not limited to daily removal of material piles that have accumulated on haul
road surfaces and decreasin g vehicle speeds on paved road surfaces from 15 mph to 5 mph. The owner or operator shall continue good housekeeping practices on paved road surfaces until paved road sweeping resumes.

iii. If a monitored exceedance of the lead NAAQS occurs after the prov isions of Condition A

5.O.i or A

- 5

- O.ii have been implemented for three (3) full calendar months the owner or operator will submit an emissions evaluation meeting the criteria and timeline specified by the Department.

In Attachment B, c onditions B

- 5.O.ii and B

- 5.O.iii state : ii. After November 30, 2014, the owner or operator shall implement good housekeeping practices on paved haul road surfaces within seven (7) days after notification by the Department that a monitored exceedance of the lead NAAQS occurr ed during months in which the inclement weather provision as specified in condition B

- 5.K.iv applied. The good housekeeping practices shall include but are not limited to daily removal of material piles that have accumulated on haul
road surfaces and decr easing vehicle speeds on paved road surfaces from 15 mph to 5 mph. The owner or operator shall continue good housekeeping practices on paved road surfaces until paved road sweeping resumes.

iii. If a monitored exceedance of the lead NAAQS occurs after the provisions of Condition B

5.O.i or B

- 5

- O.ii have been implemented for three (3) full calendar months the owner or operator will submit an emissions evaluation meeting the criteria and timeline specified by the Department.

The department will review and modify as appropriate the conditions in Alter Metal Recycling’s permit when the facility requests future changes to their construction permit.

Comment 7 (Public Access Restrictions)
The commenter noted that the attachments to the Griffin Pipe ACO require the facility to “restrict public access to the facility at all property boundary lines. ” The commenter expressed concern that this language does not provide sufficient detail and note d that the Alter Metal Recycling permit contains more specific requireme nts relating to public access restrictions . The commenter recommended that the Griffin Pipe ACO be modified to describe specific measures that are to be implemented in order to restrict public access, or if sufficient measures are already i n place that th e SIP include additional information concerning these controls and that modifications to the order be made to explicitly require
continued use of tho se public access controls.

38Department Response The department has added details in Chapter 6 regarding measures use d at Griffin Pipe to restrict public

access . Such measures incorporate multiple levels of security with a degree of redundancy, including fencing around the facility, gates at roadway entry points, and the use of 24

- hour security personnel and video surveillance. The language i n the ACO is retained without modification to avoid overprescribing perimeter security measure s while ensuring Griffin Pipe continues to restrict public access through a
flexible mechanism.

Comment 8 (oral comment from the public hearing ) The commenter expressed concerns over increased pollution as the nation grows and the commenter would like to see the state do more than is being done to control pollution. The commenter was
concerned with the overall effects of pollution on individuals extremely sensitive to pollutants, children, adults, and pets, and believes factories should not be located in the middle of towns.

Department Response Implementation of the control measures included in the lead nonattainment SIP will provide significant
lead emissions reductions. The department has developed the lead nonattainment SIP to achieve EPA’s
hea lth and welfare based lead air quality standards and to attain the lead air quality standards as expedi tiously as practicable.

39

## Appendix A. **Baseyear 2010 Haul Road**  **Emissions Calculations**

Haul road emissions cannot be directly measured and instead are computed from emission factors and facility traffic data. The DNR estimated the 2010 baseyear haul road lead emissi on at Griffin Pipe and Alter Metal Recycling using the methods and information discussed in this appendix.

Paved Road s Emission Factors The paved road emission factors for Griffin Pipe and Alter Metal Recycling were determined using site

specific data and E quation (1) from AP

- 42, Chapter 13, Section 13.2.1 (dated January 2011): 16

E = k (sL) 0.91 x (W) 1.02 (1)

where: E = lead emission factor ( pounds of lead per vehicle mile t rave led

, lb/VMT )
k = particle size multiplier for suspendable particulate (0.011 lb/VMT)

sL = the amount of lead in the suspendable particulate (g/m 2 )

, and

W = average weight (tons) of the vehicles traveling the road segment

.

The amount of suspendable particulate on the haul road s (the silt

- loading) was determined using facility

- specific sampling data collected in accordance with Appendix C.1 of AP

- 42

. Th e collected suspendable particulate (s ilt ) wa s chemically analyzed to measure its total lead content

. The lead loading value ( sL) is obtained b y multiplying the silt loading (g/m 2 ) by the mass of lead in each gram of
silt

. The average vehicle weight reflects the fleet

- average vehicle weight for that road segment

. 17 To obtain the lead emission rate (in lbs/hr) for a roadway, the lead emission fa ctor is multiplied by the VMT for a given roadway for a given hour . The VMT is derived from the length of the roadway, the amount of traffic, and operating schedules.

Unpaved Roads Emission Factors The methods for estimating fugitive lead emissions from unpaved roads a re similar to those for paved
roads

. A different equation, as provided in AP

- 42, Chapter 13, Section 13.2.2 (dated November 2006 ), is required:

E = k (s/12 ) 0.7 x (W /3 ) 0.45 (2)

where: E = lead emission factor ( pounds of lead per vehicle mile traveled, lb/VMT )
k = industrial road suspendable particulate constant ( 4.9 lb/VMT)

, s = surface material lead content of silt (%) , and W = average weight (tons) of the vehicles traveling the road.

The empirical constants 0.7 a nd 0.45 in the above equation were obtained from AP

- 42 Table 13.2.2

- 2.

16 Additional background information on haul road emission factors can be found in Chapter 13 “ Miscellaneous

Sources ” of AP

- 42, see: http://www.epa.gov/ttn/chief/ap42/ch13/index.html

17 This is required by AP

- 42 13.2.1.3: “ For example, if 99 percent of traffic on the road are 2 ton cars/trucks while the remaining 1 percent consists of 20 ton trucks, then the mean weight "W" is 2.2 tons. More specifically, Equation 1 is not intended to be used to calculate a separate emission factor for each vehicle weight class. Instead, only one emission factor should be calculated to represent the "fleet" average weight of all vehicles traveling the road.”

40Input Data Calculating the emission factors and VMTs for each haul road is a data intensive process requiring site

specific data

. Each facility supplied the necessary haul road route data, roadway segment locatio ns, segment lengths (and widths for modeling purposes)

, traffic activity data ( such as vehicle weights, trip counts, and operating schedules)

, and roadway silt sampling results. 18 These data are discussed below.



### A

**- 1.**  **Griffin Pipe** On August 2 3, 2012, Griffin Pipe collected 18 samples from their haul roads to be analyzed for surface material loading s

. All areas sampled were paved as all routes at Griffin Pipe are paved. The

appr oximate locations where samples were collected are sho wn in Figure A

- 1

. The laboratory analysis
included sieving all samples (see Appendix C.2 of AP

- 42 for a description of the required procedures)

. Sieving separate s the suspendable particulate (smaller particles likely to become airbo rne when
travelled over , referred to here as “silt” ) from the larger particles in the sample . The lead content within
the silt was analyzed in 10 of the 18 samples

. Griffin Pipe cho se to analyze t he lead content within the

pre

- sieved (bulk) material (all material collected via vacuum ing or sweeping material off the roadway ) i n the remaining 8 samples

. The analytical results from t he sampling are shown in Table A

- 1 and
Table A

- 2

.

Griffin Pipe segmented their facility traffic into 61 different roadway sections. The segments are shown

in Figure A

- 2

. Fourteen s egments were excluded from additional consideration as no haul road activity was reported for those se gments

. The DNR assigned a lead silt loading value for the remaining 47
segments from the available sampling results. The silt loading values and the lead concentrations for each segment were developed by either averaging the results from different sampl es or selecting a single representative sample , using engineering judgment as necessary

. 19 Table A

- 3 identifies which samples were used for each road segment

.

A detailed accounting of traffic activity was also provided by Griffin Pipe , including vehicle weights, trip

counts

, roadway segment lengths and widths, and traffic schedules. The DNR reviewed the information and adjusted road lengths based upon aerial imagery of the facility . The traffic data provided by Griffin Pipe accou nted for over 2

, 500 separate ( time

- variant by hour of day) vehicle trips per week. The average vehicle weight and VMT values calculated for each segment incorporate a large amount of data
and each are hour of day dependent. Due to the volume of informati on accounted for within the baseline emission rates and the associated comple xity of the spreadsheets, they are no t readily reproducible in this document. Instead, the time

- invariant characteristics for the 47 road segments are provided in Table A

- 4 (this table also provides the road widths and vehicle heights & widths used in the dispersion modeling). The total baseline haul road emissions ( see Table 3

- 1 ) were calculated by summing the hourly emission rates (not shown) and assuming haul road operations were consistent six days a week and 52 weeks per year. This is a conservative approach.

18 To accommodate emissions calculations and dispersion modeling requirements, the DNR refined or segmented the supplied haul road routes as necessary. Dispersion modeling techniques and emissions calculations m ethods require a single emission rate for each segment of roadway. Facility data may be defined according to overlapping routes differentiated by materials hauled, paths travelled, or other internal considerations. Where necessary, the DNR split haul roa ds or routes into multiple segments to accommodate emissions and modeling needs.

19 The lead concentrations analyzed from the eight pre

- sieved samples were used in thi s evaluation by assuming their lead concentrations would not vary with sieving.

41Figure A

- 1

. Approximate locations of the 18 samples collected on August 23, 2012, by Griffin Pipe

. Locations in green had the silt analyzed for lead. At l ocations marked in orange the lead was measured in samples that were not sieved ( the bulk sample)

.
Table A

- 1

. Summary of analytical results for the 10 samples with the lead content measured in the
sieved material (silt) from Griffin Pipe

.
Sample

ID Sample

Area (m 2 ) Silt Content (g) Silt Content (%) Silt Loading (g/m 2 ) Lead Content
of Silt (μ g/kg)

RD

- 1 6.50 197.63 18.6 30.40 270,000

RD

- 3 89.07 147.86 7.3 1.66 450,000

RD

- 4 132.19 140.52 7.8 1.06 180,000

RD

- 5 78.04 130.71 11.8 1.67 310,000

RD

- 7 106.19 271.03 23.0 2.55 340,000

RD

- 10 143.19 10.22 0.8 0.07 180,000

RD

- 12 4.79 94.20 17.8 19.67 92,000

RD

- 15 5.53 145.63 22.5 26.33 850,000

RD

- 17 9.56 187.70 35.0 19.63 310,000

RD

- 18 31.16 93.47 12.5 3.00 390,000

42Table A

- 2

. Silt loading of the sieved material and the l ead content of pre

- sieved (bulk) material for the remaining 8 samples collected by Griffin Pipe

.

Sample

ID Sample

Area (m 2 ) Silt Content (g) Silt Content (%) Silt Loading (g/m 2 ) Lead C ontent of

Pre

- Sieved (Bulk) Material (μ g/mg)

RD

- 2 96.99 168.50 21.5 1.74 300,000

RD

- 6 111.62 81.56 8.5 0.73 92,000

RD

- 8 126.62 100.01 10.8 0.79 210,000

RD

- 9 109.63 71.79 7.7 0.65 200,000

RD

- 11 136.05 41.12 6.0 0.30 300,000

RD

- 13 18.19 156.73 19.3 8.62 280,000

RD

- 14 3.98 167.37 20.0 42.05 130,000

RD

- 16 21.55 158.94 18.7 7.38 570,000

Figure A

- 2 . Depiction of the 61 roadway segments (all paved) ide ntified by Griffin Pipe. O nly 47
segment s are associated with haul road traffic

.

43Table A

- 3

. Roadway samples averaged (or assigned) for each road segment and the resultant silt loading, lead, and lead loading values within the silt

.

Road Segment s Samples Averaged or

Assigned Silt Loading (g/m 2 ) Lead in S ilt (μ g/k g) Pb

- Silt

L oading (g/m 2 )

1, 2, 3, 4, 11, 12, 13, 14, 15, 16, 17, 29 RD

- 2, 3, 4, 5 1.53 310,000 0.000475483
24, 25, 26, 32, 36, 37, 38, 43, 45 RD

- 12, 15, 17 21.88 417,333 0.009129862
39, 40, 41, 42, 46, 47 RD

- 8, 9 0.72 205,000 0.0001476
48, 49, 53, 56, 58 RD

- 10, 11 0.19 240,000 0.0000444
27, 28 RD

- 18 3.00 390,000 0.00117
34, 35 RD

- 14 42.05 130,000 0.0054665
5, 6, 9, 10, 18, 19, 21, 23 RD

- 1 30.40 270,000 0.008208
30, 31, 33 RD

- 7 2.55 340,000 0.000867

Table A

- 4 . Baseline characteristics of haul road segments at Griffin Pipe. Vehicle height and width values are calculated for dispersion modeling purposes

.Row NumberSegment IDLength (ft)Width (ft) Samples Averaged Silt Loading (g/m 2 ) Pb Silt (μ g/mg) Pb

- Silt

L oading (g/m 2 ) Vehicle Height

(ft) Vehicle
Width

(ft)

1 1 112 14 RD

- 2, 3, 4, 5 1.53 310,000 4.755E

- 04 12.91 8.45

2 2 177 14 RD

- 2, 3, 4, 5 1.53 310,000 4.755E

- 04 9.83 8.50

3 3 175 14 RD

- 2, 3, 4, 5 1.53 310,000 4.755E

- 04 9.82 8.50

4 4 174 14 RD

- 2, 3, 4, 5 1.53 310,000 4.755E

- 04 9.50 8.50

5 5 190 14 RD

- 1 30.40 270,000 8.208E

- 03 9.50 8.50

6 6 149 14 RD

- 1 30.40 270,000 8.208E

- 03 9.50 8.50

7 9 151 14 RD

- 1 30.40 270,000 8.208E

- 03 9.50 8.50

8 10 151 14 RD

- 1 30.40 270,000 8.208E

- 03 9.50 8.50

9 11 295 14 RD

- 2, 3, 4, 5 1.53 310,000 4.755E

- 04 9.52 8.50

10 12 295 21.3 RD

- 2, 3, 4, 5 1.53 310,000 4.755E

- 04 12.14 8.50

11 13 318 21.3 RD

- 2, 3, 4, 5 1.53 310,000 4.755E

- 04 9.67 8.50

12 14 321 30 RD

- 2, 3, 4, 5 1.53 310,000 4.755E

- 04 9.88 8.09

13 15 171 29 RD

- 2, 3, 4, 5 1.53 310,000 4.755E

- 04 8.06 5.54

14 16 171 29 RD

- 2, 3, 4, 5 1.53 310,000 4.755E

- 04 8.27 5.92

15 17 164 29 RD

- 2, 3, 4, 5 1.53 310,000 4.755E

- 04 9.07 7.63

16 18 193 29 RD

- 1 30.40 270,000 8.208E

- 03 9.50 8.50

17 19 153 14 RD

- 1 30.40 270,000 8.208E

- 03 9.50 8.50

18 21 216 14 RD

- 1 30.40 270,000 8.208E

- 03 9.50 8.50

19 23 88 14 RD

- 1 30.40 270,000 8.208E

- 03 9.50 8.50

20 24 136 14 RD

- 12, 15, 17 21.88 417,333 9.130E

- 03 9.79 6.68

21 25 78 14 RD

- 12, 15, 17 21.88 417,333 9.130E

- 03 8.75 5.50

22 26 62 30 RD

- 12, 15, 17 21.88 417,333 9.130E

- 03 11.03 8.50

23 27 209 30 RD

- 18 3.00 390,000 1.170E

- 03 9.04 7.54

44Row NumberSegment IDLength (ft)Width (ft) Samples Averaged Silt Loading (g/m 2 ) Pb Silt (μ g/mg) Pb

- Silt

L oading (g/m 2 ) Vehicle Height

(ft) Vehicle
Width

(ft)

24 28 174 26 RD

- 18 3.00 390,000 1.170E

- 03 13.00 8.50

25 29 198 26 RD

- 2, 3, 4, 5 1.53 310,000 4.755E

- 04 10.42 8.08

26 30 90 30 RD

- 7 2.55 340,000 8.670E

- 04 12.04 7.83

27 31 351 22.5 RD

- 7 2.55 340,000 8.670E

- 04 11.66 7.53

28 32 611 23 RD

- 12, 15, 17 21.88 417,333 9.130E

- 03 11.80 7.64

29 33 287 22.5 RD

- 7 2.55 340,000 8.670E

- 04 11.66 7.54

30 34 128 30 RD

- 14 42.05 130,000 5.467E

- 03 13.00 8.50

31 35 86 30 RD

- 14 42.05 130,000 5.467E

- 03 11.97 7.75

32 36 37 30 RD

- 12, 15, 17 21.88 417,333 9.130E

- 03 11.33 7.29

33 37 206 14 RD

- 12, 15, 17 21.88 417,333 9.130E

- 03 12.94 8.50

34 38 206 12 RD

- 12, 15, 17 21.88 417,333 9.130E

- 03 13.00 8.50

35 39 63 30 RD

- 8, 9 0.72 205,000 1.476E

- 04 9.50 8.50

36 40 140 30 RD

- 8, 9 0.72 205,000 1.476E

- 04 9.30 6.20

37 41 106 30 RD

- 8, 9 0.72 205,000 1.476E

- 04 9.42 7.53

38 42 262 30 RD

- 8, 9 0.72 205,000 1.476E

- 04 9.60 8.50

39 43 37 27.7 RD

- 12, 15, 17 21.88 417,333 9.130E

- 03 12.97 8.50

40 45 36 14 RD

- 12, 15, 17 21.88 417,333 9.130E

- 03 13.00 8.50

41 46 106 30 RD

- 8, 9 0.72 205,000 1.476E

- 04 9.41 7.74

42 47 146 26.4 RD

- 8, 9 0.72 205,000 1.476E

- 04 10.87 7.43

43 48 150 26.6 RD

- 10, 11 0.19 240,000 4.440E

- 05 9.49 7.94

44 49 100 30.4 RD

- 10, 11 0.19 240,000 4.440E

- 05 9.49 8.01

45 53 382 30.4 RD

- 10, 11 0.19 240,000 4.440E

- 05 10.06 8.50

46 56 110 30.4 RD

- 10, 11 0.19 240,000 4.440E

- 05 10.29 8.50

47 58 514 30.4 RD

- 10, 11 0.19 240,000 4.440E

- 05 10.29 8.50



### A

**- 2.**  **Alter Metal Recycling**  On June 3, 2013, Alter Metal Recycling collected eight silt samples on their haul road s and evaluated
each sample for both silt content and the lead content in the silt . T he approximate sampling locations
are shown in Figure A

- 3

. Th e analytical results from the silt sampling are shown in Table A

- 5

. Most haul
roads we re paved and the majority of traffic at the facility use d paved roads. A small er amount of traffic
used unpaved roads , and appropriately a smaller number of samples ( two of the eight ) were collected

on unpaved roads.

Alter Metal R ecycling identified haul route s (see Figure A

- 4 ) using roadway locations, material types transported , and an inbound/ outb ound distinction. The DNR converted the facility traffic route information provided by Alter Metal Recycling into 17 different segments, as depicted in Figure A

- 5 . The

DNR assigned lead

- loading value s from the available sampling results and segment lengths using Google Earth imagery

. The silt loading values and the lead concentrations for each segment were developed by either averaging the results from differen t samples or selecting a single representative sample. Table

A

- 6 identifies which samples were used for each road segment.

45Alter Metal Recycling provided a detailed accou nting of their traffic activity

. Traffic data included vehicle weights, trip counts, roadway and route locations, route lengths and widths, and traffic
schedules. The provided traffic data accounted for time

- variant (by hour of day and weekday versus Saturday operations ) vehicle trip inf ormation. The calculation s of the average vehicle weights and the vehicle miles travelled for each segment incorporate a large amount of data due to the complex traff ic patterns, overlapping routes , variable vehicle types and weights, and the volume of tr affic at Alter Metal Recycling . The spreadsheets that detail the baseline emission rates calculations are not reproducible in a meaningful format in this document because of this complexity. Instead, the time

- in variant
characteristics for each of the 17 road segments are provided in Table A

- 7 (this table s also provide s the
road widths , vehicle heights, and vehicle widths used in the dispersion modeling ) and total route lengths with the associated paths are given in Table A

- 8 . The total baseline haul road emissions ( see Table 3

- 1 )

were calculated by summing the hourly emission rates (not shown) and assuming the facility operated 6 days a week and 52 weeks a year. This is a conservative appr oach.

Note, a small amount of Griffin Pipe’s traffi c uses Alter Metal Recycling’s road segments 1, 3, 4, and 5. While these emissions are attributed to Alter Metal Recycling in the baseline emissions summary presented in Table 3

- 1

, for modeling purposes these emissions were separated and apportioned to each facility as appropriate.



### A

**- 3.**  **Data Caveats** As mentioned above, Griffin Pipe collected and provided lead silt

- loading data in 2012. Alter Metal Recycling collected and provided their lead silt

- loading data in 2013. The traffic activity information provided by Alter Metal Recycling is based upon ca lendar year 2012 data. Traffic data from Griffin Pipe is comparably recent. The data are not spec ific to the 2010 baseyear but are the best available and

were used to calculate the baseline inventory. While traffic levels and silt

- loadings may not re mai n constant from year to year the data are not known to be biased.

Another caveat is that the silt sampling conducted by the facilities occurs prior to any haul road sweeping or watering efforts used to mitigate fugitive dust emissions. The lead silt

- load ing values used to estimate the baseline emissions are thus expected to reflect worse case condition s . Additionally, the estimated actual haul road emissions have not been adjusted (reduced) to account for precipitation.
While t hese assumptions are conservative in nature and are expected to overpredict the true haul road baseline emission rates they represent common practices.

46Figure A

- 3 . Approximate locations of the 8 silt sam ples collected on June 3, 2013, by Alter Met al Recycling. Sample location D 1 is shown in blue to differentiate this location as an unpaved road. The roadway under sample D1 was originally constructed a s a paved road but was deteriorated and was
treated b y the DNR as an unpaved road. Sample location C1 was collected from an unpaved road.

Table A

- 5 . Analytical results from the silt sampling conducted by Alter Metal Recycling

.

Sample

ID Sample Location R oad Type Area (m 2 ) Silt

Content (g) Silt

Content (%) Silt

L oading (g/m 2 ) Lead

Content

of Silt (μg/kg)

A1 Facility access Paved 18.52 139.14 10.3 7.51 1,000,000

A2 Facility access Paved 11.02 198.23 9.8 17.99 880,000

B1 Truck scale Paved 4.02 405.99 26.8 100.99 1,300,000

B2 Truck scale Paved 3.95 306.83 27.1 77.68 1,000,000

C1 S of Non Ferrous Bldg Unpaved 4.73 304.32 14.8 64.34 1,700,000

D1 W o f Non Ferrous Bldg Unpaved* 4.10 900.9 21.0 219.73 750,000

E1 E of Maintenance Shop Paved 5.43 351.39 14.2 64.71 830,000

F1 West property line Paved 8.45 463.9 38.7 54.90 930,000 *Surface originally paved, but treated as unpaved by the DNR due to deterioration.

47Figure A

- 4

. Approximate d d epiction of the baseline routes identified by Alter Metal Recycling. Locations in gray indicate section s of roadway originally unpaved

.

48Figure A

- 5

. Approximated d epiction of the 17 roadway segments defined for Alter Metal Recycling’s
baseline traffic routes. Unpaved segments are denoted by an “(u)” after the segment number. Segment 14 (p* ) was originally constructed as a paved road but treated as unpaved due to d eterioration. All other segments are paved. Segment numbers are color

- co ded with the segment lines.

Table A

- 6 . Roadway samples averaged (or assigned) for each road segment and the resultant silt
load ing, lead, and lead loading values within the silt.

Paved Road Segments Samples Averaged Silt Loading (g/m 2 ) Lead in Silt (μg/kg) Pb

- Silt Loading (g/m 2 )

1, 2, 3, 4, 5, 6 A1, A2 12.75 940,000 0.011985546
8, 9 B1, B2 89.34 1,150,000 0.102735836
10, 11, 12, 13 E1, F1 59.81 880,000 0.052629331

Unpaved Road Segments Sample Assigned Silt Loading (%) Lead in Sil t (μg/kg) Pb Silt Content ( % )
7, 14, 15, 16, 17 C1 14.80 1,700,000 0.02516

49Table A

- 7 . Baseline characteristics of each road segment at Alter Metal Recycling

. Vehicle height and
width values are calculated for dispersion modeling.Segment ID

Type Length

- meters (feet) Width (ft) Silt Samples Averaged Silt Loading (g/m 2 ) Pb Silt (μg/mg) Pb

- Silt Loading (g/m 2 ) Vehicle Height

(ft) Vehicle
Width

(ft)

1 paved 100 (328) 25 A1, A2 12.75 940,000 0.011986 12.9 8.5

2 paved 160 (525) 25 A1, A2 12.75 940,000 0.011986 9.0 8.5

3 paved 61 (200) 25 A1, A2 12.75 940,000 0.011986 13.0 8.5

4 paved 348 (1142) 25 A1, A2 12.75 940,000 0.011986 12.9 8.5

5 paved 22 (72) 25 A1, A2 12.75 940,000 0.011986 12.9 8.5

6 paved 20 (66) 25 A1, A2 12.75 940,000 0.011986 12.9 8.5

8 paved 133 (436) 25 B1,B2 89.34 1,150,000 0.102736 13.0 8.5

9 paved 32 (105) 25 B1,B2 89.34 1,150,000 0.102736 12.9 8.5

10 paved 293 (961) 25 E1,F1 59.81 880,000 0.052629 12.9 8.5

11 paved 88 (289) 25 E1,F1 59.81 880,000 0.052629 12.9 8.5

12 paved 76 (249) 25 E1,F1 59.81 880,000 0.052629 13.0 8.5

13 paved 92 (302) 25 E1,F1 59.81 880,000 0.052629 13.0 8.5

Total Paved: 1425 (4675)Segment ID

Type Length

- meters (feet) Width (ft) Silt Samples Averaged Silt Loading (g/m 2 ) Pb Silt (μg/mg) Pb

- Silt Loading (g/m 2 ) Vehicle Height

(ft) Vehicle
Width

(ft)

7 (u) unpaved 55 (180) 25 C1 14.80 1,700,000 0.02516 9.0 8.5

14 (p*) unpaved 60 (197) 25 C1 14.80 1,700,000 0.02516 13.0 8.5

15 (u) unpaved 128 (420) 25 C1 14.80 1,700,000 0.02516 13.0 8.5

16 (u) unpaved 56 (184) 25 C1 14.80 1,700,000 0.02516 12.8 8.5

17 (u) unpaved 245 (804) 25 C1 14.80 1,700,000 0.02516 9.0 8.5
Total Unpaved : 544 (1785)

Total Length : 1 969 (6460)

Table A

- 8 . Route paths and total lengths used in the baseline for Alter Metal Recycling. Routes generally reflect a round trip path through the facility, defin ed by the segments traversed.

Route Route Path (Segments) Route Length

(m)

1 1

- 3

- 4

- 5

- 6

- 8

- 9

- 10

- 11

- 11

- 12

- 9

- 8

- 6

- 5

- 4

- 3

- 1 1,977

2 1

- 3

- 4

- 5

- 6

- 8

- 9

- 12

- 13

- 14(p*)

- 8

- 6

- 5

- 4

- 3

- 1 1,628

3 1

- 2

- 4

- 5

- 6

- 7(u)

- 16(u)

- 17(u)

- 17(u)

- 16(u)

- 7(u)

- 6

- 5

- 4

- 2

- 1 2,012

4 1

- 3

- 4

- 5

- 6

- 8

- 14(p*)

- 15(u)

- 16(u)

- 16(u)

- 15(u)

- 14(p*)

- 8

- 6

- 5

- 4

- 3

- 1 1,856

50

## Appendix B. **Griffin Pipe Administrative Consent Order**

51

### IOWA DEPARTMENT OF NATURAL RESOURCES ADMINISTRATIVE CONSENT ORDER ISSUED TO: GRIFFIN PIPE PRODUCTS CO., LLC

II. JURISDICTION

The administrative consent order is issued p ursuant to the provisions of Iowa Code sections 455B.134(9) and 455B. 138 (1) which auth orize the Director to issue

o

rder s necessary to secure compliance with or prevent a violation of Iowa Code chapter 455B, Division II , and the rules promulgated or permits pursuant thereto, and to prevent, abate, and control air pollution.

III. STATEMENT OF FACTS

1. Griffin Pipe owns a ductile iron foundry located in Council Bluffs, Iowa (the “Facility”) . Griffin Pipe manufactures ductile iron pressure pipe for potable
water transmiss ion and wastewater collection.

2. On November 12, 2008, EPA published in the Federal Register (73 FR 66964 ) a final rule that lowered the level of the lead NAAQS from 1.5 to 0 .15 micrograms per cubic meter ( μ g/m 3 

### ) of air. The revised standard requires that the
maximum monitored 3

- month rolling average not exceed 0.15 μg/m 3



### . DNR adopted the revised lead NAAQS in 2009 and the adoption became effective on November 11, 2009

.

3. DNR sited a source

- oriented ambient lead monitor near the Facility in 2009. The monitor is near the intersection of 8 th 

### Avenue and S outh 27 th 

### Street in Council Bluffs, Iowa

. In 2010, six 3

- month rolling averages over the 0 .15 μg/m 3 

### lead NAAQS were measured by DNR at this monitor . Th o

se six values did not meet the lead health standard. The maximum 3

- month average measured by DNR in 2010 occurred during t he June

- August peri od and was 0.26 μg/m 3



### . ( In 2012, f our 3

- month rolling averages over the 0.15 μg/m 3 

### lead NAAQS were monitored. Tho se four values did not meet the lead health standard. The maximum 3

- month average measured by DNR in 2012 occurred during the August

- October period and was 0.20 μg/m 3



### . )

4. On November 22, 2011, EPA published in the Federal Register (76 FR 72097 ) a nonattainment designation for portions of Pottawattamie County , Iowa. The nonattainment area includes the F acility and the designation became e ffectiv e December 31, 2011.

5. The State of Iowa must submit a SIP revision that meets the requirements of Clean Air Act section 172(c) and provides for attainment of the 2008 L ead NAAQS as expeditiously as practicable, but no later than December 31, 2016.

6. DNR a ir quality dispersion modeling of Griffin Pipe has predicted that the Facility was a contributor to the monitored lead NAAQS violations. The Facility is not the sole source of lead emissions in the nonattainment area

.

2

### IOWA DEPARTMENT OF NATURAL RESOURCES ADMINISTRATIVE CONSENT ORDER ISSUED TO: GRIFFIN PIPE PRODUCTS CO., LLC

7. On May 3, 2014 , Griffin Pipe idled operations at its Council Bluffs plant . Griffin Pipe does not presently plan to rescind its current DNR air quality permits.

8. DNR and Griffin Pipe have been working together to quantify lead emissions, identify sources that may need controls upgraded or added, and develop options for implementing changes to achieve attainment and maintenance of the 2008 Lead NAAQS

. The DNR and Griffin Pipe are entering into this administra tive consent order to create two enforceable control strategi es . Each control strategy contain s control measures and timeline s for implementation

. Griffin Pipe may choose which strategy to implement

.

9. Amendments to this administrative consent order and the attachments constitute a revision to the SIP and must be submitted to the EPA for approval.

10. By agreeing to the terms of this administrative consent order Griffin Pipe does not admit that the facility caused or contributed to monitored lead levels above the NAAQS.

IV. CONCLUSIONS OF LAW

1. The emission sources located a t the Facility include “air contaminant sources” as defined by Iowa Code section 455B.131(2), and “stationary sources” as defined by 567 I owa A dministrative C ode (IAC) 20.2.

2. 567 I AC 28.1 states that the ambient air quality standards for the State of Iowa s hall be the NAAQS located at 40 Code of Federal Regulations (CFR) Part 50, as amended through June 22, 2010. 40 CFR 50 states that the lead NAAQS is 0.15 μg/m 3 

### , arithmetic mean concentration over a 3

- month period. The monitoring data near Griffin Pipe measured 3

- month average lead concentrations in 2010 ( and 2012 ) that did not meet the lead NAAQS. The NAAQS violations in this case constitute “air pollution” as defined in Iowa Code section 455B.131(3).

3. E ffective December 31, 2011 , the Facility is locate d in a lead
nonattainment area . The lead nonattainment area is delineated according to the boundary definitions in 40 CFR 81.316

.

4. Section 191(a ) of the Clean Air Act provides that “ [a] ny State containing an area designated or redesignated under [Clean Air Act] section 107(d) as nonattainment with respect to the national primary ambient air quality standards for...lead... shall submit to the Administrator...an applicable implementation plan meeting the requirements of this part. ” Clean Air Act Section 172(c) req uires that

“ [s] uch plan provisions shall include enforceable emission limitations, and such other control measures

... as well as schedules and timetables for compliance, as may be necessary or appropriate to provide for attainment of such standard in such area by the applicable attainment date

... . ”

3

### IOWA DEPARTMENT OF NATURAL RESOURCES ADMINISTRATIVE CONSENT ORDER ISSUED TO: GRIFFIN PIPE PRODUCTS CO., LLC

5. Iowa Code sections 455B.134(9) and 455B.138(1) authorize the Director to issue order s necessary to secure compliance with or prevent a violation of Iowa Code chapter 455B, Division II, and the rules promulgated or permits issued pursuant thereto, and to prevent, abate, and control air pollution. This administrat ive consent order create s enforceable control measures to address the lead concentrations in ambient air in Council Bluffs

.

V. ORDER

THEREFORE, DNR and Griffi n Pipe agree to the following :

1. Griffin Pipe shall either (1) implement the control measures contained in Attachment A

, or (2) implement t he control measures contained in Attachment B

to this administrative consent order

. Griffin Pipe may (but is not required under this administrative consent order to) install and operate additional emission control projects and may improve the emission co ntrols listed in the attachment s as necessary to further reduce ambient lead concentrations in Council Bluffs , Iowa

, in compliance with applicable law s and administrative rules and with prior approval of the DNR ;

2. Griffin Pipe shall either (1) meet all emission limits and all point source characteristics specified in Attachment A

, or (2) meet all emissions limits and all point source characteristics specified in Attachment B to this administrative consent order;

3. T he requirements contained in this order and Attachments A and B may be modified with the written approval of DNR and Griffin Pipe

. Any request for modification to an y requirements contained in this order or an a ttachment must be approved by the DNR prior to its respective deadline . Any modifications to this order or an a ttachment may be subject to approv al of the US EPA and may resul t in the requirement to complete a modeled attainment demonstration using approved dispersion modeling techniques, if requested by DNR ;

4. Griffin Pipe shall comply with the following requirements:

A. With respect to p erformance t esting

, Griffin Pipe shall either (1)

, if opting to implement the control measures contained in Attachment A, complete performance test ing to demonstrate compliance with the lead
emission limits contained in Attachment A in accordance with the frequency and timelines specified there in

, or (2)

, if opting to implement the control measures contained in Attachment B, complete performance test ing to demonstrate compliance with the lead emission limits contained in Attachment B in accordance with the frequency and timelines specified therein

.

4

### IOWA DEPARTMENT OF NATURAL RESOURCES ADMINISTRATIVE CONSENT ORDER ISSUED TO: GRIFFIN PIPE PRODUCTS CO., LLC

In the event any performance testing conducted by G riffin Pipe demonstrates

an exceedance , Griffin Pipe shall communicate to the DNR how the exceedance will be corrected and establish with DNR a compliance plan to address the exceedance

.

B. With respect to w ork p ractices Griffin Pipe shall either (1) follow the monitoring, recordkeeping and reporting requirements contained in Attachment A to this administrative consent order when implementing the control measures specified in Attachment A beginnin g on the date this administrative consent order is signed by the D irector, unless otherwise specified in Attachment A

, or (2) follow the monitoring, recordkeeping and reporting requirements contained in Attachment B to this administrative

consent order when implementing the control measures specified in Attachment B beginning on the date this administrative consent order is signed by the Director, unless otherwise specified in Attachment B

.

If a monitoring, recordkeeping, or reporting requirement(s ) specified in Attachment A or Attachment B cannot be completed due to unforeseen circumstances, then the conditions which prevented the completion of the requirement(s) shall be documented, including the time period during which the conditions preventing completion of the requirements exist ed and the actions taken to remedy the situation.

From the date this orde r is issued until the date the F acility resumes operations the m onitoring, recordkeeping and reporting requirements contained in Paragraph 4 of thi s order shall be suspended

. Resume(s) operations shall mean the resumption of pipe products manufacture and production operations, including resumption of the cupola operations at the Facility

C. The performance testing and work practices requirements may be adjusted after performance testing is completed to more accurately represent the observed operating ranges of the equipment during the successful demonstration of compliance ;

5. Nothing in this Administrative Consent Order prevents Griffin Pipe from opting t o comply with Attachment A, and thereafter opting (at its discretion) to comply with the requirements contained in Attachment B

.

6. Griffin Pipe shall certify compliance with the provisions of this administrat ive consent order as part of Griffin Pipe ’s compliance certification obligations pursuant to its Title V Operating permit for this facility ;

7. Griffin Pipe shall notify the DNR in writing at least 60 days prior to the date the F acility resumes operations and thereafter shall notify the DNR in writing within 14 days of suspending plant operations ;

5

# ATTACHMENT A

Plant Name: Griffin Pipe Products Company

Equipment Location: 2601 9 th 

### Avenue Council Bluffs, Iowa 51501

Plant Number: 78

- 01

- 012

The following emissi on units shall conform to the requirements specified in condition A

- 1:



### A

- 1. Emission Unit Description

Emission Unit Maximum Rated Capacity Control Equipment

Cupola (EU

- 1) 60 Tons/hr Baghouse (CE

- 10) Desulfurization (EU

- 2) 60 Tons/hr Baghouse (CE

- 11) Bull Ladle (EU

- 3) 60 Tons/hr Magnesium Inoculation (EU

- 4) 60 Tons/hr
Small Diameter Casting (EU

- 6) 6 0 Tons/hr None Desulfurization (EU

- 2)

- Uncaptured 60 Tons/hr None Bull Ladle (EU

- 3)

- Uncaptured 60 Tons/hr Magnesium Inoculation (EU

- 4)

- Uncaptured 60 Tons/hr None Large Diameter Casting ( EU

- 29 ) 40 Tons/hr None Cupola Charge Handling (EU

- 17) 60 Tons/hr None Traffic Pathways NA Paved Road SweepingGrif fin Pipe Products Company 

### Attachment A Page 2 of 7
Council Bluffs , Iowa



### A

- 2

. Lead (Pb) Emission Limits
The following lead (Pb) emission limits shall not be exceeded:

Source Description EP ID lb/hr 1 tons/yr 2 Additional Limits Justification

Cupola (EU

- 1) EP

- 2A 0. 282 3 NA NA RACT

0.046 4 NA NA See Note 4 Desulfurization (EU

- 2)

EP

- 3 0.0018 3 NA NA RACT Bull Ladle (EU

- 3) Magnesium Inoculation (EU

- 4) Magnesium Inoculation

- Uncaptured (EU

- 4) EP

- 7A 0.0026 3 NA NA RACT Ladle Preheat

- Uncaptured (EU

- 19)

Desulfurization

- Uncaptured (EU

- 2)

EP

- 7B 0.0372 3 NA NA RACT Bull Ladle

- Uncaptured (EU

- 3)
S mall D iameter Casting (EU

- 6)

S mall D iameter Casting (EU

- 6) EP

- 6A 0.0043 3 NA NA RACT Building Emissions EP

- 6B 0.0025 3 NA NA RACT

Large Diameter Casting (EU

- 29) EP

- 29 0.0025 3 NA NA RACT EP

- 29A Cupola Charge Handling (EU

- 17) F UG1 0.00143 3 NA NA RACT

Traffic Pathways NA NA 5 6 RACT, 23.3(2)“c”

1 The emission limit is expressed as the average of three (3) runs.

2 The emission limit is a twelve (12) month rolling total.

3 The lead limit is established to address the nonattainment designation for a portion of Pottawattamie County published in the Federal Register (76 FR 72097) on November 22, 2011

. 4 The lead limit is an applicable requirement established in a federally enforceable Consent Decree entered in United States v. Griffin Pipe Products Co., LLC , (Civil Action No. 1:14

- cv

- 00027

– JAJ

– RAW)

5 The l ead limit is established at 0.00 2 tons of lead per rolling 3

- month total ; that correlates to a lead silt loading
content of 0.00016 g/m 2 and maximum potential operation (all raw material/product is shipped or received by truck). The lead limit is based on 95% reduction over baseline lead levels and is established to address the nonattainment designation for a portion of Pottawattamie County published in the Federal Register (76 FR 72097) on November 22, 2011

. 6 The owner or operator shall take reasonable p recautions to prevent the discharge of visible emissions of fugitive dusts beyond lot line of the property.Grif fin Pipe Products Company 

### Attachment A Page 3 of 7
Council Bluffs , Iowa



### A

- 3 . Emission Point Characteristics

These emission point s shall conform to the specifications listed below:

EP ID Stack Height, Feet Discharge Style Stack Opening, inches

EP

- 2A 100 Vertical Unobstructed 80 diameter

EP

- 3 100 Vertical Unobstructed 7 2 diameter

EP

- 7A 49 Vertical Unobstructed 122 diameter

EP

- 7B 49 Vertical Unobstructed 122 diameter

EP

- 6A 49 Vertical Unobstructed 80 diameter

EP

- 6B 49 Vertical Unobstructed 80 diameter

EP

- 29 48 Vertical Unobstructed 72 x 72

EP

- 29A 48 Vertical Unobstructed 72 x 72



### A

- 4

. Lead (Pb) Compliance Demonstration(s)

Emission Point ID Compliance Demonstration Compliance Methodology Frequency

EP

- 2A Yes Performance Testing Annual 2

EP

- 3 Yes Performance Testing Annual 2

EP

- 7A Yes Performance Testing Annual 2

EP

- 7B Yes Performance Testing Annual 2

EP

- 6A Yes Performance Testing Once Every 3

- years 2

EP

- 6B Yes Performance Testing Once Every 3

- years 2 ,3

EP

- 29 Yes Performance Testing 1 Once Every 3

- years 2

EP

- 29A Yes Performance Testing 1 Once Every 3

- years 2

F UG 1 Yes Work Practice NA Traffic Pathways Yes Silt Load Sampling Monthly 4

1 Performance testing for lead shall be conducted on EP

- 29 and EP

- 2 9 A simultaneously to demonstrate compliance

with emission limit as specified in condition A

- 2

. 2 Following a written request by Griffin Pipe Products Company and approval by Iowa DNR, the testing frequency may be decreased following initial or subsequent per formance testing.

3 Maximum operating capacity shall be based on the Cupola (EU

- 1) charge rate.

4 Following 12 monthly sampling events, based on a written request by G riffin Pipe Products Company and approval by Iowa DNR, the silt loading sampling may be r educed or eliminated.

Performance Testing Requirements

If a compliance demonstration specified above is performance testing , the owner or the owner’s authorized agent shall verify compliance with the emission limitations contained in Condition A

- 2 within 6 months after the re start date of the equipment.

If subsequent performance testing is specified above , the owner or the owner’s authorized agent shall verify compliance with the emission limitations contained in Condition A

- 2 according to the f requency and timeframe
noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

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

Each performance test must be approved by the Department. Unless otherwise specified by the Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless otherwise indicated by th e Department.Grif fin Pipe Products Company 

### Attachment A Page 4 of 7
Council Bluffs , Iowa



### A

- 4. Lead (Pb) Compliance Demonstration(s) (continued)

Per 567 IAC 25.1(7) “ a”, at the Department’s request, for each performance test a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol
for each performance test shall be submitted to the Department no later than fifteen (15) days before t he owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the prete st meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements.

The owner shall be responsible for the installation an d maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) wi ll be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department tha t this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine w hether this unit(s) is in compliance.

Silt Load Sampling Requirements

For each sampling event, silt loading sampling shall be done for at least 3 different locations. Sampling shall be completed at locations that are representative of normal conditions and shall not be conducted within 4 hours after paved road sweeping has occurred. The three sampled locations shall then be averaged to determine the silt loading
for that month. Silt load testing shall be conducted according to the procedures outlined i n AP

- 42, Appendix C.1 Procedures for Sampling Surface/Bulk Dust Loading and C.2 Procedures for Laboratory Analysis of Surface/Bulk Dust Loading Samples.

The owner or operator shall commence silt load sampling to verify compliance with the haul road operating
limitations contained in Condition A

- 5.L during the first 30

- days the facility resumes operations and subsequent sampling of haul road surface silt loading shall be completed on a monthly basis.

After 3 conse cutive months of haul road surface silt loading sampling and every month thereafter, the owner or operator shall calculate the 3

- month rolling average total silt loading content to determine compliance with the operating limit included in Condition A

- 5.L

. A s a n alternative

, the owner or operator may analyze the sampl es for
lead content and calculate the 3

- month rolling average lead silt loading to demonstrate compliance with the pollutant specific operating limit provided in Condition A

- 5.L

.

I f the 3

- m onth rolling average silt loading limit is exceeded, the owner or operator shall immediately double the frequency of sweeping

. The increased sweeping frequency shall occur until the lead silt loading resul ts are obtained
and demonstrate compliance with th e 3

- month rolling lead silt loading limit provided in Condition A

- 5.L or until such time as additional silt loading samples demonstrate compliance with the 3

- month rolling total silt loa ding limit provided in Condition A

- 5.L. The owner or operator shall m aintain records onsite that detail the date the measure d silt loading exceeded Condition A

- 5.L

, the date in which increased sweeping frequency was enacted and the date that compliance was demonstrated with Condition A

- 5.L

The owner or operator shall develop and submit a silt/lead sampling protocol to the Department for approval 30

- days prior to resuming operation

. The submitted silt/lead sampling protocol shall detail procedures for sample chain of custody, identification, storage, and lead analysis. The approved silt/lead sampling protocol shall be implemented
and retain ed onsite.Grif fin Pipe Products Company 

### Attachment A Page 5 of 7
Council Bluffs , Iowa



### A

- 5 . Operating Limits
Operating limits shall be:

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

- month period.

B. All emission uni ts specified in Table 1 below are limited to operating 1,250 hours per rolling 3

- month period.

Table 1: Scrap Melting Activities

Emission Unit Cupola (EU

- 1) Desulfurization (EU

- 2)

Bull Ladle (EU

- 3) Magnesium Inoculation (EU

- 4) Small Diameter Casting (EU

- 6) Desulfurization (EU

- 2)

- Uncaptured

Bull Ladle (EU

- 3)

- Uncaptured Magnesium Inoculation (EU

- 4)

- Uncaptured Large Diameter Casting (EU

- 29) Cupola Charge Handling (EU

- 17)

C. The pressure drop across the baghouse (CE

- 10) shall be between 3.5 to 10.0 inches of water column based on a
5

- minute average.

D. The pressure drop across the baghouse (CE

- 11) shall be between 3.5 to 10.0 inches of water column based on a
5

- minute average.

E. Maintain Baghouse (CE

- 10) according to manufacturer specifications and mainte nance schedule.

F. Maintain Baghouse (CE

- 11) according to manufacturer specifications and maintenance schedule.

G. The owner or operator shall implement work practice standards as specified in Standard Operating Procedure (SOP) Melt180CB to minimize emissions fr om Cupola Charge Handling (EU

- 17).

H. The owner or operator shall implement the scrap management plan as specified in Standard Operating
Procedure (SOP) Melt220CB

.
I. Limit public access. The o wner or operator shall restrict public access to the facility at all property boundary lines. The restriction does not apply to company employees

, contractors, delivery / shipping personnel , federal, state or local officials, emergency and maintenance service personnel (both private and public section), or others who have a legitimate reason for accessing the property

.

J. Fugitive dust emissions generated from truck traffic on the paved haul roads shall, at a minimum, be controlled by s weeping once per day ex cept as noted in Conditions A

- 5

. J (i) through (iv ). All sweeping must be completed using a Tymco DST

- 4 Sweeper or functionally equivalent sweeper type (as approved by the Department).

i. Paved road sweeping shall begin within seven (7) days after resuming operations at Griffin Pipe Products Company (Plant No. 78

- 01

- 012)

.
ii. If sweeping cannot be accomplished because the ambient air temperature (as measured at the facility during daylight opera ting hours) will be less than 35 ° F (1.7 ° C) or conditions due to weather could create hazardous driving conditions, then the sweeping shall be postponed and accomplished as soon after the scheduled date as the conditions preventing the sweeping have abated.

iii. Paved road sweeping need not occur when a rain gauge located at the site indicates that at least 0.2 inches of precipitation (water equivalent) has occurred within the preceding 24

- hour time period. However, paved road sweeping shall resume within 24

- hours after the precipitation event has ended.

iv. Paved road sweeping need not occur when the facility experiences no production or shippi ng activities on that calendar day.Grif fin Pipe Products Company 

### Attachment A Page 6 of 7
Council Bluffs , Iowa



### A

- 5. Operating Limits (continued)

K. If sweeping cannot be accomplished for the entire month due to ambient temperatures or hazardous weather, silt load testing is not required for that month.

L. The haul road surface total silt loading or lead silt loading shall not exceed 0.64 g/m 2 or 0.00016 g/m 2

, respectively

, based on a 3

- month rolling average

.
M. Bulk m aterial shipments or deliveries of product , waste and raw materials shall only occur from 7 am to 5 pm daily.

N. Best Managem ent Practices (BMP)

– The o wner or operator shall implement “good housekeeping” or best management practices to minimize fugitive emissions. Such practices include but are not limited to:

i. Clean up spills of lead containing raw materials on the haul road s urface as expeditiously as possible and in a manner consistent with good practice for minimizing emissions.

ii. Clean areas where lead containing materials are processed and where lead containing dust may be generated such as scrap melting areas in a manner co nsistent with minimizing fugitive lead emissions.

iii. Post and m aintain speed limit (15 mph) signs.

iv. Clean up of possible lead containing materials (i.e. baghouse dust) around the cupola and desulfurization baghouse buildings

.
O. Contingency Measures

i. After November 30, 2014, the owner or operator shall increase the frequency of cleaning/sweeping of the
haul roads to twice per day within seven (7) days after notification by the Department that a monitored exceedance of the lead NAAQS occurred. The owne r or operator shall also submit sweeping data to the Department and continue daily cleaning/sweeping until notified by the Department that a different cleaning/sweeping frequency shall be used.

ii. After November 30, 2014, the owner or operator shall implement good housekeeping practices on paved haul road surfaces within seven (7) days after notification by the Department that a monitored exceedance of the lead NAAQS occurred during months in which the inclement weather provision as specified in condition A

5. J.ii applied. The good housekeeping practices shall include but are not limited to daily removal of material piles that have accumulated on haul road surfaces and decreasing vehicle speeds on paved road surfaces from 15 mph to 5 mph. The owner or operato r shall continue good housekeeping practices on paved road surfaces until paved road sweeping resumes.

iii. If a monitored exceedance of the lead NAAQS occurs after the prov isions of Condition A

- 5. O .i or A

- 5

- O.ii
ha ve been implemented for three (3) full calenda r months the owner or operator will submit an emissions evaluation meeting the criteria and timeline specified by the Department.



### A

- 6 . Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, a ll records shall be kept on

- site (in hardcopy or electronic form) for a minimum of two (2) years and shall be available for inspection by the Department . Records shall be legible and maintained in an orderly manner. These records shall show the following:

A. The cumulative tons of metal charged on a rolling

- 12

- month total for each month of operation.

B. Record on a monthly basis, the number of hours that Cupola (EU

- 1) is operated . Calculate and record 3

- month rolling totals.

C. Calculate and record the average pressure drop across the b aghouse (CE

- 10) in inches of water co lumn. The average pressure drop shall be expressed and recorded as the average of all pressure drop data measured during
each 5

- minute period.

D. Calculate and record the average pressure drop across the baghouse (CE

- 11) in inches of water column. The average pressure drop shall be expressed and recorded as the average of all pressure drop data measured during
each 5

- minute period.Grif fin Pipe Products Company 

### Attachment A Page 7 of 7
Council Bluffs , Iowa



### A

- 6. Operating Condition Monitoring and Recordkeeping (continued)

E. Maintain a record of all inspections and maintenance and any action resulting from the inspection and maintenance of Baghouse (CE

- 10).

F. Maintain a record of all inspections and maintenance and any action resulting from the inspection and maintenance of Baghouse (CE

- 11).

G. Retain on

- site a copy of Standard Operating Procedure (SOP) Melt180CB and all records required by the plan
to minimize emissions from Cupola Charge Handling (EU

- 17).

H. R etain on

- site a copy o f the approved Standard Operating Procedure (SOP) Melt220CB and all records required by the plan.

I. The owner or operator shall record the frequency of cleaning/sweeping performed on the haul roads. If the roads are not cleaned due to weather, a written rec ord must be kept on site outlining the conditions.

J. The owner or operator shall record daily the date and time of bulk raw material, waste material and product received or shipped via truck

.
K. The owner or operator shall maintain a log of each silt load samp ling event that contains the following:

i. The date and time that sweeping was conducted;

ii. The date and time of silt load sampling event;

iii. The location of the sample taken;

iv. The measured silt content in grams;

v. Sample area used for silt load sampling in meters; a nd,

vi. The operator’s initials.

L. The owner or operator shall maintain a record of the 3

- month rolling average of each monthly average sampling event in g/m 2 to determine compliance with Condition A

- 5.L.

M. Prior to resuming facility operations the owner or operator shall develop a written plan to implement, at a minimum, the Best Management Practices a s specified in condition A

- 5.N . The written plan and any documentation as required by the plan shall be maintained onsite and available for inspection.

# ATTACHMENT B

Plant Name: Griffin Pipe Products Company

Equipment Location: 2601 9 th 

### Avenue Council Bluffs, Iowa 51501

Plant Number: 78

- 01

- 012

The following emissi on units shall conform to the requi rements specified in condition B

- 1:



### B

- 1. Emission Unit Description

Emission Unit Maximum Rated Capacity Control Equipment

Cupola (EU

- 1) 60 Tons/hr Baghouse (CE

- 10) Desulfurization (EU

- 2) 60 Tons/hr Baghouse (CE

- 11) Bull Ladle (EU

- 3) 60 Tons/hr Magnesium Inoculation (EU

- 4) 60 Tons/hr
Small Diameter Casting (EU

- 6) 6 0 Tons/hr None Desulfurization (EU

- 2)

- Uncaptured 60 Tons/hr Baghouse (CE

- 12 ) Bull Ladle (EU

- 3)

- Uncaptured 60 Tons/hr Magnesium Inoculation (EU

- 4)

- Uncaptured 60 Tons/hr None Large Diameter Casting (EU

- 29) 40 Tons/hr None Cupola Charge Handling (EU

- 17) 60 Tons/hr None Traffic Pathways NA Paved Road SweepingGriffin Pipe Products Company 

### Attachment B Page 2 of 7 Council Bluffs, Iowa



### B

- 2

. Lead (Pb) Emission Limits
The following lead (Pb) emission limits shall not be exceeded:

Source Description EP ID lb/hr 1 tons/yr 2 Additional Limits Justification

Cupola (EU

- 1) EP

- 2A 0. 282 3 NA NA RACT
0.046 4 NA NA See Note 4 Desulfurization (EU

- 2)

EP

- 3 0.02 3 NA NA RACT Bull Ladle (EU

- 3) Magnesium Inoculation (EU

- 4) Magnesium Inoculation

- Uncaptured (EU

- 4) EP

- 7A 0.0075 3 NA NA RACT Ladle Preheat

- Uncaptured (EU

- 19)
Desulfurization

- Secondary Capture (EU

- 2)

EP

- 7B 0.0 025 3 NA NA RACT Bull Ladle

- Secondary Capture (EU

- 3)

S mall D iameter Casting (EU

- 6)
S mall D iameter Casting (EU

- 6) EP

- 6A 0.0043 3 NA NA RACT Building Emissions EP

- 6B 0.0015 3 NA NA RACT

Large Diameter Casting (EU

- 29) EP

- 29 0.0025 3 NA NA RACT EP

- 29A Cupola Charge Handling (EU

- 17) FUG1 0.00143 3 NA NA RACT

Traffic Pathways NA NA 5 6 RACT, 23.3(2)“c”

1 The emission limit is expressed as the average of three (3) runs.

2 The emission limit is a twelve (12) month rolling total.

3 The lead limit is established to address the nonattainment designation for a portion of Pottawattamie County published in the Federal Register (76 FR 72097) on November 22, 2011

. 4 The lead limit is an applicable requirement established in a federally enforceable Consent D ecree entered in United States v. Griffin Pipe Products Co., LLC , (Civil Action No. 1:14

- cv

- 00027

– JAJ

– RAW)

5 The lead limit is established at 0.0 0 4 tons of lead per rolling 3

- month total ; that correlates to a lead silt loading
content of 0.00032 g/m 2 and m aximum potential operation (all raw material/product is shipped or received by truck) . The lead limit is based on 90 % reduction over baseline lead levels and is established to address the nonattainment designation for a portion of Pottawattamie County pub lished in the Federal Register (76 F R 72097) on November 22, 2011.

6 The owner or operator shall take reasonable precautions to prevent the discharge of visible emissions of fugitive dusts beyond lot line of the property.Griffin Pipe Products Company 

### Attachment B Page 3 of 7 Council Bluffs, Iowa



### B

- 3 . Emission Point Characteristics

Th ese emission point s shall conform to the specifications listed below:

EP ID Stack Height, Feet Discharge Style Stack Opening, inches

EP

- 2A 100 Vertical Unobstructed 80 diameter

EP

- 3 100 Vertical Unobstructed 72 diameter

EP

- 7A 49 Vertical Unobstructed 122 diameter

EP

- 7B 100 Vertical Unobstructed 68 diameter

EP

- 6A 49 Vertical Unobstructed 80 diameter

EP

- 6B 49 Vertical Unobstructed 80 diameter

EP

- 29 48 Vertical Unobstructed 72 x 72

EP

- 29A 48 Vertical Unobstructed 72 x 72



### B

- 4

. Lead (Pb) Compliance Demonstration(s)

Emission Point ID Compliance
Demonstration Compliance Methodology Frequency

EP

- 2A Yes Performance Testing Annual 2

EP

- 3 Yes Performance Testing Annual 2

EP

- 7A Yes Performance Testing Annual 2

EP

- 7B Yes Performance Testing Annual 2

EP

- 6A Yes Performance Testing Once Every 3

- years 2

EP

- 6B Yes Performance Testing Once Every 3

- years 2

, 3

EP

- 29 Yes Performance Testing 1 Once Every 3

- years 2

EP

- 29A Yes Performance Testing 1 Once Every 3

- years 2

F UG 1 Yes Work Practice NA Traffic Pathways Yes Silt Load Sampling Monthly 4

1 Performance testing for lead shall be conducted on EP

- 29 and EP

- 29 A simultaneously to demonstrate compliance

with emission l imit as specified in condition B

- 2

. 2 Following a written request by Griffin Pipe Products Company and approval by Iowa DNR, the testing frequency may be decreased following initial or subsequent performance testing.

3 Maximum operating capacity shall be based on the Cupola (EU

- 1) charge rate.

4 Following 12 monthly sampling events, based on a written request by G riffin P ipe P roducts Company and approval by Iowa DNR, the silt loading sampling may be reduced or eliminated.

Performance Testing Requirements

If an initial compliance demonstration specified above is performance testing, the owner or the owner’s authorized agent shall verify compliance with the emission limitations contained in Condition B

- 2 within sixty (60) days after achieving maximum production rate and no later than one hundred eighty (180) days a fter the initial s tart up date of the equipment

.

If subsequent performance testing is specified above, the owner or the owner’s authorized agent shall verify compliance with the emission limitations contained in Condition B

- 2 according to the frequency a nd timeframe
noted above.

If testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the table below unless another testing methodology is approved by the Department prior to testing.

Pollutant Test Run Time Test Method

Pb 1 hour 40 CFR 60, Appendix A, Method 12 or Method 29Griffin Pipe Products Company 

### Attachment B Page 4 of 7 Council Bluffs, Iowa



### B

- 4. Lead (Pb) Compliance Demonstration(s) (continued)

Each performance test must be approved by the Department. Unless otherwise specified by the Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless otherwise indicated by th e Department.

Per 567 IAC 25.1(7) “ a”, at the Department’s request, for each performance test a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol
for eac h performance test shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different , or more detailed testing requirements.

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufact urer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is
the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.

Silt Load Sampling Requirements

For each sampling event, silt loading sampling shall be done for at least 3 different locations. Sampling shall be completed at locations that are representative of normal conditions and shall not be conducted within 4 hours after paved road sweeping has occurred. The three sampled locations shall then be averaged to determine the silt loading
for that month. Silt load testing shall be conducted according to the procedures outlined in AP

- 42, Appendix C.1 Procedures for Sampling Surface/Bulk Dust Loading and C.2 Procedures for Laboratory Analysis of Surface/Bulk Dust Loading Samples.

The owner or operator shal l commence silt load sampling to verify compliance with the haul road operating
limitations contained in Condition B

- 5.M during the first 30

- days the facility resumes operations and subsequent sampling of haul road surface silt loading shall be completed o n a monthly basis.

After 3 consecutive months of haul road surface silt loading sampling and every month thereafter, the owner or operator shall calculate the 3

- month rolling average total silt loading content to determine compliance with the operating li mit included in Condition B

- 5.M. A s an alternative, the owner or operator may analyze the samples for
lead content and calculate the 3

- month rolling average lead silt loading to demonstrate compliance with the pollutant specific operating limit provided i n Condition B

- 5.M.

If the 3

- month rolling average silt loading limit is exceeded, the owner or operator shall immediately double the frequency of sweeping. The increased sweeping frequency shall occur until the lead silt loading results are obtained
and demonstrate compliance with the 3

- month rolling lead silt loading limit provided in Condition B

- 5.M or until such time as additional silt loading samples demonstrate compliance with the 3

- month rolling total silt loa ding limit provided in Condition B

- 5.M. The owner or operator shall maintain records onsite that detail the date the measured silt loading exceeded Condition B

- 5.M, the date in which increased sweeping frequency was enacted and the date that compliance was demonstrated with Condition B

- 5

. M.

The owner or operator shall develop and submit a silt/lead sampling protocol to the Department for approval 30

- days prior to resuming operation. The submitted silt/lead sampling protocol shall detail procedures for sample chain of custody, identification, storage, and lead analysis. The approved silt/lead sampling protocol shall be implemented
and retained onsite.Griffin Pipe Products Company 

### Attachment B Page 5 of 7 Council Bluffs, Iowa



### B

- 5 . Operating Limits
Operating limits shall be:

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

- mo nth period.

B. The pressure drop across the baghouse (CE

- 10) shall be between 3.5 to 10.0 inches of water column based on a
5

- minute average.

C. The pressure drop across the baghouse (CE

- 11) shall be between 3.5 to 10.0 inches of water column based on a
5

- minute average.

D. The pressure drop across the baghouse (CE

- 12 ) shall be between 3.5 to 10.0 inches of water column based on a
5

- minute average.

E. Maintain Baghouse (CE

- 10) according to manufacturer specifications and maintenance schedule.

F. Maintain Baghouse (CE

- 11) according to manufacturer specifications and maintenance schedule.

G. Maintain Baghouse (CE

- 12) according to manufacturer specifications and maintenance schedule.

H. The owner or operator shall implement work practice standards as specified in Standard Operating Procedure (SOP) Melt180CB to minimize emissions from Cupola Charge Handling (EU

- 17).

I. The owner or operator shall implement the scrap management plan as specified in Standard Operating Procedure (SOP) Melt220CB.

J. Limit public access. The o wner or operator shall restrict public access to the facility at all property boundary lines. The restriction does not apply to company employees

, contractors, delivery/shipping personnel , federal, state or local officials, emergency and maintenance service personnel (bot h private and public section), or others who have a legitimate reason f or accessing the prope rty

.
K. Fugitive dust emissions generated from truck traffic on the paved haul roads shall, at a minimum, be controlled by:

i. Sweeping 3 times a week when the haul ro ads are used six (6) days in a week, with a maximum of one day between sweeping events ex cept as noted in Conditions B

- 5

. K (i ii ) through (v i ). All sweeping must be completed using a Tymco DST

- 4 Sweeper or functionally equivalent sweeper type (as approved by the Department).

ii. Sweeping 4 times a week when the haul roads are used seven (7) days in a week ex cept as noted in
Conditions B

- 5

. K ( iii ) through ( vi ). All sweeping must be completed using a Tymco DST

- 4 Sweeper or functionally equivalent sweeper type (as approved by the Department).

iii. Paved road sweeping shall begin within seven (7) days after resuming operations at Griffin Pipe Products Company (Plant No. 78

- 01

- 012)

.
iv. If sweeping cannot be accomplished bec ause the ambient air temperature (as measured at the facility during daylight operating hours) will be less than 35 ° F (1.7 ° C) or conditions due to weather could create hazardous driving conditions, then the sweeping shall be postponed and accomplished as soon after the scheduled date as the conditions preventing the sweeping have abated.

v. Paved road sweeping need not occur when a rain gauge located at the site indicates that at least 0.2 inches of precipitation (water equivalent) has occurred within the pr eceding 24

- hour time period. However, paved road sweeping shall resume within 24

- hours after the precipitation event has ended.

vi. Paved road sweeping need not occur when the facility experiences no production or shipping activities on that calendar day.

L. If sweeping cannot be accomplished for the entire month due to ambient temperatures or hazardous weather, silt load testing is not required for that month.

M. The haul road surface total silt loading or lead silt loading shall not exceed 1.28 g/m 2 or 0.00032 g/m 2

, respectively, based on a 3

- month rolling average

.Griffin Pipe Products Company 

### Attachment B Page 6 of 7 Council Bluffs, Iowa



### B

- 5. Operating Limits (continued)

N. Best Management Practices (BMP)

– The o wner or operator shall implement “good housekeeping” or best management practices to minimize fugitive emissions. Such practices include but are not limited to:

i. Clean up spills of lead containing raw materials on the haul road surface as expeditiously as possible and in a manner consistent with good practice for minimizing emissions.

ii. Clean areas where lead containing materials are processed and where lead containing dust may be generated such as scrap melting areas in a manner consistent with minimizing fugitive lead emis sions.

iii. Post and m aintain speed limit (15 mph) signs.

iv. Clean up of possible lead containing materials (i.e. baghouse dust) around the cupola and desulfurization baghouse buildings

.
O. Contingency Measures

i. After November 30, 2014, the owner or operator shall inc rease the frequency of cleaning/sweeping of the
haul roads to once per day within seven (7) days after notification by the Department that a monitored
exceedance of the lead NAAQS occurred. The owner or operator shall also submit sweeping data to the Depa rtment and continue daily cleaning/sweeping until notified by the Department that a different cleaning/sweeping frequency shall be used.

ii. After November 30, 2014, the owner or operator shall implement good housekeeping practices on paved
haul road surfaces within seven (7) days after notification by the Department that a monitored exceedance of the lead NAAQS occurred during months in which the inclement weather provision as specified in
condition B

- 5.K.iv applied. The good housekeeping practices shall incl ude but are not limited to daily removal of material piles that have accumulated on haul road surfaces and decreasing vehicle speeds on paved road surfaces from 15 mph to 5 mph. The owner or operator shall continue good housekeeping practices on paved roa d surfaces until paved road sweeping resumes.

iii. If a monitored exceedance of the lead NAAQS occurs after the prov isions of Condition B

- 5. O .i or B

- 5

- O.ii
ha ve been implemented for three (3) full calendar months the owner or operator will submit an emissions evaluation meeting the criteria and timeline specified by the Department.



### B

- 6 . Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, a ll records shall be kept on

- site (in hardcopy or electr onic form) for a minimum of two (2) years and shall be available for inspection by the Department . Records shall be legible and maintained in an orderly manner. These records shall show the following:

A. The cumulative tons of metal charged on a rolling

- 12

- month total for each month of operation.

B. Calculate and record the average pressure drop across the baghouse (CE

- 10) in inches of water column. The average pressure drop shall be expressed and recorded as the average of all pressure drop data measured dur ing
each 5

- minute period.

C. Calculate and record the average pressure drop across the baghouse (CE

- 11) in inches of water column. The average pressure drop shall be expressed and recorded as the average of all pressure drop data measured during
each 5

- minut e period.

D. Calculate and record the average pressure drop across the baghouse (CE

- 12 ) in inches of water column. The average pressure drop shall be expressed and recorded as the average of all pressure drop data measured during
each 5

- minute period.

E. Mainta in a record of all inspections and maintenance and any action resulting from the inspection and maintenance of Baghouse (CE

- 10).

F. Maintain a record of all inspections and maintenance and any action resulting from the inspection and maintenance of Baghouse ( CE

- 11).Griffin Pipe Products Company 

### Attachment B Page 7 of 7 Council Bluffs, Iowa



### B

- 6. Operating Condition Monitoring and Recordkeeping (continued)

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

- 12).

H. Retain on

- site a copy of Standard Operating Procedure (SOP) Melt180CB and all records required by the plan to minimize emissions from Cupola Charge Handling (EU

- 17).

I. Retain on

- site a copy of the approved Standard Operating Procedure (SOP) Melt220CB and all records required by the plan.

J. The owner or operator shall record the frequency of cleaning/sweeping performed on the haul roads. If the roads are not cleaned due to weather, a written record must be kept on site outlining the conditions.

K. The owner or operator shall maintain a log of each silt load sampling event that contains the following:

i. The date and time that sweeping was conducted;

ii. The date and time of silt load sampling event;

iii. The location of the sample taken;

iv. The measured silt content in grams;

v. Sample area used for silt load sampling in meters; and,

vi. The operator’s initials.

L. The owner or operator shall maintain a record of the 3

- month rolling average of each monthly average sampling event in g/m 2 to determine compliance with Condition B

- 5.M.

M. Prior to resuming facility operations the owne r or operator shall develop a written plan to implement, at a minimum, the Best Management Practices as specified in condition B

- 5

. N. The written plan and any documentation as required by the plan shall be maintained onsite and available for inspection.

### B

**- 1.**  **Griffin Pipe’s Melt180CB & Melt220CB Standard Operating Procedures**  These documents are referenced by, but not directly appended to, the ACO.

72

# GRIFFIN PIPE PRODUCTS CO.

COUNCIL BLUFFS PLANT
STANDARD OPERATING PROCEDURE

______________________________________________________________________________ Title: Scrap Inspection Instruction #: Melt180CB Page 1 of 4 & Charge Handling
Issue Date: Revision #: 3 Date: 10

- 20

- 2014

1.0 SCOPE

This work instruction describes the steps taken when inspecting scrap for cupola melting and for handling of the cupola charge in such a manner as to min im ize fugitive dust
emissions.

2.0 EQUIPMENT

(1) Proper safety equipment including hardhat, ear and e ye protection and steel

- toed boots with metatarsal guard. (2) Radiation Detector Handheld ( Backup ) (3) Radiation Detector Fixed Mount (4) S

- 101CB Shredded Scrap (Frag)

- Latest Revision (5) S

- 102CB No. 2 Steel Scrap

- Latest Revision (6) Melt180CB

- 1 Scrap Inspection Checklist

- Latest Revision (7) Supplier Incident Report

- F

- 741002 (8) Iowa DNR

- RADIOACTIVE MATERIAL DETECTION
SYSTEMS FOR SCRAP METAL FACILITIES
REGULATORY GUIDE Rev 7/1/05
(9) 0 .25 

## μ Radiation Test puck

3.0 GENERAL REQUIREMENTS FOR SCRAP INSPECTION & CHARGE HANDLING

(1) Caution mu st always be exercised when walking on railcars and entering into the scrap yard. Ensure the crane operators are aware of your intentions to enter the scrap yard. (2) All personnel to inspect loads are required to be trained on all of the requirements
of th is procedure and with the S

- 101CB Shredded and S

- 102CB No. 2 Steel Scrap Specifications (3) Inspection Personnel are required to fill out the Melt180CB

- 1 Scrap Inspection
Checklist. (4) Purchasing issues supplier number s specific to each yard and this will be rec orded

to ensure traceability of materials. Record this number on Melt 180CB

- 1 Scrap Inspection Checklist (5) Crane operators must be aware at all times of other people, vehicles, and equipment that may be present in the scrap yard for short durations (6) Crane op erators will only move scrap metal with a scrap magnet

# GRIFFIN PIPE PRODUCTS CO.

COUNCIL BLUFFS PLANT
STANDARD OPERATING PROCEDURE

______________________________________________________________________________ Title: Scrap Inspection Instruction #: Melt180CB Page 2 of 4 & Charge Handling
Issue Date: Revision #: 3 Date: 10

- 20

- 2014
4.0 INSTRUCTIONS FOR SCRAP INSPECTION OF TRUCKS

(1) All trucks must pass thru the radiation detector located in the shipping area. Max speed is 3mph

. If radiation detector goes off

, contact maintenance to verify the operation of the
detector. Test the detector using 0

. 25 μ test puck. Retest th e truck as needed . Load
can be verified with hand held unit. If radiation is still present reject the entire
load. Do not dump any rejected loads to search for source of radiation

. (2) Visual inspection for non

- conforming products on the load can be done by any trained personnel this is typically done by the crane operator. (3) Crane operator will clean the area for unload ing then authorize the driver to dump
the truckload

. (4) Once dumped on the ground visual inspection for any non

- conforming products is
done

. Once placed continue to ch eck the load by inspecting the material as it is handled by the magnet

. I 

### nspect the ground carefully when cleaning up as this is when nonmagnet ic contamination will be readily visible (5) Notify supervision and purchasing department of non

- conformance following Supplier Incident Reporting

.

5.0 INSTRUCTIONS FOR RAILCAR INSPECTION

(1) All railcars are radiation detected by the as they cross the scale. The t op of all
railcar s are visually inspected for non

- conforming products via cameras located in
the storeroom office

. i. If manual inspection of the railcar is necessary, contact the crane operators and/or engine operators so that they are aware of you intentio n to check
the railcar. Climb the railcar ladder and visually inspect the top surface for

non

- conforming product.
ii. If fixed mount radiation detector is inoperable the handheld unit will be used to scan all the railcars in the lineup (2) Once placed in the lineu p continue to ch eck the railcar by inspecting the material as it is handled by the magnet. Also use the mirror on crane to inspect the car carefully when empty as this is when nonmagnetic contamination will be readily
visible. (3) Notify supervision and pur chasing department of non

- conformance following Supplier Incident Reporting.

6.0 INSTRUCTION FOR SCRAP DOCUMENTATATION

(1) Document time of load, scrap supplier, and trucking company or railcar # and
initial sheet for all loads that are rejected on form Melt180C B

- 1

.

# GRIFFIN PIPE PRODUCTS CO.

COUNCIL BLUFFS PLANT
STANDARD OPERATING PROCEDURE

______________________________________________________________________________ Title: Scrap Inspection Instruction #: Melt180CB Page 3 of 4 & Charge Handling
Issue Date: Revision #: 3 Date: 10

- 20

- 2014
i. A ny loads rejected for mercury, lead, and VOC containing products are documented by rating Zero (0) the Environment section of Melt180CB

- 1.
ii. Notify supervision , purchasing and the environmental department of the

non

- conforming product. (2) Sizing

- This is any material that does not meet requirement of S

- 101 or S

- 102 that are excessively large, heavy, or small and low density. (3) Chemistry

- This is any materials that visually or chemically when melted do not
meet the requirements of S

- 101 or S

- 102 Such as elevat ed Cr, Cu, Sn

- Stainless
materials and brasses etc. (4) Environmental

- These are items that do not meet environmental requirements such as Pb limits, mercury switches, Zinc plated and radiation , excess dirt, debris, fines, etc. (5) W aste

- Th ese are materials that are not to be placed in the cupola and include
excess rust fines and non

- ferrous materials such as wood, plastic , garbage, dirt
and mud etc. (6) Each inspection category should be rated using the following guidelines.
i. (2) N o visible non

- conformance is seen sco re as a two (2)
ii. (1) Minor visible non

- conformance material that can be see and can be removed without hindering operations, score this as one(1)
iii. (0) Excessive visible non

- conformance seen, score this as (0)
iv. Combine these scores to create a total score. An y rejected load will score a total score of Zero (0) even if other areas meet requirements.

v. Chemistry scores may be adjusted down after melting the load results in iron with chemistry above acceptance limits. (7) Notify Supervisor , Purchasing and the Environm ental E ngineer to all Zero Ratings as soon as practical. (8) Forward completed forms to p urchasing will compile ratings of specific yards into a database and create a feedback report to maintain control of incoming materials.
i. Any supplier with a total score of 4

- 5 will be notified of potential rejection and potential disqualification.
ii. Two l oads receiving a zero score in one month period is cause for disqualifications an approved supplier. (9) A Supplier Incident Report (SIR) is to be completed for non

- conforming p roducts. A formal Corrective Action Request (CA R) will be done for major SIR ( i.e. a rejection of a load score of Zero (0)) or a supplier has more than three environmental SIR in a year period. Purchases from that supplier will be limited
until the CAR i s completed to GPP satisfaction.

# GRIFFIN PIPE PRODUCTS CO.

COUNCIL BLUFFS PLANT
STANDARD OPERATING PROCEDURE

______________________________________________________________________________ Title: Scrap Inspection Instruction #: Melt180CB Page 4 of 4 & Charge Handling
Issue Date: Revision #: 3 Date: 10

- 20

- 2014
7.0 INSTRUCTIONS FOR CHARGE HANDLING Fugitive dust emissions associated with charge handling shall be minimized by the following

(1) All scrap metal will be handled with a scrap magnet in order to minimize non

ferrous mater ials and fines in the charge makeup (2) Crane operators will minimize the height from which scrap is dropped when unloading railcars, while loading scrap into the weight hopper and skip hoist, and at other times when scrap is being moved within the scrapyard (3) A s necessary, the scrap truck dump area on the east side of the scrap yard will be cleared using the front

- end loader to push the scrap west onto the main scrap pile. (4) The scrap truck dump area will be periodically cleaned of fines from dirt, dust,
and rust by means of scraping the area with the front

- end loader. Materials collected from this cleanup will be placed in the lime shed for proper disposal. (5) Plant scrap specifications shall limit the amount of fines, dirt, mud and other fine particulate matter in the scrap (6) A four

- sided enclosure shall be maintained around the bottom position of the skip hoist as a means to minimize emissions when scrap is dropped from the weight hopper into the skip hoist

8.0 REVISION LOG



## Date Revision # Description

2/22/2011 1 Tes ting for radiation at shipping. Inspection and reporting non

- compliant product. Wording changes.
04/08/2013 2 Wording change and clarified changes in daily inspection sheet 180CB

- 1
10/20 /2014 3 Updated to cover Change Handling procedures with minor updat ed to
other sections

9.0 REVIEW AND APPROVAL

**Jeff Suing**

______________________________________ 10/21/2014
Production Superintendent Date

**Douglas Brunow**

_________________________________ 10/21/2014 Operations Manager Date

# GRIFFIN PIPE PRODUCTS CO.

COUNCIL BLUFFS PLANT
STANDARD OPERATING PROCEDURE

______________________________________________________________________________ Title: Scrap Management Plan Instruction #: Melt 220 CB Page 1 of 2
Issue Date: October 3, 2012 Revision #: 01 Date: October 30, 2014

1.0 SCOPE

This plan is designed to meet the requirements under 40 CFR 63.10885 Iron and Steel Foundry Area Source NESHAP Subpart ZZZZZ and as outlined in section 14. G. of
Permit 10

- A

- 270

- P . This plan outlines how the plant intends to minimize contaminents, especially lead, in metallic scrap processed by the plant.

2.0 SCRAP SPECIFICATIONS
2.1 All scrap purchased from vendors will conform to scrap specifications S101CB

Shredded Steel Scrap, S102 CB

- No2 Metal Scrap and S103CB

- Plate & Structural Scrap

. 2.2 All vendors w ho supply automotive scrap will be participants in the National
Vehicle Mercury Switch Recovery Program to minimize the presence of mercury in purchased scrap.
2.3 Unrestricted Scrap , to include factory bundles, demolition debris, home scrap, return scrap, rai l, flashings, and similar uncontaminated, non

- motor vehicle scrap, are presumed to be free of contaminants.

3.0 VERIFICATION OF COMPLIANCE
3.1 Scrap crane operators will follow the Scrap Inspection SOP for inspecting and reporting non

- conforming loads.
3.2 Non

- confo rming material such as liquids, non

- ferris metal, and plastics are limited by use of magnetic cranes for sorting prior to charging.
3.3 Griffin will conduct a semiannual review of the End of Life Vehicle Solutions
Database to ensure all vehicle scrap suppliers are active members of the NVMSRP or another EPA approved program, or in the case of a broker, that all vehicle scrap supplied comes from participating members.

4.0 RECORD KEEPING
4.1 Scrap crane operators will record visual inspections of rail cars and trucks on ce per shift on the Scrap Inspection Checklist.
4.2 Completed checklists will be kept for a minimum of five (5) years. 4.3 Records of rejected loads for reasons of non

- conforming content will be kept for a
minimum of five (5) years. Reports for non

- conforming s crap will follow the Scrap Inpsection SOP.

# GRIFFIN PIPE PRODUCTS CO.

COUNCIL BLUFFS PLANT
STANDARD OPERATING PROCEDURE

______________________________________________________________________________ Title: Scrap Management Plan Instruction #: Melt 220 CB Page 2 of 2
Issue Date: October 3, 2012 Revision #: 01 Date: October 30, 2014



## Date Revision # Description

10/30 /2014 01 Review, add Instruction #, S103CB ref, & reissue with new signatures

5.0 REVIEW AND APPROVAL

_____ Douglas Brunow

___________ ____ 10/31/14___

Pr oduction Superintendent Date

______ 

# Jeffrey Suing

____________ ____10/31/14___ Operations Manager Date

## Appendix C. **Alter Metal Recycling Construction Permit**

79[SMC] ¦ CPFP¦7801043¦09022 014¦14126¦14A521 ¦ 

# Iowa Department of Natural Resources Air Quality Construction Permit

Permit Holder

Firm: Alter Metal Recycling

Contact: Responsible Party:

Ryan Carpenter Sarah Schlichtholz Reg. Env. Manager Dir. Environmental Affairs

(314) 346-6795

2603 9 th Avenue Council Bluffs, IA 51501



## Permitted Equipment

Emission Unit(s): Fugitive Dust Emissions from Truck Traffic (EU-Hauling)

Control Equipment: Paved Road Sweeping w/ Water Suppression

Emission Point: EP-1

Equipment Location: 2603 9 th Avenue Council Bluffs, IA 51501

Plant Number: 78-01-043

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state,
and federal law.

Permit No. Proj. No. Description Date Stack Testing

14-A-521 14-126 Original Permit 09/02/14 No

_______________________________________________ Under the Direction of the Director of the Department of Natural ResourcesAlter Metal Recycling Haul Roads (EU-8) Page 2 of 10 Council Bluffs, Iowa 14-A-521 

## PERMIT CONDITIONS

1. Departmental Review

This permit is issued based on information submitted by the applicant. Any misinformation, false statements or misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. In addition, the applicant may be subj ect to criminal penalties according to Iowa Code Section 455B.146A.

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply.

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the potential of that equipment for reducing air contaminant em issions. The Department assumes no liability, directly or indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, installation, maintenance or operation of the proposed equipment.

2. Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point as described in this permit and in the application for this permit. The permit holder, owner, and operator of the facility shall assure that the installation of the equipment listed in this permit conforms to the design in the application (i.e. type, maximum rated capacity, etc.). No pe rson shall construct, install, reconstruct or alter this emission unit(s), control equipment, or emissi on point without the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the provisions of this permit and all other applicable requirements.

The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and control equipment at all times in a manner consistent with good practice for minimizing emissions, as required by paragraph 567 IAC 24.2(1) "Maintenance and Repair”

.



### 3. Transferability

As limited by 567 IAC 22.3(3)”f”, this permit is not transf erable from one location to another or from one piece of equipment to another, unless the equipment is portable. When portable equipment for which a permit has been issued is to be transferred from one location to another, the Department shall be notified in writing at least seven (7) days prior to transferring to the new location unless the equipment will be located in an area which is classified as nonattainment for the National Ambient Air Quality Stan dards (NAAQS) or is a main tenance area for the NAAQS in which case notification shall be given fourteen (14) days prior to the relocation of equipment (1) (See Permit Condition 8.A.2). The owner or operator will be notified at least ten (10) days prior to the scheduled relocation if the relocation will cause a violation of the NAAQS. In su ch case, a supplemental permit shall be required prior to the initiation of construction of additional control equipment or modifications to equipment needed to meet the
standards.

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

4. Construction

A. General Requirements

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as submitted, and that adequate operation and maintenan ce is provided to ensure that no condition of air pollution is created.Alter Metal Recycling Haul Roads (EU-8) Page 3 of 10 Council Bluffs, Iowa 14-A-521 4. Construction (Continued)

In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or operator shall seek a permit amendment in order to reve rt back to the most recen t previous version of the permit. The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs: (1) the construction or implementation of the proposed project, as it affects the emission point permitted herein, is not initiated within eighteen (18) months after the permit issuance date; or (2) the construction or implementation of the proposed project, as it affects the emission point permitted herein, is not completed within thirty-six (36) months after the permit issuance date; or (3) the construction or implementation of the proposed project, as it affects the emission point permitted herein, is not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications

The owner or operator shall amend this permit or amendment prior to startup of the equipment if: (1) Any changes are made to the final plans and specifications submitted for the proposed project; or (2) This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted equipment and control equipment and the specified operation thereof.

C. Amended Permits

The owner or operator may continue to act under the provisions of the previous permit for the affected emission unit(s) and emission point, together with any previous amendment to the permit, until one of the following conditions occurs: (1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and emission point permitted herein; or (2) This current amendment becomes void.

5. Credible Evidence

As stated in 567 IAC 21.5 and also in 40 CFR Part §60.1 1(g), where applicable, any credible evidence may be used for the purpose of establishing whether a person has violated or is in violation of any provisions specified in this permit or any provisions of 567 IAC Chapters 20 through 35.

6. Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation of the emission standard if it is accomplis hed expeditiously and in a manner consistent with good practice for minimizing emissions except when another regulation applicable to the unit or process provides otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be limited to one (1) six-minute period per one (1) hour period.

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within a reasonable period of time, as specified in 567 IAC 24.1.

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate field office within eight (8) hours of, or at the start of, th e first working day following the onset of the incident (See Permit Condition 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2).Alter Metal Recycling Haul Roads (EU-8) Page 4 of 10 Council Bluffs, Iowa 14-A-521

7. Permit Violations

Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and two (2) years in jail according to Iowa Code Section 455B.146A.

8. Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Department the following written notifications: (1) Per 567 IAC 22.3(3)”b”: (a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days following initiation of construction, installation, or alteration; (b) The actual date of startup, postmarked within fift een (15) days following the start of operation; (2) Per 567 IAC 22.3(3)”f”, when portable equipment for which a permit has been issued is to be
transferred from one location to anothe r, the Department shall be notified: (a) at least fourteen (14) days before equipment relocation if the equipment will be located in a nonattainment area for the National Ambient Air Quality Standards (NAAQS) or a maintenance area for the NAAQS; (b) at least seven (7) days before equipment relocation. (3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership within thirty (30) days of the occurrence. The notification shall be mailed to:

Air Quality Bureau Iowa Department of Natural Resources 7900 Hickman Road, Suite 1 Windsor Heights, IA 50324

and include the follo wing information:

 The date of ownership change,

 The name, address, and telephone number of the responsible offici al, the contact person, and the owner of the equipment both before and after the ownership change; and

 The construction permit number(s) of the equipment changing ownership. (4) Unless specified per a federal regulation, notifi cation of each compliance test required by Permit Condition 12 shall be done not less than thirty (30) days before the required test or performance evaluation of a continuous emission monitor [567 IAC 25.1(7)]. The notification shall include:

 the time,

 the place,

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

 and other information as required by the Department; If the owner or operator does not provide timely notice to the Department, the Department shall not consider the test results or performance evaluation results to be a valid demonstration of compliance with the applicable rules or permit conditions. Upon written request, the Department may allow a notification period of less than thirty (30) days.

B. The owner or operator shall furnish the Department with the following reports: (1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported within eight (8) hours or at the start of the first working day following the onset of the incident. The report may be made by electronic mail, in person or by telephone. (2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2 shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days of the onset of the upset condition. (3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified
in Permit Condition 14 in accordance to the schedule set forth in 567 IAC 24.1. (4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring system or systems shall provide quar terly reports to the Director, no late r than thirty (30) calendar days following the end of the calendar quarter, on forms provided by the Director.Alter Metal Recycling Haul Roads (EU-8) Page 5 of 10 Council Bluffs, Iowa 14-A-521 8. Notification, Reporting, and Recordkeeping (Continued)

(5) Per 567 IAC 25.1(7), a written compliance demonstr ation report for each compliance testing event, whether successful or not, postmarked not later than six (6) weeks after the completion of the test period unless other regulations provide for other notification requirements. In that case, the more stringent reporting requirement shall be met;

C. All data, records, reports, documentation, construction plans, and calculations required under this permit shall be available at the plant during normal business hours for inspection and copying by federal, state, or local air pollution regulatory agencies and their authorized represen tatives, for a minimum of two (2) years from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

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

Construction Permit Supervisor Air Quality Bureau Iowa Department of Natural Resources 7900 Hickman Road, Suite 1 Windsor Heights, IA 50324 Telephone: (515) 725-9549 Fax: (515) 725-9501

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

Stack Testing Coordinator Air Quality Bureau Iowa Department of Natural Resources 7900 Hickman Road, Suite 1 Windsor Heights, IA 50324 Telephone: (515) 725-9545 Fax: (515) 725-9502

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

Compliance Unit Supervisor Air Quality Bureau Iowa Department of Natural Resources 7900 Hickman Road, Suite 1 Windsor Heights, IA 50324 Telephone: (515) 725-9550 Fax: (515) 725-9502 IDNR Field Office 4 1401 Sunnyside Lane Atlantic, IA 50022 Telephone: (712) 243-1934 Fax: (712) 243-6251

9. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. In permit amendments, all provisions of th e original permit remain in full force and effect unless they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in the amendment for your conveni ence only and are unappealable.

Per 561 IAC 7.4(1), the owner or operator shall file any written notice of appeal within thirty (30) days of receipt of the issued permit. The written notice of appeal shall be file d with the Director of the Department with a copy to the Legal Services Bureau Chief at the following addresses:

Director Iowa Department of Natural Resources
502 East 9 th Street Des Moines, IA 50319 Bureau Chief Legal Services Bureau Iowa Department of Natural Resources
502 East 9 th Street Des Moines, IA 50319Alter Metal Recycling Haul Roads (EU-8) Page 6 of 10 Council Bluffs, Iowa 14-A-521



### 10. Emission Limits

The following emission limits shall not be exceeded:

Pollutant lb/hr (1) tons/yr (2) Additional Limits Reference (567 IAC) Particulate Matter (PM) – Federal NA NA NA NA Particulate Matter (PM) – State NA NA NA NA

PM 10 NA NA NA NA

PM 2.5 NA NA NA NA Opacity NA NA (3) 23.3(2)”c” Sulfur Dioxide (SO 2 ) NA NA NA NA Nitrogen Oxides (NO

x ) NA NA NA NA Volatile Organic Compounds (VOC) NA NA NA NA Carbon Monoxide (CO) NA NA NA NA Lead (Pb) NA NA (4) NAAQS, RACT Carbon Dioxide equivalents (CO 2 e) NA NA NA NA Single HAP NA NA NA NA
Total HAP NA NA NA NA

(1) The emission limit is expressed as the average of three (3) runs.
(2) The emission limit is a twelve (12) month rolling total.
(3) The owner/operator shall take reasonable pr ecautions to prevent the discharge of visible emissions of fugitive dusts beyond lot line of the property.
(4) The lead limit is established at 0.01 tons of lead per rolling 3-month average; that correlates to a lead silt content of 0.002 81 g/m 2 and maximum potential operation (all raw material/product is shipped or received by truck). The lead limit is based on 95%
reduction over baseline lead levels and is established to address the nonattainment de signation for a portion of Pottawattamie County published in the Federal Register (76 FR 72097) on November 22, 2011. The compliance de monstration with this lead limit is based on maximum silt content, operating restrictions a nd work practice standards as specified in Conditions 14 and 15

. Total silt load content of 2.7 g/m 2 has been established as a surrogate for total lead silt content.

11. Emission Point Characteristics

This emission point shall conform to the specifications listed below:

Parameter Value Stack Height, (ft, from the ground) NA Discharge Style NA Stack Opening, (inches, diameter) NA Exhaust Temperature (  F) NA Exhaust Flowrate (scfm) NA

The temperature and flowrate are intended to be represen tative and characteristic of the design of the permitted emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process
and ambient conditions. If it is determined that either the temperature or flowrate above are different than the values stated, the owner or operator shall subm it a request to the Department within thirty (30) days of the discovery to determine if a permit amendment is required or submit a permit application requesting to amend the permit.Alter Metal Recycling Haul Roads (EU-8) Page 7 of 10 Council Bluffs, Iowa 14-A-521

12. Compliance Demonstration(s)

Pollutant Compliance Demonstration Compliance Methodology Frequency

PM – Federal No NA NA PM – State Yes Silt Load Sampling Monthly Basis

PM 10 No NA NA

PM 2.5 No NA NA Opacity No NA NA
SO 2 No NA NA
NO
x No NA NA
VOC No NA NA
CO No NA NA
Pb No NA NA
CO 2 No NA NA
CH 4 No NA NA
N 2 O No NA NA
CO 2 e No NA NA Single HAP No NA NA
Total HAP No NA NA

If an initial compliance demonstr ation specified above is testing , the owner or the owner’s authorized agent shall verify compliance with the emission limitations contained in Permit Condition 10 within 90 days after issuance of this air construction permit unless otherwise specified.

If subsequent testing is specified above , the owner or the owner’s authorized agent shall verify compliance with
the emission limitations contai ned in Permit Condition 10 according to th e frequency and timeframe noted above. The Department shall reserve the right to impose additio nal, different, or more detailed testing requirements.

13. New Source Performance Standards (NSPS) and National Emission Standards for Hazard ous Air Pollutants (NESHAP) Applicability

The emission unit is not subject to any of th e New Source Performance Standards (NSPS).

This project is not subject to any National Emission Standards for Hazardous Air Pollutants Area Source Standards.

Failure to include any NSPS or NESHAP requirements as a part of this permit does not relieve the permittee from the requirement to comply with all ap plicable NSPS or NESHAP requirements.

14. Operating Limits

Operating limits for this emission unit shall be:

A. All haul roads at the facility shall be paved. The facility shall complete the paving of haul road segments 7, 14, 15, and 16 by October 31, 2015.

B. The facility shall stop using haul road segment 17 by October 31, 2015.

C. Fugitive dust emissions generated from truck traffic on the paved haul roads shall, at a minimum, be controlled by:

 Sweeping, at a minimum, 3 times per week when the ha ul roads are used six (6) days in a week, with a maximum of one operating day (i.e., Sunday and holidays would not be considered operating days since there is no movement of material) between sweeping events except as noted in Conditions 14C (i) through (iii). All sweeping must be completed using a Tymc o DST-6 Sweeper or functionally equivalent sweeper type (as approved by the Department).

i. Paved road sweeping shall begin within seven (7) days of the permit issuance date.Alter Metal Recycling Haul Roads (EU-8) Page 8 of 10 Council Bluffs, Iowa 14-A-521 14. Operating Limits (Continued)

ii. If sweeping cannot be accomplished because the ambi ent air temperature (as measured at the facility during daylight operating hours) will be less than 35 o F (1.7 o C) or conditions due to weather could create hazardous driving conditions, then the sweeping shall be postponed and accomplishe d as soon after the scheduled date as the conditions preventing the sweeping have abated.

iii. Paved road sweeping need not occur when a rain gauge located at the site indicates that at least 0.2 inches of precipitation (water equivalent) has o ccurred within the preceding 24-hour time period. However, paved road sweeping shall resume within 24-hours after the precipitation event has ended.

iv. Paved road sweeping need not occur when the facility experiences no haul road traffic on that calendar day (i.e., the facility would not count this day to wards the maximum of one day between sweeping).

v. The facility may request reduced sampling frequency sh ould 12 consecutive tests show compliance with the silt load limit. The facility shall submit the test results to the Department with the permit modification request to reduce sampling frequency.

D. If sweeping cannot be accomplished for the entire month due to ambient temperatures or hazardous weather, silt load testing is not required for that month.

E. The haul road surface silt load ing shall not exceed 2.70 g/m 2

.
F. Traffic on the haul roads shall not exceed 20 mph. The speed limit shall be posted on all haul roads.

G. The facility is limited to shipping (inbound and outbound) material between the hours of 5am to 8 pm, Monday through Friday and 8 am to 12 pm on Saturday.

H. The facility is limited to processing/shipping (inbound and outbound) no more than 946,000 tons of material per rolling 12-month period.

I. Internal transfers at the facility ar e limited to Monday through Friday.

J. Best Management Practices (BMP) – Clean up spills, truc k scale areas, etc. Alter Metal shall implement “good housekeeping” or best management practices to minimize fugitive emissions. Such practices include but are not
limited to:

i. Clean up spills of raw materials or product on the haul road surface as expeditiously as possible and in a manner consistent with good practice for minimizing emissions.

ii. Clean on weekly basis, around truck scale areas and process buildings.

iii. Maintain and post speed limit signs.

K. Limit public access. Starting on either July 31, 2014, or by no later than 30 days after the date of permit issuance, whichever comes later, Alter Metal shall restri ct public access to the facility by posting signs warning of restricted access to the facility at all property boundar y lines not secured with fencing. During those days the facility is operating, in-person surveillance of the boundar y shared with the rail line shall be conducted by Alter Metal staff periodically throughout the day, including documentation as to surveillance times and locations. In lieu of in-person surveillance the facility may maintain and operate equipment adequate to ensure surveillance of the boundary shared with the rail line during plant operations.

The restriction does not apply to Alter Metal employees, employees, owner or lessees of contiguous properties, federal, state or local officials, emergency and maintenance service personnel (both private and public section), who have a legitimate reason or need for accessing the rail spur.

L. Contingency Measures

i. After November 30, 2014, the facility shall increase th e frequency of cleaning/sweeping of the haul roads to daily within seven (7) days af ter notification by the Department that a monitored exceedance of the lead NAAQS occurred. The facility shall submit sweeping data to the Department and continue daily cleaning/sweeping until notified by the Department th at a different cleaning/sweeping frequency shall be
used.

ii. If a monitored exceedance of the lead NAAQS occurs after the provisions of Permit Condition 14.L.i. have been implemented for three (3) full calendar months, Alter Metal will submit an emissions evaluation meeting the criteria and tim eline specified by the Department.Alter Metal Recycling Haul Roads (EU-8) Page 9 of 10 Council Bluffs, Iowa 14-A-521

15. Operating Condition Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. These records shall show the following:

A. The facility shall record the frequenc y of cleaning/sweeping performed on the haul roads. If the roads are not cleaned due to weather, a written record must be kept on site outlining the conditions.

B. The facility shall record daily the date and time of mate rial processed at the facility (i.e., record inbound and outbound shipments of process material).

C. The facility shall calculate on a monthly basis the amount of material proce ssed/shipped (inbound and outbound) and calculate the rolling 12-month total amount of material processed (in tons).

D. Performance testing on the haul road surface silt load ing shall be completed on a monthly basis. For each performance test, silt loading sampling shall be done for at least 3 different locations. The three sampled locations shall then be averaged to determine the silt loading average results. Performance testing shall be completed prior to paved road sweeping. Silt load te sting shall be conducted according to the procedures outlined in AP-42, Appendix C.1 Procedures for Sampling Surface/Bulk Dust Loading.

E. The owner or operator shall mainta in a log of each silt load sampling event that contains the following:

i. The date of silt load sampling event;

ii. The location of the sample taken;

iii. The measured silt content in grams;

iv. Sample area used for silt load sampling in meters; and,

v. The operator’s initials.

F. Record the date paving of haul road segments 7, 14, 15, and 16 was completed.

G. Record the date the closure of ha ul road segment 17 was finalized.

H. The facility shall maintain records of BMP activities completed under Condition 14J.

I. Record the date control measures restricting public access to the facility (posting signs, performing in-person surveillance and/or installing electronic surveillance, insta lling fences, etc.) is initiated. Record the date, with documentation, for all subsequent surveillance times and locations.

16. Continuous Emission Monitoring

This permit does not require continuous emission monitoring.



### 17. Permit History

Permit No. Proj. No. Description Date Stack TestingAlter Metal Recycling Haul Roads (EU-8) Page 10 of 10 Council Bluffs, Iowa 14-A-521



### 18. Description of Terms and Acronyms

The descriptions below are meant only as a brief explanation of terms contained within the permit and may not be the exact definition of the term or acronym as contained within the regulations.

acfm Actual cubic feet per minute Applicant The owner, company official or authorized agent
Btu British thermal unit

 C Degrees Celsius
Condensable PM Material that condenses and/or reacts upon cooling and dilution in the ambient air to form particulate matter immediately after discharge from the stack
CO 2 e Carbon dioxide equivalent which is the aggregate emissions of greenhouse gas (GHG) emissions based on global warming potentials Department Iowa Department of Natural Resources
dia. Diameter

 F Degrees Fahrenheit
ft Foot GHG Greenhouse Gas which is defined as being the group of carbon dioxide (CO 2 ), methane (CH 4 ), nitrous oxide (N 2 O), hydrofluorocarbons (HFC), perfluorocarbons (PFC) and sulfur hexafluoride (SF 6 )

g grams g/dscm Grams per dry standard cubic meter gr Grains gr/dscf Grains per dry standard cubic foot gr/scf Grains per standard cubic foot HAP Hazardous Air Pollutant(s) hp horsepower
hr Hour
lb Pound lb/hr Pounds per hour
m Meter mg Milligram
MM Million MW Megawatt NA Not Applicable
PM 2.5 Particulate Matter with an aerodynamic diameter equal to or less than 2.5 microns
PM 10 Particulate Matter with an aerodynamic diameter equal to or less than 10 microns
PM – Federal Particulate Matter that does not include the condensable PM
PM – State Particulate Matter that includes condensable PM ppm parts per million

ppm v parts per million by volume

ppm w parts per million by weight RACT Reasonably Available Control Technology scfm Standard cubic feet per minute SHAP Single hazardous air pollutant THAP Total hazardous air pollutants tons/yr Tons per year yr Year



## END OF PERMIT

## Appendix D. **Facility Changes at Alter Metal Recycling** 

In 2013 Alter Metal Recycling began construction on a project to allow the facility to recover non

- ferrous
materials from shredder fluff previously landfilled or otherwise disposed as waste. This modification is
referred to as the addition of the “ZC Plant.” According to documentation provided by Alter Metal Recycling, the emissions units a t the ZC Plant are described as a collection of conveyors and nonferrous scrap metal recovery equipment located inside the ZC Plant building, and loading, classification, and feed equipment located outdoors.

Construction of the ZC Plant affects the lead nonattainment SIP because it add s , removes, and modifies the haul road locations, affects road segment and route lengths, and changes the traffic data

. While not all road segments are affected by the addition of the ZC Plant t he resultant road segment layouts and traffic patterns are disti nctly different from the baseline. The attainment demonstration, control strategy, and construction permit s issued to Alter Metal Recycling account for a ll roadway modifications
associated with the ZC Plant addition.

The origina l (baseyear) haul road segment layout is depicted in Figure D

- 1 and the new haul road segment layout (used in the control strategy modeling) is depicted in Figure D

- 2

. Road segments not affected (in terms of the physical properties su ch as location, length or width) 20 by the addition of the ZC
Plant are depicted in Figure D

- 3 . For historical reference, the original ( base year) configuration of all the segments modified or removed with the addition of the ZC plant i s shown in Figure D

- 4 ; t he ir new

con figuration under the ZC Plant layout is displayed in Figure D

- 5

. A description of the segment changes and updated segments lengths are provided in Table D

- 1

.

Although the total length of all road segments associated with the ZC Plant (2,185 m; see Table D

- 1 ) is greater than the baseline (1,969 m; see Table A

- 7 ), total road segment length does not directly corr elate

to emissions. Changes in f acility traffic characteristic, such as traffic patterns, traffic volumes, and
resultant vehicle miles travelled are more important factors. Several high

- traffic routes have been
shortened due the addition of segment 18 (s ee Figure D

- 5 ) which is typically used in lieu of baseline segments 4, 5, and 6 (see Figure D

- 4 )

.

While three new routes (Routes 5, 6, and 7) 21 have been added, this again doesn’t necessarily increase

emissions. For example, a large amount of traffic on a short route can generate more emissions than a small amount of traffic over a longer path

. Additionally, all roads must be paved or their use
discontinued. No t only are the roadway types, traffic patterns

, and resultant vehicles miles travelled important, the most significant consideration is the reduction in the amount of suspendable lead on the roadways. In summary, t he measures required by the control strat egy equate to a 95% reduction in
baseline lead emissions from Alter Metal Recycling

.

20 VMT a nd traffic data for all road segments differ versus the baseline. Due to complexity the VMT and traffic data are not readily reproducible in a useable format in this document.

21 For informational purposes, the seven routes used by Alter Metal Recycling ar e explained in terms of road segments in Table D

- 2 . Routes 1 through 4 are similar to the baseline, however, use of segment 17(u) will be eliminated and all unpaved surfaces must be paved. Three new routes have been added to accommodate activities associated with the ZC Plant. The route paths are depicted in Figure D

- 6

.

90

### D

**- 1.**  **ZC Plant Lead Emissions**  Negligible lead emissions increases are anticipated with the operation of the ZC Plant. Alter Metal Recycling calculated the potential lead em issions from the ZC Plant at 14 lbs/yr. 22 This value is less than 1% (0.97%) of the total baseline lead emissions. The control strategy is expected to re duce lead

emission at Alter Metal Recycling by approximately 95% . Lead emissions from the ZC Plant ar e not expected to delay or interfere with the attainment of the lead NAAQS. An investigation of lead
emissions from the ZC Plant may occur in the unlikely event that contingency measures are triggered.

22 Provided by Alter Metal Recycling in the small unit exemption (SUE) documentation. The applicable SUE rules were those in 567 IAC 22.1(2) in effect prior to revisions published in the Iowa Administrative Bulletin on September 18, 20 13

.

91Figure D

- 1 . Depiction of all facility road segments as they existed in the 2010 baselin e. (Google Earth’s Imagery Date of 3/7/2012.) Unpaved routes are depicted with a “(u)” and segment 14(*) was originally paved but treated as an unpaved road in the baseline due to surface deterioration.

92Figure D

- 2 . Depiction of facility road segments expected after completion of the ZC Plant. (Google Earth’s Imagery Date of 9/21/2013.)

. The control strategy requires all segments be paved , or their use discontinued, by October 31, 2015.

93Figure D

- 3 . Road segments whose dimensions and locations are not affected by the addition of the ZC
Plant ( they are the same as in the baseyear)

. (Google Earth’s Imagery Date of 9/21/2013.) (Note, segment 14(*) is treated as an unpaved road in the baseline and as a paved road in the control strategy.)

94Figure D

- 4 . Baseline road segments who se lengths or locations are modified or removed with the
addition of the ZC Plant ( this image is shown for historical/information al purposes)

.

95Figure D

- 5

. Depiction of the modified and new r oad segments associated with the ZC Plant. (Google Earth’s Imagery Date of 9/21/2013.)

96Table D

- 1 . Road segments and lengths at Alter Metal Re cycling in the control strategy /attainment demonstration (the ZC Plant configuration) and a description of changes in the road segments between
the original (baseyear) layout and the ZC Plant layout

.Segment IDLength (m) Notes black text =no changes
blue text = modified segments; purple text = modified segments to be paved; green text = new segments due to ZC plant

1 100 Same layout as baseline

2 160 Same layout as baseline

3 61 Same layout as baseline
4' 203 ZC segments 4 and 4' (combined) are 10 m shorter than baseline segment 4 (because ZC segment 7' was shifted east about 10 m compared to baseline segment 7) 4 135

5 22 Same length as baseline, just shifted east 10 m compared to baseline segment 5

6 20 Same length as baseline, just shifted east 10 m compared to baseline segment 6
7' 55 Shifted east 10 m compared to baseline segment 7

8 143 Extended east 10 m to correspond w/ shift of segment 7'

9 32 Same layout as baseline

10 293 Same layout as baseline

11 88 Same layout as baseline

12 76 Same layout as baseline

13 92 Same layout as baseline

14 60 Same layout as baseline

15 138 Extended east 10 m to correspond w/ shift of Segment 7'

16 39 Shifted east and shortened to align with the intersection of new segment 20'_22

17 28 An extension of segment 16 to provide access to west end of ferrous yard +

18 134 New paved segment associated w/ ZC plant

19 60 New paved segment associated w/ ZC plant

21 115 New paved segment associated w/ ZC plant 20'_22 131 New paved segment associated w/ ZC plant

SUM 2,185

+ Otherwise not associated with baseline segments 17(u) (which is scheduled for elimination)

Table D

- 2

. Route paths and total lengths used in the control strategy for Alter Metal Recycling

. Routes generally reflect a round trip path through the facility and are defin ed by the segments traversed.

Route

ID Route Definition ( By Segment ID ) Total Route Length (m)

1 1

– 3

– 4'

– 18

– 8

– 9

– 10

– 11

– 11

– 12

– 9

– 8

– 18

– 4'

– 3

– 1 1,891

2 1

– 3

– 4'

– 18

– 8

– 9

– 12

– 13

– 14

– 8

– 18

– 4'

– 3

– 1 1,542

3 1

– 2

– 4'

– 18

– 7'

– 16

– 17

– 17

– 16

– 7'

– 18

– 4'

– 2

– 1 1,438

4 1

– 3

– 4'

– 18

– 8

– 14

– 15

– 16

– 17

– 17

– 16

– 15

– 14

– 8

– 18

– 4'

– 3

– 1 1,812

5 13

– 14

– 8

– 7'

– 16

– 20'_22

– 21

– 8

– 9

– 12 886

6 1

– 2

– 4'

– 19

– 21

– 6

– 5

– 4

– 4'

– 2

– 1 1,278

7 1

– 2

– 4'

– 19

– 20'_22

– 16

– 7'

– 18

– 4'

– 2

– 1 1,345

97Figure D

- 6 . A simple approx imation of the
location of the seven routes at Alter Metal Recycling that will be in use after the addition of
the ZC Plant . Route 1 is located in the top left image, Route 2 is the top right image, with route 3 is the left image on the next line down, and so
for th.

98

## Appendix E. **Proof of Publication**

**E**

**- 1.**  **Alter Metal Recycling Draft C**  **onstruction Permit**

99100

### E

**- 2.**  **Proo f of Publication of the**  **SIP’s Public N**  **otice in** The Daily Nonpareil

**.**

101102