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 National Ambient Air Quality Standards (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 standards, lowering the 

acceptable ambient lead levels by an order of magnitude, to 0.15 μg/m3

, 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 Department of 

Natural Resources (DNR) started operating a new lead monitor in Council Bluffs in November 2009. This 

monitor recorded ambient lead concentrations in 2010 that did not meet 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 plan 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 assessment 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 nonattainment 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 are located next to 

one another near the lead monitor.

The control measures require lead emissions reductions from both facilities. Although operations at 

Griffin Pipe are temporarily suspended the facility must implement one of two available control 

strategies when operations resume. Both strategies require haul road sweeping and include new 

emissions limits on existing lead sources. One option adds limits on the hours of operations while the 

second option requires the installation of a new baghouse to control existing sources. The control 

measures for Alter Metal Recycling require 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 are federally enforceable and have reduced 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 lead NAAQS violations 

are anticipated. Attainment 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 Grids ............................................................................................................................ 27

6.3. Terrain Elevations ....................................................................................................................... 27

6.4. Building Downwash..................................................................................................................... 27

6.5. Meteorological Data ................................................................................................................... 27

6.6. Background Value ....................................................................................................................... 27

3
6.7. 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 Recycling........................................................................... 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. The federal 

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 National 

Ambient Air Quality Standards (NAAQS). The lead NAAQS must be achieved as quickly as possible and 

no later than 5 years after the effective date of the designation. The nonattainment designation for an

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 Natural 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 NAAQS 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-made materials, animals, wildlife, and visibility). The primary and secondary 

NAAQS for lead are identical. The CAA requires EPA to review the NAAQS every five years and, if 

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

The EPA first established health standards for lead on October 5, 1978 (43 FR 46246). At that time the 

lead NAAQS were set at a level of 1.5 micrograms per cubic meter of air (μg/m3

), 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/m3 to 0.15 μg/m3

. 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 μg/m3 across a consecutive three-year period. The 

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/m3 Not to be exceeded

1.2. Lead Nonattainment Designation

Following a NAAQS revision, Section 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 area. On November 3, 2009, a required 

source-oriented lead monitor began operation in Council Bluffs, Iowa. In the following year (2010), 6 

three-month rolling averages greater than 0.15 μg/m3 Pb NAAQS were measured. The highest value, 

0.26 μg/m3

, occurred in the June-August 2010 average. The EPA designated a portion of Pottawattamie 

County as a nonattainment area in response to the measured lead concentrations. 

5
At approximately 950 square miles, Pottawattamie County is the second largest county in Iowa by 

geographical area, the 8th largest by population with 93,518 inhabitants1

, and is part of the Omaha 

(Nebraska)-Council Bluffs (Iowa) metropolitan statistical area. The statewide 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 Code of Federal Regulations (CFR) at 40 CFR 81.316 as 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 boundaries used to define the lead nonattainment area.

Northern boundary Avenue G

Eastern boundary N 16th / S 16th Street

Southern boundary 23rd Avenue

Western boundary N 35th / S 35th Street

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 sources, Griffin 

Pipe Products Co., LLC (Griffin Pipe) and Alter Metal Recycling, which are all near the intersections of 9th

Ave and S 27th 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

6

 
Figure 1-2. Depiction (in green) of the lead nonattainment area within the 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 western edge of Pottawattamie County, along the Missouri River. The 

topography of Pottawattamie County 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 extent 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

7

 
Figure 1-3. Topographic features within the vicinity of the nonattainment area.

The topography within the nonattainment area is comparable to flat river bottoms, displays negligible 

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.

Griffin Pipe is located just south of the 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 the approximate property boundaries of Griffin Pipe and Alter Metal 

Recycling, relative to the lead monitor (boundary data obtained from: http://gis.pottcounty.com). 

8
Figure 1-4. Approximate property boundaries 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 source oriented

monitors located to measure the maximum lead concentrations near sources with lead emissions of 1.0 

tons3 per year or more. Source-oriented monitors not eligible for an exemption based on dispersion 

modeling were required to be operational by January 1, 2010. The monitoring criteria resulted in one 

new 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 8th Ave and S 27th St in Council Bluffs. The monitor started operation on November 3, 

2009, measuring lead concentrations in total suspended particulate (TSP) and reporting concentrations 

in local conditions. 

Although a lead design value is based on three years of three-month rolling averages, a single threemonth average over the standard constitutes a NAAQS violation because the 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/m3

. 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 tons per year (75 FR 81126, December 27, 2010).

9

 
The Council Bluffs lead monitor 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/m3 (see Table 1-3). The latest available certified lead data includes 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.

Table 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 monthrolling 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

Aug 0.26 Aug 0.12 Aug 0.18 Aug 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

Two lead sources were identified within the nonattainment area, Griffin Pipe Products Co., LLC, and 

Alter Metal Recycling. Griffin Pipe is considered a major source for Title V and Prevention of Significant 

Deterioration (PSD) purposes. Alter Metal Recycling is a minor source. 

Griffin Pipe

Griffin Pipe manufactures ductile iron pressure pipe for potable 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 Council Bluffs covers 

more than 105,000 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 cupola 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 magnesium 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 metals 

are melted in the cupola, treated in the desulfurization and magnesium inoculation processes, and cast. 

On February 4, 2014, U.S. Pipe and Foundry Company announced the acquisition of a majority interest 

in Griffin Pipe. On March 3, 2014, the facility ceased operating the cupola (melting operations were 

suspended) with finishing operations 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 founded 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 facility 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 Requirements

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 for attainment and the timely implementation of all Reasonably Available 

Control Measures (RACM) & Reasonably Available Control Technologies (RACT).

CAA §172(c)(2) Reasonable further progress (RFP) requirements (met by appropriate emission 

reductions 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 provisions 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 measures necessary for the timely

attainment 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 important sources. The various control measures (which incorporate RACT/RACM) 

included in the control strategy consider implementation timeframes to ensure reasonable further 

progress (RFP) requirements are met and to ensure the NAAQS are attained as 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 demonstration 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 of enforcement methods, including procedures for monitoring compliance and 

handling violations. Additional information regarding control strategy related requirements can be 

found in 40 CFR 51 Subpart G.

The state 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 administrative requirements in 40 CFR 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 component 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 emissions 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 progress 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, two facilities within the nonattainment area emitted more 

than one pound of lead per year, Griffin Pipe and Alter Metal Recycling.8

 Baseyear 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. Actual 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/yr)

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

Uncaptured Magnesium 0.2570 514

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 2,076

Alter Metal 

Recycling (AMS)

[78-01-043]

Fugitive Haul Roads n/a 0.7182 1,436

+ For 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 emissions due to trace quantities of lead present in the fuel.

13

 
3.1. Griffin Pipe

Point source lead 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. As the

materials are heated, melted, and move through the casting process, lead content present in the scrap is 

released and vented through stacks and roof vents. The baseyear lead emissions from Griffin Pipe’s 

point sources were determined using information reviewed or calculated by the DNR. Data sources 

included stack test results, throughput information, or other facility-specific data. EPA’s online 

compilation of air pollution (AP) emissions factors in AP-42 (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 roads 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 materials used as the facility, 

such as in cement applied to the cast pipe and the natural gas used to fire the annealing furnaces, these 

trace quantities are negligible and were not considered in the development of control measures.

3.2. Alter Metal Recycling

Alter 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 source 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 

The 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 roads. In reality, roadway fugitive dust 

suppression activities in use in 2010 at Griffin Pipe or Alter Metal Recycling would reduce haul road lead 

emissions. The effects of this caveat are not readily quantifiable and it is possible the 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

 Onroad mobile sources are no longer 

associated with lead emissions. The latest tool for estimating emissions from onroad sources, the 

MOtor Vehicle Emissions 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 calculates 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, 2013) 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 sources 

have been screened from further review.

14

 
No commercial marine vehicles operate within the nonattainment area. While piston-engine aircraft 

may use leaded aviation fuel (commercial jet aviation aircraft do not use leaded fuel) no airports are 

located within the nonattainment area. 

The most recent comprehensive triennial National Emissions Inventory (NEI) (2011 Version 1, released 

September 30, 2013) estimates lead emissions from locomotive activities for all of Pottawattamie 

county at 0.002936 tons per year (tpy) of lead (~5.87 lbs/year). Locomotive emissions are not pertinent 

to the development of control measures for the lead nonattainment area. No other lead sources within 

the nonattainment area 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 national 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 effectiveness 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 affected sources are insignificant (73 FR 66964 p. 67036). 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 analyses 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 emissions, fugitive emissions (such as haul roads), 

and industrial process fugitive emissions (73 FR 66964 p. 67037). The only two facilities with relevant 

lead emissions 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 suggested 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 See73 FR 66964 (November 12, 2008), specifically page 67036.

16

 
4.1. Griffin Pipe

Griffin Pipe is the largest lead source within the nonattainment area according to the 2010 baseline 

actual emissions estimates. While the facility idled melting operations on May 3, 2014, Griffin Pipe does 

not consider the facility permanently shut down and the facility’s potential emissions remain 

unchanged. Sources at the facility must undergo a RACT/RACM review and new 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 Emission 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 EP2 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 Rooftop point source Magnesium InoculationUncaptured (EU-4)

New Pb emission limits 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 limits to 

meet NAAQS.

EP-29 Rooftop point source Large Diameter Casting (EU-29) New Pb emission limit to 

EP meet NAAQS. -29A Rooftop point source

FUG1 Fugitives Cupola Charge Handling (EU17)

Work practices to minimize 

emissions.

Haul Roads Fugitives Roadway fugitive emissions

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 the 

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 magnesium 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 For simplicity, all emission units are not always listed if an emission point is associated with more than one unit, 

this does not affect the RACT/RACM determination.

17
Figure 4-1. Approximate locations of lead emitting point sources 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 magnesium inculcation process). EPA’s March 2012 Guide to Developing Reasonable 

Available Control Measures (RACM) for Controlling Lead Emissions (EPA-457/R-12-001) suggests there is 

substantial support for adding control devices (such as filters) to control cupola 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 scrubber system was installed in 

1971. Process modifications made in 1999 expanded the use of the wet scrubber system to control 

emissions from the plunging (magnesium inoculation) process, which were previously 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 under 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 weights be removed, to the extent practicable, prior to being 

18
charged (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% of 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 the 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 as part of the PSD project (10-030) mentioned above. 

The desulfurization 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 inoculation 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, Casting, Scrap Handling, and Building Emissions

The remaining baseyear lead emissions, which constitute only a few percent of the total, are attributed

to haul roads, the large & small diameter casting processes, building emissions, and cupola charge 

handling. Despite a low emissions total the haul roads require control to provide for modeled 

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

more compared to baseline conditions is considered RACM for the haul roads. All travelled roadways at 

Griffin 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 potential of the sources to emit lead were not previously expressly limited. 

Emissions limits were developed for attainment of the lead NAAQS in the dispersion modeling 

demonstration. The new limits are necessary for attainment demonstration purposes and are 

considered RACT/RACM.

4.2. Alter 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 in 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 Roads 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 maintained when Griffin Pipe resumes operations. The ACO defines two independent control 

strategies, designated Option A and Option B. Griffin Pipe 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 Option A

The control strategy designated Option A contains, for example, new lead emissions limits, haul road 

control 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% reduction in Pb emissions.

• Shipping bulk materials and product only from 7 am to 5 pm daily.

• Implementing “good housekeeping” or best management practices (BMP), such as posting 

speed limit signs and cleaning 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) Emission Point

ID

Pb Limit

(lb/hr)

Control 

Equipment

Cupola (EU-1) EP-2A 0.282 Baghouse (CE-10)

Desulfurization (EU-2)

Bull Ladle (EU-3) EP-3 0.0018 Baghouse (CE-11)

Magnesium Inoculation (EU-4)

Magnesium Inoculation-Uncaptured (EU-4)

Ladle Preheat-Uncaptured (EU-19) EP-7A 0.0026 None

Desulfurization-Uncaptured (EU-2)

Bull Ladle-Uncaptured (EU-3) EP-7B 0.0372 None

Small Diameter Casting (EU-6)

Small Diameter Casting (EU-6) EP-6A 0.0043 None

Building Emissions EP-6B 0.0025 None

Large Diameter Casting (EU-29) a EP-29 & EP-29A 0.0025 None

Cupola Charge Handling (EU-17) FUG1 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 simultaneously. b The lead limit is established at 0.002 tons of lead per rolling 3-month total; that correlates to a lead silt content of 

0.00016 g/m2 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 loading shall not exceed 0.64 g/m2 or 0.00016 g/m2

, 

respectively, based on a 3-month rolling average.

20
Control Strategy Option B

The control strategy designated option B requires the installation of a baghouse to control emissions 

from roof vent EP-7B and tightens the emission limit for EP-7B by nearly a factor of 15 compared to

Option A. The new baghouse is located approximately 35 feet north 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. 

The frequency of sweeping is also adjusted based on similar considerations. Requirements include:

• Installing a new baghouse to control emissions from EP-7B and meeting 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 “good housekeeping” or BMP, such as posting speed limit signs and cleaning in 

appropriate situations to minimize fugitive emissions.

• Meeting new 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) Emission Point

ID

Limit

(lb/hr)

Control 

Equipment

Cupola (EU-1) EP-2A 0.282 Baghouse (CE-10)

Desulfurization (EU-2)

Bull Ladle (EU-3) EP-3 0.02 Baghouse (CE-11)

Magnesium Inoculation (EU-4)

Magnesium Inoculation-Uncaptured (EU-4)

Ladle Preheat-Uncaptured (EU-19) EP-7A 0.0075 None

Desulfurization-Secondary Capture (EU-2)

Bull Ladle-Secondary Capture (EU-3) EP-7B 0.0025 Baghouse (CE-12)

Small Diameter Casting (EU-6)

Small Diameter 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) FUG1 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 lead limit is established at 0.004 tons of lead per rolling 3-month total; that correlates to a lead silt content of 

0.00032 g/m2 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/m2 or 0.00032 g/m2

, 

respectively, based on a 3-month rolling average.

Standard Operating Procedures

Both of Griffin Pipe’s control strategies (Option A and Option B) require the implementation of work 

practice standards as specified in Standard Operating Procedures (SOPs) Melt180CB and Melt220CB. 

Melt180CB SOP prescribes methods to minimize emissions from cupola charge handling activities and 

Melt220CB SOP implements a scrap management plan designed to minimize the amount of lead in the 

scrap. These SOPs are provided in their entirety in section B-1 of Appendix B. While not all aspects of 

these 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.

21
Figure 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 requires Alter Metal Recycling to reduce their haul road emissions by sweeping 

paved roads. Unpaved roads must be paved or their use discontinued. Material shipments are limited 

to 946,000 tons per rolling 12-month period. Additional review of the control strategy is provided

below. The 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 are 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/m2 and maximum potential operation. A haul road surface silt loading

content of 2.7 g/m2 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 

provided in Figure 5-2. 

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

pm Monday through Friday, 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 Monday-Friday.

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

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

The 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 nonferrous 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 mechanisms. 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 is submitted as part of this SIP and is provided in

Appendix B.

Construction 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 permit is a legally enforceable mechanism, results in permanent lead emissions 

reductions, and is submitted as part of this SIP in Appendix C. 

23
6. Attainment Demonstration

The 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 dispersion 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 

parameters 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 modeled to account for cupola charge handling emissions at 

Griffin Pipe. Cupola charging emissions are the same in both control strategy options and are shown in 

Table 6-4. 

The haul roads 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 locations of downwash structures (blue rectangles), point 

sources (light blue dots), and volume sources (red dots) in the model. Figure 6-2 and Figure 6-3 depict 

the locations of the haul roads sources. Modifications to the facility haul roads 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 landfilled or otherwise disposed as waste) are incorporated 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 suited 

for reproduction in this document due to complexity from temporal variation and the number of haul 

road segments. In summary, the lead emissions from the haul roads are distributed spatially (by road

segment) and in time (by day of week and by hour of day) 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 Temporal 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, because internal transfers 

are allowed only Monday-Friday while inbound/outbound material may be shipped on Monday-Saturday.

24

 
Table 6-1. Hourly emission limits and stack parameters for point sources at Griffin Pipe with identical

characteristics in control strategy options A and B. 

AERMOD 

Source ID

Brief Source 

Description

Emission 

rate (Pb) 

(lb/hr)

Stack 

Height

(ft)

Gas exit 

temp

(°F)

Gas exit 

velocity 

(ft/s)

Effective 

Diameter

(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

Emission 

rate (Pb) 

(lb/hr)

Stack 

Height

(ft)

Gas exit 

temp

(°F)

Gas exit 

velocity 

(ft/s)

Effective 

Diameter

(inches)

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

GEP7A Magnesium InoculationUncaptured 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

Emission 

rate (Pb) 

(lb/hr)

Stack 

Height

(ft)

Gas exit 

temp

(°F)

Gas exit 

velocity 

(ft/s)

Effective 

Diameter

(inches)

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

GEP7A Magnesium InoculationUncaptured 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

Emission 

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. 

25
Figure 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 shown 

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 boundaries at Griffin 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 

measures. Because current conditions sufficiently preclude public access the 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 and 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 boundary (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 receptors 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 km2 (3.5 km x 4 

km) surrounding Griffin Pipe and Alter Metal Recycling. To determine the facilities’ impacts on each 

other’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 National 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 Recycling.

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 8th Avenue and 27th 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 influenced by 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 μg/m3 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 strategies. Potential (permitted/allowable) emissions 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 Recycling on Griffin Pipe’s property. All five simulations 

modeled compliance with the lead NAAQS.

Post file analyses were conducted to determine the paired spatial and temporal contributions from each 

facility at the worse-case receptor location. The AERMOD 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 lead NAAQS of 0.15 μg/m3

.

Table 6-5 and Table 6-6 show that the results of the two cumulative control strategy modeling runs 

achieve attainment with the lead NAAQS. The results for Griffin 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 concentration. 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 attainment of the lead NAAQS. The dispersion modeling 

data was transmitted to EPA Region 7 for review and approval. 

28
Table 6-5. Dispersion modeling results showing the receptor in ambient air with the highest modeled concentration attains the lead NAAQS 

using Griffin Pipe’s Option A control strategy. All concentrations are in μg/m3 calculated using EPA’s Leadpost processor or similar techniques.

Location Total 

Impact*

Alter Metal 

Recycling Griffin Pipe

Entire Facility

(Haul Roads)

Entire 

Facility

Haul 

Roads

Cupola

BH (2A)

Desulf.

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/m3

.

BH=Baghouse

Table 6-6. Dispersion modeling results showing the receptor in ambient air with the highest modeled concentration attains the lead NAAQS 

using Griffin Pipe’s Option B control strategy. All concentrations are in μg/m3 calculated using EPA’s Leadpost processor or similar techniques.

Location Total 

Impact*

Alter Metal 

Recycling Griffin Pipe

Entire Facility

(Haul Roads)

Entire 

Facility

Haul 

Roads

Cupola

BH (2A)

Desulf.

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/m3

. 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 date.” 

EPA recognizes that achieving 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 67038-67039), the RFP requirements for lead nonattainment 

“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 the 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 emissions 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) the DNR developed contingency measures which can be implemented 

quickly by Griffin Pipe and Alter Metal Recycling if either the applicable attainment date or RFP12

requirements are not met. The contingency measures for both facilities are similar and can take effect 

promptly following a simple notification process. 

The contingency measures 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 frequency another NAAQS violation occurs, then each 

facility is required to submit an emissions evaluation meeting the criteria and 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 reviews 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 strategy satisfy RFP requirements.

31

 
9. Attainment Date

The effective date for the Council Bluffs lead nonattainment area was December 31, 2011. The CAA 

requires that the area achieve the lead standards 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/m3

standard are required for attainment purposes. Additional lead emissions reductions are being 

implemented as expeditiously as practicable. The state 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 emissions 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 nonattainment 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 

nonattainment area. A special permitting process applies to such sources, referred to as a

nonattainment new source review (NA NSR) program. NA NSR is 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 XXXVI Number 12, pages 1455-1456.

10.3. CAA §110(a)(2) Requirements

Section 172(c)(7) of the CAA requires nonattainment SIPs to meet the applicable provisions of CAA 

§110(a)(2). While the provisions of 110(a)(2) address various topics there is ample evidence14 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). This nonattainment SIP submittal satisfies all applicable CAA §110(a)(2) 

criteria, and evidenced by the state’s nonattainment new source review program which addresses 

110(a)(2)(I), the included control strategy, and the associated emissions limits which are relevant to 

110(a)(2)(A). In addition, 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 techniques 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 the final rule 77 FR 34189 (June 12, 2012). 

33

 
11. Administrative Materials & Responses 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, Subpart 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. This SIP submittal 

satisfies 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 designee 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 

The Iowa Environmental Protection Commission (EPC) approved on January 21, 2015, this plan for 

submittal to EPA as a revision of the State Implementation Plan to address lead nonattainment in 

Council Bluffs. The DNR followed all applicable procedural requirements of the state’s laws and 

constitution in obtaining the 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 Iowa 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 necessary legal authority under state 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 standards 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 the 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 regulations, 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 notice 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 

opportunity 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. The DNR also provided notice of the draft permit through our construction 

permit website (note, the permit is no longer 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.

34
Notice 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 was 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 the 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 the 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 

contingency measures which would require the department to investigate, and address as appropriate, 

other potential lead sources in the area, including specifically vehicle traffic on 9th 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 9th Ave but did not include possible lead emissions 

from 9th Ave in the air quality modeling. The commenter then noted that traffic accesses Griffin Pipe’s 

and Alter Metal Recycling’s properties using 9th Ave, and asserted that 9th Avenue’s vehicle miles 

traveled (VMT) must be comparable to Griffin’s and Alter’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 

facilities 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 Response

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 9th

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, and instead provides flexibility in a review of additional lead emissions, which may 

include evaluation of possible lead emissions from vehicle movement on 9th Ave. The new language 

strengthens the contingency measures and preserves the requirement that both facilities submit an 

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

35

 
emissions 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 Recycling 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 control 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 commenter 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 overly 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 the 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 0.134 μg/m3 (under the requirements in Attachment B of 

Griffin Pipe’s ACO) and 0.130 μg/m3 (under the requirements in Attachment A of Griffin Pipe’s ACO). 

These impacts include background and are only 10 to 13 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 contributor (~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 higher level of control 

than what is 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 Griffin 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 provides compliance clarification that is missing from their own 

permit. The commenter requested that their silt loading sampling and compliance requirements be 

interpreted to have a similar meaning and that the DNR recognize this clarification in writing.

Department Response

The current language in the Alter Metal Recycling 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 supporting 

justification requesting a change in compliance measures associated with silt sampling and the 

department processes the application.

36
Comment 4 (termination language)

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 (standard operating procedures)

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 commenter 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 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. 

Comment 6 (temperature-related control strategy exemptions: 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 requirements if ambient air temperatures 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, and 2) does not require silt load testing in a month where sweeping 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 loading 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 significant 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). The commenter noted the 

language could be modified to 1) allow sweeping, without the use of water, or 2) allow for 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.

37
Department Response

To address the commenter’s concerns (as clarified 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 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 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 A5.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, conditions 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 occurred 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 decreasing 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 B5.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 noted that the Alter Metal Recycling permit contains 

more specific requirements 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 in place that the SIP include additional 

information concerning these controls and that modifications to the order be made to explicitly require 

continued use of those public access controls.

38
Department Response

The department has added details in Chapter 6 regarding measures used 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 in the ACO is retained without modification to avoid overprescribing 

perimeter security measures 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 

health and welfare based lead air quality standards and to attain the lead air quality standards as 

expeditiously 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 emission at Griffin Pipe and 

Alter Metal Recycling using the methods and information discussed in this appendix.

Paved Roads Emission Factors

The paved road emission factors for Griffin Pipe and Alter Metal Recycling were determined using sitespecific data and Equation (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 traveled, lb/VMT)

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

sL = the amount of lead in the suspendable particulate (g/m2

), and

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

The amount of suspendable particulate on the haul roads (the silt-loading) was determined using 

facility-specific sampling data collected in accordance with Appendix C.1 of AP-42. The collected

suspendable particulate (silt) was chemically analyzed to measure its total lead content. The lead 

loading value (sL) is obtained by multiplying the silt loading (g/m2

) 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 factor 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 are 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 and 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.”

40

 
Input Data

Calculating the emission factors and VMTs for each haul road is a data intensive process requiring sitespecific data. Each facility supplied the necessary haul road route data, roadway segment locations, 

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 23, 2012, Griffin Pipe collected 18 samples from their haul roads to be analyzed for surface 

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

approximate locations where samples were collected are shown 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 separates the suspendable particulate (smaller particles likely to become airborne 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 chose to analyze the lead content within the 

pre-sieved (bulk) material (all material collected via vacuuming or sweeping material off the roadway) in

the remaining 8 samples. The analytical results from the 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 segments were excluded from additional consideration as no haul road activity 

was reported for those segments. 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 samples 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 accounted 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 information accounted for within the 

baseline emission rates and the associated complexity of the spreadsheets, they are not 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 methods 

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 roads 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 this evaluation by assuming 

their lead concentrations would not vary with sieving. 

41

 
Figure 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 locations 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 (m2)

Silt Content

(g)

Silt Content

(%)

Silt Loading

(g/m2)

Lead Content

of Silt (μg/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

42
Table A-2. Silt loading of the sieved material and the lead content of pre-sieved (bulk) material for the 

remaining 8 samples collected by Griffin Pipe.

Sample 

ID

Sample 

Area (m2)

Silt Content

(g)

Silt Content

(%)

Silt Loading

(g/m2)

Lead Content of 

Pre-Sieved (Bulk)

Material (μg/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) identified by Griffin Pipe. Only 47 

segments are associated with haul road traffic.

43
Table 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 Segments

Samples 

Averaged or 

Assigned

Silt Loading 

(g/m2)

Lead in Silt 

(μg/kg)

Pb-Silt 

Loading (g/m2)

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 Number

Segment ID

Length (ft)

Width (ft)

Samples 

Averaged

Silt 

Loading 

(g/m2

)

Pb Silt 

(μg/mg)

Pb-Silt

Loading 

(g/m2)

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

44
Row Number

Segment ID

Length (ft)

Width (ft)

Samples 

Averaged

Silt 

Loading 

(g/m2

)

Pb Silt 

(μg/mg)

Pb-Silt

Loading 

(g/m2)

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 roads and evaluated 

each sample for both silt content and the lead content in the silt. The approximate sampling locations 

are shown in Figure A-3. The analytical results from the silt sampling are shown in Table A-5. Most haul 

roads were paved and the majority of traffic at the facility used paved roads. A smaller amount of traffic

used unpaved roads, and appropriately a smaller number of samples (two of the eight) were collected 

on unpaved roads. 

Alter Metal Recycling identified haul routes (see Figure A-4) using roadway locations, material types

transported, and an inbound/outbound 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 values 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 different samples or selecting a single representative sample. Table 

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

45
Alter Metal Recycling provided a detailed accounting 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 information. The calculations of the average vehicle weights and the 

vehicle miles travelled for each segment incorporate a large amount of data due to the complex traffic 

patterns, overlapping routes, variable vehicle types and weights, and the volume of traffic 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-invariant 

characteristics for each of the 17 road segments are provided in Table A-7 (this tables also provides 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 approach.

Note, a small amount of Griffin Pipe’s traffic 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 calendar year 2012 data. Traffic data from Griffin Pipe

is comparably recent. The data are not specific 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 remain 

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-loading values used 

to estimate the baseline emissions are thus expected to reflect worse case conditions. Additionally, the 

estimated actual haul road emissions have not been adjusted (reduced) to account for precipitation. 

While these assumptions are conservative in nature and are expected to overpredict the true haul road

baseline emission rates they represent common practices. 

46
Figure A-3. Approximate locations of the 8 silt samples collected on June 3, 2013, by Alter Metal 

Recycling. Sample location D1 is shown in blue to differentiate this location as an unpaved road. The 

roadway under sample D1 was originally constructed as a paved road but was deteriorated and was 

treated by 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 RoadType

Area 

(m2)

Silt

Content

(g)

Silt

Content

(%)

Silt 

Loading

(g/m2)

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 of 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.

47
Figure A-4. Approximated depiction of the baseline routes identified by Alter Metal Recycling. 

Locations in gray indicate sections of roadway originally unpaved. 

48
Figure A-5. Approximated depiction 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 deterioration. All 

other segments are paved. Segment numbers are color-coded with the segment lines. 

Table A-6. Roadway samples averaged (or assigned) for each road segment and the resultant silt 

loading, lead, and lead loading values within the silt. 

Paved Road Segments Samples 

Averaged

Silt Loading

(g/m2)

Lead in Silt

(μg/kg)

Pb-Silt Loading

(g/m2)

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 Silt

(μg/kg)

Pb Silt Content

(%)

7, 14, 15, 16, 17 C1 14.80 1,700,000 0.02516

49
Table 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/m2

)

Pb Silt 

(μg/mg)

Pb-Silt 

Loading 

(g/m2)

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/m2

)

Pb Silt 

(μg/mg)

Pb-Silt 

Loading 

(g/m2)

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: 1969 (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, defined 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 pursuant to the provisions of Iowa 

Code sections 455B.134(9) and 455B.138(1) which authorize the Director to issue 

orders 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 transmission 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 (μg/m3 ) of air. The revised standard requires that the 

maximum monitored 3-month rolling average not exceed 0.15 μg/m3 . 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 8th Avenue and South 27th Street in 

Council Bluffs, Iowa. In 2010, six 3-month rolling averages over the 0.15 μg/m3 lead 

NAAQS were measured by DNR at this monitor. Those six values did not meet the 

lead health standard. The maximum 3-month average measured by DNR in 2010 

occurred during the June-August period and was 0.26 μg/m3 . (In 2012, four 3-

month rolling averages over the 0.15 μg/m3 lead NAAQS were monitored. Those 

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/m3 .)

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 Facility and the designation became effective 

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 

Lead NAAQS as expeditiously as practicable, but no later than December 31, 2016.

6. DNR air 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 administrative 

consent order to create two enforceable control strategies. Each control strategy

contains control measures and timelines 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 at the Facility include “air contaminant 

sources” as defined by Iowa Code section 455B.131(2), and “stationary sources” as 

defined by 567 Iowa Administrative Code (IAC) 20.2.

2. 567 IAC 28.1 states that the ambient air quality standards for the State 

of Iowa shall 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/m3 , 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. Effective December 31, 2011, the Facility is located 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) requires 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 orders 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 

administrative consent order creates enforceable control measures to address the 

lead concentrations in ambient air in Council Bluffs.

V. ORDER

THEREFORE, DNR and Griffin Pipe agree to the following:

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

in Attachment A, or (2) implement the 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 controls listed in the attachments as 

necessary to further reduce ambient lead concentrations in Council Bluffs, Iowa, in 

compliance with applicable laws 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. The 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 any requirements contained in this order or an attachment must be 

approved by the DNR prior to its respective deadline. Any modifications to this 

order or an attachment may be subject to approval of the US EPA and may result 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 performance testing, Griffin Pipe shall either (1), if 

opting to implement the control measures contained in Attachment A,

complete performance testing to demonstrate compliance with the lead

emission limits contained in Attachment A in accordance with the frequency 

and timelines specified therein, or (2), if opting to implement the control 

measures contained in Attachment B, complete performance testing 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 Griffin 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 work practices 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 beginning on the date this 

administrative consent order is signed by the Director, 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 existed and the 

actions taken to remedy the situation.

From the date this order is issued until the date the Facility resumes 

operations the monitoring, recordkeeping and reporting requirements 

contained in Paragraph 4 of this 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 to 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 

administrative 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 Facility 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 9th Avenue

Council Bluffs, Iowa 51501

Plant Number: 78-01-012

The following emission 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

Bull Ladle (EU-3) 60 Tons/hr Baghouse (CE-11)

Magnesium Inoculation (EU-4) 60 Tons/hr

Small Diameter Casting (EU-6) 60 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 Sweeping 
Griffin 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/hr1 tons/yr2 Additional 

Limits Justification

Cupola (EU-1) EP-2A0.2823 NA NA RACT

0.0464 NA NA See Note 4

Desulfurization (EU-2)

EP-3 0.00183 Bull Ladle (EU-3) NA NA RACT

Magnesium Inoculation (EU-4)

MagnesiumInoculation-Uncaptured (EU-4) EP-7A 0.00263 NA NA RACT Ladle Preheat-Uncaptured (EU-19)

Desulfurization-Uncaptured (EU-2)

EP-7B 0.03723 Bull Ladle-Uncaptured (EU-3) NA NA RACT

Small Diameter Casting (EU-6)

Small Diameter Casting (EU-6) EP-6A 0.00433 NA NA RACT

Building Emissions EP-6B 0.00253 NA NA RACT

Large Diameter Casting (EU-29)

EP-29 0.00253 NA NA RACT EP-29A

Cupola Charge Handling (EU-17) FUG1 0.001433 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 lead limit is established at 0.002 tons of lead per rolling 3-month total; that correlates to a lead silt loading 

content of 0.00016 g/m2 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 precautions to prevent the discharge of visible emissions of fugitive 

dusts beyond lot line of the property.
Griffin Pipe Products Company Attachment A Page 3 of 7

Council Bluffs, Iowa

A-3. Emission Point Characteristics

These emission points 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 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 Annual2

EP-3 Yes Performance Testing Annual2

EP-7A Yes Performance Testing Annual2

EP-7B Yes Performance Testing Annual2

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 Testing1 Once Every 3-years

2

EP-29A Yes Performance Testing1 Once Every 3-years

2

FUG1 Yes Work Practice NA

Traffic Pathways Yes Silt Load Sampling Monthly4

1 Performance testing for lead shall be conducted on EP-29 and EP-29A 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 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 Griffin Pipe Products Company and 

approval by Iowa DNR, the silt loading sampling may be reduced 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 restart 

date of the equipment. 

If subsequent performance testing is specified above, the owner or the owner’s authorized agentshall verify 

compliance with the emission limitations contained in Condition A-2 according to the frequency and timeframe

noted above.

If testing is required, the owner or the owner’s authorized agentshall 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 the Department. 
Griffin 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 the owner or 

operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, 

along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and 

schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The 

Department shall reserve the right to impose additional, different, or more detailed testing requirements.

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

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

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

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

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

unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional 

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

Department to determine whether this unit(s) is in compliance.

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 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 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 limit included in Condition A-5.L. As 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 in Condition A-5.L. 

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 A-5.L or until 

such time as additional silt loading samples demonstrate compliance with the 3-month rolling total silt loading limit 

provided in Condition A-5.L. The owner or operator shall maintain records onsite that detail the date the measured

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 retained onsite.
Griffin 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 units 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 maintenance 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 from 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 owner 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 sweeping once per day except 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 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.

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 shipping activities on 

that calendar day.
Griffin 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 totalsilt loading or lead silt loading shall not exceed 0.64 g/m2or 0.00016 g/m2, 

respectively, based on a 3-month rolling average.

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

daily.

N. Best Management Practices (BMP) – The owner 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 emissions.

iii. Post and maintain 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 owner or operatorshall 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 A5.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 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 A-5.O.i or A-5-O.ii 

have been implemented for three (3) full calendar months the owner or operatorwill 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, all 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 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 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.
Griffin 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. Retain on-site a copy of 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 record 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 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/m2 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 as 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 9th Avenue

Council Bluffs, Iowa 51501

Plant Number: 78-01-012

The following emission units shall conform to the requirements 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

Bull Ladle (EU-3) 60 Tons/hr Baghouse (CE-11)

Magnesium Inoculation (EU-4) 60 Tons/hr

Small Diameter Casting (EU-6) 60 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 Sweeping 
Griffin 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/hr1 tons/yr2 Additional 

Limits Justification

Cupola (EU-1) EP-2A 0.2823 NA NA RACT

0.0464 NA NA See Note 4

Desulfurization (EU-2)

EP-3 0.023 Bull Ladle (EU-3) NA NA RACT

Magnesium Inoculation (EU-4)

Magnesium Inoculation-Uncaptured (EU-4) EP-7A 0.00753 NA NA RACT Ladle Preheat-Uncaptured (EU-19)

Desulfurization-Secondary Capture (EU-2)

EP-7B 0.00253 Bull Ladle-Secondary Capture (EU-3) NA NA RACT

Small Diameter Casting (EU-6)

Small Diameter Casting (EU-6) EP-6A 0.00433 NA NA RACT

Building Emissions EP-6B 0.00153 NA NA RACT

Large Diameter Casting (EU-29) EP-29 0.00253 NA NA RACT EP-29A

Cupola Charge Handling (EU-17) FUG1 0.001433 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 lead limit is established at 0.004 tons of lead per rolling 3-month total; that correlates to a lead silt loading 

content of 0.00032 g/m2 and maximum 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 published in the Federal Register (76 FR 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

These emission points 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 Annual2

EP-3 Yes Performance Testing Annual2

EP-7A Yes Performance Testing Annual2

EP-7B Yes Performance Testing Annual2

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 Testing1 Once Every 3-years

2

EP-29A Yes Performance Testing1 Once Every 3-years

2

FUG1 Yes Work Practice NA

Traffic Pathways Yes Silt Load Sampling Monthly4

1 Performance testing for lead shall be conducted on EP-29 and EP-29A simultaneously to demonstrate compliance 

with emission limit 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 Griffin Pipe Products 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 

agentshall 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 after the initial startup date of 

the equipment. 

If subsequent performance testing is specified above, the owner or the owner’s authorized agentshall verify 

compliance with the emission limitations contained in Condition B-2 according to the frequency and timeframe

noted above.

If testing is required, the owner or the owner’s authorized agentshall 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
Griffin 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 the 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 each 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 manufacturer, or the rate 

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

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

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

unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional 

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

Department to determine whether this unit(s) is in compliance.

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 shall 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 on 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 limit included in Condition B-5.M. As 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 in 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 loading 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-month 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 owner 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. 

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 roads are used six (6) days in a week, with a maximum of one day 

between sweeping events except 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). 

ii. Sweeping 4 times a week when the haul roads are used seven (7) days in a week except 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 because 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 preceding 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 totalsilt loading or lead silt loading shall not exceed 1.28 g/m2 or 0.00032 g/m2

, 

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 owner 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 emissions.

iii. Post and maintain 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 once per day within seven (7) days after notification by the Department that a monitored 

exceedance of the lead NAAQS occurred. The owner or operatorshall 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 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 decreasing 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 operatorwill 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, all 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. 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 during 

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-minute 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. 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).
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/m2 to determine compliance with Condition B-5.M. 

M. Prior to resuming facility operations the owner 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 minimize fugitive dust 

emissions.

2.0 EQUIPMENT

(1) Proper safety equipment including hardhat, ear and eye 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) 0.25μ Radiation Test puck

3.0 GENERAL REQUIREMENTS FOR SCRAP INSPECTION & CHARGE 

HANDLING

(1) Caution must 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 this 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 numbers specific to each yard and this will be recorded 

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 operators 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 0.25μ test puck. Retest the 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 unloading 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 check the load by inspecting the material as it is 

handled by the magnet. Inspect the ground carefully when cleaning up as this is 

when nonmagnetic 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 top of all

railcars 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 intention 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 lineup continue to check 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 purchasing 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 Melt180CB-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. Any 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 elevated 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) Waste- These 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) No visible non-conformance is seen score 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. Any 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 Environmental Engineer to all Zero 

Ratings as soon as practical.

(8) Forward completed forms to purchasing 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 loads 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 products. 

A formal Corrective Action Request (CAR) 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 is 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 nonferrous materials 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) As 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 Testing 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 updated 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 #: Melt220CB 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 S101CBShredded Steel Scrap, S102CB- No2 Metal Scrap and S103CB- Plate & 

Structural Scrap.

2.2 All vendors who 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, rail, 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-conforming 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 once 

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 scrap will follow the 

Scrap Inpsection SOP.
GRIFFIN PIPE PRODUCTS CO.

COUNCIL BLUFFS PLANT

STANDARD OPERATING PROCEDURE ______________________________________________________________________________

Title: Scrap Management Plan Instruction #: Melt220CB 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___

Production Superintendent Date

______Jeffrey Suing____________ ____10/31/14___

Operations Manager Date
Appendix C. Alter Metal Recycling Construction Permit

79
[SMC] ¦ CPFP¦7801043¦09022014¦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 9th 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 9th 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 Resources 
Alter 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 subject to criminal penalties according to Iowa Code Section 455B.146A. 

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

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

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

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

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

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

installation, maintenance or operation of the proposed equipment. 

2. Owner and Operator Responsibility 

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

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

facility shall assure that the installation of the equipment listed in this permit conforms to the design in the 

application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this 

emission unit(s), control equipment, or emission point without the required amended permit. 

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

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

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

provisions of this permit and all other applicable requirements. 

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

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

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

3. Transferability 

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

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

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

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

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

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

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

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

the initiation of construction of additional control equipment or modifications to equipment needed to meet the 

standards. 

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

4. Construction 

A. General Requirements 

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

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

pollution is created. 

 
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 revert back to the most recent previous version of the 

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

only and are unappealable. 

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

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

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

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

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

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

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

B. Changes to Plans and Specifications 

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

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

(2) This permit becomes void. 

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

equipment and control equipment and the specified operation thereof. 

C. Amended Permits 

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

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

following conditions occurs: 

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

emission point permitted herein; or 

(2) This current amendment becomes void. 

5. Credible Evidence 

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

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

permit or any provisions of 567 IAC Chapters 20 through 35. 

6. Excess Emissions 

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are 

not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good 

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

otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be 

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

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

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

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

a reasonable period of time, as specified in 567 IAC 24.1. 

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

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

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

required initial reports within seven (7) days of the onset of the upset condition (See Permit Condition 8.B.2).
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 fifteen (15) days following the start of operation; 

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

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

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

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

area for the NAAQS; 

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

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

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

Air Quality Bureau 

Iowa Department of Natural Resources 

7900 Hickman Road, Suite 1 

Windsor Heights, IA 50324 

and include the following information: 

 The date of ownership change, 

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

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

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

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

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

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

 the time, 

 the place, 

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

 and other information as required by the Department; 

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

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

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

notification period of less than thirty (30) days. 

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

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

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

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

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

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

of the onset of the upset condition. 

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

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

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

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

following the end of the calendar quarter, on forms provided by the Director. 
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 demonstration report for each compliance testing event, 

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

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

stringent reporting requirement shall be met; 

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

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

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

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

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

Construction Permit Supervisor 

Air Quality Bureau 

Iowa Department of Natural Resources 

7900 Hickman Road, Suite 1 

Windsor Heights, IA 50324 

Telephone: (515) 725-9549 

Fax: (515) 725-9501

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

Stack Testing Coordinator 

Air Quality Bureau 

Iowa Department of Natural Resources 

7900 Hickman Road, Suite 1 

Windsor Heights, IA 50324 

Telephone: (515) 725-9545 

Fax: (515) 725-9502 

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

Compliance Unit Supervisor 

Air Quality Bureau 

Iowa Department of Natural Resources 

7900 Hickman Road, Suite 1 

Windsor Heights, IA 50324 

Telephone: (515) 725-9550 

 Fax: (515) 725-9502 

IDNR Field Office 4 

1401 Sunnyside Lane 

Atlantic, IA 50022 

Telephone: (712) 243-1934 

Fax: (712) 243-6251 

9. Appeal Rights 

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

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

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

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

the amendment for your convenience only and are unappealable. 

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

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

Legal Services Bureau Chief at the following addresses: 

Director 

Iowa Department of Natural Resources 

502 East 9th Street 

Des Moines, IA 50319 

Bureau Chief 

Legal Services Bureau 

Iowa Department of Natural Resources 

502 East 9th Street 

Des Moines, IA 50319 
Alter 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 

PM10 NA NA NA NA 

PM2.5 NA NA NA NA 

Opacity NA NA (3) 23.3(2)”c” 

Sulfur Dioxide (SO2) NA NA NA NA 

Nitrogen Oxides (NOx) 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 (CO2e) 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 precautions 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 0.00281 

g/m2

 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. The compliance demonstration with this lead 

limit is based on maximum silt content, operating restrictions and work practice standards as specified in Conditions 14 and 15. 

Total silt load content of 2.7 g/m2

 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 representative and characteristic of the design of the permitted 

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

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

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

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

PM10 No NA NA 

PM2.5 No NA NA 

Opacity No NA NA 

SO2 No NA NA 

NOx No NA NA 

VOC No NA NA 

CO No NA NA 

Pb No NA NA 

CO2 No NA NA 

CH4 No NA NA 

N2O No NA NA 

CO2e No NA NA 

Single HAP No NA NA 

Total HAP No NA NA 

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

verify compliance with the emission limitations contained in Permit Condition 10 within 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 contained in Permit Condition 10 according to the frequency and timeframe noted above. 

The Department shall reserve the right to impose additional, different, or more detailed testing requirements. 

13. New Source Performance Standards (NSPS) and 

 National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability 

The emission unit is not subject to any of the 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 applicable 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 haul 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 Tymco 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 ambient air temperature (as measured at the facility 

during daylight operating hours) will be less than 35o

 F (1.7o 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 haul road traffic on that calendar 

day (i.e., the facility would not count this day towards the maximum of one day between sweeping). 

v. The facility may request reduced sampling frequency should 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 loading shall not exceed 2.70 g/m2

. 

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 are limited to Monday through Friday. 

J. Best Management Practices (BMP) – Clean up spills, truck 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 restrict public access to the facility by posting signs warning 

of restricted access to the facility at all property boundary lines not secured with fencing. During those days the 

facility is operating, in-person surveillance of the boundary 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 the frequency of cleaning/sweeping of the haul roads 

to daily within seven (7) days after 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 that 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 timeline 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 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. 

B. The facility shall record daily the date and time of material 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 processed/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 loading 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 testing 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 maintain 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 haul 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, installing 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 Testing 

 
Alter 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 

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

emissions based on global warming potentials 

Department Iowa Department of Natural Resources 

dia. Diameter 

F Degrees Fahrenheit 

ft Foot 

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

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

sulfur hexafluoride (SF6) 

g grams 

g/dscm Grams per dry standard cubic meter 

gr Grains 

gr/dscf Grains per dry standard cubic foot 

gr/scf Grains per standard cubic foot 

HAP Hazardous Air Pollutant(s) 

hp horsepower 

hr Hour 

lb Pound 

lb/hr Pounds per hour 

m Meter 

mg Milligram 

MM Million 

MW Megawatt 

NA Not Applicable 

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

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

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

PM – State Particulate Matter that includes condensable PM 

ppm parts per million 

ppmv parts per million by volume 

ppmw parts per million by weight 

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 at 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 adds, 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 the resultant road segment layouts and 

traffic patterns are distinctly different from the baseline. The attainment demonstration, control 

strategy, and construction permits issued to Alter Metal Recycling account for all roadway modifications 

associated with the ZC Plant addition.

The original (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 such as location, length or width)20 by the addition of the ZC 

Plant are depicted in Figure D-3. For historical reference, the original (baseyear) configuration of all the

segments modified or removed with the addition of the ZC plant is shown in Figure D-4; their new 

configuration 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 correlate 

to emissions. Changes in facility 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 (see 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. Not 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, the measures required by the control strategy equate to a 95% reduction in 

baseline lead emissions from Alter Metal Recycling. 

20 VMT and 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 are 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 emissions 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 reduce lead 

emission at Alter Metal Recycling by approximately 95%. Lead emissions from the ZC Plant are 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, 2013.

91

 
Figure D-1. Depiction of all facility road segments as they existed in the 2010 baseline. (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.

92
Figure 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.

93
Figure 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.)

94
Figure D-4. Baseline road segments whose lengths or locations are modified or removed with the 

addition of the ZC Plant (this image is shown for historical/informational purposes).

95
Figure D-5. Depiction of the modified and new road segments associated with the ZC Plant. (Google 

Earth’s Imagery Date of 9/21/2013.)

96
Table D-1. Road segments and lengths at Alter Metal Recycling 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 ID

Length (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

4 135 (because ZC segment 7' was shifted east about 10 m compared to baseline segment 7)

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 defined 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

97
Figure D-6. A simple approximation 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 

forth.

98
Appendix E. Proof of Publication

E-1. Alter Metal Recycling Draft Construction Permit

99
100
E-2. Proof of Publication of the SIP’s Public Notice in The Daily Nonpareil.

101
102