RE: EnviroFocus Technologies (Gulf Coast Recycling) 

 

Mr. Green,

EnviroFocus Technologies, LLC is a secondary lead smelter located in Tampa. We recently issued a DRAFT 

Construction Permit to them for enclosure of their blast furnace, including ventilation of the enclosure to a baghouse, and 

an increase in the existing production limit (see attached). The Technical Evaluation summarizes the project along with 

an evaluation of each pollutant and limits taken to avoid PSD. The attached spreadsheet details the PSD review.

For determination of estimated “actual” fugitive emissions of PM and Pb from the blast furnace, we used an estimation of 

95% control for the existing partial enclosure at the facility. We never projected a specific control efficiency for the 

proposed enclosure including ventilation to a control device because the emission limit was calculated from requested 

emission limits in gr/dscf from the baghouse. However, given that 40 CFR 63 - Subpart X requires that the enclosure 

operate at negative pressure with in-draft through any doorway, and that it be vented to a control device, a control 

efficiency of greater than 95% would seem reasonable. A control efficiency beyond 99.0% could be possible, but would 

definitely require scrutiny of the enclosure design and efficiency of the control device.

Hope this helps.

Regards,

Jeff Sims

Environmental Protection Commission of Hillsborough County

simsj@epchc.org

(813)627-2600 ext. 1285

(813) 627-2660 (FAX)

 

From: Koerner, Jeff [mailto:Jeff.Koerner@dep.state.fl.us] 

Sent: Tuesday, October 02, 2007 4:04 PM 

To: Danny.Greene@erg.com

Cc: Lee, Diana 

Subject: Re: Enviro Focus Tech (Gulf Coast Recycling)

 

 

Mr. Greene, 

I was forwarded your e-mail regarding this facility. I believe there have been discussions on enclosing the blast furnace 

area. The project is being handled by the local air program, the Environmental Protection Commission of Hillsborough 

County. Please contact the air permitting supervisor, Diana Lee, at 813/627-2600 for details.

Jeff Koerner, BAR - Air Permitting North 

Florida Department of Environmental Protection 

850/921-9536 

 

From: "Sims, Jeff" <SimsJ@epchc.org>

To: "'Danny.Greene@erg.com'" <Danny.Greene@erg.com>

Date: 10/4/2007 11:18 AM

Subject: RE: EnviroFocus Technologies (Gulf Coast Recycling)

CC: "Woodard, Sterlin" <Woodard@epchc.org>, "Lee, Diana" <Lee@epchc.org>

Attachments: 0570057-018-AC-D.doc; FINAL Envirofocus Furnace Increase Calculations - 9-07.xls

Page 1 of 2
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From: Danny Greene [mailto:Danny.Greene@erg.com] 

Sent: Tuesday, October 02, 2007 11:15 AM 

To: Friday, Barbara 

Subject: Enviro Focus Tech (Gulf Coast Recycling)

Barbara, I am working with EPA (Chuck French, 919 541-7912) to evaluate control options 

for use in developing residual risk standards for secondary lead smelting facilities and 

we heard about Enviro Focus Tech's plan to enclose the blast furnace area to reduce 

fugitive

emissions. Do you know if there are any documents or calculations that 

show the approximate percent reduction that is expected to result from the blast furnace 

area enclosure?

Thanks for the help,

Danny

Danny Greene 

Senior Environmental Engineer 

Eastern Research Group, Inc. 

1600 Perimeter Park 

Morrisville, NC 27560 

phone: (919) 468-7909 

fax: (919) 468-7801

Page 2 of 2
M E M O R A N D U M

DATE: September 10, 2007 

TO: Richard D. Garrity, Ph.D. 

FROM: Jeff Sims THRU: Sterlin K. Woodard, P.E. 

 Diana M. Lee, P.E. 

SUBJECT: Construction Permit - EnviroFocus Technologies, LLC (EFT) 

Attached is draft Permit No. 0570057-018-AC for the enclosure of the existing blast furnace area and 

for an increase in the lead production limit from the blast furnace at EnviroFocus Technologies, LLC 

(EFT), formerly known as Gulf Coast Recycling, Inc. The facility is a secondary lead smelting 

operation located at 1901 N. 66th Street, Tampa, FL 33619. 

The application for enclosure of the blast furnace has been submitted in conjunction with Appendix 

AM-1, Additional Measures for Fugitive Dust Control Plan as referenced in Permit No. 0570057-

016-AV. The purpose of the enclosure is to capture and control fugitive particulate matter (PM) and 

lead (Pb) emissions from the blast furnace area. Permanent walls will be erected around the blast 

furnace and connected to the existing roof. Four overhead doors, three man doors, and a 10’ hinged 

door will be installed for employee and equipment movement into and out of the blast furnace area; 

however, these doors will typically remain closed. There will also be a permanent opening left between 

the blast furnace area and the feed material containment room to allow for frequent traffic between 

these areas; however, a “horseshoe” type ventilation hood will be placed around the perimeter of the 

opening to create a null air flow within the opening. This was done to prevent drawing lead bearing 

dust into the blast furnace enclosure area. The dust material within the enclosure will be vented 

through a Torit Downflo Oval Cartridge dust collector with a 65,000 acfm fan and out an 80’ stack. 

The immediate area around the blast furnace will be vented through a shroud, similar to a chimney, that 

extends down from the roof to a height of approximately 15’. The remaining air in the room is vented 

through the previously mentioned horseshoe vent. 

The PM and Pb emissions emitted around the blast furnace have always been considered fugitive, and 

therefore have never been limited within the air permit. However, these emissions are more 

appropriately designated as “unconfined” since fugitive emissions are defined as emissions that cannot 

be reasonably pass through a stack or vent. Since the enclosure is now collecting these unconfined 
emissions, they are being added to the overall facility-wide limits for PM and Pb emissions. It is 

significant to note that the enclosure project is an overall improvement in emission reduction and, even 

though this construction permit will specify a higher facility-wide PM limit than the existing operating 

permit, the addition of the enclosure is estimated to remove approximately 5 ton/yr of PM and 0.15 

ton/yr of Pb emissions previously emitted to the atmosphere. The total facility-wide potential 

emissions will increase from 23.3 ton/yr to 34.4 ton/yr for PM, and will remain at 1.6 ton/yr for Pb. 

This application also requested an increase in permitted annual lead production from the blast furnace 

from 26,500 ton/yr to 32,000 ton/yr. The increase in production is to be achieved through a more 

efficient process with increased automation and monitoring of the system along with a reduction in 

maintenance downtime. Based on the initial application and evaluation of potential increases in 

emissions, this request made the project subject to PSD for several pollutants per our evaluation. 

Additional correspondence was received from EFT that reduced the requested emission rates to levels 

below the PSD threshold, pursuant to Rule 62-212.400(2), F.A.C., for all the affected pollutants. 

Credit for improved control of PM and Pb by the enclosure was included in the PSD determination. 

The new limits to be implemented with this permit are detailed in the Technical Evaluation. 

Also included in this permit is an amended version of the Baghouse Standard Operation and 

Maintenance Procedures Manual. EFT indicated their desire to replace some aging bag leak 

detectors in the baghouses with more reliable modern detectors. The Baghouse Standard Operation 

and Maintenance Procedures Manual was modestly amended to allow more flexibility for 

replacement of detectors with equivalent units as long as they meet all the requirements from 40 CFR 

63.548. If the units are replaced, an updated version of the Plan including details of the units installed 

will be required from the permittee at time of operating permit revision. 

The new enclosure and blast furnace (including tapping and charging) is subject to PM and Pb 

RACT, NSPS requirements of 40 CFR 60 – Subpart L, and the MACT requirements of Subpart 

X of the NESHAP for Pb and VOC (blast furnace only). The limits requested by the applicant are 

typically stricter than the limits specified by the applicable regulations. 

Based on our review, we recommend issuance of the permit as drafted. 

jds: 0570057-018-AC 
TECHNICAL EVALUATION 

AND 

PRELIMINARY DETERMINATION 

FOR 

EnviroFocus Technologies, LLC

Hillsborough County 

Construction Permit 

Application Number 

0570057-018-AC 

Environmental Protection Commission of 

Hillsborough County 

Tampa, FL 

September 11, 2007 
I. Project Description

 A. Applicant: 

EnviroFocus Technologies, LLC 

1901 N. 66th Street 

Tampa, FL 33619 

John Tapper 

Chief Operating Officer 

 B. Engineer: 

Russell S. Kemp, P.E. 

P.E. No.: 56355 

ENVIRON International Corp. 

1600 Parkwood Circle, Suite 310 

Atlanta, GA 30339 

 C. Project and Location: 

This permit is for the enclosure of the existing blast furnace area and for an increase in the lead 

production limit from the blast furnace at EnviroFocus Technologies, LLC (EFT), formerly known as 

Gulf Coast Recycling, Inc. The facility is a secondary lead smelting operation located at 1901 N. 66th

Street, Tampa, FL 33619. 

The application for the enclosure of the blast furnace has been submitted in conjunction with Appendix 

AM-1, Additional Measures for Fugitive Dust Control Plan as referenced in Permit No. 0570057-

016-AV. The purpose of the enclosure is to capture and control fugitive particulate matter (PM) and 

lead (Pb) emissions from the blast furnace area. The enclosure will be vented through a dust collector 

and eventually out an 80’ stack. 

The PM and Pb emissions emitted around the blast furnace have always been considered fugitive, and 

therefore have never been limited within the air permit. However, these emissions are more 

appropriately designated as “unconfined” since fugitive emissions are defined as emissions that cannot 

be reasonably pass through a stack or vent. Since the enclosure is now collecting these unconfined 

emissions, they are being added to the overall facility-wide limits for PM and Pb emissions. It is 

significant to note that the enclosure project is an overall improvement in emission reduction and, even 

though this construction permit will specify a higher facility-wide PM limit than the existing operating 

permit, the addition of the enclosure is estimated to remove approximately 5 ton/yr of PM and 0.15 

ton/yr of Pb emissions currently emitted to the atmosphere. 

This application also requested an increase of the annual lead production from the blast furnace from 

26,500 ton/yr to 32,000 ton/yr. A related change in the approximate maximum charging rate to the 

furnace from 6.5 ton/hr to 7.9 ton/hr was included in the request. The increase in production is to be 

achieved through a more efficient process with increased automation and monitoring of the system 

along with a reduction in maintenance downtime. An initial evaluation of potential increases in 

emissions from this request indicated the project was subject to PSD for several pollutants. Additional 

correspondence from EFT reduced the requested emission rates to levels below the PSD threshold, 
pursuant to Rule 62-212.400(2), F.A.C., for all the affected pollutants. Credit for improved control of 

PM and Pb by the enclosure was included in the PSD determination. A discussion of the PSD analysis 

for each pollutant and the new limits to be implemented are as follows: 

Sulfur Dioxide (SO2) - A five-year period from July 1997 through June 2002 was used to develop an 

average emission factor for SO2. Stack test data was used until October 2001 and CEM data available 

after that date was used for the remainder. A two-year period from December 1999 to November 2001 

was used to determine baseline actual emissions of 847 ton/yr. As defined in Rule 62-210.200(277), 

F.A.C., the significant emission rate signifying the PSD threshold for SO2 is 40 ton/yr. Therefore, the 

future PSD-avoidance allowable emission rate is 886 ton/yr, which is equivalent to an annual average of 

55.4 lb of SO2 per ton of lead produced using the increased production limit of 32,000 tons of lead. The 

existing emission limit for the blast furnace is 1015 ton/yr. 

Nitrogen Oxides (NOx) – NOx emissions were estimated using an emission factor of 21 lb/ton for 

combustion of coke and 100 lb/MMBtu for combustion of natural gas. A two-year period from January 

2005 through December 2006 was used to determine total baseline actual emissions of 41.7 ton/yr. As 

defined in Rule 62-210.200(277), F.A.C., the significant emission rate signifying the PSD threshold for 

NOx is 40 ton/yr. Therefore, the future PSD-avoidance allowable emission rate is 81 ton/yr, which was 

based on the limitation that no more than 7,300 ton/yr of coke can be processed in the blast furnace. 

Carbon Monoxide (CO) – A five-year period from January 2002 through December 2006 was used to 

develop an average emission factor for CO using stack test data. A two-year period from January 2002 

to December 2003 was used to determine baseline actual emissions of 812 ton/yr. As defined in Rule 

62-210.200(277), F.A.C., the significant emission rate signifying the PSD threshold for CO is 100 

ton/yr. Therefore, the future PSD-avoidance allowable emission rate is 911 ton/yr. The existing 

emission limit for the blast furnace is 1400 ton/yr. 

Volatile Organic Compounds (VOC) – A five-year period from January 1998 through December 

2002 was used to develop an average emission factor for VOC using stack test data. A two-year period 

from December 1999 to November 2001 was used to determine baseline actual emissions of 57.8 ton/yr 

for the blast furnace and 2.1 ton/yr for the tapping/charging (hygiene baghouse). The hygiene baghouse 

was included in this determination since VOC emissions are captured by the system and stack test data 

was available. As defined in Rule 62-210.200(277), F.A.C., the significant emission rate signifying the 

PSD threshold for VOC is 40 ton/yr. Therefore, the future PSD-avoidance allowable emission rates are 

89 ton/yr, or 102 ppm, for the blast furnace and 10 ton/yr, or 18 ppm, for tapping/charging. The 

existing emission limits are 104.7 ton/yr for the blast furnace and 12.0 ton/yr for tapping/charging. 

Particulate Matter (PM) – A five-year period from January 1998 through December 2002 was used 

to develop an average emission factor for PM using stack test data. A two-year period from December 

1999 to November 2001 was used to determine baseline actual emissions of 1.63 ton/yr for the blast 

furnace and 0.94 ton/yr for the tapping/charging (hygiene baghouse). The hygiene baghouse was 

included in this determination since PM emissions are captured by the system and stack test data was 

available. Credit was also given for the improved control of PM emissions provided by the enclosure 

that is included with this project. Baseline actual emissions from the enclosure were estimated at 15.57 

ton/yr using a 24.2 lb/ton emission factor from AP-42 and an assumed 95% capture efficiency from the 

hygiene hoods. As defined in Rule 62-210.200(277), F.A.C., the significant emission rates signifying the 

PSD threshold for PM/PM10 are 25/15 tons/yr. The requested PSD-avoidance allowable limit from the 

applicant for the enclosure control system is 9.8 ton/yr, based on an emission rate of 0.004 gr/dscf and a 

65,000 acfm baghouse rating. This resulted in a perceived PM decrease of 5.81 ton/yr. The future 
PSD-avoidance allowable emission rates are 12.0 ton/yr for the blast furnace and 7.4 ton/yr for 

tapping/charging. These annual emissions were calculated based on the existing emission limit of 0.011 

gr/dscf for PM for both the blast furnace and tapping/charging, as specified in the current permit. The 

existing emission limits are 10.7 ton/yr for the blast furnace and 7.4 ton/yr for tapping/charging. The 

increase in the allowable emission limit for the blast furnace is due to the use of an increased flow rating 

of 29,000 dscfm in the calculations, which was utilized based on more recent stack tests. 

Lead (Pb) – A five-year period from January 2002 through December 2006 was used to develop an 

average emission factor for Pb using stack test data. A two-year period from January 2002 to 

December 2003 was used to determine baseline actual emissions of 0.37 ton/yr for the blast furnace and 

0.10 ton/yr for the tapping/charging (hygiene baghouse). The hygiene baghouse was included in this 

determination since Pb emissions are captured by the system and stack test data was available. Credit 

was also given for the improved control of Pb emissions provided by the enclosure that is included with 

this project. Baseline actual emissions from the enclosure were estimated at 0.39 ton/yr using a 0.6 

lb/ton emission factor from AP-42 and an assumed 95% capture efficiency from the hygiene hoods. As 

defined in Rule 62-210.200(277), F.A.C., the significant emission rate signifying the PSD threshold for 

Pb is 0.6 tons/yr. The requested PSD-avoidance allowable limit from the applicant for the enclosure 

control system is 0.21 ton/yr, based on an emission rate of 0.000085 gr/dscf and a 65,000 acfm 

baghouse rating. This resulted in a perceived Pb decrease of 0.18 ton/yr. Therefore, the future PSDavoidance allowable emission rates are 0.78 ton/yr for the blast furnace and 0.42 ton/yr for 

tapping/charging. The annual emissions were calculated based on an emission rate of 0.00072 gr/dscf 

and a flow rating of 29,000 dscfm (based on more recent stack test data) for the blast furnace, and an 

emission rate of 0.00062 gr/dscf and a flow rating of 18,000 dscfm for the hygiene baghouse. The 

existing emission limits are 0.83 ton/yr for the blast furnace and 0.59 ton/yr for tapping/charging. 

Mercury was also analyzed using reference material from the NESHAP BID, and it was determined that 

any increase in mercury emissions would not exceed the significant emission rate threshold for PSD 

applicability. The remaining pollutants referenced by Rule 62-210.200(277), F.A.C. are not believed to 

be emitted in significant quantities from secondary lead smelting blast furnaces. 

The blast furnace enclosure will encompass the blast furnace and tapping and charging operations, 

except for the baghouses controlling those operations. Since the tapping and charging operation is now 

enclosed, the minimum required face velocities and associated testing requirements on the hoods for 

tapping and charging have been removed; however, the permit includes general requirements to 

maintain the tapping and charging in operation as designed. In addition, the opacity requirements for 

the charging and tapping doors have also been removed. The blast furnace enclosure has been assigned 

the most stringent opacity limit of 3% for the baghouse exhaust and any enclosure opening to account 

for their removal. 

Also included in this permit is an amended version of the Baghouse Standard Operation and 

Maintenance Procedures Manual. The applicant indicated their desire to replace some aging bag leak 

detectors in the baghouses with more reliable modern detectors. The Baghouse Standard Operation 

and Maintenance Procedures Manual was modestly amended to allow more flexibility for 

replacement of detectors with equivalent units as long as they meet all the requirements from 40 CFR 

63.548. If the units are replaced, an updated version of the Plan including details of the units installed 

will be required from the permittee at time of operating permit revision. 

The new enclosure and blast furnace (including tapping and charging) is subject to PM and Pb 

RACT, NSPS requirements of 40 CFR 60 – Subpart L, and the MACT requirements of Subpart X 
of the NESHAP for Pb and VOC (blast furnace only). The limits requested by the applicant are 

typically stricter than the limits specified by the applicable regulations. 

The project has been assigned NEDS Source Classification Code Nos. 3-04-004-03 (secondary metal 

lead – blast furnace) and 3-04-004-99 (secondary metal lead – miscellaneous). The Standard Industrial 

Code for the project is No. 3317. The project is located at 1901 N. 66th Street, Tampa. UTM 

Coordinates of the location are 17-364.0 East and 3093.5 North, Hillsborough County. 

D. Process and Controls: 

 

The facility recycles spent automotive and industrial lead-acid batteries to produce lead ingots. The 

batteries go through a shredder where most of the acid is drained, and then pass through a hammer mill. 

 The crushed material then passes through counter current, flotation, and separation equipment that 

separate the metallic lead, plastic, and lead salts or muds. The metallic lead and small amounts of plastic 

and rubber are all conveyed to the material charging storage area. The muds are slurried with soda ash 

to form lead carbonate and sodium sulfate that are separated in a filter process. The press cake is also 

sent to the material charging storage area. The M.A. 41DS Battery Recycling System is designed to 

reduce the sulfur content of the blast furnace feed stock and resulting sulfur dioxide emissions from the 

furnace. 

A single 36” x 72” oval Blast Furnace is used for producing molten lead from the various materials 

charged into the blast furnace. The blast furnace charge is approximately composed of 85% leadbearing materials, 8-12% coke, 2.5% limerock, and 2.5% cast iron. Lead-bearing materials may 

include, but are not limited to, CRTs, re-run slag, and indigenous materials such as respirators, 

baghouse dust, and treatment plant sludge. Material is charged via a mechanical skip hoist with 

automatically opened charged doors at the top of the furnace. 

Lead and slag are both tapped and collected at the base of the furnace. Lead is tapped to form 

buttons, which are sold or transported to the refining area. CO and VOC flue gas emissions from 

the blast furnace are controlled by the use of a 10 MMBtu/hr afterburner. Particulate matter and 

lead emissions directly from the blast furnace are controlled by enclosures and a 34,000 acfm ten 

compartment baghouse fabricated by Gulf Coast Recycling, Inc., which was modeled after a 

Wheelabrator-Frye Dustube Model 126, Series 55 shaker baghouse. Emissions from the blast 

furnace charging, skiphoist, and blast furnace tapping emissions are captured by hoods or 

enclosures and vented to an approximately 20,000 ACFM, three compartment, shaker baghouse 

similar in design to the previously mentioned baghouse. 

The proposed enclosure will cover approximately 10,000 ft2and surround the blast furnace area by 

installing permanent walls and connecting to the existing roof. A 14’x14’ overhead “speed door” will 

be installed between the blast furnace area and the refining area to allow for easier movement of 

equipment back and forth. Two 14’x14’ manual overhead doors along with an 8’x14’ manual overhead 

door will also be installed for equipment movement into and out of the blast furnace area; however, 

these doors will typically remain closed. There will also be three man doors for employee access and a 

10’x10’ hinged door for occasional access to the blast furnace for crucible removal and other 

maintenance activities. Finally, there will be a permanent 12.7’x20’ opening left between the blast 

furnace area and the feed material containment room to allow for frequent traffic between the rooms. A 

“horseshoe” type hood will be placed around the perimeter of the opening and approximately 32,500 

acfm will be drawn to create a null air flow within the opening. This was done to prevent migration of 

fugitive emissions back and forth between the enclosures. 
The blast furnace enclosure will be maintained under a negative pressure and be vented through a 

65,000 acfm Torit Downflo Oval Cartridge dust collector (Model #DFO 4-96). The dust collector has 

96 filter cartridges, total filter media area of 18,420 ft2, and an air:cloth ratio of 3.5:1, and is cleaned 

using pulsed-jet. The final exhaust is out an 80’ stack. The enclosure includes the operation of the 

“hygiene” baghouse, so additional airflow is being drawn from the enclosure and vented to the hygiene 

baghouse. The total estimated air flow removal from the enclosure will be 83,000 acfm. 

The air drawn to the new Torit baghouse will come from two distinct ducts. One 40” duct will 

transport air collected from the previously mentioned horseshoe vent. The second extraction point will 

be from the top of a new inner shroud, similar to a chimney, that will extend down from the roof to a 

height of approximately 15’ above the floor and immediately surround the blast furnace. Air will be 

drawn from the building interior into the bottom of the shroud and pulled upward toward a 40” duct. 

This is expected to remove the majority of heat released from the blast furnace. The two 40” ducts will 

combine into a single 56” duct before entering the Torit baghouse. 

 E. Application Information: 

Received on: May 3, 2007 

Information Requested: June 1, 2007 

Application Complete: June 20, 2007 
II. Rule Applicability

This project is subject to the preconstruction review requirements of Chapter 403, Florida Statutes, 

Chapters, 62-204, 62-210, 62-212, 62-296, and 62-297, Florida Administrative Code (F.A.C.) and 

Chapter 1-3 of the Rules of the Environmental Protection Commission of Hillsborough County. 

 This project is not subject to the requirements of Rule 62-212.400, Prevention of Significant 

Deterioration, F.A.C. or Rule 62-212.500, New Source Review for Nonattainment Areas, F.A.C., 

since the project is below the significant emission increase levels for SO2, NOx, CO, VOC, PM/PM10 

and Pb (see Part I – Section C). 

 This project is subject to the requirements of Rule 62-212.300, Sources Not Subject to Prevention of 

Significant Deterioration or Nonattainment Requirements, F.A.C., since it is a source of air pollution 

requiring a permit under this rule. 

This project is subject to the requirements of Rule 62-213, Operation Permits for Major Sources of Air 

Pollution, F.A.C., since the facility is a major source by state definition. 

 This project is subject to the requirements of Rule 62-296.320, General Pollutant Emission Limiting 

Standards, F.A.C., since the project is a source of PM, Pb, SO2, VOC, NOx, and CO, and has a 

potential to emit odors. 

 This project is not subject to the requirements of Rule 62-296.401 through 62-296.417, Specific 

Emission Limiting and Performance Standards, F.A.C., since there is no applicable source specific 

category in this rule. 

 This project is not subject to the requirements of Rule 62-296.500, Reasonably Available Control 

Technology for VOC and NOX Emitting Facilities, F.A.C., since there is no applicable source specific 

category in this rule. 

 This project is subject to the requirements of Rule 62-296.600, Reasonably Available Control 

Technology - Lead, F.A.C., since the source falls under Secondary Lead Smelting Operations (Rule 

62-296.603, F.A.C.). 

 This project is subject to the requirements of Rule 62-296.700, Reasonably Available Control 

Technology Particulate Matter, F.A.C., since the source falls under Miscellaneous Manufacturing 

Process Operations (Rule 62-296.712, F.A.C.). 

 This project is subject to the requirements of Rule 62-204.800, Federal Regulations Adopted by 

Reference, F.A.C., since the facility is subject to the requirements in 40 CFR 60, Subpart L (Standards 

of Performance for Secondary Lead Smelters) and 40 CFR 63, Subpart X (National Emission 

Standards for Hazardous Air Pollutants from Secondary Lead Smelting). 

 This project is subject to the requirements of Chapter 84-446, Laws of Florida and Chapter 1-3, Rules 

of the Environmental Protection Commission of Hillsborough County. 
III. Summary of Emissions

 

 Emission Unit/ 

Regulated Current Future Allowable 

Pollutants Actual Emissions Actual Emissions (PTE) Emissions 

 TPY TPY 

EU015 – Blast Furnace Enclosure 

 (including previously unconfined emissions from blast furnace) 

 

PM 15.6 9.8 0.004 gr/dscf 

Pb 0.39 0.21 0.000085 gr/dscf 

Opacity N/A N/A 3%

 

EU001 – Blast Furnace 

 

SO2 847 886 N/A 

NOx 41.7 81 N/A 

CO 812 911 N/A 

VOC 57.8 89.4 102 ppm 

PM 1.6 12.0 0.011 gr/dscf 

Pb 0.37 0.78 0.00072 gr/dscf 

Opacity N/A N/A 3% 

EU004 – Furnace Tapping and Charging 

 

VOC 2.1 10.0 18 ppm 

PM 0.9 7.4 0.011 gr/dscf 

Pb 0.10 0.42 0.00062 gr/dscf 

Opacity N/A N/A 3% 

The emission units are subject to PM-RACT, Pb-RACT, 40 CFR 60 – Subpart L, and 40 CFR 63 – 

Subpart X. With the exception of NOx, the current actual emissions were calculated using 5 years 

worth of stack test data from the previous 10-year period. The calculation for SO2 also included data 

acquired from the SO2 CEM. The details of the calculations of emissions are discussed in Part I – 

Section C of this Technical Evaluation. 

In order to limit their PTE and avoid PSD with this project, the facility elected to accept more stringent 

emission limits than required by the applicable regulations for all of the pollutants listed, with the 

exception of PM for both EU001 and EU004. These PSD-avoidance allowable emissions will be 

specified in the permit. Credit for improved control of PM and Pb by the enclosure was included in the 

PSD determination. PM, Pb and VOC emissions were based on air flow ratings of 29,000 dscfm for 

the blast furnace baghouse, 18,000 dscfm for the hygiene baghouse, and 65,000 acfm for the new 

enclosure baghouse. 

Inventory of Title III pollutants is not estimated to be greater than 10 TPY individually and greater 

than 25 TPY collectively. 
IV. Conclusions: 

The emission limits proposed by the applicant will meet all of the requirements of Chapters 62-204, 62-

210, 62-212, 62-296, and 62-297, F.A.C., and Chapter 1-3, Rules of the Commission. 

 The General and Specific Conditions listed in the proposed permit (attached) will assure compliance 

with all the applicable requirements of Chapters 62-204, 62-210, 62-212, 62-296, and 62-297, F.A.C. 

V. Proposed Agency Action: 

Pursuant to Section 403.087, Florida Statutes and Rule 62-4.070, Florida Administrative Code the 

Environmental Protection Commission of Hillsborough County hereby gives notice of its intent to issue 

a permit to construct the aforementioned air pollution source in accordance with the draft permit and 

its conditions as stipulated (see attached). 
CERTIFIED MAIL 

In the Matter of an 

Application for Permit by: 

Mr. John Tapper File No.: 0570057-018-AC 

Chief Operating Officer County: Hillsborough 

EnviroFocus Technologies, LLC 

1901 N. 66th Street 

Tampa, FL 33619 

__________________________________/ 

INTENT TO ISSUE

The Environmental Protection Commission of Hillsborough County (EPC), as delegated by the Florida 

Department of Environmental Protection (DEP) gives notice of its intent to issue a permit (copy attached) for 

the proposed project as detailed in the application specified above, for the reasons stated below. 

 The applicant, EnviroFocus Technologies, LLC, applied on May 3, 2007 to the EPC for a permit to 

construct an enclosure for the existing blast furnace area and to increase the lead production limit from the blast 

furnace for their secondary lead smelting facility located at 1901 N. 66th Street, Tampa, FL 33619. 

Particulate Matter (PM) and Lead (Pb) emissions from the new enclosure building will be controlled by a 

65,000 acfm Torit Downflo Oval Cartridge dust collector (Model #DFO 4-96). Carbon Monoxide and 

Volatile Organic Compound emissions from the existing blast furnace are controlled by an afterburner, Sulfur 

Dioxide emissions are controlled through use of a desulfurization system, and PM and Pb emissions are 

controlled through use of a 34,000 acfm baghouse. To allow for the production increase, the facility has 

accepted stricter emission limits than currently required in order to avoid the applicability of Rule 62-212.400, 

F.A.C. – Prevention of Significant Deterioration. 

 The EPC has permitting jurisdiction under Chapter 403 Florida Statutes (F.S.) and Florida 

Administrative Code (F.A.C.) Chapters 62-4 and 62-210. The project is not exempt from permitting 

procedures. The EPC has determined that an air pollution construction permit is required to commence 

construction at the described facility. 

 The EPC intends to issue this permit based on the belief that reasonable assurances have been provided 

to indicate that operation of the source will comply with the appropriate provisions of Florida Administrative 

Code (F.A.C.) Chapters 62-204 through 62-297 and 62-4. 

Pursuant to Section 403.815 and 403.0872, F.S. and Rules 62-103.150 and 62-210.350(3), F.A.C., 

you (the applicant) are required to publish at your own expense the enclosed Notice of Intent to Issue Permit. 

The notice shall be published one time as soon as possible, in the legal advertisement section of a newspaper of 
general circulation in the area affected. For the purpose of this rule, "publication in a newspaper of general 

circulation in the area affected" means publication in a newspaper meeting the requirements of Sections 50.011 

and 50.031, F.S., in the county where the activity is to take place. Where there is more than one newspaper of 

general circulation in the county, the newspaper used must be one with significant circulation in the area that 

may be affected by the permit. If you are uncertain that a newspaper meets these requirements, please contact 

the EPC at the address or telephone number listed below. The applicant shall provide proof of publication 

to the EPC, Air Permitting Section, at 3629 Queen Palm Dr., Tampa, Florida 33619 (Phone 813-627-

2600 - FAX 813-627-2660) within 7 (seven) days of publication. Failure to publish the notice and provide 

proof of publication within the allotted time may result in the denial of the permit pursuant to Rule 62-

103.150(6), F.A.C. 

 The EPC will issue the final permit with the attached conditions unless a timely petition for an 

administrative hearing is filed pursuant to Section 120.569 and 120.57 F.S. before the deadline for filing a 

petition. The procedures for petitioning for a hearing are set forth below. 

A person whose substantial interests are affected by the proposed permitting decision may petition for 

an administrative proceeding (hearing) under Sections 120.569 and 120.57, F.S. The petition must contain the 

information set forth below and must be filed (received) in the Legal Department of the EPC at 3629 Queen 

Palm Dr., Tampa, Florida 33619, Phone 813-627-2600, Fax 813-627-2602. Petitions filed by the permit 

applicant or any of the parties listed below must be filed within 14 (fourteen) days of receipt of this notice of 

intent. Petitions filed by any persons other than those entitled to written notice under Section 120.60(3), F.S. 

must be filed within 14 (fourteen) days of publication of the public notice or within 14 (fourteen) days of 

receipt of this notice of intent, whichever occurs first. Under Section 120.60(3), however, any person who 

asked the EPC for notice of agency action may file a petition within 14 (fourteen) days of receipt of that notice, 

regardless of the date of publication. A petitioner shall mail a copy of the petition to the applicant at the 

address indicated above, at the time of filing. The failure of any person to file a petition within the appropriate 

time period shall constitute a waiver of that person's right to request an administrative determination (hearing) 

under Sections 120.569 and 120.57, F.S.; or to intervene in this proceeding and participate as a party to it. 

Any subsequent intervention will be only at the approval of the presiding officer upon the filing of a motion in 

compliance with Rule 28-106.205, F.A.C. 

A petition that disputes the material facts on which the EPC’s action is based is required to contain the 

following information: 

(a) The name and address of each agency affected and each agency’s file or identification number if 

known; 

(b) The name, address, and telephone number of the petitioner and the name, address, and telephone 

number of each petitioner’s representative, if any, which shall be the address for service purposes during the 

course of the proceedings; and an explanation of how the petitioner’s substantial interests will be affected by 

the EPC’s determination; 

(c) A statement of how and when the petitioner received notice of the EPC action; 

(d) A statement of all disputed issues of material fact. If there are none, the petition must so 

indicate; 

(e) A concise statement of the ultimate facts alleged, including the specific facts the petitioner contends 

warrant reversal or modification of the EPC’s proposed action; 

(f) A statement of specific rules or statutes that the petitioner contends requires reversal or 

modification of the EPC’s proposed action, including an explanation of how the alleged facts relate to the 

specific rules or statutes; and 

(g) A statement of the relief sought by the petitioner, stating precisely the action petitioner wishes the 
EPC to take with respect to the EPC’s proposed action. 

A petition that does not dispute the material facts upon which the EPC’s action is based shall state that 

no such facts are in dispute and otherwise shall contain the same information as set forth above as required by 

Rule 28-106.301, F.A.C. 

Because the administrative hearing process is designed to formulate final agency action, the filing of a 

petition means that the EPC's final action may be different from the position taken by it in this notice of intent. 

Persons whose substantial interests will be affected by any such final decision of the EPC on the application 

have the right to petition to become a party to the proceeding, in accordance with the requirements set forth 

above. 

Mediation under section 120.573, F.S. is not available in this proceeding. 

 

 This action is final and effective on the date filed with the Clerk of the EPC unless a petition is filed in 

accordance with above. Upon the timely filing of a petition, this order will not be effective until further order 

of the EPC. 

In addition to the above, a person subject to regulation has a right to apply to the Department of 

Environmental Protection for a variance from or waiver of the requirements of particular rules, on certain 

conditions, under Section 120.542, F.S. The relief provided by this state statute applies only to state rules, not 

statutes, and not to any federal regulatory requirements. Applying for a variance or waiver does not substitute 

or extend the time for filing a petition for an administrative hearing or exercising any other right that a person 

may have in relation to the action proposed in this notice of intent. 

 The application for a variance or waiver is made by filing a petition with the Office of General Counsel 

of the Department of Environmental Protection, 3900 Commonwealth Boulevard, Mail Station #35, 

Tallahassee, FL 32399-3000. The petition must specify the following information: 

(a) The name, address, and telephone number of the petitioner, 

(b) The name, address, and telephone number of the attorney or qualified representative of the 

petitioner, if any, 

(c) Each rule or portion of a rule from which a variance or waiver is requested, 

(d) The citation to the statute underlying (implemented by) the rule identified in (c) above, 

(e) The type of action requested, 

(f) The specific facts that would justify a variance or waiver for the petitioner, 

(g) The reason by the variance or waiver would serve the purposes of the underlying statute 

(implemented by the rule), and 

(h) A statement whether the variance or waiver is permanent or temporary and, if temporary, a 

statement of the dates showing the duration of the variance or waiver requested. 

 The Department will grant a variance or waiver when the petition demonstrates both that the 

application of the rule would create a substantial hardship or violate principles of fairness, as each of the those 

terms is defined in Section 120.542(2), F.S., and that the purpose of the underlying statute will be or has been 

achieved by other means by the petitioner. 

Persons subject to regulation pursuant to any federally delegated or approved air program should be 

aware that Florida is specifically not authorized to issue variances or waivers from any requirements of any 

such federally delegated or approved program. The requirements of the program remain fully enforceable by 
the Administrator of United States Environmental Protection Agency and by any person under the Clean Air 

Act unless and until the Administrator separately approves any variance or waiver in accordance with the 

procedures of the federal program. 

Any person listed below may request to obtain additional information, a copy of the application (except 

for information entitled to confidential treatment pursuant to Section 403.111, F.S.), all relevant supporting 

materials, and all other materials available to the EPC that are relevant to the permit decision. Interested 

persons may contact Diana M. Lee, P.E., at the above address or call (813) 627-2600, for additional 

information. 

Any party to this order has the right to seek judicial review of it under Section 120.68 of the Florida 

Statues, by filing a notice of appeal under rule 9.110 of the Florida rules of Appellate Procedure with the 

EPC’s Legal Office at 3629 Queen Palm Dr., Tampa, Florida 33619 and with the clerk of the Department of 

Environmental Protection in the Office of General Counsel, Mail Station 35, 3900 Commonwealth Boulevard, 

Tallahassee, Florida 32399-3000, and by filing a copy of the notice of appeal accompanied by the applicable 

filing fees with the appropriate district court of appeal. The notice must be filed within thirty days after this 

order is filed with the clerk of the Department. 

 Executed in Tampa, Florida 

 ENVIRONMENTAL PROTECTION COMMISSION 

 OF HILLSBOROUGH COUNTY 

 __________________________________ 

 Richard D. Garrity, Ph.D. 

 Executive Director 

cc: Russell S. Kemp, P.E., ENVIRON International Corp. 

Florida Department of Environmental Protection, Southwest District (e-mail) 
CERTIFICATE OF SERVICE

The undersigned duly designated clerk hereby certifies that this INTENT TO ISSUE and all copies 

were mailed before the close of business on _________________ to the listed persons. 

 FILING AND ACKNOWLEDGEMENT 

 FILED, on this date, pursuant to Section 120.52(7), Florida Statutes, with 

the designated clerk, receipt of which is hereby acknowledged. 

 _____________________ _____________ 

 Clerk Date 
ENVIRONMENTAL PROTECTION COMMISSION 

OF HILLSBOROUGH COUNTY 

NOTICE OF INTENT TO ISSUE PERMIT 

The Environmental Protection Commission of Hillsborough County (EPC), as delegated by the 

Florida Department of Environmental Protection (DEP) gives notice of its intent to issue air pollution 

permit no. 0570057-018-AC to EnviroFocus Technologies, LLC for the construction of an enclosure for 

the existing blast furnace area and for an increase in the lead production limit from the blast furnace for their 

secondary lead smelting facility. Particulate Matter (PM) and Lead (Pb) emissions from the new enclosure 

building will be controlled by a 65,000 acfm Torit Downflo Oval Cartridge dust collector (Model #DFO 4-96). 

Carbon Monoxide and Volatile Organic Compound emissions from the existing blast furnace are controlled by 

an afterburner, Sulfur Dioxide emissions are controlled through use of a desulfurization system, and PM and Pb 

emissions are controlled through use of a 34,000 acfm baghouse. To allow for the production increase, the 

facility has accepted stricter emission limits than currently required in order to avoid the applicability of Rule 

62-212.400, F.A.C. – Prevention of Significant Deterioration. The facility is located at 1901 N. 66th Street, 

Tampa, FL 33619 in Hillsborough County. 

A Best Available Control Technology (BACT) determination was not required. 

 The EPC will issue the Final permit with the conditions of the DRAFT permit unless a timely petition 

for an administrative hearing is filed pursuant to Sections 120.569 and 120.57, F.S. before the deadline for 

filing a petition. The procedures for petitioning for hearing are set forth below. 

A person whose substantial interests are affected by the proposed permitting decision may petition for 

an administrative proceeding (hearing) under Sections 120.569 and 120.57, F.S. The petition must contain the 

information set forth below and must be filed (received) in the Legal Department of the EPC at 3629 Queen 

Palm Dr., Tampa, Florida 33619, Phone 813-627-2600, Fax 813-627-2602. Petitions filed by the permit 

applicant or any of the parties listed below must be filed within 14 (fourteen) days of receipt of this notice of 

intent. Petitions filed by any persons other than those entitled to written notice under Section 120.60(3), F.S. 

must be filed within 14 (fourteen) days of publication of the public notice or within 14 (fourteen) days of 

receipt of this notice of intent, whichever occurs first. Under Section 120.60(3), however, any person who 

asked the EPC for notice of agency action may file a petition within 14 (fourteen) days of receipt of that notice, 

regardless of the date of publication. A petitioner shall mail a copy of the petition to the applicant at the 

address indicated above, at the time of filing. The failure of any person to file a petition within the appropriate 

time period shall constitute a waiver of that person's right to request an administrative determination (hearing) 

under Sections 120.569 and 120.57, F.S., or to intervene in this proceeding and participate as a party to it. 

Any subsequent intervention will be only at the approval of the presiding officer upon the filing of a motion in 

compliance with Rule 28-106.205 of the F.A.C. 

A petition that disputes the material facts on which the EPC’s action is based is required to contain the 

following information: 

(a) The name and address of each agency affected and each agency’s file or identification number if 

known; 

(b) The name, address, and telephone number of the petitioner, and the name, address, and telephone 

number of each petitioner’s representative, if any, which shall be the address for service purposes during the 

course of the proceedings; and an explanation of how the petitioner’s substantial interests will be affected by 

the agency determination; 
(c) A statement of how and when petitioner received notice of the EPC action; 

(d) A statement of all disputed issues of material fact. If there are none, the petition must so indicate; 

(e) A concise statement of the ultimate facts alleged, including the specific facts the petitioner contends 

warrant reversal or modification of the EPC proposed action; 

(f) A statement of specific rules or statutes the petitioner contends requires reversal or modification of 

the EPC’s proposed action, including an explanation of how the alleged facts relate to the specific rules or 

statutes; and 

(g) A statement of the relief sought by the petitioner, stating precisely the action petitioner wishes the 

EPC to take with respect to the EPC’s proposed action. 

A petition that does not dispute the material facts upon which the EPC’s action is based shall state that 

no such facts are in dispute and otherwise shall contain the same information as set forth above as required by 

Rule 28-106.301. 

Because the administrative hearing process is designed to formulate final agency action, the filing of a 

petition means that the EPC's final action may be different from the position taken by it in this notice of intent. 

Persons whose substantial interests will be affected by any such final decision of the EPC on the application 

have the right to petition to become a party to the proceeding, in accordance with the requirements set forth 

above. 

Mediation under section 120.573, F.S. is not available in this proceeding. 

 This action is final and effective on the date filed with the Clerk of the EPC unless a petition is filed in 

accordance with above. Upon the timely filing of a petition this order will not be effective until further order of 

the EPC. 

Any party to this order has the right to seek judicial review of it under Section 120.68 of the Florida 

Statues, by filing a notice of appeal under rule 9.110 of the Florida rules of Appellate Procedure with the 

EPC’s Legal Office at 3629 Queen Palm Dr., Tampa, Florida 33619 and with the clerk of the Department of 

Environmental Protection in the Office of General Counsel, Mail Station 35, 3900 Commonwealth Boulevard, 

Tallahassee, Florida 32399-3000, and by filing a copy of the notice of appeal accompanied by the applicable 

filing fees with the appropriate district court of appeal. The notice must be filed within thirty days after this 

order is filed with the clerk of the Department. 

 The complete project file is available for public inspection during normal business hours, 8:00 a.m. to 

5:00 p.m., Monday through Friday, except legal holidays, at the Environmental Protection Commission of 

Hillsborough County, 3629 Queen Palm Dr., Tampa, FL 33619. The complete project file includes the 

proposed Permit, the application, and the information submitted by the responsible official, exclusive of 

confidential records under Section 403.111, F.S. Interested persons may contact Diana M. Lee, P.E., at the 

above address, or call 813-627-2600, for additional information. Any written comments filed shall be available 

for public inspection. If written comments received result in a significant change in the proposed agency 

action, the EPC shall revise the proposed permit and require, if applicable, another Public Notice. 

 
ENVIRONMENTAL PROTECTION COMMISSION OF 

HILLSBOROUGH COUNTY, as Delegated by 

STATE OF FLORIDA 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

NOTICE OF PERMIT 

Mr. John Tapper 

Chief Operating Officer 

EnviroFocus Technologies, LLC 

1901 N. 66th Street 

Tampa, FL 33619 

Dear Mr. Tapper: 

Re: Hillsborough County - AP 

Enclosed is Permit Number 0570057-018-AC to construct an enclosure for the existing blast furnace area and 

to increase the lead production limit from the blast furnace at your secondary lead smelting facility located at 

1901 N. 66th Street, Tampa, FL 33619, issued pursuant to Section 403.087, Florida Statutes. 

Any party to this order (permit) has the right to seek judicial review of the permit pursuant to Section 120.68, 

Florida Statutes, by the filing of a Notice of Appeal pursuant to Rule 9.110, Florida Rules of Appellate 

Procedure, with the Clerk of the EPC in the Legal Department at 3629 Queen Palm Dr., Tampa, FL 33619; 

and by filing a copy of the Notice of Appeal accompanied by the applicable filing fees with the appropriate 

District Court of Appeal. The Notice of Appeal must be filed within 30 days from the date this Notice is filed 

with the clerk of the EPC. 

Executed in Tampa, Florida. 

 Sincerely, 

 Richard D. Garrity, Ph.D. 

 Executive Director 

RDG/JDS/jds 

cc: Russell S. Kemp, P.E., ENVIRON International Corp. 

Florida Department of Environmental Protection, Southwest District (e-mail) 
EnviroFocus Technologies, LLC Page Two 

Tampa, FL 33619 

CERTIFICATE OF SERVICE

This is to certify that this NOTICE OF PERMIT and all copies were mailed before the close of 

business on _________________________ to the listed persons. 

 Clerk Stamp 

FILED, on this date, pursuant to Section 120.52(7), Florida 

Statutes, with the designated clerk, receipt of which is hereby 

acknowledged. 

 

 

 ___________________________ _____________ 

 Clerk Date 
Page 1 of 18 

PERMITTEE: PERMIT/CERTIFICATION 

EnviroFocus Technologies, LLC Permit No.: 0570057-018-AC 

1901 N. 66th Street County: Hillsborough 

Tampa, FL 33619 Expiration Date: March 11, 2009 

 Project: Blast Furnace Enclosure/ 

 Production Limit Increase 

This permit is issued under the provisions of Chapter 403, Florida Statutes, and Florida Administrative Code 

Rules 62-204, 62-210, 62-212, 62-296, 62-297, and 62-4. The above named permittee is hereby authorized to 

perform the work or operate the facility shown on the application and approved drawing(s), plans, and other 

documents, attached hereto or on file with the EPC and made a part hereof and specifically described as 

follows: 

For the construction of an enclosure (EU No. 015) around the existing blast furnace area and for the increase 

in the lead production limit from the blast furnace at the secondary lead smelting facility. The new enclosure 

will be identified as Blast Furnace Enclosure. 

The facility recycles spent automotive and industrial lead-acid batteries to produce lead ingots. Batteries arrive 

at the facility by truck and are off-loaded directly to the battery process area. The batteries first go through a 

shredder where most of the acid is drained. They then pass through a hammer mill that serves as the primary 

crusher. The crushed material then passes through counter current, flotation, and separation equipment that 

separates the metallic lead, plastic, and lead salts or muds. The metallic lead and small amounts of plastic and 

rubber are all conveyed to the material charging storage area. The muds are slurried with soda ash to form lead 

carbonate and sodium sulfate that are separated in a filter process. The press cake is also sent to the material 

charging storage area. The M.A. 41DS Battery Recycling System is designed to reduce the sulfur content of 

the blast furnace feed stock and resulting sulfur dioxide emissions from the furnace. 

Lead-bearing materials from the processed batteries are stored in piles in a partially enclosed structure. 

Batteries for the blast furnace charge are taken from the older piles, and a single 36” x 72” oval Blast 

Furnace is used for producing molten lead from the various materials charged into the blast furnace. The 

blast furnace charge is approximately composed of 85% lead-bearing materials, 8-12% coke, 2.5% limerock, 

and 2.5% cast iron. Lead-bearing materials may include, but are not limited to, CRTs, re-run slag, and 

indigenous materials such as respirators, baghouse dust, and treatment plant sludge. Material is charged via a 

mechanical skip hoist with automatically opened charged doors at the top of the furnace. Blast furnace 

operations are limited by the amount of blast lead produced annually. 

Lead and slag are both tapped and collected at the base of the furnace. Lead is tapped to form buttons, 

which are sold or transported to the refining area. The refining operation is not affected by this 

construction permit. CO and VOC flue gas emissions from the blast furnace are controlled by the use of 
Page 2 of 18 

a 10 MMBtu/hr afterburner. Particulate matter and lead emissions directly from the blast furnace are 

controlled by enclosures and a 34,000 acfm ten compartment baghouse fabricated by Gulf Coast 

Recycling, Inc., which was modeled after a Wheelabrator-Frye Dustube Model 126, Series 55 shaker 

baghouse. Emissions from the blast furnace charging, skiphoist, and blast furnace tapping emissions are 

captured by hoods or enclosures and vented to an approximately 20,000 ACFM, three compartment, 

shaker baghouse similar in design to the previously mentioned baghouse. Note that all flow rates listed 

herein are estimates based on a review of the history of flow rates recorded during the annual compliance 

tests. 

The blast furnace enclosure will cover approximately 10,000 ft2and surround the blast furnace area by 

installing permanent walls and connecting to the existing roof. A 14’x14’ overhead “speed door” will be 

installed between the blast furnace area and the refining area to allow for easier movement of equipment back 

and forth. Two 14’x14’ manual overhead doors along with an 8’x14’ manual overhead door will also be 

installed for equipment movement into and out of the blast furnace area; however, these doors will typically 

remain closed. There will also be three man doors for employee access and a 10’x10’ hinged door for 

occasional access to the blast furnace for crucible removal and other maintenance activities. Finally, there will 

be a permanent 12.7’x20’ opening left between the blast furnace area and the feed material containment room 

to allow for frequent traffic between the rooms. A “horseshoe” type hood will be placed around the perimeter 

of the opening and approximately 32,500 acfm will be drawn to create a null air flow within the opening. This 

was done to prevent migration of fugitive emissions back and forth between the enclosures. 

The blast furnace enclosure will be maintained under a negative pressure and be vented through a 65,000 acfm 

Torit Downflo Oval Cartridge dust collector (Model #DFO 4-96). The dust collector has 96 filter cartridges, 

total filter media area of 18,420 ft2, and an air:cloth ratio of 3.5:1, and is cleaned using pulsed-jet. The final 

exhaust is out an 80’ stack. The enclosure includes the operation of the “hygiene” baghouse, so additional 

airflow is being drawn from the enclosure and vented to the hygiene baghouse. The total estimated air flow 

removal from the enclosure will be 83,000 acfm. 

The air drawn to the new Torit baghouse will come from two distinct ducts. One 40” duct will transport air 

collected from the previously mentioned horseshoe vent. The second extraction point will be from the top of a 

new inner shroud, similar to a chimney, that will extend down from the roof to a height of approximately 15’ 

above the floor and immediately surround the blast furnace. Air will be drawn from the building interior into 

the bottom of the shroud and pulled upward toward a 40” duct. This is expected to remove the majority of 

heat released from the blast furnace. The two 40” ducts will combine into a single 56” duct before entering the 

Torit baghouse. 

This permit also allows for an increase in the annual lead production from the blast furnace from 26,500 ton/yr 

to 32,000 ton/yr. A related change in the approximate maximum charging rate to the furnace from 6.5 ton/hr 

to 7.9 ton/hr was included in the request. The increase in production is to be achieved through a more efficient 

process with increased automation and monitoring of the system along with a reduction in maintenance 

downtime. To allow for the production increase, the facility has accepted stricter emission limits than currently 

required in order to avoid the applicability of Rule 62-212.400, F.A.C. – Prevention of Significant 

Deterioration. Credit for improved control of PM and Pb by the enclosure was included in the PSD 

determination. 

An amended version of the Baghouse Standard Operation and Maintenance Procedures Manual has been 

attached to this permit to allow flexibility for replacement of bag leak detectors in the baghouses. An updated 
Page 3 of 18 

version of this manual will be required from the permittee following any replacement of bag leak detectors.

The facility is subject to PM and Pb RACT, NSPS requirements of 40 CFR 60 – Subpart L, and the 

MACT requirements of Subpart X of the NESHAP for Pb and VOC. Visible emission testing and stack 

testing will be required on the enclosure openings and baghouse exhaust for the new enclosure. 

Additional testing in the doorways of the enclosure will also be required to ensure negative draft into the 

building. Stack testing of multiple pollutants will also be required on the blast furnace in conjunction with 

the increase in production. 

Location: 1901 N. 66th Street, Tampa 

UTM: 17-364.0E 3093.5N NEDS NO: 0057 

EU ID No.: 001 – Blast Furnace Exhaust 

 004 – Blast Furnace Tapping and Charging 

 015 – Blast Furnace Enclosure 

Replaces Permit Nos.: N/A 

References Permit No.: 0570057-016-AV 
PERMITTEE: PERMIT/CERTIFICATION NO.: 0570057-018-AC 

EnviroFocus Technologies, LLC PROJECT: Blast Furnace Enclosure/Production Increase 

Page 4 of 18 

Facility-wide Conditions:

Subsection A

A.1. A part of this permit is the attached General Conditions. [Rule 62-4.160, F.A.C.] 

A.2. Issuance of this permit does not relieve the permittee from complying with all applicable emission limiting 

standards or other requirements of Chapters 62-204, 62-210, 62-212, 62-296 and 62-297, F.A.C., or any other 

requirements under federal, state, or local law. [Rule 62-210.300, F.A.C.] 

A.3. General Pollutant Emission Limiting Standards. Objectionable Odor Prohibited. The permittee shall 

not cause, suffer, allow, or permit the discharge of air pollutants which cause or contribute to an 

objectionable odor. 

[Rule 62-296.320(2), F.A.C.] 

A.4. General Particulate Emission Limiting Standards. General Visible Emissions Standard. Except for 

emissions units that are subject to a particulate matter or opacity limit set forth or established by rule and 

reflected by conditions in this permit, no person shall cause, let, permit, suffer or allow to be discharged 

into the atmosphere the emissions of air pollutants from any activity, the density of which is equal to or 

greater than that designated as Number 1 on the Ringelmann Chart (20 percent opacity). EPA Method 9 

is the method of compliance pursuant to Chapter 62-297. F.A.C.. 

[Rule 62-296.320(4)(b)1. & 4, F.A.C.] 

A.5. Prevention of Accidental Releases (Section 112(r) of CAA).

A) The permittee shall submit its Risk Management Plan (RMP) to the Chemical Emergency 

Preparedness and Prevention Office (CEPPO) RMP Reporting Center when, and if, such 

requirement becomes applicable. Any Risk Management Plans, original submittals, revisions or 

updates to submittals, should be sent to: 

RMP Reporting Center 

Post Office Box 3346 

Merrifield, VA 22116-3346 

Telephone: 703/816-4434 

and, 

B) The permittee shall submit to the permitting authority Title V certification forms or a compliance 

schedule in accordance with Rule 62-213.440(2), F.A.C. 

[40 CFR 68] 

A.6. The use of property, facilities, equipment, processes, products, or compounds, or the commission of paint 

overspraying or any other act, that causes or materially contributes to a public nuisance is prohibited, pursuant 

to the Hillsborough County Environmental Protection Act, Section 16, Chapter 84-446, Laws of Florida, as 

Amended. 
PERMITTEE: PERMIT/CERTIFICATION NO.: 0570057-018-AC 

EnviroFocus Technologies, LLC PROJECT: Blast Furnace Enclosure/Production Increase 

Page 5 of 18 

A.7. No owner or operator of a lead processing operation shall cause, allow, or permit the emissions of lead 

or particulate matter (PM), including emissions of lead or PM from vehicular movement, transportation of 

materials, construction, alteration, demolition or wrecking, or industrial-related activities such as loading, 

unloading, charging, melting, tapping, casting, storing or handling, unless reasonably available control 

technology and maximum available control technology are employed to control such lead emissions. RACT 

and MACT measures shall include, but not be limited to, the following: 

[Rules 62-296.601(2), 62-296.320(4)(c)2. and 62-4.070(3), F.A.C., 40 CFR 63 Subpart X, Consent Order 

of September 4, 1996, and Construction Permit Nos. 0570057-002,008,009, 010-AC] 

A) Maintain enclosed screw conveyor below the furnace baghouse hoppers to prevent re-entrained dust. 

B) Maintain wind breaks and panels installed along the south side of the furnace baghouse support 

structure, south and west sides of group pile storage building, and windbreak installed along the entire 

south property boundary. 

C) Minimize vehicular traffic on unpaved areas. 

D) Maintain vegetation coverage on all of the unpaved plant grounds. 

E) Three times daily, regardless of plant operation, vacuum paved traffic areas using a HEPA filter 

equipped vacuum, except when natural precipitation makes it impractical. For all other paved areas 

such as the furnace area, the refining area, and the battery breaking area, use a directed water wash 

three times daily regardless of plant operation. The directed water wash will be to clean pavement and 

to collect settled dust. Simply wetting the area will not constitute a directed water wash. 

F) Maintain a tire wash, or utilize pressure washing techniques, for the front-end loaders and forklifts used 

in the battery pile storage building to prevent tracking of lead bearing materials outside the roofed areas 

of the plant. 

G) Minimize slag transfer with front-end loader through the plant. Store, handle, and process slag in 

enclosed structures. 

H) Use only trained personnel for furnace operations. 

I) Maintain the sprinkler system and operate it in accordance with the sprinkler plan as detailed in the SOP 

for the Control of Fugitive Emissions (attached to Title V operating permit). 

J) Water the lead-bearing materials in the group battery storage pile building with sufficient frequency and 

quantity to prevent the formation of dust. 

K) Maintain the partial enclosure in the refining and furnace areas and the battery breaking area. 

L) Maintain the partial enclosure in the furnace area, apply wet suppression for the storage of any lead 

bearing materials (excluding lead buttons), and maintain a vehicle wash at the exit of the area. 

M) Maintain daily records of all wet suppression, pavement cleaning and vehicle washing activities as per 

the SOP for the Control of Fugitive Emissions. 

N) Using hoods, fans, filters, and similar equipment as detailed in the permitting applications to capture, 

contain, and control lead and particulate matter emissions. 

O) Applying water or chemicals to control emissions from such activities as demolition of buildings, 

grading roads, construction, and land clearing.
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P) Ensure proper operation of the blast furnace tapping and charging collection system, including 

evaluation of its operation following completion of the blast furnace enclosure.

Q) Minimize the generation of emissions during the construction of the new blast furnace enclosure 

wherever practical.

A.8. At all times, including periods of startup, shutdown, and malfunction, the permittee shall operate and 

maintain any affected source, including associated air pollution control equipment, in a manner consistent with 

good air pollution control practices for minimizing emissions at least to the levels required by all relevant 

standards. Determination of whether acceptable operating and maintenance procedures are being used will be 

based on information available to the EPC which may include, but is not limited to, monitoring results, opacity 

observations, review of operating and maintenance procedures, and inspection of the source. Malfunctions 

shall be corrected as soon as practicable after their occurrence in accordance with the startup, shutdown, and 

malfunction plan. [40 CFR 63.6(e)(1)(i) and (ii), 40 CFR 60.11(d), and Rule 62-4.070(3), F.A.C] 

A.9. When appropriate, any recording, monitoring or reporting requirements that are time-specific shall 

be in accordance with the effective date of this permit, which defines day one. 

[Rule 62-213.440(1), F.A.C.] 

A.10. The permittee shall submit all compliance related notifications and reports, data, certifications and 

requests required of this permit to the Environmental Protection Commission of Hillsborough County at: 

Environmental Protection Commission of Hillsborough County 

Air Management Division 

3629 Queen Palm Drive 

Tampa, FL 33619 

Phone: (813) 627-2600 

Fax: (813) 627-2660 

A.11. Any reports, data, notifications, certifications and requests required to be sent to the United States 

Environmental Protection Agency Region 4 should be sent to: 

United States Environmental Protection Agency Region 4 

Air & EPCRA Enforcement Branch 

Air Compliance Section 

61 Forsyth Street 

Atlanta, Georgia 30303 

Phone: (404) 562-9099 

Fax: (404) 562-9095 
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A.12. Submit to the Environmental Protection Commission of Hillsborough County each calendar year on or 

before March 1, completed DEP Form 62-210.900(5), “Annual Operating Report for Air Pollutant Emitting 

Facility”, for the preceding calendar year. [Rule 62-210.370(3), F.A.C.] 

A.13. Statement of Compliance. The annual statement of compliance pursuant to Rule 62-

213.440(3)(a)2., F.A.C., shall be submitted to the Department and EPA within 60 (sixty) days after the 

end of the calendar year using DEP Form No. 62-213.900(7), F.A.C. 

[Rules 62-213.440(3) and 62-213.900, F.A.C.] 

A.14. Notwithstanding any of the other Specific Conditions of this permit, the following Subparts of 40 

CFR 63 A shall apply to this facility: 63.1; 63.2; 63.3; 63.4; 63.5; 63.6(a), (b), (c), (e), (f), (g), (i), and 

(j); 63.7; 63.8; 63.9(a), (b), (c), (d), (e), (g), (h)(1-3), h(5-6), and (j); 63.10; and 63.12-15. 

A.15. When the Environmental Protection Commission of Hillsborough County (EPC) after investigation, has 

good reason (such as complaints, increased visible emissions or questionable maintenance of control 

equipment) to believe that any applicable emission standard contained in Rules 62-204, 62-210, 62-212, 62-

296, or 62-297, F.A.C., or in a permit issued pursuant to those rules is being violated, it may require the owner 

or operator of the source to conduct compliance tests which identify the nature and quantity of pollutant 

emissions from the source and to provide a report on the results of said tests to the EPC. [Rule 62-

297.310(7)(b), F.A.C.] 

A.16. The permittee shall provide timely notification to the Environmental Protection Commission of 

Hillsborough County prior to implementing any changes that may result in a modification to this permit 

pursuant to Rule 62-210.200(187), F.A.C., Modification. The changes do not include normal maintenance, 

but may include, and are not limited to, the following, and may also require prior authorization before 

implementation: 

[Rules 62-210.300 and 62-4.070(3), F.A.C.] 

A) Alteration or replacement of any equipment or major component ofsuch equipment. 

B) Installation or addition of any equipment which is a source of air pollution. 

C) Processing or charging any new materials into the blast furnace or the refining kettles. 

A.17. If the permittee wishes to transfer this permit to another owner, an "Application for Transfer of Permit" 

(DEP Form 62-210.900(7)) shall be submitted, in duplicate, to the Environmental Protection Commission of 

Hillsborough County within 30 days after the sale or legal transfer of the permitted facility. 

[Rule 62-4.120, F.A.C.] 

 

A.18. Certification by Responsible Official (RO). In addition to the professional engineering certification 

required for applications by Rule 62-4.050(3), F.A.C., any application form, report, compliance 

statement, compliance plan and compliance schedule submitted pursuant to Chapter 62-213, F.A.C., shall 

contain a certification signed by a responsible official that, based on information and belief formed after 

reasonable inquiry, the statements and information in the document are true, accurate, and complete. 
PERMITTEE: PERMIT/CERTIFICATION NO.: 0570057-018-AC 

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Any responsible official who fails to submit any required information or who has submitted incorrect 

information shall, upon becoming aware of such failure or incorrect submittal, promptly submit such 

supplementary information or correct information. 

[Rule 62-213.420(4), F.A.C.]

A.19. A minimum of two copies of an operating permit application for a Title V Operating Permit Revision 

shall be submitted to the Environmental Protection Commission of Hillsborough County at least 90 days prior 

to the expiration date of this permit, but no later than 180 days after commencing operation of the new 

blast furnace enclosure. The application shall include the most recent 3 months of records required by this 

permit. 

[Rules 62-213.420(1)(a)4. and 62-210.300(2), F.A.C.] 
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Specific Conditions:

Subsection B

 

EU No. 001 – Blast Furnace Exhaust 

EU No. 004 – Blast Furnace Tapping and Charging 

EU No. 015 – Blast Furnace Enclosure 

B.1. [Reserved.] 

B.2. All applicable rules of the Environmental Protection Commission of Hillsborough County including 

design discharge limitations specified in the application shall be adhered to. The permit holder may also need 

to comply with county, municipal, federal, or other state regulations prior to construction. 

[Rule 62-4.070(7), F.A.C.] 

B.3. [Reserved.] 

B.4. In order to exempt the facility from a PSD review as requested by the permittee, the total emissions from 

the blast furnace operations detailed in this subsection shall not exceed 29.2 tons of particulate matter, 911 tons 

of carbon monoxide, 99 tons of volatile organic compounds, 886 tons of sulfur dioxide, 1.4 tons of lead, and 

81 tons of nitrogen oxides for any consecutive twelve month period. 

[Rules 62-212.300 and 400, F.A.C. and Construction Permit Application received May 3, 2007] 

Enforceable Potential to Emit (PTE) Parameters

B.5. In order to ensure compliance with the emissions limitations of Specific Condition No. B.4, the following 

limitations shall apply: 

[Construction Permit Nos. 0570057-002,008,009-AC and Construction Permit Application received May 3, 

2007] 

A) Hours of operation on the blast furnace operations are continuous (8760 hrs for any 12 consecutive 

month period). 

B) Raw material charging rates on a daily basis shall be consistent with the following approximate 

percentages: 85% lead-bearing materials, 8-12% coke, 2.5% limerock, and 2.5% cast iron. Leadbearing materials may include, but are not limited to, CRTs, re-run slag, and indigenous materials 

such as respirators, baghouse dust, and treatment plant sludge. The following rates represent the 

approximate hourly material input into the blast furnace. 

 Source Process Rate

Blast Furnace 7.9 tons charged/hour 
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C) The total lead produced from the blast furnace operation shall not exceed 32,000 tons for any 12 

consecutive month period. 

D) The total amount of coke used in the blast furnace operation shall not exceed 7,300 tons for any 12 

consecutive month period. 

B.6. The blast furnace enclosure and tapping and charging ventilation systems shall be in operation at all times 

during any blast furnace operation. [Rule 62-4.070(3), F.A.C.] 

Emissions Limitations and Standards

Furnace Operations (One blast furnace, tapping and charging operations for the furnace, and blast 

furnace enclosure around the blast furnace area) 

B.7. The permittee shall not discharge lead emissions to exceed the following: 

 

A) In order to exempt the facility from PSD, the discharge from blast furnace, the furnace charging and 

tapping, and the blast furnace enclosure must meet the following limits. Each vent must meet the 

standards by itself (no averaging). The maximum emission rates shall not exceed the following: 

[Construction Permit Application received May 3, 2007 and Rules 62-4.070(3) and 62-212.400, 

F.A.C.] 

 Emission Limit Tons per 

 (gr/dscf) 12 months

 Blast Furnace Stack 0.00072 0.78 

 Tapping and Charging Stack 0.00062 0.42 

 Blast Furnace Enclosure Stack 0.000085 0.21 

B) 2.0 mg/dscm (0.00087 gr/dscf) for the blast furnace, the process fugitive sources consisting of the 

charging and the tapping, and the discharge from the blast furnace enclosure. Each vent must meet the 

standards by itself (no averaging). [40 CFR 63 Subpart X and Rule 62-204.800 F.A.C.] 

C) 0.010 gr/dscf for the blast furnace [Rule 62-296.603, F.A.C.] 

D) 0.002 gr/dscf for the process fugitive sources consisted of the charging and tapping vented to control 

equipment [Rule 62-296.603, F.A.C.] 

B.8. The permittee shall not discharge particulate matter emissions to exceed the following: 

A) In order to exempt the facility from PSD, the discharge from blast furnace, the furnace charging and 

tapping, and the blast furnace enclosure must meet the following limits. Each vent must meet the 

standards by itself (no averaging). The maximum emission rates shall not exceed the following: 

[Construction Permit Application received May 3, 2007; and Rules 62-4.070(3) and 62-212.400, 

F.A.C.] 
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 Emission Limit Tons per 

 (gr/dscf) 12 months

 Blast Furnace Stack 0.011 12.0 

 Tapping and Charging Stack 0.011 7.4 

 Blast Furnace Enclosure Stack 0.004 9.8 

B) 50 mg/dscm (0.022 gr/dscf) for the discharge from the blast furnace, the tapping and charging sources, 

and the blast furnace enclosure. [40 CFR 60.122(a) and Rule 62-296.800 F.A.C.] 

C) 0.03 gr/dscf for the discharge from the blast furnace, the tapping and charging sources, and the 

blast furnace enclosure. [Rule 62-296.700, F.A.C.] 

B.9. The permittee shall not discharge visible emissions in excess of the following: 

[Rules 62-296.603 and 62-296.712, F.A.C.; and 40 CFR 60.122(a)(2)] 

 

A) 3% from any opening of the blast furnace enclosure or the exit from the blast furnace enclosure 

baghouse. 

B) 3% at the exit of the control equipment controlling the blast furnace and the tapping and charging 

sources. 

B.10. In order to exempt the facility from PSD, the maximum total hydrocarbons (VOC) potential to emit 

from the blast furnace exhaust shall not exceed 89 tons per any 12 consecutive month period, and the blast 

furnace shall not discharge total hydrocarbons (VOC) in excess of 102 ppm by volume, expressed as propane 

corrected to 4 percent C02, to the atmosphere. [Construction Permit Application received May 3, 2007; Rule 

62-212.400, F.A.C.; and 40 CFR 63.543(c)] 

 

B.11. In order to exempt the facility from PSD, the maximum total hydrocarbons (VOC) potential to emit 

from the blast furnace tapping and charging exhaust shall not exceed 10 tons per any consecutive 12-month 

period, and the blast furnace tapping and charging operation shall not discharge total hydrocarbons (VOC) in 

excess of 18 ppm by volume, expressed as propane, to the atmosphere. [Construction Permit Application 

received May 3, 2007; Rule 62-212.400, F.A.C.; and 40 CFR 63.543(g)] 

B.12. In order to exempt the facility from PSD, the maximum carbon monoxide potential to emit from the 

blast furnace exhaust shall not exceed more than 208 pounds per hour or 911 tons per consecutive 12-month 

period emitted to the atmosphere. 

[Construction Permit Application received May 3, 2007; and Rule 62-212.400, F.A.C.] 

B.13. In order to ensure compliance with the emission limiting standards of Specific Condition Nos. 

B.10 and B.12, the permittee shall maintain and operate a natural gas - fired afterburner with a minimum 

temperature and residence time established during the compliance demonstrations required under this 

permit. 

[Construction Permit 0570057-002,008,009-AC, 40 CFR 63 Subpart X, and Rule 62-212.300, F.A.C.] 
PERMITTEE: PERMIT/CERTIFICATION NO.: 0570057-018-AC 

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{Permitting Note: The EPC staff has determined that the monitoring and recordkeeping requirements 

required by the MACT (Pb, VOC) and Pb RACT, along with the CAM Plan for CO and the requirement 

to maintain an SO2 CEM, meet the requirements of periodic monitoring.} 

B.14. In order to exempt the facility from PSD, the maximum sulfur dioxide potential to emit from the blast 

furnace exhaust shall not exceed 886 tons per consecutive 12-month period, and the blast furnace shall not 

discharge more than 55.4 pounds ofsulfur dioxide per ton of lead produced as an annual average, based on a 12-

consecutive month average updated at the beginning of each month. Compliance with this emission limitation 

will be demonstrated by the stack testing requirements of Specific Condition No. B.20 and recordkeeping 

requirements of Specific Condition No. B.41. 

[Construction Permit Application received May 3, 2007; and Rule 62-212.400, F.A.C.] 

B.15. In order to ensure compliance with the emission limiting standard of Specific Condition Nos. B.4 and 

B.14, the permittee shall maintain and operate a M.A. Industries Model 41 Desulfurization System to process 

all incoming batteries prior to charging to the furnace. 

[Construction Permit 0570057-002,008,009-AC; Rule 62-4.070(3), F.A.C.; and Construction Permit 

Application received May 3, 2007] 

B.16. [Reserved.] 

B.17. The blast furnace enclosure shall be ventilated to ensure that the enclosed area achieves an air velocity 

into the enclosure at all doorway openings, excluding the passageway between the enclosure and containment 

room, of not less than 75 meters per minute (250 feet per minute). Allsuch exhaust shall be directed to control 

equipment that shall not discharge lead in excess of the limitations in Specific Condition No. B.7.A). 

[Rule 62-4.070(3), F.A.C.] 

B.18. [Reserved.] 

Testing Methods and Procedures

B.19. The permittee shall test the emissions from the blast furnace enclosure (EU015) for the following 

pollutants within 120 days of completion of construction of the enclosure. Testing of these pollutants shall 

continue annually thereafter. The permittee shall submit 2 copies to the Air Compliance Section of the Air 

Management Division of the Environmental Protection Commission of Hillsborough County within 45 days of 

such testing. Testing procedures shall be consistent with the requirements of the 40 CFR 63 and Rule 62-297, 

F.A.C. The permittee shall also submit a complete notification of the compliance status along with the test 

report in accordance with 40 CFR 63.9(h).[Rule 62-297.310(7)(a)4. and 62-4.070(3), F.A.C.] 
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(X) Pb (Baghouse Exhaust) (X) Opacity (Baghouse Exhaust and Enclosure Doorway Openings) 

(X) PM (Baghouse Exhaust) (X) Face Velocity (Enclosure Doorway Openings)

B.20. The permittee shall test the emissions from the following emission units for the following pollutants 

within 120 days of completion of construction of the enclosure. Testing of these pollutants shall continue 

annually thereafter. The permittee shall submit 2 copies to the Air Compliance Section of the Air Management 

Division of the Environmental Protection Commission of Hillsborough County within 45 days of such testing. 

Testing procedures shall be consistent with the requirements of the 40 CFR 63 and Rule 62-297, F.A.C. The 

permittee shall also submit a complete notification of the compliance status along with the test report in 

accordance with 40 CFR 63.9(h). [Rule 62-297.310(7)(a)4. and 62-4.070(3), F.A.C.] 

Blast Furnace Exhaust

(X) Pb (X) Hydrocarbons 

(X) PM (X) Opacity 

(X) Carbon Monoxide (X) Sulfur Dioxide 

Tapping and Charging Baghouse Exhaust

(X) Pb (X) Opacity 

(X) PM (X) Hydrocarbons 

B.21. Compliance with the emission limitations of Specific Condition Nos. B.7, B.8, B.9, B.10, B.11, B.12, 

B.14, B.16, B.17, B.18, B.19 and B.20. shall be demonstrated using the EPA test methods 1, 2, 3, 3B, 4, 5, 6, 

9, 10, 12, and 25A contained in the 40 CFR 60, Appendix A and adopted by reference in Rule 62-297, F.A.C. 

The requirements of 40 CFR 63.547 also must be met. The minimum requirements for stack sampling facilities 

source sampling and reporting, shall be in accordance with Rule 62-297, F.A.C., 40 CFR 60, Appendix A and 

40 CFR 63. In the case of the EPA Method 9 test, all readings shall be at least 30 minutes in duration and 

concurrent with one of the Method 12 runs. 

B.22 Compliance with the face velocity requirement on the Blast Furnace Enclosure shall be determined 

in accordance with the following test methods: 

[Rule 62-4.070(3), F.A.C., and 40 CFR 63.547] 

1. The face velocity for the Blast Furnace Enclosure shall be measured directly using the 

following procedures: 

(i) The permittee shall use a propeller anemometer or equivalent device meeting the 

requirements of 40 CFR 63.547(d)(2)(ii) through (d)(2)(iv). 

(ii) Doorway air velocity into the building shall be determined for each doorway, excluding the 

passageway between the enclosure and containment room, by placing the anemometer in the plane of the 

doorway opening near its center. 
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(iii) Doorway air velocity into the building shall be determined for each doorway that is open during 

normal operation with all remaining doorways in the position they are in during normal operation. 

B.23. The permittee shall provide at least the minimum requirements for stack sampling facilities as specified 

in 40 CFR 60.8(e)(1), (2), (3) and (4), 40 CFR 63.7, and Rule 62-297, F.A.C. Sources sampling platforms, 

platform access, and other associated work areas, whether permanent or temporary, shall be in accordance 

with Occupational Safety and Health Administration standards per 29 CFR 1910, Subparts D and E. 

B.24. Testing of emissions shall be conducted with the blast furnace operating at capacity with conditions 

representative of normal operations. Capacity is defined as 90-100% of the approximate rated capacity as 

specified in Specific Condition No. B.5.B). Testing of the blast furnace enclosure shall occur with the blast 

furnace in normal operation along with typical movement of the enclosure openings for plant activities. To 

help simulate the maximum generation of PM and Pb emissions, including re-entrained fugitives from the blast 

furnace area floor, movement of plant machinery (i.e. forklifts, etc.) in the blast furnace area shall continue 

during the tests. Movement of plant equipment, specifically from the containment room into the blast furnace 

enclosure, shall continue at a frequency reflecting, at a minimum, normal movement around the blast furnace 

area. If it is impracticable to test at capacity, then the source operation is limited to 110% of the test load until 

a new test is conducted. Once the unit is so limited, then operation at higher capacities is allowed for no more 

than fifteen days for purposes of additional compliance testing to regain the rated capacity in the permit, with 

prior notification to the EPC. For the blast furnace, the type and amounts of materials charged during the test 

must also be included. Failure to submit the input rates, output rates, control equipment parameters such as 

pressure drops, afterburner temperatures, and actual operating conditions may invalidate the tests. 

During compliance testing of the blast furnace for PM and Pb, testing of the blast furnace exhaust must be 

performed with a minimum of 9 of the 10 baghouse chambers in operation. As indicated in Specific Condition 

No. B.35, a minimum of 9 baghouse chambers must be in operation at all times during normal operation. 

Special PM and Pb testing to demonstrate compliance with less than 9 chambers in operation will be required 

within 15 days, if the blast furnace is operated with less than 9 baghouse chambers in operation. 

[Rules 62-297 and 62-4.070, F.A.C] 

B.25. The permittee shall notify the Air Compliance Section of the Environmental Protection Commission of 

Hillsborough County at least 60 days prior to the date on which a formal compliance test is to begin of the 

date, time and place of each such test, and the contact person who will be responsible for coordinating and 

having such test conducted. Along with the notification, the permittee shall submit a site-specific test plan to 

include a test program summary, the schedule, data quality objectives, and both the internal and the external 

quality assurance program. [40 CFR 63.7 and 63.9] 

B.26. The permittee shall analyze SO2 performance audit samples during each EPA Method 6 performance 

test of the blast furnace. The audit samples shall be requested by the permittee at least 30 days prior to the test 

date. Audit materials may be obtained by contacting the appropriate EPA Regional Office or the EPC. If 

the Administrator fails to provide required PA materials to an owner or operator of an affected source in 
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time to analyze the PA samples during a performance test, the requirement to conduct a PA under this 

paragraph shall be waived for such source for that performance test. 

[40 CFR 63.7] 

B.27. Records of each performance test required by the permit shall be retained by the permittee for a 

minimum of 5 years and made available upon request. 

[40 CFR 63.7] 

B.28. Visible emission tests shall be performed using EPA Method 9 and shall be thirty (30) minutes in 

duration pursuant to Rule 62-297.310 F.A.C. The visible emission tests must be conducted in accordance with 

the following requirements: 

[Rules 62-296.600, 62-296.712 and 62-297, F.A.C.; and 40 CFR 60.123] 

A) The visible emission test on the blast furnace shall be conducted concurrent with one of the Method 12 

runs while the furnace is operating at capacity. 

B) The visible emission test on the blast furnace tapping and charging operation shall be on the 

charging/tapping baghouse exhaust. 

C) The visible emission tests on the Blast Furnace Enclosure shall be performed consistent with the testing 

requirements of Specific Condition No. B.24. Visible emission tests shall be conducted on the 

enclosure baghouse exhaust and all enclosure doorway openings typically or routinely open during 

normal operation. Observations shall be made at the highest point of opacity observed from the 

enclosure operation. 

B.29. The permittee shall monitor and record the temperature of the afterburner at least every 15 minutes 

during the annual hydrocarbon compliance test and determine an arithmetic average for the recorded 

temperature measurements. 

[40 CFR 63.548(j)(1)] 

Monitoring and Record Keeping 

B.30. The permittee shall calibrate and maintain a device to monitor and to record the temperature in the 

afterburner chamber on a continuous basis. If the 3-hour average temperature falls more than 50°F below the 

3-hour average temperature during the previous annual carbon monoxide (CO) compliance demonstration, it 

shall constitute an excursion of temperature thresholds as specified in Appendix CAM of the Title V operating 

permit. [Rule 62-4.070(3), F.A.C.] 

B.31. The permittee shall calibrate and maintain a device to monitor and to record the temperature in the 

afterburner chamber on a continuous basis. If the 3-hour average temperature falls more than 50°F below the 

3-hour average temperature during the previous annual hydrocarbon (VOC) compliance demonstration, it shall 

constitute a violation of the applicable emission standard for VOC listed in this permit. 

[40 CFR 63.548(j)(1)] 
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B.32. As specified in Specific Condition Nos. B.30 and B.31, the baseline temperature for normal operation of 

the afterburner shall be determined from the 3-hour average temperatures from the annual CO and VOC 

compliance tests, whichever is higher. The minimum operating temperature of the afterburner shall be 50°F 

below the higher of the compliance tests 3-hour average temperatures. The 3-hour average temperature of the 

afterburner must remain above this minimum operating temperature. 

[Rule 62-4.070(3), F.A.C. and 40 CFR 63.548(j)(1)] 

B.33. An updated version of the Operation and Maintenance Plan (Baghouses Standard Operation and 

Maintenance Procedures Manual) has been attached to this permit to allow more flexibility for replacement 

of the bag leak detectors with equivalent units as long as they meet all the requirements from 40 CFR 63.548. 

In order to meet the particulate RACT requirements of Rules 62-296.700, F.A.C., the lead RACT 

requirements of Rule 62-296.600, F.A.C., and the MACT requirements of 40 CFR 63.548, the 

Baghouses Standard Operation and Maintenance Procedures Manual shall be updated by the permittee to 

include the new Blast Furnace Enclosure baghouse and details on any replacements of the bag leak 

detectors. The updated version of the plan shall be submitted with the application for Title V Permit 

Revision required by Specific Condition No. A.19. Any aspects of the Compliance Assurance and 

Monitoring (CAM) Plan, the Startup, Shutdown and Malfunction Plan, or the SOP for the Control of 

Fugitive Emissions that were affected by this construction permit should also be included with the 

Revision application. [Rules 62-4.070(3), 296.600, and 62-296.700, F.A.C.; 40 CFR 63.548] 

B.34. Excess emissions resulting from the start-up, shutdown or malfunction of any emissions unit shall be 

permitted for provided best operational practices to minimize emissions are adhered to, and the duration of the 

excess emissions shall be minimized but in no case exceed two hours in any 24 hours period unless specifically 

authorized by the Department for longer duration. For sulfur dioxide control, best operational practice shall 

mean that no battery processing will be done unless the desulfurization equipment is operational. For 

hydrocarbon and carbon monoxide control, best operational practice shall require that if the instantaneous 

afterburner temperature falls below the minimum afterburner operating temperature (as specified in Specific 

Condition No. B.32) for more than one hour, the furnace operation shall accept no more lead bearing material. 

[Rules 62-210.700, and 62-4.070(3), F.A.C.] 

B.35 For particulate matter and lead control, best operational practices shall mean the emission unit can 

continue for up to two hours following the alarm being triggered for a broken bag. After 2 hours, the cell 

where the broken bag is located shall be sealed off, or the bag will have been replaced to continue operation of 

that particular emission unit. The procedures used to determine the cause of the alarm must be initiated within 

30 minutes of the alarm. Under normal operations, the baghouse for the blast furnace exhaust shall be 

operated with at least 9 of the 10 baghouse chambers in operation. If the baghouse is operated with less than 9 

chambers in operation, then a compliance test under equivalent conditions shall be conducted within 15 days. 

The EPC may also request a compliance demonstration on the charging/tapping baghouse if a compartment is 

sealed off while the emission unit is operated for any period of time. 
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[Rule 62-210.700, F.A.C. and 40 CFR 63.548(f)(1)] 

B.36. Excess emissions which are caused entirely or in part by poor maintenance, poor operation, or any 

other equipment or process failure which may reasonably be prevented during startup, shutdown, or 

malfunction shall be prohibited. 

[Rule 62-210.700(4), F.A.C.] 

B.37. If an excess emission occurs, the permittee shall file a report semiannually covering the periods 

January to June and July to December within 30 days of the period. The report shall be consistent with 

the requirements of 40 CFR 63.10(d)(5)(i). If the action taken is not consistent with the permittee’s 

startup, shutdown, and malfunction plan, the more immediate reporting requirements of 40 CFR 

63.10(5)(d)(ii) shall apply. 

B.38. The permittee shall calibrate and maintain a continuous emission monitor (CEM) for the pollutant sulfur 

dioxide on the blast furnace exhaust line in accordance with the manufacturer’s operation and maintenance 

plan. The CEM shall be in continuous operation during any blast furnace operation. The permittee shall 

provide notification to EPC as soon as possible (within 24 hours) when unexpected failure of the SO2 CEM 

occurs. If failure occurs during non-working hours or on the weekend, notification shall occur by fax or phone 

message to the Compliance Section of EPC on the same date as the event or on the next business day. 

Following the initial certification of the SO2 continuous emissions monitor, the permittee may request that the 

continuous emission monitor become the referenced method by requesting an alternate sampling procedure 

pursuant to Rule 62-297.620, F.A.C. 

[Rules 62-4.070(3), and 62-4.130 F.A.C. and 40 CFR 70.6(a)(3)(iii)(B)] 

B.39. The permittee shall establish a conversion factor for the purpose of converting SO2 CEM monitoring 

data from ppm into units of lbs of SO2 per ton of lead produced each hour as specified in Specific Condition 

No. B.14, using information from the most recent compliance test. 

[Rule 62-4.070(3), F.A.C.] 

 

B.40. The permittee shall maintain and calibrate a device which continuously measures and records the 

pressure drop across each baghouse compartment controlling the emission units covered under this permit. 

[Rule 62-4.070(3), F.A.C.] 

B.41. The permittee shall keep the following records to ensure compliance with Specific Condition Nos. B.4, 

B.5 and B.14: 

[Rule 62-4.070(3), F.A.C.] 

A) Monthly hours of operation for the blast furnace. 

B) Monthly and rolling twelve month totals of the amount of lead produced in tons from the blast furnace. 
PERMITTEE: PERMIT/CERTIFICATION NO.: 0570057-018-AC 

EnviroFocus Technologies, LLC PROJECT: Blast Furnace Enclosure/Production Increase 

Page 18 of 18 

C) Monthly and rolling twelve month totals ofsulfur dioxide emissions, in tons per year, to be calculated by 

multiplying the most recent stack test or CEM results in pounds of SO2 per ton of lead produced times 

the monthly lead production from the furnace operation. 

D) Rolling twelve month average of the pounds of sulfur dioxide per ton of lead produced from the blast 

furnace, updated each month and based off the most recent SO2 stack test or CEM results multiplied by 

the most recent twelve month’s production of lead. 

B.42. The permittee shall keep a record of the material input to the blast furnace for each and every hour 

and back calculate a ton per hour input figure based on actual hours of operation as recorded on the 

operator log sheets. 

[Rule 62-4.070(3), F.A.C.] 

B.43. All record keeping required by this permit shall be maintained for at least five years by the permittee and 

made available to the EPC upon request. 

[40 CFR 63 Subpart X] 

B.44. In order to demonstrate compliance with Specific Condition Nos. B.9. and B.17., the permittee shall 

conduct a daily instantaneous visible emissions check on each emissions unit, and maintain records for at least 5 

years. 

B.45 The permittee shall maintain continuous operation of bag leak detection systems on the blast furnace 

exhaust baghouse, the blast furnace tapping and charging baghouse, and the blast furnace enclosure baghouse 

in conjunction with 40 CFR 63.548. [Rule 62-4.070(3), F.A.C. and 40 CFR 63.548] 

 

 ENVIRONMENTAL PROTECTION COMMISSION 

 OF HILLSBOROUGH COUNTY 

 __________________________________ 

Richard D. Garrity, Ph.D. 

 Executive Director
Envirofocus PSD Determination

Increase the blast furnace processs rate to 32,000 TPY of lead production and 7.9 TPH of charge.

Pollutant Baseline Period Ave. EF (lb/ton) Basis for EF

Total Production 

in 24-month 

period (tons)

Tons Emitted in 24-

month period

Current 

Actuals TPY

Future Actuals 

Requested TPY

Increase 

(tpy)

PSD 

Threshold 

(tpy) PSD

EF factor needed 

to be non-PSD 

(lb/ton)

Future Actuals 

Needed to 

Avoid PSD 

(TPY)

SO2 July 1997-June 1999 72.18 Stack test 48217 1757.22947 878.61 1015 136.39 40 Yes 57.41 918.51

NOx

2000-2001(coke 

usage) 21.00 Fire 5437.8 57.10 28.55 87.20

Natural Gas (MMCF) 100.00 AP-42 58.7 2.94 1.47 4.38

Total 30.02 91.58 61.56 40 Yes 4.37 69.92

CO 2003-2004 62.60 Stack test 48942 1512.7494 756.37 855 98.63 100 No 53.44 855.00

VOC

1999-2000 (blast 

furnace) 5.66 Stack test 50352 144.201394 72.10 104.7 32.60 6.54 104.7

1999-2000 (hygiene 

bgahouse) 0.20 Stack test 50352 5.062848 2.53 10.0 0.62

Total 74.63 114.6914499 40.06 40 Yes 7.17

PM/PM10

1999-2000 (blast 

furnace) 0.151 Stack test 50352 3.489705 1.74 10.7 8.99

1999-2000 (hygiene 

bgahouse) 0.086 Stack test 50352 2.132636 1.07 7.4 6.37

Fugitives 1.21 50352 30.46 15.23 3.872 -11.36

Total 18.04 22.0 4.00 25/15 No 1.38 27.90

Lead

2004-2005 (blast 

furnace) 0.051 Stack test 44808 1.1361816 0.57 0.85 0.28

2004-2005 (hygiene 

baghouse) 0.00137 Stack test 44808 0.0313 0.0156 0.45 0.44 0.03

Fugitives 0.03 44808 0.67 0.34 0.096 -0.24

Total 0.92 1.4 0.48 0.6 No 0.09 1.49

Mercury

2002-2003 (Blast 

Furnace) 0.00091 NESHAP BID 52292 0.02379286 0.001 0.001456 0.0003 0.1 No 0.0001 0.0146

Notes:

SO2 The test conducted in 9/25/97, which resulted in an SO2=62.45 lb/ton, may have been the only one conducted with 100% desulphurized materials.

Other tests conducted in 1997 were without the desulphurization process fully operational.

Did not provide test data for 1999. Two tests were conducted, on 3/5/99 with an SO2=50.4 lb/ton and 

on 7/29/99 with an SO2=56.4 lb/ton.

NOx Coke usage for 2005 is 3,675 tons and for 2006 is 4,003 tons. By giving them a limit of 7,000 tons of coke usage and using the 2005 and 2006 numbers it will be below the PSD limit. 

Natural Gas EF=100lb/MMCF. Coke EF=21 lb/ton. Did not provide amount of natural gas burned in 2001.

Did not provide future Coke or natural gas usage with the blast furnace increase.

CO Since the permitted CO annual limit is 1400 tpy, they will have to take a restriction.

VOC Takes into account blast furnace and hygiene baghouse. Requesting reduction in 

hygene baghouse from 12 to 10 tpy, which equates to new equivalent limit of 16.6 ppm.

VOC limit of 104.7 tpy was established to avoid PSD previously.

PM & Pb Takes into account blast furnace, hygiene baghouse and fugitives that will be ducted 

into the new baghouse.

Need to verify fugitive factor.

Future actuals based on limits required by Rule in permit ... except for Pb for hygiene. Pb for hygiene was reduced from current permit limit of 0.59 tpy to

 0.45 tpy based on a request from the applicant ... this equates to a new limit of 0.00067 gr/dscf (currently 0.00087 gr/dscf).
EnviroFocus Technologies - PSD Analysis of Production Increase including Enclosure

0570057-018-AC

FINAL Calculations for DRAFT AC

Pollutant Baseline Period Ave. EF (lb/ton) Basis for EF

Total 

Production in 

24-month 

period (tons)

Current 

Actuals TPY

Future 

Actuals 

Requested 

TPY

Increase 

(tpy)

PSD 

Threshold 

(tpy) PSD

EF factor 

needed to 

be nonPSD 

(lb/ton)

Future 

Actuals 

Needed 

to Avoid 

PSD 

(TPY)

SO2 Dec '99 - Nov '01 65.81

Stack 

test/CEM 51472 846.9 886.3 39.4 40 No 55.39 886.3

NOx

2005-2006(coke 

usage) 21.00 Fire 7678 40.3 76.7 7,300 tpy coke limit

Natural Gas (MMCF) 100.00 AP-42 54.3 1.4 4.4

Total 41.7 81.0 39.4 40 No 5.10 81.6

CO 2002-2003 62.10 Stack test 52292 811.9 911 99.1 100 No 56.94 911 208 lb/hr

VOC

12/99-11/01 (blast 

furnace) 4.49 Stack test 51472 57.8 89.0 31.2 5.56 102.4 ppm 29,000 DSCFM

12/99-11/01 (hygiene 

baghouse) 0.16 Stack test 51472 2.1 9.8 7.7 0.61 18.4 ppm 18,000 DSCFM

Total 59.9 98.8 38.9 40 No 6.17 99.3 combined

PM/PM10

12/99-11/01(blast 

furnace) 0.126706593 Stack test 51472 1.63 12.0 10.35 .011 GR/DSCF

12/99-11/01 (hygiene 

baghouse) 0.073237406 Stack test 51472 0.94 7.4 6.49 .011 GR/DSCF

Fugitives 1.21 51472 15.57 9.8 -5.81 .004 GR/DSCF

Total 18.14 29.2 11.03 25/15 No 1.82 33.14

Lead

2002-2003 (blast 

furnace) 0.028366041 Stack test 52292 0.37 0.78 0.41 .00072 GR/DSCF

2002-2003 (hygiene 

baghouse) 0.00798 Stack test 52292 0.10 0.42 0.31 0.03 .00062 GR/DSCF

Fugitives 0.03 52292 0.39 0.21 -0.18 .000085 GR/DSCF

Total 0.87 1.41 0.54 0.6 No 0.09 1.41

Mercury

2002-2003 (Blast 

Furnace) 0.00091 NESHAP BID 52292 0.0012 0.0015 0.0003 0.1 No 0.0001 0.0912

Jeff Sims

9-11-07
Test Data

Year Test Date SO2 (lbs/hr)

Blast Furnace 

Production (tph)

SO2 (lb/ton) 

Output

Blast Furnace 

Lead Out (tpy)

SO2 (tpy) 

Lead 

Produced

1997 9/25/1997 206.7 3.31 62.447

12/11/1997 252.1 3.5 72.029

1998 3/17/1998 261.4 3.2 81.688 Added

6/25/1998 183.6 3 61.200

7/20/1998 234 3.14 74.522 Added

9/21/1998 222.8 3.43 64.956

12/9/1998 295.4 3 98.467

1999 3/5/1999 171.4 3.4 50.412

7/29/1999 208.8 3.67 56.894

6/8/2000 215.7 3.77 57.215 26480 12/99-11/00

6/26/2001 140.8 3.18 44.277 24992 12/00-11/01

CEM (10-01 to 

6-02) 65.656

65.81 25736 846.89 Ave./Year

Year Test Date CO (lbs/hr)

Blast Furnace 

Production (tph)

CO (lb/ton) 

Output

Avg Blast 

Furnace Metals 

Out (tpy)

CO (tpy) Lead 

Produced

2002 7/16/2002 209.7 3.25 64.52307692 26414 852.1562769

2003 7/24/2003 171.5 3.5 49 25878 634.011 24471

2004 7/27/2004 234.7 3.08 76.20 0

2005 7/28/2005 117.2 2.75 42.61818182 0

2006 7/19/2006 243.9 3.12 78.17307692 0

Average 62.10 26146 811.87 Ave./Year

Year Test Date VOC (lbs/hr)

Blast Furnace 

Production (tph)

VOC (lb/ton) 

Output

Blast Furnace 

Metals Out (tpy)

VOC (tpy) 

Lead 

Produced

Blast Furnace

1998 6/25/1998 12.10 3 4.034 PPMV

1999

7/29/1999 Blast 

Furnace 15.70 3.67 4.277 63.6

2000

6/8/2000 Blast 

Furnace 26.52 3.77 7.036 26480 12/99-11/00 136.1

2001 6/26/2001 6.85 3.18 2.154 24992 12/00-11/01 40.2

2002 7/16/2002 16.11 3.25 4.956

Average 4.491 25736 57.80 Ave./Year 0.14

Hygiene BH

1998 6/24/1998 0.28 2.75 0.100

1999

7/28/99 

Hygiene BH 0.63 3.5 0.179

9/9/99 Hygiene 

BH 0.34 3.5 0.096

2000

6/07/00 

Hygiene BH 0.88 3.42 0.258 26480 12/99-11/00

2001 6/25/2001 1.01 3.42 0.296 24992 12/00-11/01

2002 7/15/2002 0.11 3.25 0.035

Average 0.16 25736 2.07 Ave./Year
Year Test Date PM (lbs/hr)

Blast Furnace 

Production (tph)

PM (lb/ton) 

Output

Blast Furnace 

Metals Out (tpy)

PM (tpy) Lead 

Produced

Blast furnace

1998 6/25/1998 0.45 3 0.150

1998 9/21/1998 0.61 3.43 0.178

12/9/1998 0.6828 3 0.228

1999

3/5/1999 Blast 

Furnace 0.53 3.4 0.156 0.00

7/29/99 Blast 

Furnace 0.09 3.67 0.025 0.00

2000

6/08/00 Blast 

Furnace 0.69 3.77 0.182 26480 2.41 12/99-11/00

2001 6/26/2001 0.07 3.18 0.021 24992 12/00-11/01

2002 7/16/2002 0.24 3.25 0.075

Average 0.127 25736 1.63

Hygene BH

1998 6/24/1998 0.107 2.75 0.039

1999 7/28/1999 0.389 3.5 0.111 0.00

2000 6/7/2000 0.209 3.42 0.061 26480 0.81 12/99-11/00

2001 6/25/2001 0.208 3.42 0.061 24992 12/00-11/01

2002 7/15/2002 0.306 3.25 0.094

Average 0.073 25736 0.94 Ave./Year

Year Test Date Pb (lbs/hr)

Blast Furnace 

Production (tph)

Pb (lb/ton) 

Output

Blast Furnace 

Metals Out (tpy)

Pb (tpy) Lead 

Produced

Blast Furnace

2002 7/16/2002 0.0504 3.25 0.0155 26414

2003 7/24/2003 0.0115 3.5 0.0033 25878

2004

7/27/04 Blast 

Furnace 0.1627 3.08 0.0528 0.00

2005

7/28/05 Blast 

Furnace 0.1335 2.75 0.0485 0.00

2006 7/19/2006 0.0676 3.12 0.0217

Average 0.028 26146 0.37 Ave./Year

Hygiene BH

2002 7/15/2002 0.1149 3.25 0.0354 26414

2003 7/22/2003 0.002069 3.5 0.0006 25878

2004

8/03/04 Hygene 

BH 0.007109 3.08 0.0023 0.00

2005

7/27/05 Hygene 

BH 0.001301 2.96 0.0004 0.00

2006 7/18/2006 0.003617 3 0.0012

Average 0.0080 26146 0.10 Ave./Year
Data Verification

Year

Blast 

Furnace 

Metals Out 

(tpy)

Coke 

Usage 

(tpy)

Test Date 

(SO2) 

SO2 Test 

Data 

(lb/ton)

Test Date 

(CO)

CO Test Data 

(lb/ton)

Test Date 

(VOC)

VOC Test 

Data (lb/ton)

Test Date 

(PM)

PM Test 

Data 

(lb/ton)

Test Date 

(Hg)

Lead Test 

Data (lb/ton)

Natual Gas 

Burned 

(MMCF/YR)

1997 22585.67 6/27/1997 97.95 feedstock?

9/25/1997 62.45 no output ref?

12/11/1997 72.03

1998 24802.19 3/17/1998 * no test record

6/25/1998 61.20

7/20/1998 * no test record

9/21/1998 64.96

12/9/1998 98.47

1999 23876 3/5/1999 50.41 7/29/1999 4.28 3/5/1999 0.16

7/29/1999 56.89 7/29/1999 0.02

2000 26476 2757.6 6/8/2000 7.04 6/8/2000 0.18 34.7

2001 24332 2680.2 24

2003 25878 7/24/2003 49

2004 23064 7/27/2004 76.20 7/27/2004 0.05

2005 21744 7/28/2005 0.05

NOx Emissions:

Coke EF=21 lb/ton. Reference: Fire 1-01-008-01

Natural Gas EF=100lb/MMCF Reference: AP-42
SO2 CEM Data

Date SO2 (lb/ton)

SO2 (12-

month avg)

SO2 (24-

month avg) SO2 (lbs) SO2 (tons)

SO2 (12-

month avg) 

TPY

SO2 lb/ton 

avg. for 

2002-2003

Oct-01 68.5 68.5 153811 76.91

Nov-01 78.5 78.5 143557 71.78

Dec-01 64.8 64.8 101066 50.53

Jan-02 70.1 70.1 164134 82.07

Feb-02 66 66 132552 66.28

Mar-02 59.8 59.8 115680 57.84 70.1

Apr-02 60.4 60.4 127128 63.56 66

May-02 64.1 64.1 141924 70.96 59.8

Jun-02 58.7 58.7 134294 67.15 60.4

Jul-02 61.4 65.66 127194 63.60 64.1

Aug-02 61.8 151085 75.54 58.7

Sep-02 66.2 65.03 134429 67.21 813.43 61.4

Oct-02 72.3 65.34 173773 86.89 823.41 61.8

Nov-02 73.5 64.93 166148 83.07 834.70 66.2

Dec-02 73 65.61 169333 84.67 868.84 72.3

Jan-03 73.6 65.90 169039 84.52 871.29 73.5

Feb-03 67.9 66.06 144691 72.35 877.36 73

Mar-03 71.6 67.04 137280 68.64 888.16 73.6

Apr-03 64.9 67.42 138617 69.31 893.90 67.9

May-03 58.2 66.93 127445 63.72 886.66 71.6

Jun-03 59.8 67.02 124879 62.44 881.96 64.9

Jul-03 64 67.23 146642 73.32 891.68 58.2

Aug-03 52 66.42 106922 53.46 869.60 59.8

Sep-03 55.4 65.52 65.27 113093 56.55 858.93 64

Oct-03 49.7 63.63 64.49 113112 56.56 828.60 52

Nov-03 54.5 62.05 63.49 119582 59.79 805.32 55.4

Dec-03 59.6 60.93 63.27 135518 67.76 788.41 49.7

Jan-04 60.9 59.88 62.89 126269 63.13 767.03 54.5

Feb-04 57.1 58.98 62.52 112351 56.18 750.86 59.6

Mar-04 58.6 57.89 62.47 113885 56.94 739.16 63.2708333

Apr-04 68.3 58.18 62.80 124013 62.01 731.86

May-04 76.5 59.70 63.31 168602 84.30 752.43

Jun-04 72.1 60.73 63.87 125395 62.70 752.69

Jul-04 72.1 61.40 64.32 150797 75.40 754.77

Aug-04 63.6 62.37 64.39 116750 58.38 759.68

Sep-04 62.1 62.93 64.22 112349 56.17 759.31

Oct-04 45.2 62.55 63.09 92988 46.49 749.25

Nov-04 55.5 62.63 62.34 102449 51.22 740.68

Dec-04 45.7 61.48 61.20 67488 33.74 706.67

Jan-05 43.1 59.99 59.93 69919 34.96 678.49

Feb-05 49.7 59.38 59.18 76233 38.12 660.43

Mar-05 43.3 58.10 58.00 73334 36.67 640.16

Apr-05 50.1 56.58 57.38 85629 42.81 620.97

May-05 48.4 54.24 56.97 66182 33.09 569.76

Jun-05 55 52.82 56.77 98505 49.25 556.31

Jul-05 60.1 51.82 56.61 88250 44.13 525.04

Aug-05 60.8 51.58 56.98 128092 64.05 530.71

Sep-05 59.5 51.37 57.15 125798 62.90 537.43

Oct-05 61.7 52.74 57.65 133677 66.84 557.78

Nov-05 68.9 53.86 58.25 148857 74.43 580.98

Dec-05 67.6 55.68 58.58 134875 67.44 614.68

Average 62.724
Based on AOR

Year

Lead 

Casted 

(tpy) 

Refining Year

Blast 

Furnace 

Metals In 

(tpy) Year

Blast 

Furnace 

Metals 

Out (tpy) Year

Metals 

into 

Kettles 

(tpy)

1997 20955.07 1997 31213.25 1997 22585.67 1997 22585.67

1998 22071.37 1998 30975.6 1998 24802.19 1998 24802.19

1999 22959.82 1999 37986.8 1999 23876 1999 25721.3

2000 24286.4 2000 39498.2 2000 26476 2000 27673.9

2001 22780.1 2001 38393.6 2001 24332 2001 26859.8

2003 23940.3 2003 35490.8 2002 26414 2002

2004 22673.4 2004 32929.8 2003 25878 2003 28157.1

2005 17839 2005 31197.9 2004 23064 2004 24916.2

2005 21744 2005 22107.4

52292

Total Avg 62.724 820.0

12-M Avg 67.42 881.4

24-M Avg 65.27 853.3

Avg.2002-03 63.27 827.1

2-yr Blast Prod.

Avg.2000-01 50808 25404

Avg.2002-03 52292 26146