oregon department of environmental quality …
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Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 1 of 41
OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY
STANDARD
AIR CONTAMINANT DISCHARGE PERMIT
Northwest Region
700 NE Multnomah St., Suite 600
Portland, OR 97232
This permit is being issued in accordance with the provisions of ORS 468A.040 and based on the
land use compatibility findings included in the permit record.
ISSUED TO:
Columbia Steel Casting Co., Inc.
P.O. Box 83095
Portland, OR 97283
INFORMATION RELIED UPON:
Application No.: 021205
Date Received: 10/25/2004
PLANT SITE LOCATION:
10425 N. Bloss Avenue
Portland, OR 97283
LAND USE COMPATIBILITY FINDING:
Approving Authority: City of Portland
Approval Date: 12/01/1994
ISSUED BY THE DEPARTMENT OF ENVIRONMENTAL QUALITY
_________________________________________________ _______________________
Steven A. Dietrich, Northwest Region Air Quality Manager Date
Source(s) Permitted to Discharge Air Contaminants (OAR 340-216-8010):
Table 1 Code Source Description SIC/NAICS
Part B, 39 Gray iron and steel foundries, malleable iron foundries, steel
investment foundries, steel foundries 100 or more tons/year
metal charged, not elsewhere identified
3325/331513
Steven A. Dietrich (Feb 18, 2021 15:36 PST)Steven A. Dietrich
02/18/2021
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 2 of 41
TABLE OF CONTENTS
1.0 DEVICE, PROCESS AND POLLUTION CONTROL DEVICE (PCD)
IDENTIFICATION..........................................................................................................................3
2.0 GENERAL EMISSION STANDARDS AND LIMITS .......................................................5 3.0 SPECIFIC PERFORMANCE AND EMISSION STANDARDS ........................................7 4.0 OPERATION AND MAINTENANCE REQUIREMENTS ..............................................15 5.0 PLANT SITE EMISSION LIMITS ....................................................................................17 6.0 COMPLIANCE DEMONSTRATION ...............................................................................17
7.0 SOURCE TESTING ...........................................................................................................20 8.0 RECORDKEEPING REQUIREMENTS ...........................................................................24
9.0 REPORTING REQUIREMENTS ......................................................................................29 10.0 ADMINISTRATIVE REQUIREMENTS ..........................................................................32 11.0 DEQ CONTACTS / ADDRESSES ....................................................................................33 12.0 GENERAL CONDITIONS AND DISCLAIMERS ...........................................................33
13.0 40 CFR 63, SUBPART ZZZZZ, TABLE 3 (LARGE FOUNDRIES) ...............................35 14.0 EMISSION FACTORS .......................................................................................................37 15.0 ABBREVIATIONS, ACRONYMS, AND DEFINITIONS ...............................................41
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 3 of 41
1.0 DEVICE, PROCESS AND POLLUTION CONTROL DEVICE
(PCD) IDENTIFICATION
The devices, processes, and pollution control devices regulated by this permit are the following:
Devices and Processes
Description Device ID
Pollution Control Device
Description
PCD
ID
#1 6MT Steel Electric Arc
Furnace #1
41,000 cfm Pangborn Shaker
Baghouse CD #1
#2 10TT Steel Electric Arc
Furnace #1
#3 10TT Manganese Electric Arc
Furnace #2
35,000 cfm National Shaker
Baghouse CD #2
Scrap Prep & Charge Makeup –
Torch Cutting TC
Inductotherm Steel Induction
Furnace, Bldg. #8 (two crucibles
w/one power supply)
None -
Inductotherm Induction Furnace,
Bldg. 11 (two crucibles w/one
power supply)
None -
Main Foundry Sand System
(Mills 1 & 3) #5 20,000 cfm Fuller Reverse Pulse
Baghouse CD #5
Group 8 Sand System (Mill 2) #6 27,000 cfm Wheelabrator Shaker
Baghouse CD #6
Core Room Sand System #9 5,000 cfm Fabric Filters NW Pulse
Jet CD #9
South Foundry Sand System
(Mills 1 & 3) #17 18,000 cfm Fabric Filters NW
Reverse Pulse
CD
#17
Main Foundry Shakeout #3 45,000 cfm Fuller Reverse Pulse
Baghouse CD #3
Group 3 & 6 Sand System (Mill
4) #8 45, 000 cfm Fabric Filters NW
Shaker Baghouse CD #8
National Sand Reclaimer #4 10,000 cfm Fuller Reverse Pulse
Baghouse CD #4
Group 9 Sand Reclaim System #20 20,000 cfm LMC Pulse Jet
Baghouse
CD
#20
SMS Sand Reclaimer #22 4,800 cfm LMC Pulse Jet
Baghouse
CD
#22
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 4 of 41
Devices and Processes
Description Device ID
Pollution Control Device
Description
PCD
ID
Sand Dryer at Landfill #23 6,000 cfm Torit Reverse Pulse
Baghouse
CD
#23
Joslyn Burn/Arc #1 #10 15,000 cfm Wheelabrator Shaker
Baghouse
CD
#10
South Foundry Burn/Arc #15 55,000 cfm Wheelabrator Shaker
Baghouse
CD
#15
Joslyn Rotoblast #1 #7 16,000 cfm Pangborn Shaker
Baghouse CD #7
Joslyn Rotoblast #2 #24 6,000 cfm Wheelabrator Shaker
Baghouse
CD
#24
Main Foundry Table Blast and
Blast Room #26 Torit Pulse Jet Baghouse 15,000
cfm
CD
#26
Joslyn Turnblast #16 6,500 cfm US Air Pulse Jet
Baghouse
CD
#16
Joslyn Spinblast #19 5,300 cfm Wheelabrator Shaker
Baghouse
CD
#19
Main Foundry Burn/Weld
#11
#12
#13
American Sheet Metal Baffle
Chambers:
CD #11: 23,000 cfm
CD #12: 15,300 cfm
CD #13: 33,000 cfm
CDs #
11, 12,
13
Pattern Shop PS 15,000 cfm Rotoclone CD
#18
Heat Treat Ovens (13 misc.),
0.35-12 MMBtu/hr
HT1,
HT2A,
HT3,
HT4,
HT5,
HT6,
HT10,
HT12,
HT13,
HT14-1/2,
HT18,
HT20,
HT21
None -
Heat treat Oven #102; 18
MMBtu/hr HT102 None -
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 5 of 41
Devices and Processes
Description Device ID
Pollution Control Device
Description
PCD
ID
Core Ovens (3); 0.5-0.75
MMBtu/hr CO1-3 None -
Ladle Heaters (3); 0.6 MMBtu/hr LH1-3 None -
Floor Pouring and Cooling FP&C None -
Casting Painting CP None -
Mold Wash MW flaming off the coatings that
contain alcohol solvent FO
2.0 GENERAL EMISSION STANDARDS AND LIMITS
2.1. Visible Emissions
The permittee must comply with the following visible emission limits from air contaminant
sources other than fugitive emission sources, as applicable. Opacity must be measured as a six-
minute block average using EPA Method 9.
a. Emissions from #5, #11, #12, #13, #15, HT1, TC, #1, #2, #3, #4, #6, #7, #8, #9, #10, #16,
#17, #19, #20, #22, #23, # 24, HT3, HT4, HT5, HT6, HT10, HT12, HT13, HT14-1/2,
HT18, HT21, HT102, PS, #26, HT2A, and HT20 must not equal or exceed 20% opacity.
[OAR 340-208-0110(3)(b), (4) and (7)]
b. Any devices or processes installed, constructed, or modified on or after April 16, 2015
must not equal or exceed 20% opacity. [OAR 340-208-0110(4) and (7)]
2.2. Fugitive Emissions
a. The permittee must take reasonable precautions to prevent fugitive dust emissions from
leaving the property of a source. Reasonable precautions include, but are not limited to:
[OAR 340-208-0210]
i. Using, where possible, water or chemicals for control of dust in the demolition of
existing buildings or structures, construction operations, the grading of roads or
the clearing of land;
ii. Applying water or other suitable chemicals on unpaved roads, materials
stockpiles, and other surfaces which can create airborne dusts;
iii. Enclosing (full or partial) materials stockpiles in cases where application of water
or other suitable chemicals are not sufficient to prevent particulate matter,
including dust, from becoming airborne;
iv. Installing and using hoods, fans, and fabric filters to enclose and vent the handling
of dusty materials;
v. Installing adequate containment during sandblasting or other similar operations;
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 6 of 41
vi. Covering, at all times when in motion, open bodied trucks transporting materials
likely to become airborne; and
vii. Promptly removing earth or other material that does or may become airborne from
paved streets.
b. If requested by DEQ, the permittee must:
i. Prepare and submit a fugitive emission control plan within 60 days of the request;
ii. Implement the DEQ approved plan whenever fugitive emissions leave the
property for more than 18 seconds in a six-minute period; and
iii. Keep the plan on site and make the plan available upon request. [OAR 340-208-
0210]
c. In no case may fugitive dust emissions leave the property of a source for a period or
periods totaling more than 18 seconds in a six-minute period. Fugitive emissions must be
measured by EPA method 22 with the minimum observation time of six minutes.
2.3. Particulate Matter Emissions
The permittee must comply with the following particulate matter emission limits. For fuel
burning equipment that burns wood fuel by itself or in combination with any other fuel, emission
results are corrected to 12% CO2. For fuel burning equipment that burns fuels other than wood,
emission results are corrected to 50% excess air.
a. Particulate matter emissions from #1, #26, HT2A, and HT20 must not exceed 0.10 grains
per standard cubic foot. [OAR 340-226-0210(2)(a)(A), (b)(A) and (c)]
b. Particulate matter emissions from #5, #11, #12, #13, #15, HT1, and TC must not exceed
0.15 grains per dry standard cubic foot. [OAR 340-226-0210(2)(a)(A), (b)(A) and (c)]
c. Particulate matter emissions from #2, #3, #4, #6, #7, #8, #9, #10, #16, #17, #19, #20, #22,
#23, # 24, HT3, HT4, HT5, HT6, HT10, HT12, HT13, HT14-1/2, HT18, HT21, HT102,
and PS must not exceed 0.14 grains per dry standard cubic foot. [OAR 340-226-
0210(2)(b)(B)]
d. Non-fugitive particulate matter emissions from processes listed in OAR 340-226-0300
must not exceed the process weight emission standards shown in Table 1 of OAR 340-
226-0310.
e. Particulate matter emissions from any fuel burning equipment (except solid fuel burning
devices that have been certified under OAR 340-262-0500) that is installed, constructed
or modified on or after April 16, 2015 must not exceed 0.10 grains per dry standard cubic
foot, corrected to 12% CO2 or 50% excess air. [OAR 340-228-0210(2)(c)]
f. Particulate matter emissions from any device or process (other than fugitive emissions
sources, fuel burning equipment, refuse burning equipment, or solid fuel burning devices
certified under OAR 340-262-0500) that is installed, constructed or modified after April
16, 2015 must not exceed 0.10 grains per dry standard cubic foot. [OAR 340-226-
0210(2)(c)]
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 7 of 41
2.4. Particulate Matter Fallout
The permittee must not cause or permit the deposition of any particulate matter larger than 250
microns in size at sufficient duration or quantity, as to create an observable deposition upon the
real property of another person. [OAR 340-208-0450]
2.5. Nuisance and Odors
The permittee must not cause or allow the emission of odorous or other fugitive emissions so as
to create nuisance conditions off the permittee’s property. Nuisance conditions will be verified
by DEQ personnel. [OAR 340-208-0300]
2.6. Complaint Log
The permittee must maintain a log of all complaints received by the permittee in person, in
writing, by telephone or through other means that specifically refer to air pollution, odor, or
nuisance concerns associated with the permitted facility. Documentation must include: [OAR
340-214-0114]
a. The date the complaint was received;
b. The date and time the complaint states the condition was present;
c. A description of the pollution or odor condition;
d. The location of the complainant/receptor relative to the plant site;
e. The status of plant operation or activities during the complaint’s stated time of pollution
or odor condition; and
f. A record of the permittee’s actions to investigate the validity of each complaint and a
record of actions taken for complaint resolution.
2.7. Fuels and Fuel Sulfur Content
a. The permittee must not use any fuels other than natural gas, propane, butane or No. 2
distillate oil (diesel).
b. The permittee must not use No. 2 distillate oil with more than 0.5% sulfur by weight.
3.0 SPECIFIC PERFORMANCE AND EMISSION STANDARDS
3.1. Baghouse Operation
The permittee must observe the following baghouse operation and maintenance requirements:
a. The permittee must maintain the differential pressure of each fabric/cartridge filter
baghouse within the range observed during the most recent approved performance test or
either the manufacturer’s design specification or equivalent documentation detailing
proper operation and maintenance of the unit if performance testing has not been
conducted.
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 8 of 41
b. The permittee must post the differential pressure observed during the most recent valid
performance test or either the manufacturer’s design specification or equivalent
documentation detailing proper operation and maintenance of the unit on each respective
fabric/cartridge filter baghouse at the facility.
c. The permittee must monitor and record the differential pressure of each fabric/cartridge
filter baghouse at least once per day during operation of associated emissions units.
d. The permittee must investigate and commence corrective action measures within 24
hours of an observed excursion of the designed differential pressure range of any
fabric/cartridge filter baghouse.
e. The permittee must correct the problem as soon as practicable, but no later than 10
calendar days from the date of discovery.
f. When replacing fabric/cartridge filters in any baghouse the permittee may not substitute a
filter with lower control efficiency specifications than the bag design relied upon to
establish a related emission factor used in this permit.
3.2. NESHAP Subpart ZZZZZ – Small Foundries
The permittee must comply with all applicable provisions of 40 CFR 63 Subpart ZZZZZ. The
affected source under Subpart ZZZZZ is each iron and steel foundry (refer to 40 CFR 63
Subparts ZZZZZ and/or Subpart A for definitions of terminology stated in these associated
conditions). The following conditions summarize the applicable requirements of Subpart ZZZZZ
for Small Foundries, but are not intended to supersede the Subpart:
a. The permittee must comply with the following requirements of the General Provisions
(40 CFR part 63, subpart A): §63.1 through 63.5; §63.6(a), (b), (c), and (e)(1); §63.9;
§63.10(a), (b)(1), (b)(2)(xiv), (b)(3), (d)(1), (d)(4), and (f); and §63.13 through 63.16.
Requirements of the General Provisions not cited in the preceding sentence do not apply
to the owner or operator of a new or existing affected source that is classified as a small
foundry. [40 CFR 63.10890(i)]
b. Metallic scrap management program. For each segregated metallic scrap storage area,
bin or pile, the permittee must comply with the materials acquisition requirements in this
condition. A copy of the material specifications must be kept onsite and readily available
to all personnel with material acquisition duties, and a copy must be provided to each
scrap provider. [40 CFR 63.10885(a)]
i. Restricted metallic scrap. The permittee must prepare and operate at all times
according to written material specifications for the purchase and use of only metal
ingots, pig iron, slitter, or other materials that do not include post-consumer
automotive body scrap, post-consumer engine blocks, post-consumer oil filters,
oily turnings, lead components, chlorinated plastics, or free liquids. For the
purpose of this condition, “free liquids” is defined as material that fails the paint
filter test by EPA Method 9095B, “Paint Filter Liquids Test” (revision 2),
November 2004 (incorporated by reference—see §63.14). The requirements for
no free liquids do not apply if the owner or operator can demonstrate that the free
liquid is water that resulted from scrap exposure to rain.
ii. General iron and steel scrap. The permittee must prepare and operate at all times
according to written material specifications for the purchase and use of only iron
and steel scrap that has been depleted (to the extent practicable) of organics and
HAP metals in the charge materials used by the iron and steel foundry.
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 9 of 41
The materials specifications must include specifications for metallic scrap
materials charged to a scrap preheater or metal melting furnace to be depleted (to
the extent practicable) of the presence of used oil filters, chlorinated plastic parts,
accessible lead-containing components (such as batteries and wheel weights), and
a program to ensure the scrap materials are drained of free liquids.
c. Mercury requirements. [40 CFR 63.10885(b)]
i. The permittee must maintain records that document its procured scrap does not
contain motor vehicle scrap and is not subject to Subpart ZZZZZ mercury
management requirements or that the only materials from motor vehicles in the
scrap are materials recovered for their specialty alloy content (including, but not
limited to, chromium, nickel, molybdenum, or other alloys) and, based on the
nature of the scrap and purchase specifications, the scrap is not reasonably
expected to contain mercury switches.
ii. The permittee is prohibited from accepting and using other motor vehicle scrap
that does not meet the description in Condition 3.2.c.i above.
d. The permittee must use a binder chemical formulation that does not use methanol as a
specific ingredient of the catalyst formulation for each furfuryl alcohol warm box mold or
core making line. This requirement does not apply to the resin portion of the binder
system. [40 CFR 63.10886]
3.3. NESHAP Subpart ZZZZZ – Large Foundries
The affected source under Subpart ZZZZZ is each iron and steel foundry (refer to 40 CFR 63
Subparts ZZZZZ and/or Subpart A for definitions of terminology stated in these associated
conditions). The following conditions summarize the applicable requirements of Subpart ZZZZZ
for Large Foundries, but are not intended to supersede the Subpart:
a. If the annual metal melt production exceeds 20,000 tons during the preceding year, the
permittee must comply with the following requirements for large foundries by the
applicable dates in Condition 9.2.c. [40 CFR 63.10890(h)]
b. See Condition 13.0. for reference/guidance to the applicability of the General Provisions
to Subpart ZZZZZ for large foundries.
c. The permittee must not discharge to the atmosphere emissions from any metal melting
furnace or group of all metal melting furnaces that exceed 0.8 pounds of particulate
matter (PM) per ton of metal charged or 0.06 pounds of total metal HAP per ton of metal
charged. [40 CFR 63.10895(c)]
d. The permittee must not discharge to the atmosphere fugitive emissions from foundry
operations that exhibit opacity greater than 20 percent (6-minute average), except for one
6-minute average per hour that does not exceed 30 percent. [40 CFR 63.10895(e)]
e. The permittee must comply with the requirements for a large foundry for at least 3 years
before reclassifying as a small foundry, even if annual metal melt production falls below
20,000 tons. After 3 years, the permittee may reclassify your facility as a small foundry
provided the annual metal melt production for the preceding calendar year was 20,000
tons or less. If the permittee reclassifies a large foundry as a small foundry, the permittee
must submit a notification of reclassification to the Administrator within 30 days and
comply with the requirements for a small foundry no later than the date of notifying the
Administrator of the reclassification. If the annual metal melt production exceeds 20,000
tons during a subsequent year,
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 10 of 41
the permittee must submit a notification of reclassification to the Administrator within 30
days and comply with the requirements for a large foundry no later than the date of
notifying the Administrator of the reclassification. [40 CFR 63.10881(d)(2)]
f. Metallic scrap management program. For each segregated metallic scrap storage area,
bin or pile, the permittee must comply with the materials acquisition requirements in this
condition. A copy of the material specifications must be kept onsite and readily available
to all personnel with material acquisition duties, and a copy must be provided to each
scrap provider. [40 CFR 63.10885(a)]
i. Restricted metallic scrap. The permittee must prepare and operate at all times
according to written material specifications for the purchase and use of only metal
ingots, pig iron, slitter, or other materials that do not include post-consumer
automotive body scrap, post-consumer engine blocks, post-consumer oil filters,
oily turnings, lead components, chlorinated plastics, or free liquids. For the
purpose of this condition, “free liquids” is defined as material that fails the paint
filter test by EPA Method 9095B, “Paint Filter Liquids Test” (revision 2),
November 2004 (incorporated by reference—see §63.14). The requirements for
no free liquids do not apply if the owner or operator can demonstrate that the free
liquid is water that resulted from scrap exposure to rain.
ii. General iron and steel scrap. The permittee must prepare and operate at all times
according to written material specifications for the purchase and use of only iron
and steel scrap that has been depleted (to the extent practicable) of organics and
HAP metals in the charge materials used by the iron and steel foundry. The
materials specifications must include specifications for metallic scrap materials
charged to a scrap preheater or metal melting furnace to be depleted (to the extent
practicable) of the presence of used oil filters, chlorinated plastic parts, accessible
lead-containing components (such as batteries and wheel weights), and a program
to ensure the scrap materials are drained of free liquids.
g. Mercury requirements. [40 CFR 63.10885(b)]
i. The permittee must maintain records that document its procured scrap does not
contain motor vehicle scrap and is not subject to Subpart ZZZZZ mercury
management requirements or that the only materials from motor vehicles in the
scrap are materials recovered for their specialty alloy content (including, but not
limited to, chromium, nickel, molybdenum, or other alloys) and, based on the
nature of the scrap and purchase specifications, the scrap is not reasonably
expected to contain mercury switches.
ii. The permittee is prohibited from accepting and using other motor vehicle scrap
that does not meet the description in Condition 3.3.g.i above.
h. The permittee must use a binder chemical formulation that does not use methanol as a
specific ingredient of the catalyst formulation for each furfuryl alcohol warm box mold or
core making line. This requirement does not apply to the resin portion of the binder
system. [40 CFR 63.10886]
i. The permittee must operate a capture and collection system for each metal melting
furnace unless that furnace is specifically uncontrolled as part of an emissions averaging
group. Each capture and collection system must meet accepted engineering standards,
such as those published by the American Conference of Governmental Industrial
Hygienists. [40 CFR 63.10895(b)]
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 11 of 41
j. The permittee must prepare and operate at all times according to a written operation and
maintenance (O&M) plan for each control device for an emissions source subject to a
PM, metal HAP, or opacity emissions limit in Conditions 3.3.c and 3.3.d. The permittee
must maintain a copy of the O&M plan at the facility and make it available for review
upon request. At a minimum, each plan must contain the following information: [40 CFR
63.10896(a)]
i. General facility and contact information;
ii. Positions responsible for inspecting, maintaining, and repairing emissions control
devices which are used to comply with this subpart;
iii. Description of items, equipment, and conditions that will be inspected, including
an inspection schedule for the items, equipment, and conditions. For baghouses
that are equipped with bag leak detection systems, the O&M plan must include
the site-specific monitoring plan required in Condition 3.3.m.ii.
iv. Identity and estimated quantity of the replacement parts that will be maintained in
inventory; and
k. The permittee may use any other O&M, preventative maintenance, or similar plan which
addresses the requirements in Condition 3.3.j of this section to demonstrate compliance
with the requirements for an O&M plan. [40 CFR 63.10896(b)]
l. The permittee must conduct an initial inspection of each PM control device for a metal
melting furnace at an existing affected source. The permittee must conduct each initial
inspection no later than 60 days after the applicable compliance date for each installed
control device which has been operated within 60 days of the compliance date. For an
installed control device which has not operated within 60 days of the compliance date,
the permittee must conduct an initial inspection prior to startup of the control device.
Following the initial inspections, the permittee must perform periodic inspections and
maintenance of each PM control device for a metal melting furnace at an existing
affected source. Initial and periodic inspections must be performed according to the
requirements in this condition. The permittee must record the results of each initial and
periodic inspection and any maintenance action in the logbook required in Condition
8.6.b.xi. [40 CFR 63.10897(a)]
i. For the initial inspection of each baghouse, the permittee must visually inspect the
system ductwork and baghouse units for leaks and must also inspect the inside of
each baghouse for structural integrity and fabric filter condition. Following the
initial inspections, each baghouse must be inspected and maintained according to
the following requirements:
A. Conduct monthly visual inspections of the system ductwork for leaks.
B. Conduct inspections of the interior of the baghouse for structural integrity
and to determine the condition of the fabric filter every 6 months.
ii. For the initial inspection of each dry electrostatic precipitator, the permittee must
verify the proper functioning of the electronic controls for corona power and
rapper operation, that the corona wires are energized, and that adequate air
pressure is present on the rapper manifold. The permittee must also visually
inspect the system ductwork and electrostatic housing unit and hopper for leaks
and inspect the interior of the electrostatic precipitator to determine the condition
and integrity of corona wires, collection plates, hopper, and air diffuser plates.
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 12 of 41
Following the initial inspection, the permittee must inspect and maintain each dry
electrostatic precipitator according to the following requirements:
A. Conduct a daily inspection to verify the proper functioning of the
electronic controls for corona power and rapper operation, that the corona
wires are energized, and that adequate air pressure is present on the rapper
manifold.
B. Conduct monthly visual inspections of the system ductwork, housing unit,
and hopper for leaks.
C. Conduct inspections of the interior of the electrostatic precipitator to
determine the condition and integrity of corona wires, collection plates,
plate rappers, hopper, and air diffuser plates every 24 months.
iii. For the initial inspection of each wet electrostatic precipitator, the permittee must
verify the proper functioning of the electronic controls for corona power, that the
corona wires are energized, and that water flow is present. The permittee must
also visually inspect the system ductwork and electrostatic precipitator housing
unit and hopper for leaks and inspect the interior of the electrostatic precipitator to
determine the condition and integrity of corona wires, collection plates, plate
wash spray heads, hopper, and air diffuser plates. Following the initial inspection,
the permittee must inspect and maintain each wet electrostatic precipitator
according to the following requirements:
A. Conduct a daily inspection to verify the proper functioning of the
electronic controls for corona power, that the corona wires are energized,
and that water flow is present.
B. Conduct monthly visual inspections of the system ductwork, electrostatic
precipitator housing unit, and hopper for leaks.
C. Conduct inspections of the interior of the electrostatic precipitator to
determine the condition and integrity of corona wires, collection plates,
plate wash spray heads, hopper, and air diffuser plates every 24 months.
iv. For the initial inspection of each wet scrubber, the permittee must verify the
presence of water flow to the scrubber. The permittee must also visually inspect
the system ductwork and scrubber unit for leaks and inspect the interior of the
scrubber for structural integrity and the condition of the demister and spray
nozzle. Following the initial inspection, the permittee must inspect and maintain
each wet scrubber according to the following requirements:
A. Conduct a daily inspection to verify the presence of water flow to the
scrubber.
B. Conduct monthly visual inspections of the system ductwork and scrubber
unit for leaks.
C. Conduct inspections of the interior of the scrubber to determine the
structural integrity and condition of the demister and spray nozzle every
12 months.
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 13 of 41
m. The permittee may install, operate, and maintain a bag leak detection system for each
negative pressure baghouse or positive pressure baghouse as an alternative to the
baghouse inspection requirements in Condition 3.3.l.i. Each bag leak detection system
must be installed, operated, and maintained according to the following requirements: [40
CFR 63.10897(d)]
i. Each bag leak detection system must meet the following requirements:
A. The system must be certified by the manufacturer to be capable of
detecting emissions of particulate matter at concentrations of 10
milligrams per actual cubic meter (0.00044 grains per actual cubic foot) or
less.
B. The bag leak detection system sensor must provide output of relative
particulate matter loadings and the owner or operator shall continuously
record the output from the bag leak detection system using a strip chart
recorder, data logger, or other means.
C. The system must be equipped with an alarm that will sound when an
increase in relative particulate loadings is detected over the alarm set point
established in the operation and maintenance plan, and the alarm must be
located such that it can be heard by the appropriate plant personnel.
D. The initial adjustment of the system must, at minimum, consist of
establishing the baseline output by adjusting the sensitivity (range) and the
averaging period of the device, and establishing the alarm set points. If the
system is equipped with an alarm delay time feature, you also must adjust
the alarm delay time.
E. Following the initial adjustment, do not adjust the sensitivity or range,
averaging period, alarm set point, or alarm delay time. Except, once per
quarter, the permittee may adjust the sensitivity of the bag leak detection
system to account for seasonable effects including temperature and
humidity according to the procedures in the monitoring plan required by
Condition 3.3.m.ii.
F. For negative pressure baghouses, induced air baghouses, and positive
pressure baghouses that are discharged to the atmosphere through a stack,
the bag leak detector sensor must be installed downstream of the baghouse
and upstream of any wet scrubber.
G. Where multiple detectors are required, the system's instrumentation and
alarm may be shared among detectors.
ii. The permittee must prepare a site-specific monitoring plan for each bag leak
detection system to be incorporated in the permittee’s O&M plan. The permittee
must operate and maintain each bag leak detection system according to the plan at
all times. Each plan must address all of the following items:
A. Installation of the bag leak detection system.
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 14 of 41
B. Initial and periodic adjustment of the bag leak detection system including
how the alarm set-point will be established.
C. Operation of the bag leak detection system including quality assurance
procedures.
D. Maintenance of the bag leak detection system including a routine
maintenance schedule and spare parts inventory list.
E. How the bag leak detection system output will be recorded and stored.
F. Procedures for determining what corrective actions are necessary in the
event of a bag leak detection alarm as required in Condition 3.3.m.iii.
iii. In the event that a bag leak detection system alarm is triggered, the permittee must
initiate corrective action to determine the cause of the alarm within 1 hour of the
alarm, initiate corrective action to correct the cause of the problem within 24
hours of the alarm, and complete corrective action as soon as practicable, but no
later than 10 calendar days from the date of the alarm. Record the date and time of
each valid alarm, the time corrective action was initiated, the correction action
taken, and the date on which corrective action was completed. Corrective actions
may include, but are not limited to:
A. Inspecting the bag house for air leaks, torn or broken bags or filter media,
or any other condition that may cause an increase in emissions.
B. Sealing off defective bags or filter media.
C. Replacing defective bags or filter media or otherwise repairing the control
device.
D. Sealing off a defective baghouse department.
E. Cleaning the bag leak detection system probe, or otherwise repairing the
bag leak detection system.
F. Shutting down the process producing the particulate emissions.
n. The permittee must make monthly inspections of the equipment that is important to the
performance of the total capture system (i.e., pressure sensors, dampers, and damper
switches). This inspection must include observations of the physical appearance of the
equipment (e.g., presence of holes in the ductwork or hoods, flow constrictions caused by
dents or accumulated dust in the ductwork, and fan erosion). The permittee must repair
any defect or deficiency in the capture system as soon as practicable, but no later than 90
days and must record the date and results of each inspection and the date of repair of any
defect or deficiency. [40 CFR 63.10897(e)]
o. The permittee must install, operate, and maintain each CPMS or other measurement
device according to the permittee’s O&M plan. The permittee must record all information
needed to document conformance with these requirements. [40 CFR 63.10897(f)]
p. In the event of an exceedance of an established emissions limitation (including an
operating limit), the permittee must restore operation of the emissions source (including
the control device and associated capture system) to its normal or usual manner or
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 15 of 41
operation as expeditiously as practicable in accordance with good air pollution control
practices for minimizing emissions. The response shall include minimizing the period of
any startup, shutdown or malfunction and taking any necessary corrective actions to
restore normal operation and prevent the likely recurrence of the exceedance. The
permittee must record the date and time correction action was initiated, the correction
action taken, and the date corrective action was completed. [40 CFR 63.10897(g)]
q. If the permittee chooses to comply with an emissions limit in Condition 3.3.c. using
emissions averaging, the permittee must calculate and record for each calendar month the
pounds of PM or total metal HAP per ton of metal melted from the group of all metal
melting furnaces at the foundry. The permittee must calculate and record the weighted
average pounds per ton emissions rate for the group of all metal melting furnaces at the
foundry determined from the performance test procedures in Conditions 7.2.d and 7.2.e.
[40 CFR 63.10897(h)]
r. The permittee may change the operating limits for a wet scrubber, electrostatic
precipitator, or baghouse if the permittee meet the following requirements. [40 CFR
63.10898(l)]
i. Submit a written notification to the Administrator of a plan to conduct a new
performance test to revise the operating limit.
ii. Conduct a performance test to demonstrate compliance with the applicable
emissions limitation in Condition 3.3.c.
iii. Establish revised operating limits according to the applicable procedures in Table
2 to 40 CFR 63 Subpart ZZZZZ.
3.4. NESHAP Subpart CCCCCC – Gasoline Dispensing Facilities
The permittee may be subject to the federal regulations in 40 CFR Part 63 Subpart CCCCCC for
gasoline dispensing activities. The Environmental Quality Commission has not adopted or
incorporated these requirements in Oregon Administrative Rules, and are therefore, only
enforceable by the United States Environmental Protection Agency.
4.0 OPERATION AND MAINTENANCE REQUIREMENTS
4.1. Operation of Pollution Control Devices and Processes
The permittee must operate and ensure proper functioning of all air pollution control devices and
components at all times when the associated emission source is operating. [OAR 340-226-0120]
4.2. Surface Coating Restriction
The permittee is prohibited from using surface coatings that contain compounds of chromium,
lead, manganese, nickel, and/or cadmium.
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 16 of 41
4.3. Gasoline Dispensing Facilities
a. The permittee must not allow gasoline to be handled in a manner that would result in
vapor releases to the atmosphere for extended periods of time. Measures to be taken
include, but are not limited to the following: [40 CFR 63.11116(a), (b), (d) and OAR
340-244-0240]
i. Minimize gasoline spills;
ii. Clean up spills as expeditiously as practicable;
iii. Cover all open gasoline containers and all gasoline storage tank fill-pipes with a
gasketed seal when not in use;
iv. Do not top off or overfill vehicle tanks;
v. Post a sign at the gasoline dispensing facility instructing a person filling up a
motor vehicle to not top off the vehicle tank;
vi. Minimize gasoline sent to open waste collection systems that collect and transport
gasoline to reclamation and recycling devices, such as oil/water separators.
vii. Ensure cargo tanks unloading at the gasoline dispensing facility comply with the
requirements of Condition 4.3.a; and
viii. Portable gasoline containers that meet the requirements of 40 CFR Part 59,
subpart F, are considered acceptable for compliance with Condition 4.3.a.iii.
b. Except for gasoline storage tanks with a capacity of less than 250 gallons, the permittee
must only load gasoline into storage tanks at the facility utilizing submerged filling as
follows:
i. Submerged fill pipes installed on or before Nov. 9, 2006, must be no more than 12
inches from the bottom of the storage tank.
ii. Submerged fill pipes installed after Nov. 9, 2006, must be no more than 6 inches
from the bottom of the storage tank.
c. The applicable distances above must be measured from the point in the opening of the
submerged fill pipe that is the greatest distance from the bottom of the storage tank.
4.4. Highest and Best Practicable Treatment and Control
The permittee must provide the highest and best practicable treatment and control of air
contaminant emissions in every case so as to maintain overall air quality at the highest possible
levels, and to maintain contaminant concentrations, visibility reduction, odors, soiling, and other
deleterious factors at the lowest possible levels as provided below. [OAR 340-226-0100]
a. The permittee must not conduct any oxygen lancing on the #3 10TT Manganese Electric
Arc Furnace except when utilizing additional control equipment with prior written
approval of the Department.
b. The permittee must not backcharge in any electric arc furnace.
c. The permittee must, during tapping of either #1 6MT or #2 10TT Electric Arc Furnaces
shut the melting power off on both furnaces and divert all collection capacity (41,000
cfm) to the furnace collection hood.
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 17 of 41
5.0 PLANT SITE EMISSION LIMITS
5.1. Plant Site Emission Limits (PSEL)
The permittee must not cause or allow plant site emissions to exceed the following: [OAR 340-
222-0040 and/or OAR 340-222-0041, OAR 340-222-0060]
Pollutant Limit Units
PM 42
tons per year
PM10 28
PM2.5 19
NOX 39
CO 99
VOC 72
GHGs (CO2e) 87,000
5.2. Annual Period
The annual plant site emissions limits apply to any 12-consecutive calendar month period. [OAR
340-222-0035]
6.0 COMPLIANCE DEMONSTRATION
6.1. Monitoring Requirements
The permittee must monitor the operation and maintenance of the facility and associated air
contaminant control devices as follows: [OAR 340-226-0120]
a. Quantity (tons) of metal melted in the #1 6MT and #2 10TT steel EAFs.
b. Quantity (tons) of metal melted in the #3 10TT manganese EAF.
c. Quantity (tons) of metal melted in the induction furnaces (Building #8 and 11).
d. Quantity (tons) of sand throughput for the Main Foundry Sand System (Mills 1 & 3).
e. Quantity (tons) of sand throughput for the Group 8 Sand System (Mill 2).
f. Quantity (tons) of sand throughput for the Core Room Sand system.
g. Quantity (tons) of sand throughput for the South Foundry Sand System (Mills 1 & 3).
h. Quantity (tons) of sand throughput for the Main Foundry Shakeout.
i. Quantity (tons) of sand throughput for the Group 3 & 6 Sand System (Mill 4).
j. Quantity (tons) of sand throughput for the National Sand Reclaimer.
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 18 of 41
k. Quantity (tons) of sand throughput for the Group 9 Sand Reclaim system.
l. Quantity (tons) of sand throughput for the SMS Sand Reclaimer.
m. Quantity (tons) of sand processed through the Sand Dryer at Landfill.
n. Quantity (tons) of steel processed through the Joslyn Burn Arc #1.
o. Quantity (tons) of steel processed through the South Foundry Burn/Arc.
p. Quantity (tons) of steel processed through the Joslyn Rotoblast #1.
q. Quantity (tons) of steel processed through the Joslyn Rotoblast #2.
r. Quantity (tons) of steel processed through the Main Foundry Rotoblast.
s. Quantity (tons) of steel processed through the Joslyn Turnblast.
t. Quantity (tons) of steel processed through the Joslyn Spinblast.
u. Quantity (tons) of steel processed through the Main Foundry Rotoblast Room.
v. Quantity (tons) of steel processed through the Main Foundry Burn/Weld.
w. Number of patterns produced by the Pattern Shop.
x. Quantity of fuel combusted (MMft3 for gaseous fuels and gal for liquid fuels).
y. Name and quantity (pounds or gallons) of each coating/solvent used.
z. Name and quantity (pounds or gallons) of each mold/core wash used.
aa. Name and quantity of each coating, solvent, and mold/core wash shipped off site.
bb. If the permittee uses the Alternative PM PSEL Compliance methodology of Condition
6.3.; Quantity of PM captured by the respective control device (in lbs). If, based on
source operations, monthly PM capture monitoring is not feasible, monitoring may be
performed on an alternate schedule and the determined emission rate extrapolated to a
monthly value.
6.2. PSEL Compliance Monitoring using Emission Factors
The permittee must calculate the emissions for each 12-consecutive calendar month period based
on the following calculation for each pollutant except GHGs: [OAR 340-222-0080]
E = (EF * P) / 2000 pounds
where:
E = pollutant emissions (tons/year);
= symbol representing “summation of”;
EF = pollutant emission factor (see Condition 14.0);
P = process throughput (e.g., metal melted, natural gas combusted)
6.3. Alternative PM PSEL Compliance Monitoring
For any process controlled by a PM control device (e.g., baghouse, filter, rotoclone), the
permittee may demonstrate compliance with the PSEL for each 12-consecutive calendar month
period based on the following calculation for PM, PM10, and PM2.5:
E = (MC * 0.01) / 2000 pounds
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 19 of 41
where:
E = pollutant emissions (tons/year);
MC = Mass captured by PM control device (lbs/yr);
0.01 = 1 – Control efficiency (99%)
6.4. PSEL Compliance Monitoring: VOC Emissions
The permittee must demonstrate compliance with the annual VOC PSEL for each 12 consecutive
calendar month period based on the following formula:
EVOC-A= (EVOC-M)
EVOC-M= EVOC-CB + EVOC-CS
EVOC-CS= [(CX * DX * KX) – W] / 2,000
EVOC-CB= [(EFX * TX)] / 2,000 where:
EVOC-A = Annual VOC emissions in tons
EVOC-M = Monthly VOC emissions in tons
EVOC-CS= Monthly VOC emissions from coatings, cleaners, solvents, and other
liquids in tons
EVOC-CB= Monthly VOC emissions from combustion and furnaces in tons
C = Material usage for the period in gallons
D = Material density in pounds per gallon
K = VOC concentration expressed as a decimal
X = Subscript X represents a specific material
W = Weight of VOC shipped offsite in pounds
EF = Emission factor (see Condition 14.0)
T = Throughput (e.g., metal melted, natural gas combusted)
6.5. Emission Factors
The permittee must use the default emission factors provided in Condition 14.0 for calculating
pollutant emissions, unless alternative emission factors are approved in writing by DEQ. The
permittee may request or DEQ may require using alternative emission factors provided they are
based on actual test data or other documentation (e.g., AP-42 compilation of emission factors)
that has been reviewed and approved by DEQ. [OAR 340-222-0080]
6.6. Greenhouse Gas Emissions
The permittee must calculate greenhouse gas emissions in metric tons and short tons for each 12-
consecutive calendar month period to determine compliance with the GHG PSEL by using the
following: [OAR 340-215-0040]
a. DEQ Fuel Combustion Greenhouse Gas Calculator
https://www.oregon.gov/deq/FilterDocs/ghgCalculatorFuelCombust.xlsx;
b. EPA emission quantification methodologies as prescribed in 40 CFR Part 98 subparts E
through UU; and
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 20 of 41
c. https://ccdsupport.com/confluence/display/help/Optional+Calculation+Spreadsheet+Instr
uctions.
6.7. PSEL Compliance Monitoring
The permittee must demonstrate compliance with the PSEL by totaling the emissions from all
point sources calculated under Conditions 6.2, 6.3, 6.4, and 6.6. [OAR 340-222-0080]
7.0 SOURCE TESTING
7.1. Source Testing Requirements
The permittee must perform the following source tests within 18 months of permit issuance
unless an extension is approved by DEQ: [OAR 340-212-0120]
a. the permittee must conduct a source test of the three Electric Arc Furnaces (#1 6MT Steel
Electric Arc Furnace, #2 10TT Steel Electric Arc Furnace, and #3 10TT Manganese
Electric Arc Furnace) to verify emission factors used to determine compliance with the
PSELs of Condition 5.1 for Particulate Matter, PM10, PM2.5, NOx, and CO and must test
these units for As, Cr, Pb, Ni, and Mn emissions using the following test methods and
procedures:
b. DEQ approved testing conducted after July 1, 2020, may satisfy the testing requirements
of this permit.
c. The permittee must perform oxygen lancing on the #1 6MT and #2 10TT Electric Arc
Furnaces during the performance test.
d. During the source test, the following parameters must be monitored and recorded:
i. Visible emissions as measured by EPA Method 9 for a period of at least six
minutes during or within 30 minutes before or after each test run;
ii. Quantity of metal melted;
iii. Baghouse pressure differential
iv. Times that oxygen lancing occurs in the #1 6MT and #2 10TT Electric Arc
Furnaces; and
v. Oxygen flow for each oxygen lancing event in the #1 6MT and #2 10TT Electric
Arc Furnaces.
e. All tests must be conducted in accordance with DEQ’s Source Sampling Manual and the
approved source test plan. The source test plan must be submitted at least 30 days in
advance and approved by the Regional Source Test Coordinator. The source test report
must be submitted to the Regional Source Test Coordinator within 60 days of the test
unless otherwise approved in the source test plan.
Tested Pollutant Reference Test Method*
PM See Condition 7.1.f
NOx EPA Method 7E
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 21 of 41
Tested Pollutant Reference Test Method*
CO EPA Method 10 but the test must include quality
assurance from EPA Method 7E
As, Cr, Pb, Ni,
and Mn EPA Method 29
Opacity EPA Method 9
*Substitution of alternative test methods must be pre-approved by the DEQ.
f. For particulate matter, PM10, and PM2.5, the permittee must use:
i. Oregon Method 5 or
ii. EPA 201 or 201A for front-half, filterable particulate matter and EPA Method
202 for back-half, condensable particulate matter. The sample-volume
requirements of the Department’s Source Sampling Manual for Method 5 apply to
Methods 201 and 201A as well.
iii. The minimum sample-mass requirements in Method 5I apply separately to the
front and back half samples instead of the Manual’s sample-volume requirements.
If performing Oregon Method 5, adopt all procedures and quality assurance in
Method 5I, applying the requirements for acetone to the other solvents, water and
methylene chloride. For emission-factor verification, the minimum sample mass
requirement applies at the level of the permit’s current, applicable emission factor
for reporting emissions instead of half the emission limit.
g. Only regular operating staff may adjust the combustion system or production processes
and emission control parameters during the source test and within two hours prior to the
source test. Any operating adjustments made during the source test, which are a result of
consultation with source testing personnel, equipment vendors or consultants, may render
the source test invalid.
7.2. NESHAP Subpart ZZZZZ – Large Foundries
If the annual metal melt production exceeds 20,000 tons during the preceding year, the permittee
must comply with the following requirements for large foundries by the applicable dates in
Condition 9.2.c. [40 CFR 63.10890(h)] The following conditions summarize the applicable
compliance demonstration requirements of 40 CFR Subpart ZZZZZ for Large Foundries, but are
not intended to supersede the Subpart:
a. The permittee must conduct a performance test to demonstrate initial compliance with the
applicable emissions limits for each metal melting furnace or group of all metal melting
furnaces that is subject to an emissions limit in Condition 3.3.c and for each building or
structure housing foundry operations that is subject to the opacity limit for fugitive
emissions in Condition 3.3.d. The test must be conducted within 180 days of the
compliance date and results must be reported in the notification of compliance status. [40
CFR 63.10898(a)]
i. The permittee may choose to submit the results of a prior performance test for PM
or total metal HAP that demonstrates compliance with the applicable emissions
limit for a metal melting furnace or group of all metal melting furnaces provided
the test was conducted within the last 5 years using the methods and procedures
specified in this condition and either no process changes have been made since
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 22 of 41
the test, or it can be demonstrated that the results of the performance test, with or
without adjustments, reliably demonstrate compliance with the applicable
emissions limit despite such process changes.
ii. If the permittee chooses to submit the results of a prior performance test
according to Condition 7.2.a.i of this section, the permittee must submit a written
notification to the Administrator of intent to use the previous test data no later
than 60 days after the compliance date. The notification must contain a full copy
of the performance test and contain information to demonstrate, if applicable, that
either no process changes have been made since the test, or that the results of the
performance test, with or without adjustments, reliably demonstrate compliance
despite such process changes.
iii. If the permittee has an electric induction furnace equipped with an emissions
control device at an existing foundry, the permittee may use the test results from
another electric induction furnace to demonstrate compliance with the applicable
PM or total metal HAP emissions limit in Condition3.3.c provided the furnaces
are similar with respect to the type of emission control device that is used, the
composition of the scrap charged, furnace size, and furnace melting temperature.
iv. If the permittee has an uncontrolled electric induction furnace at an existing
foundry, the permittee may use the test results from another electric induction
furnace to demonstrate compliance with the applicable PM or total metal HAP
emissions limit in Condition 3.3.c provided the test results are prior to any control
device and the electric induction furnaces are similar with respect to the
composition of the scrap charged, furnace size, and furnace melting temperature.
v. For electric induction furnaces that do not have emission capture systems, the
permittee may install a temporary enclosure for the purpose of representative
sampling of emissions. A permanent enclosure and capture system is not required
for the purpose of the performance test.
b. The permittee must conduct subsequent performance tests to demonstrate compliance
with all applicable PM or total metal HAP emissions limits in Condition 3.3.c for a metal
melting furnace or group of all metal melting furnaces no less frequently than every 5
years and each time the permittee elects to change an operating limit or make a process
change likely to increase HAP emissions. [40 CFR 63.10898(b)]
c. The permittee must conduct each performance test according to the requirements in 40
CFR 63.7(e)(1), Table 1, and Conditions 7.2.d through 7.2.g. [40 CFR 63.10898(c)]
d. To determine compliance with the applicable PM or total metal HAP emissions limit in
3.3.c for a metal melting furnace in a lb/ton of metal charged format, compute the
process-weighted mass emissions (Ep) for each test run using the following equation: [40
CFR 63.10898(d)]
Where:
Ep = Process-weighted mass emissions rate of PM or total metal HAP, pounds of PM or total metal HAP per ton
(lb/ton) of metal charged;
C = Concentration of PM or total metal HAP measured during performance test run, grains per dry standard cubic foot
(gr/dscf);
Q = Volumetric flow rate of exhaust gas, dry standard cubic feet per hour (dscf/hr);
T = Total time during a test run that a sample is withdrawn from the stack during melt production cycle, hr;
P = Total amount of metal charged during the test run, tons; and
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 23 of 41
K = Conversion factor, 7,000 grains per pound.
e. To determine compliance with the applicable emissions limit in Condition 3.3.c for a
group of all metal melting furnaces using emissions averaging: [40 CFR 63.10898(e)]
i. Determine and record the monthly average charge rate for each metal melting
furnace at your iron and steel foundry for the previous calendar month; and
ii. Compute the mass-weighted PM or total metal HAP using the following equation
Where:
EC = The mass-weighted PM or total metal HAP emissions for the group of all metal melting furnaces at the
foundry, pounds of PM or total metal HAP per ton of metal charged;
Epi = Process-weighted mass emissions of PM or total metal HAP for individual emission unit i as determined
from the performance test and calculated using Equation 1 of this section, pounds of PM or total metal HAP
per ton of metal charged;
Tti = Total tons of metal charged for individual emission unit i for the calendar month prior to the
performance test, tons; and
n = The total number of metal melting furnaces at the iron and steel foundry.
iii. For an uncontrolled electric induction furnace that is not equipped with a capture
system and has not been previously tested for PM or total metal HAP, the
permittee may assume an emissions factor of 2 pounds per ton of PM or 0.13
pounds of total metal HAP per ton of metal melted in Equation 2 of this section
instead of a measured test value. If the uncontrolled electric induction furnace is
equipped with a capture system, the permittee must use a measured test value.
f. To determine compliance with the applicable PM or total metal HAP emissions limit for
a metal melting furnace in Condition 3.3.c when emissions from one or more regulated
furnaces are combined with other non-regulated emissions sources, the permittee may
demonstrate compliance using the procedures below: [40 CFR 63.10898(f)]
i. Determine the PM or total metal HAP process-weighted mass emissions for each
of the regulated streams prior to the combination with other exhaust streams or
control device.
ii. Measure the flow rate and PM or total metal HAP concentration of the combined
exhaust stream both before and after the control device and calculate the mass
removal efficiency of the control device using the following equation.
Where:
Ei = Mass emissions rate of PM or total metal HAP at the control device inlet, lb/hr;
Eo = Mass emissions rate of PM or total metal HAP at the control device outlet, lb/hr.
iii. Meet the applicable emissions limit based on the calculated PM or total metal
HAP process-weighted mass emissions for the regulated emissions source using
the following equation:
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 24 of 41
Where:
Ep1released = Calculated process-weighted mass emissions of PM (or total metal HAP) predicted to be released to
the atmosphere from the regulated emissions source, pounds of PM or total metal HAP per ton of metal
charged; and
Ep1i = Process-weighted mass emissions of PM (or total metal HAP) in the uncontrolled regulated exhaust
stream, pounds of PM or total metal HAP per ton of metal charged.
g. To determine compliance with an emissions limit for situations when multiple sources are
controlled by a single control device, but only one source operates at a time or other
situations that are not expressly considered in Conditions 7.2.d through 7.2.f, submit a
site-specific test plan to the Administrator for approval according to the requirements in
40 CFR 63.7(c)(2) and (3). [40 CFR 63.10898(g)]
h. Conduct each opacity test for fugitive emissions according to the requirements in 40 CFR
63.6(h)(5) and Table 1 of 40 CFR 63 Subpart ZZZZZ. [40 CFR 63.10898(h)]
i. Conduct subsequent performance tests to demonstrate compliance with the opacity limit
in Condition 3.3.d. no less frequently than every 6 months and each time you make a
process change likely to increase fugitive emissions. [40 CFR 63.10898(i)]
j. In the performance test report, the permittee must certify that the capture system operated
normally during the performance test. [40 CFR 63.10898(j)]
8.0 RECORDKEEPING REQUIREMENTS
8.1. Operation and Maintenance
The permittee must maintain the following records related to the operation and maintenance of
the facility and associated air contaminant control devices: [OAR 340-214-0114]
a. Baghouse operational parameters:
i. Records documenting the date, time, and differential pressure reading for each
fabric/cartridge filter baghouse.
ii. Records of baghouse inspections and bag replacement.
iii. Records documenting the engineering design specifications or equivalent
documentation detailing proper operation and maintenance for all fabric/cartridge
filter baghouses at the facility.
iv. Date and time corrective action commenced and completion date of corrective
action for noted excursions of a baghouse/fabric filter operational design range.
b. Quantity (tons) of metal melted in the #1 6MT and #2 10TT steel EAFs.
c. Quantity (tons) of metal melted in the #3 10TT manganese EAF.
d. Quantity (tons) of metal melted in the induction furnaces (Building #8 and 11).
e. Quantity (tons) of sand throughput for the Main Foundry Sand System (Mills 1 & 3).
f. Quantity (tons) of sand throughput for the Group 8 Sand System (Mill 2).
g. Quantity (tons) of sand throughput for the Core Room Sand system.
h. Quantity (tons) of sand throughput for the South Foundry Sand System (Mills 1 & 3).
i. Quantity (tons) of sand throughput for the Main Foundry Shakeout.
j. Quantity (tons) of sand throughput for the Group 3 & 6 Sand System (Mill 4).
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 25 of 41
k. Quantity (tons) of sand throughput for the National Sand Reclaimer.
l. Quantity (tons) of sand throughput for the Group 9 Sand Reclaim system.
m. Quantity (tons) of sand throughput for the SMS Sand Reclaimer.
n. Quantity (tons) of sand processed through the Sand Dryer at Landfill.
o. Quantity (tons) of steel processed through the Joslyn Burn Arc #1.
p. Quantity (tons) of steel processed through the South Foundry Burn/Arc.
q. Quantity (tons) of steel processed through the Joslyn Rotoblast #1.
r. Quantity (tons) of steel processed through the Joslyn Rotoblast #2.
s. Quantity (tons) of steel processed through the Main Foundry Rotoblast.
t. Quantity (tons) of steel processed through the Joslyn Turnblast.
u. Quantity (tons) of steel processed through the Joslyn Spinblast.
v. Quantity (tons) of steel processed through the Main Foundry Rotoblast Room.
w. Quantity (tons) of steel processed through the Main Foundry Burn/Weld.
x. Number of patterns produced by the Pattern Shop.
y. Quantity of fuel combusted (MMft3 for gaseous fuels and gal for liquid fuels).
z. Name and quantity (pounds or gallons) of each coating/solvent used.
aa. Name and quantity (pounds or gallons) of each mold/core wash used.
bb. Name and quantity of each coating, solvent, and mold/core wash shipped off site.
cc. For each VOC containing, solvent, and mold/core wash used, records identifying the
product name and VOC content in lbs/gal. Records must be updated upon change of
product or change of product formulation.
dd. If the permittee uses the Alternative PM PSEL Compliance methodology of Condition
6.3; Quantity of PM captured by the respective control device (in lbs). If, based on source
operations, monthly PM capture monitoring is not feasible, monitoring may be performed
on an alternate schedule and the determined emission rate extrapolated to a monthly
value.
ee. Monthly, and 12-month emission rate calculations in accordance with Conditions 6.2,
6.3, 6.4, and 6.6 to demonstrate compliance with each of the PSELs of Condition 5.1
8.2. Excess Emissions
a. The permittee must maintain the records of excess emissions listed below and as defined
in OAR 340-214-0300 through 340-214-0340, recorded on occurrence. Typically, excess
emissions are caused by process upsets, startups, shutdowns, or scheduled maintenance.
In many cases, excess emissions are evident when visible emissions are greater than 20%
opacity as a six-minute block average.
i. The date and time of the beginning of the excess emissions event and the duration
or best estimate of the time until return to normal operation;
ii. The date and time the permittee notified DEQ of the event;
iii. The equipment involved;
iv. Whether the event occurred during planned startup, planned shutdown, scheduled
maintenance, or as a result of a breakdown, malfunction, or emergency;
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 26 of 41
v. Steps taken to mitigate emissions and corrective action taken, including whether
the approved procedures for a planned startup, shutdown, or maintenance activity
were followed;
vi. The magnitude and duration of each occurrence of excess emissions during the
course of an event and the increase over normal rates or concentrations as
determined by continuous monitoring or best estimate (supported by operating
data and calculations); and
vii. The final resolution of the cause of the excess emissions;
b. If there is an ongoing excess emission caused by an upset or breakdown, the permittee
must immediately take action to minimize emissions by reducing or ceasing operation of
the equipment or facility, unless doing so could result in physical damage to the
equipment or facility, or cause injury to employees. In no case may the permittee operate
more than 48 hours after the beginning of the excess emissions, unless continued
operation is approved by DEQ in accordance with OAR 340-214-0330(4).
c. In the event of any excess emissions which are of a nature that could endanger public
health and occur during non-business hours, weekends, or holidays, the permittee must
immediately notify DEQ by calling the Oregon Emergency Response System (OERS).
The current number is 1-800-452-0311.
d. If startups or shutdowns may result in excess emissions, the permittee must submit
startup/shutdown procedures used to minimize excess emissions to DEQ for prior
authorization, as required in OAR 340-214-0310. New or modified procedures must be
received by DEQ in writing at least 72 hours prior to the first occurrence of the excess
emission event. The permittee must abide by the approved procedures and have a copy
available at all times.
e. If permittee anticipates that scheduled maintenance may result in excess emissions, the
permittee must submit scheduled maintenance procedures used to minimize excess
emissions to DEQ for prior authorization, as required in OAR 340-214-0320. New or
modified procedures must be received by DEQ in writing at least 72 hours prior to the
first occurrence of the excess emission event. The permittee must abide by the approved
procedures and have a copy available at all times.
f. The permittee must maintain a log of all excess emissions in accordance with OAR 340-
214-0340(3).
8.3. Complaints
The permittee must maintain a log of all complaints received by the permittee in person, in
writing, by telephone or through other means according to Condition 2.6. Documentation must
include all information identified in Condition 2.6. [OAR 340-214-0114]
8.4. Retention of Records
Unless otherwise specified, the permittee must retain all records for a period of at least five (5)
years from the date of the monitoring sample, measurement, report, or application and make
them available to DEQ upon request. The permittee must maintain the two (2) most recent years
of records onsite. [OAR 340-214-0114]
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 27 of 41
8.5. NESHAP Subpart ZZZZZ – Small Foundry
The following conditions summarize the applicable recordkeeping requirements of 40 CFR
Subpart ZZZZZ for Small Foundries, but are not intended to supersede the Subpart:
a. The permittee must maintain files of all information (including all reports and
notifications) for at least 5 years following the date of each occurrence, measurement,
maintenance, corrective action, report, or record. At a minimum, the most recent 2 years
of data shall be retained on site. The remaining 3 years of data may be retained off site.
[40 CFR 63.10890(d)]
b. The permittee must maintain the following records: [40 CFR 63.10890(e)]
i. Records supporting initial notification of applicability and notification of
compliance status.
ii. Records of written materials specifications according to 3.2.b and records that
demonstrate compliance with the requirements for restricted metallic scrap in
3.2.b.i and/or for the use of general scrap in 3.2.b.ii and for mercury in 3.2.c, as
applicable. The permittee must keep records documenting compliance with 3.2.c.i
for scrap that does not contain motor vehicle scrap.
iii. Records to document use of binder chemical formulation that does not contain
methanol as a specific ingredient of the catalyst formulation for each furfuryl
alcohol warm box mold or core making line. These records must be the Material
Safety Data Sheet (provided that it contains appropriate information), a certified
product data sheet, or a manufacturer's hazardous air pollutant data sheet.
iv. Records of the annual quantity and composition of each HAP-containing chemical
binder or coating material used to make molds and cores. These records must be
copies of purchasing records, Material Safety Data Sheets, or other documentation
that provides information on the binder or coating materials used.
v. Records of metal melt production for each calendar year.
8.6. NESHAP Subpart ZZZZZ – Large Foundry
If the annual metal melt production exceeds 20,000 tons during the preceding year, the permittee
must comply with the following requirements for large foundries by the applicable dates in
Condition 9.2.c. [40 CFR 63.10890(h)] The following conditions summarize the applicable
recordkeeping requirements of 40 CFR Subpart ZZZZZ for Large Foundries, but are not
intended to supersede the Subpart:
a. The permittee must maintain files of all information (including all reports and
notifications) for at least 5 years following the date of each occurrence, measurement,
maintenance, corrective action, report, or record. At a minimum, the most recent 2 years
of data shall be retained on site. The remaining 3 years of data may be retained off site.
Such files may be maintained on microfilm, on a computer, on computer floppy disks, on
magnetic tape disks, or on microfiche. [40 CFR 63.10899(a)]
b. In addition to the records required by 40 CFR 63.10, the permittee must keep records of
the information specified below: [40 CFR 63.10899(b)]
i. Records of written materials specifications according to Condition 3.3.f and
records that demonstrate compliance with the requirements for restricted metallic
scrap in Condition 3.3.f.i and/or for the use of general scrap in Condition 3.3.f.ii
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 28 of 41
and for mercury in Condition 3.3.g.i. Records documenting compliance with
Condition 3.3.g.i for scrap that does not contain motor vehicle scrap.
ii. The permittee must keep records to document use of any binder chemical
formulation that does not contain methanol as a specific ingredient of the catalyst
formulation for each furfuryl alcohol warm box mold or core making line as
required by Condition 3.3.h. These records must be the Material Safety Data
Sheet (provided that it contains appropriate information), a certified product data
sheet, or a manufacturer's hazardous air pollutant data sheet.
iii. The permittee must keep records of the annual quantity and composition of each
HAP-containing chemical binder or coating material used to make molds and
cores. These records must be copies of purchasing records, Material Safety Data
Sheets, or other documentation that provide information on the binder or coating
materials used.
iv. The permittee must keep records of monthly metal melt production for each
calendar year.
v. The permittee must keep a copy of the operation and maintenance plan as
required by Condition 3.3.j. and records that demonstrate compliance with plan
requirements.
vi. If the permittee uses emissions averaging, records of the monthly metal melting
rate for each furnace at the iron and steel foundry, and records of the calculated
pounds of PM or total metal HAP per ton of metal melted for the group of all
metal melting furnaces required by Condition 3.3.q.
vii. If applicable, records for bag leak detection systems as follows:
A. Records of the bag leak detection system output;
B. Records of bag leak detection system adjustments, including the date and
time of the adjustment, the initial bag leak detection system settings, and
the final bag leak detection system settings; and
C. The date and time of all bag leak detection system alarms, and for each
valid alarm, the time you initiated corrective action, the corrective action
taken, and the date on which corrective action was completed.
viii. Records of capture system inspections and repairs as required by Condition 3.3.n.
ix. Records demonstrating conformance with your specifications for the operation of
CPMS as required by Condition 3.3.o.
x. Records of corrective action(s) for exceedances and excursions as required by
Condition 3.3.p.
xi. Record the results of each inspection and maintenance required by Condition 3.3.l
for PM control devices in a logbook (written or electronic format).
The logbook must be kept onsite and made available to the Administrator upon
request. The permittee must keep records of the information as follows:
A. The date and time of each recorded action for a fabric filter, the results of
each inspection, and the results of any maintenance performed on the bag
filters.
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 29 of 41
B. The date and time of each recorded action for a wet or dry electrostatic
precipitator (including ductwork), the results of each inspection, and the
results of any maintenance performed for the electrostatic precipitator.
C. The date and time of each recorded action for a wet scrubber (including
ductwork), the results of each inspection, and the results of any
maintenance performed on the wet scrubber.
9.0 REPORTING REQUIREMENTS
9.1. Excess Emissions
a. The permittee must notify DEQ of excess emissions events if the excess emission is of a
nature that could endanger public health.
b. The permittee must also submit follow-up reports summarizing records of excess
emissions as required in Condition 8.2 when required by DEQ. Such notice must be
provided as soon as possible, but never more than one hour after becoming aware of the
problem. Notice must be made to the regional office identified in Condition 11.0 by
email, telephone, facsimile, or in person.
9.2. NESHAP Subpart ZZZZZ – Small Foundry Reporting
The following conditions summarize the applicable reporting requirements of 40 CFR 63
Subpart ZZZZZ for Small Foundries, but are not intended to supersede the Subpart:
a. The permittee must submit semiannual compliance reports to the Administrator according
to the requirements in §63.10(e). The report must clearly identify any deviation from the
pollution prevention management practices in Conditions 3.2.b, 3.2.c, and 3.2.d and the
corrective action taken. [40 CFR 63.10890(f)]
b. The permittee must submit a written notification to the Administrator of the initial
classification of your facility as a small foundry as required in 40 CFR 63.10880(f) and
(g), as applicable, and for any subsequent reclassification as required in Condition 9.2.c.
[40 CFR 63.10890(g)]
c. If the annual metal melt production of the small foundry exceeds 20,000 tons during the
preceding calendar year, the permittee must submit a notification of foundry
reclassification to the Administrator within 30 days and comply with the following
requirements. [40 CFR 63.10881(d)(1)]
i. If the permittee’s small foundry has never been classified as a large foundry, the
permittee must comply with the requirements for a large foundry no later than 2
years after the date of the foundry's notification that the annual metal melt
production exceeded 20,000 tons.
ii. If the permittee’s small foundry had previously been classified as a large foundry,
the permittee must comply with the requirements for a large foundry no later than
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 30 of 41
the date of the foundry's most recent notification that the annual metal melt
production exceeded 20,000 tons.
9.3. NESHAP Subpart ZZZZZ – Large Foundry Reporting
If the annual metal melt production exceeds 20,000 tons during the preceding year, the permittee
must comply with the following requirements for large foundries by the applicable dates in
Condition 9.2.c. [40 CFR 63.10890(h)] The following conditions summarize the applicable
reporting requirements of 40 CFR 63 Subpart ZZZZZ for Large Foundries, but are not intended
to supersede the Subpart:
a. The permittee must submit semiannual compliance reports to the Administrator according
to the requirements in 40 CFR 63.10(e). The reports must include, at a minimum, the
following information as applicable: [40 CFR 63.10899(c)]
i. Summary information on the number, duration, and cause (including unknown
cause, if applicable) of excursions or exceedances, as applicable, and the
corrective action taken;
ii. Summary information on the number, duration, and cause (including unknown
cause, if applicable) for monitor downtime incidents (other than downtime
associated with zero and span or other calibration checks, if applicable); and
iii. Summary information on any deviation from the pollution prevention
management practices in Conditions 3.3.f through 3.3.h and the operation and
maintenance requirements in Conditions 3.3.j. and 3.3.k. and the corrective action
taken.
b. The permittee must submit written notification to the Administrator of the initial
classification of the existing affected source as a large iron and steel facility as required
in 40 CFR 63.10880(f) and (g), as applicable, and for any subsequent reclassification as
required in Condition 3.3.e. [40 CFR 63.10899(d)]
9.4. Annual Report
For each year this permit is in effect, the permittee must submit to DEQ by March 1 two (2)
paper copies and one (1) electronic copy of the following information for the previous calendar
year. If March 1 falls on a weekend or Monday holiday, the permittee must submit their annual
report on the next business day.
a. Operating parameters as listed in Condition 6.1:
i. Quantity of steel melted annually in each Electric Arc and Induction furnace, in
tons.
ii. Quantity of sand used annually in each mold and coremaking line, and each sand
reclamation line.
iii. Pattern production, in 1000’s of patterns.
iv. Throughput on each burn arc station, in tons steel of castings.
v. Usage of coatings, solvents, and mold & core washes, in gallons.
vi. Fuel consumption for stationary sources, in millions of cubic feet (MMft3) for
gaseous fuels and gallons for liquid fuels.
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 31 of 41
b. Calculations of annual pollutant emissions determined each month in accordance with
Condition 6.2, 6.3, 6.4, and 6.6.
c. A brief summary listing the date, time, and the affected device/process for each excess
emission that occurred during the reporting period.
d. Summary of complaints relating to air quality received by permittee during the year in
accordance with Condition 2.6.
e. List permanent changes made in facility process, production levels, and pollution control
equipment which affected air contaminant emissions.
f. List major maintenance performed on pollution control equipment.
9.5. Greenhouse Gas Registration and Reporting
a. If the calendar year greenhouse gas emissions (CO2e) are ever greater than or equal to
2,756 tons (2,500 metric tons), the permittee must annually register and report its
greenhouse gas emissions with DEQ in accordance with OAR 340 division 215.
b. If the calendar year greenhouse gas emissions (CO2e) are less than 2,756 tons (2,500
metric tons) for three consecutive years, the permittee may stop reporting greenhouse gas
emissions but must retain all records used to calculate greenhouse gas emissions for the
five years following the last year that they were required to report. The permittee must
resume reporting its greenhouse gas emissions if the calendar year greenhouse gas
emissions (CO2e) are greater than or equal to 2,756 tons (2,500 metric tons) in any
subsequent calendar year.
9.6. Notice of Change of Ownership or Company Name
The permittee must notify DEQ in writing using a DEQ “Transfer Application Form” within 60
days after the following:
a. Legal change of the name of the company as registered with the Corporations Division of
the State of Oregon; or
b. Sale or exchange of the activity or facility.
9.7. Construction or Modification Notices
The permittee must notify DEQ in writing using a DEQ “Notice of Intent to Construct Form,” or
other permit application form and obtain approval in accordance with OAR 340-210-0205
through 340-210-0250 and OAR 340-245-0060(4)(c) before:
a. Constructing, installing, or establishing a new stationary source that will cause an
increase in any regulated pollutant emissions;
b. Making any physical change or change in operation of an existing stationary source that
will cause an increase, on an hourly basis at full production, in any regulated pollutant
emissions; or
c. Constructing or modifying any air pollution control equipment.
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 32 of 41
10.0 ADMINISTRATIVE REQUIREMENTS
10.1. Permit Renewal Application
The permittee must submit the completed application package for renewal of this permit 180
days prior to the expiration date. Two (2) paper copies and one (1) electronic copy of the
application must be submitted to the DEQ Permit Coordinator listed in Condition 11.2. [OAR
340-216-0040]
10.2. Permit Modifications
Application for a modification of this permit must be submitted at least 60 days prior to the
source modification. When preparing an application, the applicant should also consider
submitting the application 180 days prior to allow DEQ adequate time to process the application
and issue a permit before it is needed. A special activity fee must be submitted with an
application for the permit modification. The fees and two (2) copies of the application must be
submitted to the DEQ Business Office.
10.3. Annual Compliance Fee
The permittee must pay the annual fees specified in OAR 340-216-8020, Table 2, Part 2 and 3
for a Standard ACDP by December 1 of each year this permit is in effect. An invoice indicating
the amount, as determined by DEQ regulations will be mailed prior to the above date. Late fees
in accordance with Part 5 of the table will be assessed as appropriate.
10.4. Change of Ownership or Company Name Fee
The permittee must pay the non-technical permit modification fee specified in OAR 340-216-
8020, Table 2, Part 4 with an application for changing the ownership or the name of the
company.
10.5. Special Activity Fees
The permittee must pay the special activity fees specified in OAR 340-216-8020, Table 2, Part 4
with an application to modify the permit.
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 33 of 41
11.0 DEQ CONTACTS / ADDRESSES
11.1. Business Office
The permittee must submit payments for invoices, applications to modify the permit, and any
other payments to DEQ’s Business Office:
Oregon Dept. of Environmental Quality
Financial Services – Revenue Section
700 NE Multnomah St., Suite 600
Portland, Oregon 97232-4100
11.2. Permit Coordinator
The permittee must submit all notices and applications that do not include payment to the Permit
Coordinator.
Oregon Dept. of Environmental Quality
Northwest Region AQ Permit Coordinator
700 NE Multnomah St., Suite 600
Portland, OR 97232-4100
11.3. Report Submittals
Unless otherwise notified, the permittee must submit all reports (annual reports, source test plans
and reports, etc.) to DEQ’s Region. If you know the name of the Air Quality staff member
responsible for your permit, please include it:
Oregon Dept. of Environmental Quality
Northwest Region Air Quality
700 NE Multnomah St., Suite 600
Portland, OR 97232-4100
11.4. Web Site
Information about air quality permits and DEQ’s regulations may be obtained from the DEQ web
page at www.oregon.gov/deq/.
12.0 GENERAL CONDITIONS AND DISCLAIMERS
12.1. Permitted Activities
a. Until this permit expires or is modified or revoked, the permittee is allowed to discharge
air contaminants from the following:
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 34 of 41
i. Processes and activities directly related to or associated with the
devices/processes listed in Condition 1.0 of this permit;
i. Any categorically insignificant activities, as defined in OAR 340-200-0020, at the
source; and
ii. Construction or modification changes that are Type 1 or Type 2 changes under
OAR 340-210-0225 that are approved by DEQ in accordance with OAR 340-210-
0215 through 0250, if the permittee complies with all of the conditions of DEQ’s
approval to construct and all of the conditions of this permit.
b. Discharge of air contaminants from any other equipment or activity not identified herein
is not authorized by this permit.
12.2. Other Regulations
In addition to the specific requirements listed in this permit, the permittee must comply with all
other applicable legal requirements enforceable by DEQ.
12.3. Conflicting Conditions
In any instance in which there is an apparent conflict relative to conditions in this permit, the
most stringent conditions apply. [OAR 340-200-0010]
12.4. Masking of Emissions
The permittee must not cause or permit the installation of any device or use any means designed
to mask the emissions of an air contaminant that causes or is likely to cause detriment to health,
safety, or welfare of any person or otherwise violate any other regulation or requirement. [OAR
340-208-0400]
12.5. DEQ Access
The permittee must allow DEQ’s representatives access to the plant site and pertinent records at
all reasonable times for the purposes of performing inspections, surveys, collecting samples,
obtaining data, reviewing and copying air contaminant emissions discharge records and
conducting all necessary functions related to this permit in accordance with ORS 468.095.
12.6. Permit Availability
The permittee must have a copy of the permit available at the facility at all times. [OAR 340-
216-0020(3)]
12.7. Open Burning
The permittee may not conduct any open burning except as allowed by OAR 340, division 264.
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 35 of 41
12.8. Asbestos
The permittee must comply with the asbestos abatement requirements in OAR 340, division 248
for all activities involving asbestos-containing materials, including, but not limited to,
demolition, renovation, repair, construction, and maintenance.
12.9. Property Rights
The issuance of this permit does not convey any property rights in either real or personal
property, or any exclusive privileges, nor does it authorize any injury to private property or any
invasion of personal rights, nor any infringement of federal, state, or local laws or regulations.
12.10. Permit Expiration
a. A source may not be operated after the expiration date of the permit, unless any of the
following occur prior to the expiration date of the permit: [OAR 340-216-0082]
i. A timely and complete application for renewal of this permit or for a different
ACDP has been submitted; or
ii. A timely and complete application for renewal or for an Oregon Title V
Operating Permit has been submitted, or
iii. Another type of permit (ACDP or Oregon Title V Operating Permit) has been
issued authorizing operation of the source.
b. For a source operating under an ACDP or Oregon Title V Operating Permit, a
requirement established in an earlier ACDP remains in effect notwithstanding expiration
of the ACDP, unless the provision expires by its terms or unless the provision is modified
or terminated according to the procedures used to establish the requirement initially.
12.11. Permit Termination, Revocation, or Modification
DEQ may terminate, revoke, or modify this permit pursuant to OAR chapter 340 division 216.
[OAR 340-216-0082].
13.0 40 CFR 63, SUBPART ZZZZZ, TABLE 3 (LARGE
FOUNDRIES)
If the annual metal melt production exceeds 20,000 tons during the preceding year, the permittee
must comply with the following requirements for large foundries by the applicable dates in
Condition 9.2.c. [40 CFR 63.10890(h)]
Citation Subject Applies to
large foundry? Explanation
63.1 Applicability Yes.
63.2 Definitions Yes.
63.3 Units and abbreviations Yes.
63.4 Prohibited activities Yes.
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 36 of 41
Citation Subject Applies to
large foundry? Explanation
63.5 Construction/reconstruction Yes.
63.6(a)-(g) Compliance with standards and
maintenance requirements Yes.
63.6(h) Opacity and visible emissions
standards Yes.
63.6(i)(i)-(j)
Compliance extension and
Presidential compliance
exemption
Yes.
63.7(a)(3), (b)-(h) Performance testing
requirements Yes.
63.7(a)(1)-(a)(2) Applicability and performance
test dates No
Subpart ZZZZZ
specifies
applicability and
performance test
dates.
63.8(a)(1)-(a)(3),
(b), (c)(1)-(c)(3),
(c)(6)-(c)(8), (d),
(e), (f)(1)-(f)(6),
(g)(1)-(g)(4)
Monitoring requirements Yes.
63.8(a)(4)
Additional monitoring
requirements for control
devices in §63.11
No.
63.8(c)(4) Continuous monitoring system
(CMS) requirements No.
63.8(c)(5)
Continuous opacity monitoring
system (COMS) minimum
procedures
No.
63.8(g)(5) Data reduction No.
63.9 Notification requirements Yes.
63.10(a), (b)(1)-
(b)(2)(xii) -
(b)(2)(xiv), (b)(3),
(d)(1)-(2), (e)(1)-
(2), (f)
Recordkeeping and reporting
requirements Yes.
63.10(c)(1)-(6),
(c)(9)-(15)
Additional records for
continuous monitoring systems No.
63.10(c)(7)-(8)
Records of excess emissions
and parameter monitoring
exceedances for CMS
Yes.
63.10(d)(3) Reporting opacity or visible
emissions observations Yes.
63.10(e)(3) Excess emissions reports Yes.
63.10(e)(4) Reporting COMS data No.
63.11 Control device requirements No.
63.12 State authority and delegations Yes.
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 37 of 41
Citation Subject Applies to
large foundry? Explanation
63.13-63.16
Addresses of State air
pollution control agencies and
EPA regional offices.
Incorporation by reference.
Availability of information and
confidentiality. Performance
track provisions
Yes.
14.0 EMISSION FACTORS
PM, PM10 and PM2.5
Control
Device
ID
Emission
Point
EF for
PM
EF for
PM10
EF
for
PM2.5
Monitored
Parameter
(P)
Units EF Reference
CD #1
#1 6MT
Steel and #2
10TT Steel
Electric Arc
Furnace
0.0152 0.0152 .0152 steel
melted
lb/ton
steel
melted
December 2005
Stack Test,
DEQ AQ-EF08
CD #2
#3 10TT
Manganese
Electric Arc
Furnace
0.31 0.31 0.31 steel
melted
lb/ton
steel
melted
April 1982
Stack Test,
DEQ AQ-EF08
Melting – 2
Induction
Furnaces
Accounted for in Roof
Vent Fugitive emissions
steel
melted
lb/ton
metal
melted
PM/PM10 by
MiniVol
Testing
CD #5
Main
Foundry
Sand System
(Mills 1 & 3)
0.038 0.038 0.038 sand
throughput
lb/ton
sand
April 1981
Stack Test,
DEQ AQ-EF08
CD #6
Group 8
Sand System
(Mill 2)
0.021 0.021 0.021 sand
throughput
lb/ton
sand
April 1996
Stack Test,
DEQ AQ-EF08
CD #9 Core Room
Sand System 0.027 0.027 0.027
sand
throughput
lb/ton
sand
Baghouse Dust
Study, DEQ
AQ-EF08
CD
#17
South
Foundry
Sand System
(Mills 1 & 3)
0.01 0.01 0.01 sand
throughput
lb/ton
sand
Baghouse Dust
Study, DEQ
AQ-EF08
CD #3
Main
Foundry
Shakeout
0.037 0.037 0.037 sand
throughput
lb/ton
sand
Baghouse Dust
Study, DEQ
AQ-EF08
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 38 of 41
Control
Device
ID
Emission
Point
EF for
PM
EF for
PM10
EF
for
PM2.5
Monitored
Parameter
(P)
Units EF Reference
CD #8
Group 3 & 6
Sand System
(Mill 4)
0.038 0.038 0.038 sand
throughput
lb/ton
sand
Baghouse Dust
Study, DEQ
AQ-EF08
CD #4
National
Sand
Reclaimer
0.061 0.061 0.061 sand
throughput
lb/ton
sand
Baghouse Dust
Study, DEQ
AQ-EF08
CD
#20
Group 9
Sand
Reclaim
System
0.029 0.029 0.029 Sand
throughput
lb/ton
sand
Baghouse Dust
Study, DEQ
AQ-EF08
CD
#22
SMS Sand
Reclaimer 0.06 0.06 0.06
Sand
throughput
lb/ton
sand
Baghouse Dust
Study, DEQ
AQ-EF08
CD
#23
Sand Dryer
at Landfill 0.01 0.01 0.01
Sand
throughput
lb/ton
sand
Baghouse Dust
Study, DEQ
AQ-EF08
CD
#10
Joslyn
Burn/Arc #1 0.027 0.027 0.027
metal
processed
lb/ton
metal
Baghouse Dust
Study, DEQ
AQ-EF08
CD
#15
South
Foundry
Burn/Arc
0.001 0.001 0.001 metal
processed
lb/ton
metal
October 1980
Stack Test,
DEQ AQ-EF08
CD #7 Joslyn
Rotoblast #1 0.08 0.08 0.08
metal
processed
lb/ton
metal
Baghouse Dust
Study, DEQ
AQ-EF08
CD
#24
Joslyn
Rotoblast #2 0.08 0.08 0.08
metal
processed
lb/ton
metal
Baghouse Dust
Study, DEQ
AQ-EF08
CD
#26
Main
Foundry
Table Blast
and Blast
Room
0.014 0.014 0.014 metal
processed
lb/ton
metal
Baghouse Dust
Study, DEQ
AQ-EF08
CD
#16
Joslyn
Tumblast 0.02 0.02 0.02
metal
processed
lb/ton
metal
Baghouse Dust
Study, DEQ
AQ-EF08
CD
#19
Joslyn
Spinblast 0.14 0.14 0.14
metal
processed
lb/ton
metal
Baghouse Dust
Study, DEQ
AQ-EF08
CDs
#11,
12, 13
Main
Foundry
Burn/Weld
0.014 0.014 .014 metal
processed
lb/ton
metal
November 1980
Stack Test,
DEQ AQ-EF08
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 39 of 41
Control
Device
ID
Emission
Point
EF for
PM
EF for
PM10
EF
for
PM2.5
Monitored
Parameter
(P)
Units EF Reference
CD
#18 Pattern Shop 0.05 0.05 0.05 patterns
lb/1000
patterns
Assume 99%
control with
baghouse, DEQ
AQ-EF08
Natural Gas
Combustion 2.5 2.5 2.5
MMft3 nat.
gas
lb/
MMft3
ODEQ Form
AQ-EF05
Bldg. 8 Roof
Vent
Fugitives
1.24 0.67 0.33 metal
melted
lb/ton
metal
melted
PM/PM10 by
MiniVol
Testing, AP-42
Table 12.10-8
(Pouring,
cooling)
Bldg. 11
Roof Vent
Fugitives
1.3 0.8 0.39 metal
melted
lb/ton
metal
melted
PM/PM10 by
MiniVol
Testing, AP-42
Table 12.10-8
(Pouring,
cooling)
Alternate
Method for
PM
See Condition 6.3 Assume 99%
control
Nitrogen Oxides -NOX
Emission Point EF for NOx Monitored Parameter
(P) Units EF Reference
#1 6MT Steel
and #2 10TT
Steel Electric
Arc Furnace
0.32 Metal melted lb/ton metal AP-42 Table
12.10-5
#3 10TT
Manganese
Electric Arc
Furnace
0.32 Metal melted lb/ton metal AP-42 Table
12.10-5
Melting – 2
Induction
Furnaces
0.01 Metal melted lb/ton metal
Fire v6.25
Factor ID
#16110
Natural Gas
Combustion 100 MMft3 nat. gas lb/MMft3
AP-42 Table
1.4-1
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 40 of 41
Carbon Monoxide – CO
Emission Point EF for CO
Monitored
Parameter
(P)
Units EF Reference
#1 6MT Steel
and #2 10TT
Steel Electric
Arc Furnace
4.05 Metal melted lb/ton metal December 2005
Stack Test
#3 10TT
Manganese
Electric Arc
Furnace
0.30 Metal melted lb/ton metal
Columbia Steel
Engineering
Tests
Melting – 2
Induction
Furnaces
0 Metal melted lb/ton metal AP 42 Table
12.10-5
Pouring, Cooling
& Shakeout
Material
Thermal
Decomposition
EF
Material Used
(e.g., cereal, oil,
binder, resin)
lb/lb material Material SDS
Natural Gas
Combustion 84 MMft3 nat. gas lb/MMft3
AP-42 Table
1.4-1
Volatile Organic Compounds - VOC
Emission Point EF for VOC Monitored Parameter
(P) Units EF Reference
#1 6MT Steel
and #2 10TT
Steel Electric
Arc Furnace
0.18 Metal melted lb/ton steel AP 42-Table
12.10-5
#3 10TT
Manganese
Electric Arc
Furnace
0.18 Metal melted lb/ton steel AP 42-Table
12.10-5
Melting – 2
Induction
Furnaces
0.18 Metal melted lb/ton steel AP 42-Table
12.10-5 for EAF
Pouring, Cooling
& Shakeout Mass Balance Mass Balance lb/ton steel MSDS
Mold & Core
Alcohol Wash Mass Balance Mass Balance lb/gal
DEQ, 50%
destruction eff.
Mold &
Core Making Mass Balance Mass Balance lb/ton steel MSDS
Casting
Painting Mass Balance Mass Balance lb/gal MSDS
Pattern
Painting Mass Balance Mass Balance lb/gal MSDS
Natural Gas
Combustion 5.5 MMft3 nat. gas lb/ MMft3
AP-42 Table
1.4-2
Issued Permit Number: 26-1869-ST-01
Expiration Date: 02/01/2026
Page 41 of 41
15.0 ABBREVIATIONS, ACRONYMS, AND DEFINITIONS
ACDP Air Contaminant Discharge
Permit
ASTM American Society for Testing
and Materials
AQMA Air Quality Maintenance Area
calendar
year
The 12-month period
beginning January 1st and
ending December 31st
CAO Cleaner Air Oregon
CFR Code of Federal Regulations
CO
CO2e
carbon monoxide
carbon dioxide equivalent
DEQ Oregon Department of
Environmental Quality
dscf dry standard cubic foot
EPA US Environmental Protection
Agency
FCAA Federal Clean Air Act
Gal
GHG
gallon(s)
greenhouse gas
gr/dscf grains per dry standard cubic
foot
HAP Hazardous Air Pollutant as
defined by OAR 340-244-
0040
I&M inspection and maintenance
lb pound(s)
MMBtu million British thermal units
NA not applicable
NESHAP National Emissions Standards
for Hazardous Air Pollutants
NOX nitrogen oxides
NSPS New Source Performance
Standard
NSR New Source Review
O2 oxygen
OAR Oregon Administrative Rules
ORS Oregon Revised Statutes
O&M operation and maintenance
Pb lead
PCD pollution control device
PEMS Predictive emission
monitoring system
PM particulate matter
PM10
PM2.5
particulate matter less than 10
microns in size
particulate matter less than 2.5
microns in size
ppm part per million
PSD Prevention of Significant
Deterioration
PSEL Plant Site Emission Limit
PTE Potential to Emit
RACT Reasonably Available Control
Technology
scf standard cubic foot
SER Significant Emission Rate
SIC Standard Industrial Code
SIP State Implementation Plan
SO2 sulfur dioxide
Special
Control
Area
as defined in OAR 340-204-
0070
TACT Typically Achievable Control
Technology
VE visible emissions
VOC volatile organic compound
year A period consisting of any 12-
consecutive calendar months