oregon title v operating permit review report · oregon title v operating permit review report ......

Review Report/Permit No. 26-2068-

Application number: 023385

of 29

Revised 2/22/08

OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY

OREGON TITLE V OPERATING PERMIT

REVIEW REPORT

Northwest Region

2020 SW Fourth Avenue, Suite 400

Portland, OR 97201

Source Information:

SIC 3325

NAICS 331513

Source Categories (Part and code) N/A

Compliance and Emissions Monitoring Requirements:

Unassigned emissions Y

Emission credits N

Compliance schedule N

Source test [date(s)] Y

COMS N

CEMS N

Ambient monitoring N

Reporting Requirements

Annual report (due date) 2/15

Emission fee report (due date) 2/15

SACC (due date) 7/30

Quarterly report (due dates) N/A

Monthly report (due dates) N/A

Excess emissions report Y

Other reports N/A

Air Programs

NSPS (list subparts) N

NESHAP (list subparts) ZZZZZ

CAM Y

Regional Haze (RH) N

Synthetic Minor (SM) Y

Part 68 Risk Management N

CFC N

RACT Y

TACT N

Title V Y

ACDP (SIP) N

Major HAP source N

Federal major source Y

NSR N

PSD N

Acid Rain N

Clean Air Mercury Rule (CAMR) N

Permit number: 26-2068

Application Number: 023385

of 29

Revised 2/22/08

TABLE OF CONTENTS

ESCO’S AGREEMENT TO MAKE IMPROVEMENTS TO EMISSION CONTROLS ............................................. 4

INTRODUCTION ....................................................................................................................................................... 11

PERMITTEE IDENTIFICATION .............................................................................................................................. 11

FACILITY DESCRIPTION ........................................................................................................................................ 11

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING ....................... 15

PLANT SITE EMISSION LIMITS ............................................................................................................................. 18

HAZARDOUS AIR POLLUTANTS .......................................................................................................................... 24

PUBLIC NOTICE ....................................................................................................................................................... 26

EMISSIONS DETAIL SHEETS ................................................................................................................................. 26

RESPONSES TO COMMENTS ................................................................................................................................. 27

Permit number: 26-2068

Application Number: 023385

of 29

Revised 2/22/08

LIST OF ABBREVIATIONS USED IN THIS REVIEW REPORT

ACDP Air Contaminant Discharge Permit

Act Federal Clean Air Act

Annual Calendar Year

AOD Argon-oxygen decarburization

ASTM American Society of Testing and Materials

Btu British thermal unit

CAM Compliance Assurance Monitoring

CFR Code of Federal Regulations

CO Carbon Monoxide

CPMS Continuous parameter monitoring system

DEQ Department of Environmental Quality

dscf Dry standard cubic feet

EAF Electric arc furnace

EAL Emission action level

EF Emission factor

EPA US Environmental Protection Agency

EU Emissions Unit

FCAA Federal Clean Air Act

FSA Fuel sampling and analysis

GHG Greenhouse Gas

gr/dscf Grain per dry standard cubic feet (1 pound

= 7000 grains)

HAP Hazardous Air Pollutant as defined by

OAR 340-244-0040

ID Identification number or label

I&M Inspection and maintenance

INDF Induction furnace

NA Not applicable

NOx Nitrogen oxides

O2 Oxygen

OAR Oregon Administrative Rules

ODEQ Oregon Department of Environmental

Quality

ORS Oregon Revised Statutes

O&M Operation and maintenance

Pb Lead

PCD Pollution Control Device

PCS Pouring, cooling and shakeout

PM Particulate matter

PM10 Particulate matter less than 10 microns in

size

PM2.5 Particulate matter less than 2.5 microns in

size

ppm Parts per million

PSEL Plant Site Emission Limit

psia pounds per square inch, actual

SER Significant Emission Rate

SERP Source emissions reduction plan

SO2 Sulfur dioxide

SSM Startup, Shutdown and Malfunction

ST Source test

VE Visible emissions

VMT Vehicle miles traveled

VOC Volatile organic compounds

Review Report/Permit No.: 26-2068


of 29

Revised 5/19/04

ESCO’S AGREEMENT TO MAKE IMPROVEMENTS TO EMISSION CONTROLS

1. DEQ has renewed the Title V air permit for ESCO Corporation, located at 2141 NW 25th

Avenue, Portland.

1.a. The permit includes conditions that require ESCO to improve its air emissions control systems and

procedures.

1.b. The above referenced permit conditions are summarized in the table below and can be found in the

permit in the Best Work Practices Agreement section.

1.c. Background information on the development of these conditions as well as information about

ESCO’s plants and processes can be found in paragraphs 2 through 30 (pages 5 to 9). The rest of

this review report addresses the other conditions in the permit.

1.d. ESCO proposes to do, or has already done, the following:

No. Project Purpose

1 Improve capture and control of Doghouse and Side Floor

PCS fugitives. Ensure cooling in the Doghouse occurs in

the controlled section of the building.

Reduce emissions of dust and

reduce odor impacts in

neighborhood.

2 Add control to Air Arc Cutting- Lower Finishing Reduce emissions of dust and

metals.

3 Add control to Air Arc Cutting- Upper Finishing Reduce emissions of dust and

metals.

4 Seal leaks and openings on P3 Pouring Cooling Shakeout Reduce odor impacts in

neighborhood.

5 Install thermal oxidation or alternative control technology

on sand coating pug mill, or substitute a low phenol binder

system.

Reduce emissions of phenol and

odor impacts.

6 Continue alternative binder studies, especially for chain

castings.

Reduce odor impacts.

7 Install bag leak detection on EAF and AOD baghouses. Improve monitoring and

maintenance of these baghouses to

minimize emissions of dust and

metals.

8 Modify operational specifications to limit door and other

openings to improve capture on EAF and AOD processes.

Minimize emissions of dust and

metals.

9 Add/improve procedures on EAF and AOD operations that

directly affect capture. Evaluate additional control

mechanisms for EAF capture systems and high canopy

hood dampers. Optimize operating procedures and provide

routine training.


metals.

10 Take corrective actions to reduce fugitives on thermal sand

reclaim baghouse by installing course fraction separator to

improve collection and reduce wear on baghouse.

Improve reliability of baghouse to

minimize emissions of dust.

11 Identify and implement operating changes to reduce

emissions at dump back and transfer points.


metals.




metals.



of 29

Revised 5/19/04

13 Conduct study to quantify emissions from thermal sand

reclaim and to determine if thermal sand reclaim can be

operated at recommended temperature.

Ensure that emissions of organic

compounds are minimized.

14 Modify operations at the AOD to improve capture. Minimize emissions of dust and

metals.

15 Ensure operators use control equipment at workbench

stations in finishing area.


metals.

16 Develop and implement Incident (Atypical) Investigation

Plan.

Change operating procedures if

necessary to minimize production

problems and emissions of dust and

metals.

17 Perform an engineering study of feasible capture and

control methods for emissions from pour points in slinger

bay, including estimates of potential reductions.

Alternatively, ESCO may propose a different study or

emission reduction project, which it shall implement

instead of the slinger bay study, if approved by the NAC.

Reduce/minimize emissions of dust

and metals.

Background information

2. Note on the terms “air toxics” and “Hazardous Air Pollutants”: these terms are often used interchangeably,

but they have somewhat different meanings. Both terms refer to air pollutants that are toxic, but Hazardous

Air Pollutants (HAPs) refer to the 187 specific chemicals or groups of chemicals listed in the Clean Air Act

and subject to regulation by the U.S. Environmental Protection Agency (EPA) and state environmental

regulatory agencies such as DEQ. The term air toxics is a broader term and includes all of the Hazardous

Air Pollutants as well as other air pollutants that are toxic but are not subject to the regulations that apply to

the listed Hazardous Air Pollutants. In this section of this report both terms are used; in the remainder of

the report only the term Hazardous Air Pollutants (or HAPs) is used.

3. People living and working the Northwest Portland neighborhood to the south of ESCO’s plants have

complained to DEQ for a number of years about odors, dust and other air emissions from ESCO’s plants.

An article published in the USA Today newspaper in late 2008 about the effect of industrial emissions on

nearby schools raised the level of concern, and the Northwest District Association (NWDA) and Neighbors

for Clean Air (NCA) led a drive to get ESCO to reduce emissions.

4. In 2009, ESCO engaged in a series of discussions with neighborhood representatives and agreed to

consider improvements to their air pollution control systems. A negotiating group consisting of

neighborhood representatives, ESCO, local legislators, and DEQ was formed. ESCO hired an engineering

consulting firm (ERM) to review their operations and emissions control systems. ERM recommended a

number of improvements, and ESCO proposed to make some of the recommended improvements.

Concurrently, neighborhood representatives felt that an independent review of ESCO’s operations and the

ERM report was needed before they could agree with ERM’s conclusions and ESCO’s proposal. DEQ

supported this request by the community and hired Mr. Jim Karas to perform the independent audit of the

facilities and ERM’s report. Mr. Karas and his associate generally confirmed ERM’s recommendations and

made some additional recommendations1. As a result of Mr. Karas’ review and further discussions with the

negotiating group, ESCO revised the list of improvements they proposed to make.

5. Related to the discussions described above, in mid-2010 ESCO informed DEQ that they would be willing

to enter into a Best Work Practices Agreement (BWPA). ESCO also informed the neighborhood

1 ERM’s and Mr. Karas’ reports are not summarized in this document, but both are available from DEQ.



of 29

Revised 5/19/04

representatives that they were willing to discuss a Good Neighbor Agreement (GNA). The BWPA and

GNA are both briefly described in some of the following paragraphs.

6. As a result of the work and negotiations summarized above, a number of new permit conditions have been

written that require ESCO to make the improvements they proposed. The new permit conditions are

summarized in paragraphs 1 and 30.

Best Work Practices Agreement, Good Neighbor Agreement and Title V permit

7. DEQ’s nuisance rules, Oregon Administrative Rules (OAR) 340-208-0300 through -0320 provide two

options for DEQ to attempt to resolve a suspected nuisance; both options may lead to negotiating a Best

Work Practices Agreement (BWPA) for the purpose of resolving the suspected nuisance.

7.a. The first option for resolving a suspected nuisance is for DEQ to determine that a facility is

creating a nuisance and is violating the rules. Under this option, the rules identify a BWPA as a

way to resolve the nuisance. However, this approach presents significant challenges for DEQ

because criteria for determining a nuisance may be difficult to apply and because DEQ lacks

precedents and procedures that would ensure consistent determinations in all situations.

7.b. The second option for resolving a suspected nuisance is for the facility to agree to a BWPA

without agreeing that the facility is actually causing a nuisance. This option allows a BWPA to be

negotiated without the challenges described in 7.a, above.

8. Under the nuisance rules, a BWPA is a voluntary, negotiated agreement between the facility that is

suspected of causing a nuisance and DEQ to implement specific practices to abate the suspected nuisance.

The rules also state that a BWPA will be made part of the permit.

9. DEQ identified a suspected nuisance condition associated with odors, dust and air toxics, but has not

determined that a nuisance actually exists. Based on the suspected nuisance, DEQ asked if ESCO would

agree to negotiate a BWPA, and ESCO agreed. The BWPA terms and conditions negotiated between the

neighborhood representatives, ESCO and DEQ are included directly in the permit; a separate, stand-alone

BWPA document will not be created.

10. The Good Neighbor Agreement (GNA) is an agreement between organizations representing the Northwest

neighborhood residents and ESCO; the GNA was signed in November, 2011. The organizations

representing the Northwest neighborhood are the Northwest District Association (NWDA), Neighbors for

Clean Air (NCA), and the Northwest Environmental Defense Center (NEDC). The parties involved in the

GNA attached a copy of the draft Title V permit to the GNA, but the GNA is not part of the permit.

11. The Title V permit is an operating permit required by both federal and state law. The permit includes limits

based on the air pollution regulations that apply to ESCO, as well as monitoring and recordkeeping

requirements. The permit also includes conditions to implement the negotiated BWPA.

Summary of ESCO’s processes and emissions

12. ESCO is a steel foundry that makes steel parts that are used mainly for mining, dredging and construction.

The size of the parts ranges from about 40 pounds each up to several thousand pounds each. The process

involves melting and refining steel; pouring the steel into a mold (pouring); allowing the steel to cool and

harden (cooling); removing the part from the mold (shakeout); finishing operations such as cutting,

grinding, welding and sandblasting; and painting. ESCO has two plants, the Main Plant on NW Vaughn

Street, and Plant 3 on NW Yeon Avenue. The Main Plant makes larger parts, typically over 50 pounds

each. Plant 3 makes smaller parts, typically less than 50 pounds each.

Melting



of 29

Revised 5/19/04

13. Steel is mainly iron usually with a small amount of carbon, and may contain other metals to make specific

steel alloys. ESCO produces parts made of steel alloys that have the necessary physical properties to meet

customer demand, such as the ability to resist wearing out. Metals added to the steel are mainly manganese,

chromium and nickel, with lesser amounts of other metals. Steel also contains small amounts of impurities,

such as lead.

14. ESCO’s production process starts with scrap steel. Some of the scrap steel is purchased from vendors; some

is returned, worn out parts produced by ESCO or other steel foundries; and some is steel that is recycled

from ESCO’s manufacturing process. The scrap steel used by ESCO does not contain any automotive

scrap, and ESCO’s purchase agreements clearly state that automotive scrap must be excluded. The scrap

steel is melted in 3 electric arc furnaces (EAFs), two EAFs that each melt 10 tons of steel at a time at the

Main Plant on NW Vaughn, and one EAF that melts 5 tons at a time at Plant 3 on NW Yeon. Other metals

are added to the melted steel to make the required alloys.

15. Some of the steel made at the Main Plant is further processed in a unit known as an Argon-Oxygen

Decarburization (AOD) vessel. Molten steel is carried by crane and poured into the AOD vessel and a

mixture of argon and oxygen are bubbled through the steel; this process removes excess carbon from the

steel.

16. The melting processes (EAFs and AOD) are the main sources of toxic metal emissions. Emissions from

these processes are controlled by baghouses, which are large fabric filters.

Pour-back and transfer

17. Pour-back involves pouring molten steel from an EAF into a large bucket called a ladle, and then pouring it

back into the EAF. This mixes the steel and added metals. Molten steel is also moved by crane in ladles to

the AOD or to where pouring will take place. Pouring molten steel from one container into another is called

a transfer. Pour-back and transfer create smoke and dust, and takes place in areas that do not have

emissions control systems.

Mold and core making

18. Molten steel is poured into molds that are shaped to produce the desired part. If the desired part includes

hollow areas, cores are placed in the molds to form the hollows. Molds and cores are generally made from

sand, with binders added to make the sand hold its shape. Different types of binders are used for different

molds, including clay as well as phenolic urethane (a type of plastic) binders. Making molds and cores is a

minor source of odors at the Main Plant, and a more significant source of odors at Plant 3 because the

molds used at Plant 3 are made with phenol-formaldehyde resin and phenolic urethane binder.

Pouring, cooling and shakeout

19. Molten steel is poured from a ladle into a mold to make the desired steel part. The steel is then allowed to

cool and solidify. The steel part is then removed from the mold by breaking up the mold; this process is

called shakeout. With smaller parts, shakeout is done by putting the mold onto a shaking conveyor belt; the

shaking and tumbling break up the mold to release the part inside. With larger molds, shakeout is done

manually by workers. These three operations are referred to as pouring, cooling, and shakeout or PCS.

Some pouring and cooling takes place in areas that have baghouses for emissions control, while pouring

and cooling of larger castings at the Main Plant take place in areas that do not have emission controls.

Shakeout occurs in areas that have baghouses to control dust emissions.

20. It is generally believed that pouring, cooling and shakeout are the processes that create the most odor,

although this is not the only source of odors. When the hot, molten steel comes into contact with the molds

and cores, the binder used in the molds and cores is partially decomposed and emitted as smoke and

odorous gases, some of which contain air toxics. The odor is similar to the odor of hot automobile brakes.

Shakeout creates dust as the molds break up. Pouring, cooling and shakeout takes place in several locations

in the Main Plant, and in one location at Plant 3; some of these areas have emissions controls and some

don’t.



of 29

Revised 5/19/04

Finishing

21. The parts removed from the molds require finishing operations such as cutting, grinding, welding,

sandblasting and heat treating. There are two areas where finishing operations take place at the Main Plant,

and one at Plant 3. Prior to 2011 most of these finishing operations took place in areas that have baghouses

or other emission control devices to control dust and metal emissions. In 2011 ESCO added additional

controls to these areas.

Painting

22. At the Main Plant, parts are painted by dipping them into paint vats, or by hand if the parts are too large to

fit into the vats. At Plant 3, parts are spray painted in paint booths. ESCO uses paints that do not contain

Hazardous Air Pollutants.

Areas identified for improvement

23. A pouring, cooling and shakeout area known as the “Doghouse” in the Main Plant is believed to be the

most significant source of odors. A large number of relatively small parts are poured in the Doghouse. The

Doghouse currently has partial emissions controls that control dust emissions from the shakeout conveyor

line and part of one cooling area. However, the pouring area, part of one cooling area and a second cooling

area have no emissions controls. Improving the emissions controls in the Doghouse was identified as the

top priority for reducing dust emissions as well as reducing odors in the neighborhood.

24. At Plant 3, sand is mixed with phenol-formaldehyde resin in equipment known as the Pug Mill; the

sand/binder mix is then used to make molds. The Pug Mill is a source of odors, and is also the largest

source of phenol, an organic air toxic and Hazardous Air Pollutant. Adding an emissions control system to

the Pug Mill will help reduce odors and reduce emissions of phenol.

25. The Air Arc Cutting booths (including the Chain Table Air Arc Cutting station and the Lower Finishing

Area) at the Main Plant did not have emissions controls prior to 2011; in 2011, ESCO added baghouses to

control the Air Arc Cutting emissions. Air Arc Cutting was identified as a small source of metallic HAP

emissions over a year’s time, but the short term emissions could contribute to emissions “spikes”.

26. ESCO will develop or revise operating procedures at the EAFs and Main Plant AOD to improve emissions

capture and minimize fugitive emissions from these operations.

27. Improvements to the way dump-back and transfers of molten steel are done may help reduce emissions

from these operations. ESCO will conduct internal studies to determine if procedures can be improved.

28. Bag leak detection systems will be installed on the baghouses that control emissions from the EAFs and

Main Plant AOD. A baghouse is a large filter system that uses a large number of fabric bags to capture dust

emissions. Bag leak detection systems can detect problems, such as leaks in bags, long before the emissions

become visible. Tied to detecting leaks is a requirement to perform maintenance when a certain level of

leakage is detected. This will help ensure that the baghouses perform more reliably and efficiently to keep

emissions from these processes to a minimum.

29. ESCO will conduct a study to determine if emission controls can be added to the Slinger Bay to reduce

emissions, or may propose a different study or emission reduction project.



of 29

Revised 5/19/04

Best Work Practices Agreement (BWPA) permit conditions summary

30. The full BWPA permit conditions are in the Title V permit, in the Best Work Practices Agreement section.

The BWPA conditions are designed to address the areas of improvement as described in paragraphs 23-29,

and are summarized below and in paragraph 1:

No. Project Purpose

1 Improve capture and control of Doghouse and Side Floor

PCS fugitives. Ensure cooling in the Doghouse occurs in

the controlled section of the building.

Reduce emissions of dust and

reduce odor impacts in

neighborhood.

2 Add control to Air Arc Cutting- Lower Finishing Reduce emissions of dust and

metals.

3 Add control to Air Arc Cutting- Upper Finishing Reduce emissions of dust and

metals.

4 Seal leaks and openings on P3 Pouring Cooling Shakeout Reduce odor impacts in

neighborhood.

5 Install thermal oxidation or alternative control technology

on sand coating pug mill, or substitute a low phenol binder

system.

Reduce emissions of phenol and

odor impacts.

6 Continue alternative binder studies, especially for chain

castings.

Reduce odor impacts.

7 Install bag leak detection on EAF and AOD baghouses. Improve monitoring and

maintenance of these baghouses to

minimize emissions of dust and

metals.

8 Modify operational specifications to limit door and other

openings to improve capture on EAF and AOD processes.


metals.

9 Add/improve procedures on EAF and AOD operations that

directly affect capture. Evaluate additional control

mechanisms for EAF capture systems and high canopy

hood dampers. Optimize operating procedures and provide

routine training.


metals.

10 Take corrective actions to reduce fugitives on thermal sand

reclaim baghouse by installing course fraction separator to

improve collection and reduce wear on baghouse.

Improve reliability of baghouse to

minimize emissions of dust.




metals.




metals.

13 Conduct study to quantify emissions from thermal sand

reclaim and to determine if thermal sand reclaim can be

operated at recommended temperature.

Ensure that emissions of organic

compounds are minimized.

14 Modify operations at the AOD to improve capture. Minimize emissions of dust and

metals.



of 29

Revised 5/19/04

15 Ensure operators use control equipment at workbench

stations in finishing area.


metals.

16 Develop and implement Incident (Atypical) Investigation

Plan.

Change operating procedures if

necessary to minimize production

problems and emissions of dust and

metals.

17 Perform an engineering study of feasible capture and

control methods for emissions from pour points in slinger

bay, including estimates of potential reductions.

Alternatively, ESCO may propose a different study or

emission reduction project, which it shall implement

instead of the slinger bay study, if approved by the NAC.

Reduce/minimize emissions of dust

and metals.

End of first section of report



of 29

Revised 5/19/04

INTRODUCTION

31. In accordance with OAR 340-218-0120(1)(f), this review report is intended to provide the legal and factual

basis for the permit conditions. In most cases, the legal basis for a permit condition is included in the

permit by citing the applicable regulation. In addition, the factual basis for the requirement may be the

same as the legal basis. However, when the regulation is not specific and only provides general

requirements, this review report is used to provide a more thorough explanation of the factual basis for the

permit conditions.

32. ESCO’s current Title V permit was issued on August 10, 2004. One significant change was made to the

permit during the permit term.

Date Permit revision or

notification

Brief explanation

January, 2006 Administrative Amendment The permit was revised to clarify emissions

testing requirements.

33. The permit has been significantly revised compared to the permit issued in 2004. An overview of the rules

and requirements that apply to this facility begins on page 41. In general, the major changes to the permit

are:

33.a. The Best Work Practices Agreement, summarized at the beginning of this report, has been added;

33.b. Several new permit conditions to implement the National Emission Standards for Hazardous Air

Pollutants (NESHAP) for area source steel foundries, 40 CFR Part 63 Subpart ZZZZZ have been

added; and

33.c. The permit has been reorganized.

PERMITTEE IDENTIFICATION

34. ESCO Corporation’s Main Plant, located at 2141 NW 25th

Avenue, Portland, Oregon is an existing steel

foundry/metals casting operation which produces wear parts for construction, mining, and dredging

equipment. ESCO has operated at this site since 1913.

35. ESCO Corporation’s Plant 3, located at 2211 NW Brewer Avenue, Portland, Oregon is an existing steel

foundry/metals casting operation which produces wear parts for the construction, mining, and timber

industries. ESCO has operated at this site since 1955.

36. The two plants have been determined to constitute one source and were issued a single Title V permit

because both are under common ownership, they have the same two digit SIC code, and they are

considered adjacent.

FACILITY DESCRIPTION

37. Major processes at both plants are described in paragraphs 12 through 22 of this report.

EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION

38. The emissions units at the Main Plant are the following:

MU-1 MELT (metal melting operations) ESCO melts clean scrap steel in two production electric arc

furnaces (EAF1 and EAF2). A portion of the molten metal is further refined in an argon-oxygen

decarburization unit (AOD8). This emissions unit includes all metal melting and refining activities

conducted at the Main Plant.



of 29

Revised 5/19/04

Emissions from the metal melting operations are controlled by 2 baghouses. Baghouses 301010 and

301250 control emissions from the EAFs and the AOD respectively.

MU-2 PCS (pouring, cooling and shakeout operations) This emissions unit covers air emissions from the

pouring of metal into molds, the subsequent cooling of the poured metal and molds, and the physical

separation of solidified castings from the molds (“shakeout”). Dust collector 301110 controls emissions

from pouring and cooling at the Doghouse pouring floor. Baghouse 301150 controls emissions from the

Doghouse Mold Dump (shakeout). Dust collectors 301110 and 301040 control emissions from shakeout on

the Main Pouring Floor.

MU-3 MAT (material handling and sand reclamation) ESCO conducts a number of material handling

activities at the Main Plant. These include handling of raw materials (scrap steel and sand),

reclamation/reuse (sand), and processing of byproduct materials (slag). This emissions unit addresses all

materials handling and casting finishing activities conduction at the Main Plant.

MU-4 SAND/SHOT BLAST (shot/ sand blasting) Abrasive cleaning is used to remove unwanted material

from the surface of castings.

MU-5 CUT/GRIND (grinding and finishing operations) This emission unit includes various grinding and

abrasive cutting activities on its raw castings before they are painted, packaged and shipped to customers.

MU-6 HOTWORK (Arc-air burning, cutting welding and heat treating operations) This emissions unit

covers finishing operations that includes arc-air burning, arc cutting and welding and heat treating

operations.

MU-7 MOLD/CORE (mold making and core making operations) Molds and cores respectively define the

outer and inner dimensions of the finished casting. ESCO’s molds and cores are made of sand to which

various binder ingredients are added. This emissions unit includes activities associated with the

manufacturing of cores and molds for the casting operations. It includes core washing, core baking, and

use of “support chemicals” directly related to core and mold making.

MU-8 VOC (facility-wide volatile organic compound (VOC) usage) This emissions unit addresses all VOC

emissions from the Main Plant which are not covered by other emissions units (miscellaneous usage).

MU-9 COAT (casting painting operations) This emissions unit covers VOC emissions and Reasonably

Available Control Technology (RACT) -related requirements unique to ESCO’s coating (paint dip-tank)

operations.

MU-10 NG (facility-wide natural gas (NG) usage) Natural gas is used in heat treat ovens, paint- and core-

drying ovens, ladle heaters, miscellaneous “spot usage” (e.g., heating of castings with hand-held burners

prior to weld or arc repair), and for building heat and hot water. This emissions unit includes all air

emissions from the combustion of natural gas at the Main Plant.

39. The emissions units at Plant 3 are the following:

3U-1 MELT (metal melting operations). ESCO melts clean scrap steel in one production electric arc

furnace (EAF5) and an electric induction furnace (INDF3). Induction furnace INDF3 is used mainly to

melt batches of stainless steel scrap for special parts. ESCO also operates another small induction furnace

(INDF4) and a small AOD (AODRES) for research purposes. This emissions unit includes all metal

melting and refining activities (production and research) conducted at Plant 3. Research and Development

activities are not regulated by the permit, however they are subject to applicable general emission standards

and limitations. Emissions from the EAF and AODRES are controlled by two baghouses, 3-30112S and 3-

30124N. Emissions from INDF3 are controlled by the pouring, cooling and shakeout baghouses. There are



of 29

Revised 5/19/04

no emissions control on the INDF4 research induction furnace, however the emissions from this device are

insignificant. INDF4 has a capacity of only 400 lbs is only used a few times per year.

3U-2 PCS (pouring, cooling and shakeout operations). This emissions unit covers air emissions from the

pouring of metal into molds, the subsequent cooling of the poured metal and molds, and the physical

separation of solidified castings from the molds (“shakeout”). Emissions from pouring, cooling and casting

are captured by an enclosure that was added in 2002, and controlled by 2 new baghouses, 3-301160 and 3-

301170.

3U-3 MAT (material handling and sand reclamation). ESCO conducts a number of material handling

activities at Plant 3. These include handling of raw materials (scrap steel and sand), reclamation/reuse

(sand), and processing of byproduct materials (slag). Baghouses 3-301150 and 3-301510 control emissions

from sand handling and reclamation.

3U-4 SAND/SHOT BLAST (shot/ sand blasting). Abrasive cleaning is used to remove unwanted material

from the surface of castings. Baghouses 3-301210, 3-301390, and 3-301400 control emissions from sand

and shot blasting.

3U-5 CUT/GRIND (grinding and finishing operations). This emission unit includes various grinding and

abrasive cutting activities on its raw castings before they are painted, packaged and shipped to customers.

Emissions controls on cutting and grinding operations include 3-301440 and 3-301500.

MU-6 HOTWORK (heat treating operations). This emissions unit covers only heat treating operations at

plant 3.

3U-7 MOLD/CORE (mold making and core making operations). Molds and cores respectively define the

outer and inner dimensions of the finished casting. ESCO’s molds and cores are made of sand which

various binder ingredients are added. This emissions unit includes activities associated with the

manufacturing of cores and molds for the casting operations. It includes core washing, and use of “support

chemicals” directly related to core and mold making. Baghouses 3-301210, 3-301390, and 3-301400

control particulate emissions from mold making and core making operations.

3U-8 VOC (facility-wide volatile organic compound (VOC) usage). This emissions unit addresses all VOC

emissions from Plant 3 which are not covered by other emissions units (miscellaneous usage).

MU-9 COAT2 (casting painting operations). This emissions unit covers VOC emissions and Reasonably

Available Control Technology (RACT) -related requirements related to ESCO’s Plant 3 coating (spray

painting) operations.

3U-10 NG (facility-wide natural gas (NG) usage). Natural gas is used in heat treat ovens, ladle heaters,

miscellaneous “spot usage” (e.g., heating of castings with hand-held burners prior to weld or arc repair),

and for building heat and hot water. This emissions unit includes all air emissions from the combustion of

natural gas at Plant 3.

40. Categorically insignificant activities may include the following:

Constituents of a chemical mixture present at less than 1% by weight of any chemical or compound

regulated under OAR Chapter 340, Divisions 200 through 268, excluding Divisions 248 and 262, or less

than 0.1% by weight of any carcinogen listed in the U.S. Department of Health and Human Service's

Annual Report on Carcinogens when usage of the chemical mixture is less than 100,000 pounds/year

Evaporative and tail pipe emissions from on-site motor vehicle operation

2 3U-9 COAT is a newly-defined emissions unit at Plant 3. In the previous permit, all surface coating operations

were covered by emissions unit MU-9. The former emissions unit 3U-9 NG was renamed to 3U-10 NG.



of 29

Revised 5/19/04

Distillate oil, kerosene, and gasoline fuel burning equipment rated at less than or equal to 0.4 million Btu/hr

Natural gas and propane burning equipment rated at less than or equal to 2.0 million Btu/hr

Office activities

Janitorial activities

Personal care activities

Groundskeeping activities including, but not limited to building painting and road and parking lot

maintenance

Instrument calibration

Maintenance and repair shop

Air cooling or ventilating equipment not designed to remove air contaminants generated by or released

from associated equipment

Refrigeration systems with less than 50 pounds of charge of ozone depleting substances regulated under

Title VI, including pressure tanks used in refrigeration systems but excluding any combustion equipment

associated with such systems

Bench scale laboratory equipment and laboratory equipment used exclusively for chemical and physical

analysis, including associated vacuum producing devices but excluding research and development facilities

Temporary construction activities

Warehouse activities

Accidental fires

Air vents from air compressors

Electrical charging stations

Fire brigade training

Instrument air dryers and distribution

Fire suppression

Blueprint making

Routine maintenance, repair, and replacement such as anticipated activities most often associated with and

performed during regularly scheduled equipment outages to maintain a plant and its equipment in good

operating condition, including but not limited to steam cleaning, abrasive use, and woodworking

Electric motors

Storage tanks, reservoirs, transfer and lubricating equipment used for ASTM grade distillate or residual

fuels, lubricants, and hydraulic fluids

Pressurized tanks containing gaseous compounds

Emissions from wastewater discharges to publicly owned treatment works (POTW) provided the source is

authorized to discharge to the POTW, not including on-site wastewater treatment and/or holding facilities

Fire suppression and training

Paved roads and paved parking lots within an urban growth boundary

Hazardous air pollutant emissions of fugitive dust from paved and unpaved roads except for those sources

that have processes or activities that contribute to the deposition and entrainment of hazardous air

pollutants from surface soils

Health, safety, and emergency response activities

Ash piles maintained in a wetted condition and associated handling systems and activities

Oil/water separators in effluent treatment systems

Combustion source flame safety purging on startup



of 29

Revised 5/19/04

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING

Oregon Administrative Rules (OAR)

41. This section briefly summarizes the rules and requirements that apply to this facility; the full text of each

condition may be found in the permit. Requirement summaries are grouped as they are in the permit in the

following categories:

41.a. Facility-wide requirements;

41.b. Visible emissions;

41.c. Particulate matter emissions;

41.d. Operating and maintenance requirements and startup, shutdown and malfunction plan;

41.e. Scrap metal, binders and surface coating requirements; and

41.f. Insignificant activities.

42. Facility-wide requirements.

Requirement Monitoring and recordkeeping

OAR 340-208-0300: The facility must not cause a nuisance. Monitoring for this requirement is to

record and investigate complaints.

OAR 340-208-0450: The facility must not 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.

Monitoring for this requirement is to

record and investigate complaints.

OAR 340-242-0420: Employee Commute Options (ECO)

Program. Per an agreement with DEQ, ESCO is exempt

from the ECO Program.

n/a

40 CFR Part 68: Accidental release prevention. ESCO must

comply if they become subject to these regulations.

n/a

OAR 340-232-0040: Non-categorical RACT. The RACT

level of control has been determined to be 0 % reduction, or

no additional controls.

n/a

43. Visible emissions.


OAR 340-208-0210(2): Take reasonable precautions to

prevent particulate matter from becoming airborne from

material handing or storage, use, repair or construction of

buildings or roads, or equipment operation.

Conduct at least one 30-minute visual

survey per month at each plant, and keep

records of surveys.

OAR 340-208-0210(2) and 340-226-0120(2): Take

corrective action if visible emissions that leave the plant site

boundaries are discovered.

OAR 340-208-0600: Do not discharge any air contaminant

that is 20 percent opacity or greater into the atmosphere for a

period of or periods totaling more than 30 seconds in any

one hour.

OAR 340-208-0110(2) Do not emit or allow to be emitted

any air contaminant into the atmosphere, for a period or

periods aggregating more than three minutes in any one hour



of 29

Revised 5/19/04

which is equal to or greater than 20% opacity.

OAR 340-226-0120(2) Requirement to take corrective action

to reduce visible emissions from any baghouse/dust

collector.

40 CFR 63.10895(e): Do 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.

44. Particulate matter emissions.


OAR 340-226-0210(1)(b): Do not emit particulate matter in

excess of 0.1 grain per dry standard cubic foot from the

listed emissions units.

OAR 340-212-0240(3)(a) and -0250

(CAM): Continuously monitor the

pressure drop on the listed baghouses.

OAR 340-226-0310: Do not emit particulate matter in excess

of the amount shown in Table 1 OAR 340-226-0310 for the

process weight allocated to that device.

OAR 340-212-0240(3)(a) and -0250



OAR 340-226-0120: Take corrective action to restore

operation of the emission unit and/or control device to its

normal manner if the baghouse pressure drop recorded for

any listed baghouse listed below is outside of the operating

range in the approved Air Emission Control Device

Operating Plan.

OAR 340-212-0240(3)(a) and -0250



40 CFR 63.10895(c)(1): Do not emit more than 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 from

any Electric Arc Furnace or the Plant 3 production Induction

Furnace.

40 CFR 63.10898(b): Conduct source

tests to demonstrate compliance with the

limit at least every 5 years.



of 29

Revised 5/19/04

45. Operating and maintenance requirements and startup, shutdown and malfunction plan.


OAR 340-226-0120: Operate the emissions control system(s)

for a process whenever the process is operating.

OAR 340-226-0120: Operate all emission control devices

associated with the emissions units identified in the permit

condition in accordance with an Air Emission Control

Device Operating Plan.

Perform monthly inspections of all air

pollution control equipment associated

with the emissions units listed in the

permit condition.

40 CFR 63.10895(b): Operate a capture and collection

system for each metal melting furnace (all EAFs and

production Induction Furnace).

40 CFR 63.10897(e): 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) on all

EAFs and the production Induction

Furnace.

40 CFR 63.10896(a): Operate at all times according to a

written operation and maintenance (O&M) plan.

40 CFR 63.10897(g): In the event of an exceedance of an

emissions limitation for fugitive opacity or the PM limits for

EAFs and the production Induction Furnace, restore

operation of the emissions source (including the control

device and associated capture system) to its normal or usual

manner or operation as expeditiously as practicable.

40 CFR 63.10897(a): Conduct periodic

inspections of each PM control device for

all EAFs and the production Induction

Furnace.

40 CFR 63.6(e)(3): Develop and implement a written startup,

shutdown, and malfunction plan that describes procedures

for operating and maintaining all EAFs and the production

Induction Furnace during periods of startup, shutdown, and

malfunction.

46. Scrap metal, binders and surface coating requirements.


40 CFR 63.10885(a) and (a)(1): Comply with the metallic

scrap management program requirements.

40 CFR 63.10899(b)(1): Keep the

required records pertaining to scrap

materials.

40 CFR 63.10886: 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.

Monitor and record information about

each binder and coating material used for

mold or core making.

OAR 340-232-0160(5)(j): Comply with the VOC limits

specified in the condition for surface coating (painting)

operations.

Monitor the VOC content of coatings

used.

47. Insignificant activities.

As identified earlier in this Review Report, this facility has insignificant emissions units (IEUs) that include

categorically insignificant activities and aggregate insignificant emissions, as defined in OAR 340-200-

0020. For the most part, the standards that apply to IEUs are for opacity (20% limit) and particulate matter



of 29

Revised 5/19/04

(0.1 gr/dscf limit). The Department does not consider it likely that IEUs could exceed an applicable

emissions limit or standard because IEUs are generally equipment or activities that do not have any

emission controls (e.g., small natural gas fired space heaters) and do not typically have visible emissions.

Since there are no controls, no visible emissions, and the emissions are less than one ton per year, the

Department does not believe that monitoring, recordkeeping, or reporting is necessary for assuring

compliance with the standards.

PLANT SITE EMISSION LIMITS

Summary of how Plant Site Emission Limits, Netting Basis and Unassigned Emissions are calculated and how

they are interrelated

48. This section of the report provides a brief summary of how Plant Site Emission Limits, unassigned

emissions and netting basis are calculated and how they are interrelated. The following section shows the

calculations.

49. When new facilities that will emit pollutants are built, or existing facilities increase their emissions,

additional regulatory requirements may be triggered before the emissions or emissions increase can be

approved. There is more than one criterion for determining if additional requirements are triggered, but one

of the main criteria is whether the Plant Site Emission Limit (PSEL) is greater than the netting basis by the

Significant Emission Rate (SER) or more. The additional requirements may include modeling of emission

impacts to ensure that air quality standards are not violated; obtaining emission offsets; identifying and

installing new emission control systems; or a combination of requirements. The terms PSEL, Baseline

Emission Rate, Netting Basis and Unassigned Emissions and how they are interrelated are briefly described

below.

Significant Emission Rate (SER)

50. If a facility requests an emission increase that is equal to or more than the SER over their netting basis,

additional requirements are triggered. If the emission increase is less than the SER over the netting basis,

no additional requirements apply. The SERs for the pollutants emitted by ESCO are established in OAR

340, Division 200, and are:

Pollutant

SER

(tons/yr)

PM 25

PM10 15

PM2.5 10

SO2 40

NOx 40

CO 100

VOC 40

Pb 0.6

GHG 75,000

PSEL

51. The PSEL is a facility-wide cap on emissions. Individual PSELs are established for each criteria pollutant

emitted by the facility; in addition, PSELs may also be established for Hazardous Air Pollutants. PSELs are

typically calculated using a maximum production rate and emission factors for each process at the facility

and are expressed (in ESCO’s case) as pounds of emissions per ton of production. In some cases, the



of 29

Revised 5/19/04

maximum production rate used in the calculations is the physical maximum production rate; in other cases,

the facility may choose to limit their maximum production (and emissions) to keep emissions below certain

trigger levels.

52. PSELs may also be established for Hazardous Air Pollutants (HAPs) if a facility wishes to be classified as a

Synthetic Minor source of HAPs. A facility is considered a major source of HAPs if their HAP emissions

have the potential to equal or exceed 10 tons per year of any single HAP or 25 tons per year of all HAPs

combined. A facility is considered a minor source (or area source) of HAPs if their potential HAP

emissions are less than 10 tons per year of any single HAP or 25 tons per year of all HAPs combined. A

facility that has potential HAP emissions above these levels but that chooses to limit their HAP emissions

to less than these levels is classified as a Synthetic Minor source of HAPs. OAR 340 Division 200 specifies

that Synthetic Minor facilities will have HAP PSELs of 9 tons per year of any single HAP and 24 tons per

year of all HAPs combined.

Netting Basis

53. To determine if a facility triggers additional regulatory requirements, the facility’s PSEL is compared to the

netting basis. If the PSEL is greater than the netting basis by the Significant Emission Rate (SER) or more,

additional requirements are triggered. The SER for each pollutant is specified in OAR 340, Division 200.

Netting basis is also defined in OAR 340, Division 200. ESCO’s netting basis is comprised of 2

components: the baseline emission rate (discussed below) and reductions required by rule. One of the

reductions required by rule occurs if a facility has unassigned emissions (also discussed below) that are

greater than the SER. In this case the unassigned emissions and netting basis were first adjusted downward

on July 1, 2007 and may be adjusted again at each permit renewal after that if necessary. Facilities that

have a netting basis greater than their PSEL are able to increase their PSELs more easily because they are

less likely to trigger additional requirements before the increase can be approved. The program of reducing

unassigned emissions and netting basis is intended to make it more likely that a facility will trigger

additional requirements if and when they request a higher PSEL; however, even with these reductions,

increases that are less than the SER will not trigger additional requirements.

54. Some of ESCO’s unassigned emissions and netting bases were adjusted downward on July 1, 2007; this is

discussed in more detail in the next section of this report.

55. There is no netting basis for HAPs.

Baseline emission rate

56. The baseline emission rate for most pollutants is the actual emissions that occurred during a 12-month

period in the years 1977/78 or an earlier 12-month period. Facilities that were permitted after 1978 have a

baseline emission rate of zero (0). PM2.5 does not have a baseline emission rate, rather the initial PM2.5

netting basis is calculated directly from the PM10 netting basis. The Greenhouse Gas baseline emission rate

is based on actual emissions during a 12-month period in the years 2000 through 2010.

57. There is no baseline emission rate for HAPs.

Unassigned emissions

58. If a facility’s netting basis is greater than its PSEL, the difference (netting basis minus PSEL) becomes

unassigned emissions. As noted above, if the unassigned emissions are greater than the SER, beginning on

July 1, 2007 and if necessary at each permit renewal thereafter, the unassigned emissions are reduced to the

SER and the netting basis is reduced by the same amount.

59. There are no unassigned emissions for HAPs.



of 29

Revised 5/19/04

Unassigned Emissions Reductions

60. The permit issued in 2004 established the netting basis and unassigned emissions for each pollutant.

Condition 46.a. of that permit stated that unassigned emissions greater than the Significant Emission Rate

(SER) would be reduced to the SER on July 1, 2007 if they were not used before that date. No unassigned

emissions were used before July 1, 2007, so unassigned emissions greater than the SER were reduced to the

SER on that date. The unassigned emissions before and on/after July 1, 2007 are shown in the table below.

Pollutant

Unassigned

Emissions

before July 1,

2007

(tons/yr)

Unassigned

Emissions

on/after July

1, 2007

(tons/yr)

Amount

of

reduction

(tons/yr) Explanation

PM 50 25 25 Unassigned emissions reduced to SER. PM

SER = 25.

PM10 50 15 35 Unassigned emissions reduced to SER. PM10

SER = 15.

SO2 --- --- --- No unassigned emissions.

NOx 6 6 0 Unassigned emissions already less than SER.

NOx SER = 40.

CO --- --- --- No unassigned emissions.

VOC 29 29 0 Unassigned emissions already less than SER.

VOC SER = 40.

Pb ---- --- --- No unassigned emissions.

61. When the unassigned emissions were reduced on July 1, 2007, the netting basis was also reduced by the

same amount. The table below shows the netting basis before and on/after July 1, 2007; the amount of

reduction is the same as the reduction applied to the unassigned emissions.

Pollutant

Netting Basis

before July 1,

2007

(tons/yr)

Amount of

reduction

(tons/yr)

Netting Basis

on/after July 1,

2007

(tons/yr)

PM 264 25 239

PM10 264 35 229

SO2 8 --- 8

NOx 71 0 71

CO 277 --- 277

VOC 122 0 122

Pb 0.1 --- 0.1

62. In 2011, PM2.5 became a regulated air pollutant and rules were adopted that specify how to determine the

initial netting basis for PM2.5. The definition of Netting Basis in OAR 340, Division 200 states that the

initial netting basis for PM2.5 is the PM2.5 fraction of the PM10 netting basis in effect on May 1, 2011. DEQ

has no information that can reliably be used to establish the PM2.5 fraction for ESCO’s emissions, so it has

been assumed that all of ESCO’s PM10 emissions are PM2.5; in other words, it is assumed that the PM2.5

fraction is 1. The PM10 netting basis in effect on May 1, 2011 is the same as the PM10 netting basis

established on July 1, 2007 since there were no changes to the PM10 netting basis between July 1, 2007 and



of 29

Revised 5/19/04

May 1, 2011. Therefore the PM2.5 netting basis is the same as the PM10 netting basis and equals 229 tons

per year. The rules also state that there is no baseline emission rate for PM2.5.

63. Greenhouse gases (GHG) also became a regulated air pollutant in 2011. The definition of baseline emission

rate in OAR 340, Division 200 states that the baseline emission rate means the actual emission rate during a

baseline period. The definition of baseline period in OAR 340, Division 200 states that the baseline period

for GHG is any consecutive 12 month period during the years 2000 through 2010. ESCO selected calendar

year 2007 for their baseline period, and calculated GHG emissions during that time of 25,826 tons on a

CO2e basis (rounded off to 25,800 tons). Thus, ESCO’s GHG baseline emission rate is 25,800 tons per

year. ESCO’s GHG netting basis for GHG is the same.

64. The netting basis for each pollutant is shown in the table below and is the starting point for the permit

renewal that DEQ proposes to issue in 2012.

Pollutant

Netting Basis

before July 1,

2007

(tons/yr)

Amount of

reduction

(tons/yr)

Netting Basis

starting point

for 2012 permit

renewal

(tons/yr)

PM 264 25 239

PM10 264 35 229

PM2.5 n/a n/a 229

SO2 8 --- 8

NOx 71 0 71

CO 277 --- 277

VOC 122 0 122

Pb 0.1 --- 0.1

GHG n/a n/a 25,800



of 29

Revised 5/19/04

65. The proposed PSELs are shown in the table below, along with the PSELs from the permit issued in 2004.

The PSEL rules (OAR 340, Division 222) state that if estimated emissions of a pollutant are less than the

generic PSEL level, then the PSEL will be set at the generic level defined in the rules. In ESCO’s case, the

estimated emissions of SO2 and GHG are less than the generic PSEL levels of 39 tons per year for SO2 and

74,000 tons per year for GHG, so the PSELs for these 2 pollutants are set at the generic levels. The PSELs

for the other pollutants are based on the emission rates calculated in the Detail Sheets3 for this permit

renewal. The emission rates are based on the following maximum steel production rates: 30,350 tons per

year at the Main Plant, and 20,380 tons per year at Plant 3, for a total steel production of 50,730 tons per

year.

Pollutant

Proposed

Plant Site

Emission

Limit

(tons/yr)

PSEL in 2004

permit

(tons/yr)

Amount of

change

(tons/yr)

PM 134 214 -80

PM10 134 214 -80

PM2.5 134 n/a n/a

SO2 39 39 0

NOx 65 65 0

CO 348 312 +36

VOC 93 93 0

Pb -- * 0.5 0

GHG 74,000 n/a n/a

* OAR 340-222-0020(3) states that PSELs are not required for pollutants

that will be emitted at less than the de minimis emission level listed in

OAR 340-200-0020 from the entire source. The deminimis level for lead

is 0.1 ton per year (OAR 340 Division 200, Table 4). The permit includes

a voluntary lead limit of 0.1 tons per year in condition 47, and as long as

this limit is in the permit, a PSEL for lead is not required. Therefore DEQ

has deleted the lead PSEL from the permit and will leave only the

voluntary lead limit in condition 47. However, the 0.1 ton per year lead

limit is voluntary, and to avoid giving the false impression that DEQ can

continue to set a lead limit of 0.1 ton per year even if ESCO withdraws it,

DEQ has added a note clarifying that a lead PSEL will be set at 0.5 ton

per year in accordance with OAR 340-222-0041(1) in the event the

voluntary lead limit of 0.1 ton per year is withdrawn.

3 The Detail Sheets file is a large spreadsheet that is difficult to print because of the size and layout of the pages. The

Detail Sheets are available in electronic format; see the last page of this document for how to access the Detail

Sheets.



of 29

Revised 5/19/04

66. Unassigned emissions must be calculated for PM2.5 because it is a new pollutant in this permit, and

unassigned emissions must be recalculated for PM and PM10 because the PSELs for these 2 pollutants

have decreased. There are no unassigned emissions for GHG because the GHG PSEL is greater than the

GHG netting basis. The unassigned emissions for the remaining pollutants are unchanged. Unassigned

emissions equal the netting basis minus the PSEL, and are set equal to zero if the result is a negative

number. The table below shows the proposed PSELs and unassigned emissions.

PM unassigned emissions = 239 minus 134 = 105 tons per year.

PM10 unassigned emissions = 229 minus 134 = 95 tons per year.

PM2.5 unassigned emissions = 229 minus 134 = 95 tons per year.

The table below shows the proposed PSELs and unassigned emissions.

Plant Site Emission Limit table

Pollutant

Plant Site Emission

Limit (tons/yr)

Unassigned Emissions

(tons/yr)

Emission Reduction

Credit (tons/yr)

PM 134 105 0

PM10 134 95 0

PM2.5 134 95 0

SO2 39 0 0

NOx 65 6 0

CO 348 0 0

VOC 93 29 0

GHG 74,000 0 0

Unassigned emissions for PM, PM10 and PM2.5 are greater than the SER and will be reduced to the SER

at the next renewal of this permit unless they are used before that.

SIGNIFICANT EMISSION RATE

67. The proposed PSEL is greater than the netting basis for four pollutants as shown below. However, all

increases over the netting basis are less than the SER. All increases are approvable and there are no

additional requirements to be met.

Pollutant

Plant Site Emission

Limit (tons/yr)

Netting Basis

(tons/yr)

PSEL increase over

netting basis

(tons/yr)

Significant

Emission Rate

(tons/yr)

PM 134 239 -105 25

PM10 134 229 -95 15

PM2.5 134 229 -95 10

SO2 39 8 +31 40

NOx 65 71 -6 40

CO 348 277 +71 100

VOC 93 122 -29 40

GHG 74,000 25,800 +48,200 75,000



of 29

Revised 5/19/04

HAZARDOUS AIR POLLUTANTS

68. ESCO determined that their HAP emissions would equal or exceed the major HAP source thresholds of 10

tons per year of any single HAP and 25 tons per year of all HAPs combined if their production were to

exceed approximately 50,730 tons per year. ESCO has chosen to limit their production and accept HAP

limits to remain a Synthetic Minor source of HAPs. HAP emissions may not exceed 9 tons per year of any

single HAP and 24 tons per year of all HAPs combined.

ESCO’s estimated HAP emissions at a production rate of 50,730 tons per year are shown in the following

table:

Pollutant

Emissions,

lb/yr

Emissions,

tons/yr Pollutant

Emissions,

lb/yr

Emissions,

tons/yr

Lead 207.0 0.10 Trimethylbenzene 93.9 0.05

Mn 1,256.1 0.63 POMs* 0.0 0.00

Ni 191.3 0.10 Hexane 781.6 0.39

Cr 132.7 0.07 Dichlorobenzene 0.4 0.00

Hg 3.9 0.00 Acrolein 134.3 0.07

Cd 56.6 0.03 Ethylbenzene 216.4 0.11

Co 14.1 0.01 Xylenes 879.9 0.44

As 11.9 0.01 Biphenyl 520.4 0.26

Sb 1.3 0.00 Aniline 624.7 0.31

Se 23.1 0.01 Acetaldehyde 1,217.4 0.61

Phenol 16,936.6 8.47 Methylnaphthalene 1,527.2 0.76

Formaldehyde 6,331.9 3.17 Propionaldehyde 35.5 0.02

Benzene 3,800.8 1.90 Cyanide compounds 628.3 0.31

Cresols 4,673.7 2.34 Dimethylaniline 236.8 0.12

Toluene 2,081.1 1.04 Tetrachloroethylene 38.0 0.02

Naphthalene 2,454.5 1.23 Trichloroethylene 946.0 0.47

Triethylamine 306.2 0.15 Cumene 125.6 0.06

Diisocyanates 22.4 0.01 MIBK 162.6 0.08

Styrene 292.7 0.15

Total HAPs 46,967.2 23.5

*POMs excluding naphthalene and methylnaphthalene



of 29

Revised 5/19/04

COMPLIANCE HISTORY

69. During the last permit term, ESCO had 2 violations of rules or the permit. The violations and enforcement

action taken are summarized below:

69.a. ESCO was required to submit notification of its compliance status for management practices for

metallic scrap in 40 CFR 63.10885(a) and binder formulations in 40 CFR 63.10886 by February 1,

2009. ESCO submitted the compliance notification on July 13, 2009, in violation of the

compliance notification requirement. This was a Class II violation and DEQ issued a Warning

Letter to ESCO on February 3, 2010.

69.b. On August 6, 2010, DEQ received a report from ESCO Corporation (ESCO) detailing an incident

with ESCO’s Main Plant Fuller dust collector (the Fuller). The report states that over the period

from July 9, 2010, through July 21, 2010, the Fuller dust collector, a baghouse which serves to

control emissions from the Doghouse shakeout process, was either turned off or was operated at

reduced effectiveness while shakeout continued to occur in the Doghouse Mold Dump (shakeout)

area. Operating the Doghouse shakeout process while the Fuller dust collector was off was a

violation of condition 17 of the Title V permit (a Class II violation); and failing to take corrective

action as expeditiously as practicable to bring the Fuller dust collector back to full efficiency was a

violation of condition 18 of the Title V permit (a Class II violation). For these violations DEQ

assessed a civil penalty of $5,200.00; ESCO paid the penalty on December 28, 2010.

SOURCE TEST RESULTS

70. Source test results are included in the Detail Sheets, see the last page of this document.



of 29

Revised 5/19/04

PUBLIC NOTICE

71. This permit was put on public notice from Dec. 23, 2011 to Feb. 1, 2012. DEQ held a public hearing on

January 24, 2012, at Legacy Good Samaritan Hospital, Auditorium, 1015 NW 22nd

Avenue, Portland,

Oregon. The Information session began at 6:30 p.m. followed by the formal hearing. Two public

comments were received at the hearing. In addition, written comments were submitted by ESCO.

After the comment period and hearing DEQ reviewed the comments. DEQ’s responses to the comments are

detailed at the end of this report beginning on page 27.

The proposed permit was sent to EPA for a 45 day review period on February 3, 2012, and on February 8,

2012 EPA notified DEQ that the permit could be issued.

Any person may petition the EPA within 60 days after the expiration of EPA's 45-day review period to

make an objection. Any such petition must be based only on objections to the permit that were raised with

reasonable specificity during the public comment period provided for in OAR 340-218-0210, unless the

petitioner demonstrates that it was impracticable to raise such objections within such period, or unless the

grounds for such objection arose after such period.

EMISSIONS DETAIL SHEETS

72. The final detail sheets file name is 26-2068-DSver11302011-03012012.xlsx.



of 29

Revised 5/19/04

RESPONSES TO COMMENTS

Two verbal comments were received at the ESCO public hearing on January 24, 2012, and one set of written

comments were received. Based on the comments and an internal review by DEQ staff a number of minor changes

and corrections were made to the permit and review report, but no substantive changes were made. The comments

are copied or described below, followed by DEQ’s response, followed by a list of changes made as a result of the

internal DEQ review.

Hearing comment: Sharon Genasci

I participated in the GNA. First of all my name is Sharon Genasci, I live just a block from here on Johnson

Street, and I’m here as a private citizen, rather than representing the group that I’m probably known to be with.

And living in that situation that far away from the plant, I’m on Johnson and the streets are alphabetical to

Vaughn where the plant is situated, we’ve for years been really bothered by the very strong industrial smells that

really upset going out and working in the garden.

Now I think in the last few years we’ve seen some improvement, and we’ve been working on this issue with the

plant and with the other neighbors for 15 years, more than that, probably 16 years now. I was part of a committee

that helped negotiate the GNA and we signed it because we felt it was a step in the right direction, and certainly

everybody’s happy that ESCO has agreed to reduce their air pollution by approximately 20 percent over a 5 year

period, but given the long-standing problems we’ve had with the odors and dust emissions over all these years,

this wasn’t nearly as much of a correction as we hoped for. We signed a minority report against the GNA,

pointing out in that that the decision not to put any controls at all on Slinger Bay, which is the big rectangular

building on 24th and Vaughn that has huge vents that open directly to the neighborhood with big fans underneath

to blow out the emissions. This was a very serious mistake and I was away during the time that this was agreed

with ESCO that this would be part of the GNA that they would do nothing for 5 years more about correcting

these emissions, because their process of molten scrap metal happens there on the floor in different locations and

is directly vented to the neighborhood. The second thing that we objected to was that there was no provision

made for fenceline monitoring, so that the neighbors in order to have a good faith agreement with the company

really needed the means to check for themselves to see what’s actually coming out of the plant. I really believe

they’re sincere in their intentions to improve things, but we need to know. And that’s really all I wanted to say.

Hearing comment: Bill Welch

My name is Bill Welch, I live at 2705 NW Pettygrove in NW Portland. I serve on a planning committee for this

neighborhood, and have done so for quite a few years. Where my house sits I keep noticing there’s this constant

breeze, I live just a little bit above the school, there’s a constant breeze from the NW that sweeps across the

neighborhood and it’s pretty constant in the summer, not as constant in the winter, but as a result of that I keep

noticing (our porch is one of the places that monitoring has been done, and I have no idea what sort of

contaminants or lack of such that have been in our porch monitoring), but I am concerned that in the next few

years we anticipate having 2000 dwelling units basically downwind of ESCO being put up between Thurman

and Pettygrove and from 23rd down to 18th/19th, and they are all going to be in the path of any contaminants

that do come out of the ESCO facilities, and it seems to me they’re just in the process of planning and just a few

buildings are being built now, but with that kind of intense development, it seems like it would behoove both

Con-way and ESCO to get together, because my concern is that… you know, I really don’t want Con-way to be

there in that kind of development, but if they are going to be there, it seems like it should be the best

development possible, not one that’s going to be contaminated. I also think that if ESCO is going to go for an

IPO they’d want to clear that out as much as possible, assure their new owners and investors that they are not

going to be contaminating the neighborhood and their investors are not going to be liable for any future claims

against them. And in that sense I think it’s really incumbent on them to clear that up before they go for their IPO

this spring.



of 29

Revised 5/19/04

Response to hearing comments

DEQ appreciates these comments, and agrees in general that ambient monitoring in the neighborhood would be

valuable. DEQ does not have the resources to perform ambient monitoring in NW Portland at this time. DEQ

also acknowledges the concern about the proposed Con-way development, but DEQ does not have a planning

role in land use projects such as this.

DEQ notes that neither of these comments addresses conditions in the permit, and no changes to the permit have

been made as a result of these comments.

Written comments: ESCO

ESCO pointed out a number of minor errors in the permit and review report. Based on these comments, the

corrections listed below were made to the permit and review report.

Permit corrections based on ESCO’s comments

On the cover page, the mailing address was changed.

Condition 9, corrected the reference from “EU 5 Coat” to “MU-9 Coat”.

Condition 19, Table 19-1, baghouse ID numbers for #2 and #3 Wheelabrator were reversed.

Condition 22.c, “60 days” was changed to “30 days” to be consistent with condition 70.a.

Condition 29.c.v.6, changed incorrect reference from “paragraph (d)(3) of this section” to “condition 34 of

this permit”.

Condition 83.c, changed “Oregon Accident Response System (OARs)” to “Oregon Emergency Response

System (OERS) at 1-800-452-0311”, and deleted “The current number is 1-800-452-0311.”

Review report corrections based on ESCO’s comments

Paragraph 15, changed “Carburization” to “Decarburization”.

Paragraph 18, changed “all of the molds used at Plant 3 are made with phenolic urethane binder” to “the

molds used at Plant 3 are made with phenol-formaldehyde resin and phenolic urethane binder”.

Paragraph 24, changed “At Plant 3, sand is mixed with phenolic urethane binder” to “At Plant 3, sand is

mixed with phenol-formaldehyde resin”.

Paragraph 38, changed “Baghouse 301100” to “Dust collector 301110”, 2 instances.

End of responses to comments

Corrections to the permit based on internal DEQ review

A number of minor changes to the permit were identified by DEQ’s Office of Compliance and Enforcement staff.

The changes are described below.

Condition 24.a, changed “shall” to “must”.

Condition 24.d, added “Permittee must”.

Condition 29.d.iii, changed “Description” to “A description”.

Condition 30, fourth line, corrected “or” to “of”.

Condition 31, changed “correction” to “corrective”, two instances.

Condition 40.c, deleted “that”.

Condition 53.b.i, changed “will” to “must”.

Condition 66, changed “The plant site emissions must not exceed the following limits” to “The permittee

must not exceed the following plant site emission limits”.



of 29

Revised 5/19/04

Condition 67, changed “The plant site emissions of Hazardous Air Pollutants must not exceed the

following limits” to “The permittee must not exceed the following plant site emission limits of Hazardous

Air Pollutants”.

Condition 68, changed “Emission factors for Hazardous Air Pollutants may be revised” to “DEQ may

revise the emission factors for Hazardous Air Pollutants”.

Condition 68.a, added “to DEQ”.

Condition 68.c.ii, changed “the limit of detection must be used” to “permittee must use the limit of

detection”.

Condition 69.a, note with asterisk, changed “shall” to “must”, and changed “VOC content from data sheets

supplied by the manufacturer and actual records of coatings, thinners and solvents used in the coating

process shall be used” to “Permittee must use VOC content from data sheets supplied by the manufacturer

and actual records of coatings, thinners and solvents used in the coating process”.

Condition 71, changed “All Modified Method 9 testing shall be conducted for a minimum period of 6

minutes, though longer periods may be required by specific permit conditions. Modified Method 9 testing

shall be performed in accordance with the ODEQ Source Testing Manual, and shall be conducted by a

certified plume observe” to “Permittee must conduct all Modified Method 9 testing for a minimum period

of 6 minutes, though longer periods may be required by specific permit conditions. Permittee must perform

the Modified Method 9 testing in accordance with the ODEQ Source Testing Manual, and the testing must

be conducted by a certified plume observer”.

Condition 74, changed “Methods used to determine actual emissions for fee purposes must also be used for

compliance determination” to “Permittee must use the same methods to determine compliance as those

used to determine actual emissions for fee purposes”.

Condition 82.c, changed “The report must be submitted” to “The permittee must submit the report”.

Condition 86, changed “shall” to “must”.

Condition 87, changed “shall commence” to “are in effect”.

Condition 88.a, changed “shall be” to “is”, and “shall” to “must”.

Condition 88.b, changed “shall be” to “is”, and “shall” to “must”.

Condition 91, changed “The” to “Permittee’s”.

Condition 91.c, changed “shall” to “must”.

Condition 91.c.ii.2, changed “shall” to “must”.

End of document

oregon title v operating permit review report · oregon title v operating permit review report ......

Documents