public notice...public notice waupaca foundry, inc. has applied to the tennessee department of...

PUBLIC NOTICE

Waupaca Foundry, Inc. has applied to the Tennessee Department of Environment and Conservation, Division of Air Pollution Control for

renewal of their major source (Title V) operating permit subject to the provisions of Tennessee Air Pollution Control Regulations 1200-03-09-

.02(11) (Title V Regulations). A major source operating permit is required by both the Federal Clean Air Act and Tennessee’s air pollution

control regulations. However, it should be noted that this facility has a current major source operating permit.

The applicant is Waupaca Foundry, Inc. with a site address of 134 Waupaca Drive, Etowah, TN 37331. They have applied for renewal of their existing major source (Title V) operating permit for their grey and ductile iron operation. EPA has agreed to treat this draft Part 70 permit as a proposed Part 70 permit and to perform its 45-day review provided by the law concurrently with the public notice period. If any substantive comments are received, EPA’s 45-day review period will cease to be performed concurrently with the public notice period. In this case, EPA’s 45-day review period will start once the public notice period has been completed and EPA receives notification from the Tennessee Air Pollution Control Division that comments have been received and resolved. The status regarding EPA’s 45-day review of these permits and the deadline for submitting a citizen’s petition can be found at the following website address:

https://www.epa.gov/caa-permitting/tennessee-proposed-title-v-permits”

The draft permit includes a waste sand and metal recovery operation, source 54-0174-24, authorized by permit 973233 and includes

modifications to the P30 cupola, source 54-0174-17, for removal of requirements for continuous emission monitoring systems for

nitrogen oxides and opacity authorized by permit 976951.

Copies of the application materials and draft permit are available for public inspection during normal business hours at the following location:

Tennessee Department of Environment

and Conservation

Division of Air Pollution Control

Chattanooga Environmental Field

Office

1301 Riverfront Parkway, Suite 206

Chattanooga, TN 37402

At this time, visitors are seen at the Chattanooga Environmental Field Office by appointment only. You should contact the Chattanooga

Environmental Field Office for an appointment to review the document by calling 423-634-5745.

Electronic copies of the draft permits are available by accessing the TDEC internet site located at:

http://www.tn.gov/environment/topic/ppo-air

Questions concerning the source may be addressed to John Trimmer at (615) 532-0552 or by e-mail at [email protected].

Interested parties are invited to review these materials and comment. In addition, a public hearing may be requested at which written or oral

presentations may be made. To assure that written comments are received and addressed in a timely manner, written comments must be

submitted using one of the following methods:

1. Mail, private carrier, or hand delivery: Address written comments to Ms. Michelle W. Owenby, Director, Division of Air

Pollution Control, William R. Snodgrass Tennessee Tower, 312 Rosa L. Parks Avenue 15th Floor, Nashville, Tennessee 37243.

2. E-mail: Submit electronic comments to [email protected].

A final determination will be made after weighing all relevant comments.

Individuals with disabilities who wish to review information maintained at the above-mentioned depositories should contact the Tennessee

Department of Environment and Conservation to discuss any auxiliary aids or services needed to facilitate such review. Such contact may be

in person, by writing, telephone, or other means, and should be made no less than ten days prior to the end of the public comment period to

allow time to provide such aid or services. Contact the Tennessee Department of Environment and Conservation ADA Coordinator, William R.

Snodgrass Tennessee Tower, 312 Rosa L. Parks Avenue 22nd Floor, Nashville, TN 37243, 1-(866)-253-5827. Hearing impaired callers may use

the Tennessee Relay Service, 1-(800)-848-0298.

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Do not publish the information below:

For the McMinn County “Daily Post Athenian” -- publish once during the time period of April 22 through April 29, 2020.

Air Pollution Control DATE: APRIL 16, 2020

https://urldefense.com/v3/__https:/www.epa.gov/caa-permitting/tennessee-proposed-title-v-permits__;!!PRtDf9A!7sDUpqYVUpKGRkTA2-RS8kSQ7KybHg9lxQjH1dRpdNZ8Uj6IrphRa6EN1nosfoX_2A$

http://www.tn.gov/environment/topic/ppo-air

mailto:[email protected]

Assigned to –John Trimmer

No alterations to the above are allowed:

Waupaca Foundry, Inc. must pay to place this advertisement in the newspaper

Air Pollution Control must be furnished with an affidavit from the newspaper stating that the ad was run and the date of the ad or one complete

sheet from the newspaper showing this advertisement, the name of the newspaper and the date of publication. Mail to John Trimmer, Division

of Air Pollution Control, William R. Snodgrass Tennessee Tower, 15th Floor, 312 Rosa L. Parks Avenue, Nashville, Tennessee 37243.

STATE OF TENNESSEE

AIR POLLUTION CONTROL BOARD

DEPARTMENT OF ENVIRONMENT AND CONSERVATION

NASHVILLE, TENNESSEE 37243

OPERATING PERMIT (TITLE V) Issued Pursuant to Tennessee Air Quality Act This permit fulfills the requirements of Title V of the Federal Clean Air Act (42 U.S.C. 7661a-7661e) and the federal regulations

promulgated thereunder at 40 CFR Part 70. (FR Vol. 57, No. 140, Tuesday, July 21, 1992 p.32295-32312). This permit is issued in

accordance with the provisions of paragraph 1200-03-09-.02(11) of the Tennessee Air Pollution Control Regulations. The permittee has

been granted permission to operate an air contaminant source in accordance with emissions limitations and monitoring requirements set

forth herein.

Date Issued: TBD Permit Number:

573114

Date Expires: TBD

Issued To: Installation Address:

Waupaca Foundry, Inc. 134 Waupaca Drive

Etowah

Installation Description: Grey and Ductile Iron Foundry 01: Phase I – Mold Cooling and Shakeout, Cast Handling & Finishing

02: Phase I – Sand System, Preparation, return & Cooling – Molten Metal Handling

03: Phase I – Return Metal Handling

04: Phase I – Spent Dust Handling

08: Phase I – Air Make-Up

09: Phase I – Miscellaneous Natural Gas or Propane Usage

17: Phase I – Cupola

18: Phase I – Ductile Iron Treatment and Desulfurization

20: Phase I – Phenolic-Urethane Core Making Operation

21: Phase I – One (1) 50 kW Internal Combustion, Natural Gas (Liquid Propane as backup) Fired Emergency Backup Generator,

Equipped with a 82.1 hp Engine (I.D. GENERAC, SG050) [Insignificant Activity - removed from permit]

24: Waste Sand and Metal Recovery Operation

Facility ID: 54-0174

Renewal Application Due Date: Primary SIC: 3321 Between TBD and TBD

Information Relied Upon: Title V permit renewal application revision dated December 11, 2018

Construction permit applications dated November 20, 2017, December 12, 2017, December 20, 2017, and letter dated February 9, 2018

Construction permit application dated May 28, 2019

_____________________DRAFT______

TECHNICAL SECRETARY

No Authority is Granted by this Permit to Operate, Construct, or Maintain any Installation in Violation of any Law, Statute,

Code, Ordinance, Rule, or Regulation of the State of Tennessee or any of its Political Subdivisions.

POST AT INSTALLATION ADDRESS

7/11/19 RDA-1298

Permit Number: 573114 DRAFT Expiration Date: TBD

i

CONTENTS

SECTION A

GENERAL PERMIT CONDITIONS

A1. Definitions 1

A2. Compliance requirement 1

A3. Need to halt or reduce activity 1

A4. The permit 1

A5. Property rights 1

A6. Submittal of requested information 1

A7. Severability clause 2

A8. Fee payment 2

A9. Permit revision not required 2

A10. Inspection and entry 2

A11. Permit shield 3

A12. Permit renewal and expiration 3

A13. Reopening for cause 3

A14. Permit transference 4

A15. Air pollution alert 4

A16. Construction permit required 4

A17. Notification of changes 4

A18. Schedule of compliance 5

A19. Title VI 5

A20. 112 (r) 5

SECTION B

GENERAL CONDITIONS for MONITORING, REPORTING, and ENFORCEMENT

B1. Recordkeeping 6

B2. Retention of monitoring data 6

B3. Reporting 6

B4. Certification 6

B5. Annual compliance certification 6

B6. Submission of compliance certification 7

B7. Emergency provisions 7

B8. Excess emissions reporting 7

B9. Malfunctions, startups and shutdowns - reasonable measures required 8 B10. (Reserved) TAPCR 1200-03-20-.04(2) is no longer a part of the SIP. 8

B11. Report required upon the issuance of notice of violation 8


ii

CONTENTS

SECTION C

PERMIT CHANGES

C1. Operational flexibility changes 9

C2. Section 502(b)(10) changes 9

C3. Administrative amendment 9

C4. Minor permit modifications 10

C5. Significant permit modifications 10

C6. New construction or modifications 10

SECTION D

GENERAL APPLICABLE REQUIREMENTS

D1. Visible emissions 11

D2. General provisions and applicability for non-process gaseous emissions 11

D3. Non-process emission 11

D4. General provisions and applicability for process gaseous 11

D5. Particulate emissions from process emission sources 11

D6. Sulfur dioxide emission standards 11

D7. Fugitive dust 11

D8. Open burning 12

D9. Asbestos 12

D10. Annual certification of compliance 12

D11. Emission Standards for Hazardous Air Pollutants 12

D12. Standards of Performance for New Stationary Sources 12

D13. Gasoline Dispensing Facilities 12

D14. Internal Combustion Engines 12


iii

CONTENTS

SECTION E

SOURCE SPECIFIC EMISSION STANDARDS, OPERATING LIMITATIONS, and

MONITORING, RECORDKEEPING and REPORTING REQUIREMENTS

E1. Fee payment: actual emissions basis 13

E2. Reporting requirements 16

E3-1 – E3-12 -General Permit requirements 18

E4. MACT Provisions 21

E5-1– E5-8 - Requirements of Source 01 22



E8-1– E8-4- Requirements of Source 04 29

E9-1– E9-4- Requirements of Source 08 29





E14-1 - Requirements of Source 21 (Removed from permit) 41

E15-1– E15-2 – Requirements of Source 24 41

END OF PERMIT NUMBER 573114 42

ATTACHMENTS

ATTACHMENT 1 Opacity Matrix Decision Tree for Visible Emission

Evaluation Methods 1, 2 and 9 dated June 18, 1996 and

Amended September 11, 2013 3 Pages

ATTACHMENT 2 Requirements of 40 CFR Part 63, Subpart EEEEE 31 Pages

ATTACHMENT 3 Operation and Maintenance Plan 15 Pages

ATTACHMENT 4 Title V Fee Selection Form APC 36 2 Pages

ATTACHMENT 5 Letter Dated February 9, 2018 1 Page


1

SECTION A

GENERAL PERMIT CONDITIONS

A permit issued under the provisions of paragraph 1200-03-09-.02(11) is a permit issued pursuant to the requirements of Title V

of the Federal Act and its implementing Federal regulations promulgated at 40 CFR, Part 70.

A1. Definitions. Terms not otherwise defined in the permit shall have the meaning assigned to such terms in the referenced

regulation.

TAPCR 1200-03

A2. Compliance requirement. All terms and conditions in a permit issued pursuant to paragraph 1200-03-09-.02(11) including any

provisions designed to limit a source's potential to emit, are enforceable by the Administrator and citizens under the Federal Act.

The permittee shall comply with all conditions of its permit. Except for requirements specifically designated herein as

not being federally enforceable (State Only), non-compliance with the permit requirements is a violation of the Federal Act and

the Tennessee Air Quality Act and is grounds for enforcement action; for a permit termination, revocation and reissuance, or

modification; or for denial of a permit renewal application. Non-compliance with permit conditions specifically designated

herein as not being federally enforceable (State Only) is a violation of the Tennessee Air Quality Act and may be grounds for

these actions.

TAPCR 1200-03-09-.02(11)(e)2(i) and 1200-03-09-.02(11)(e)1(vi)(I)

A3. Need to halt or reduce activity. The need to halt or reduce activity is not a defense for noncompliance. It shall not be a

defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in

order to maintain compliance with the conditions of the permit. However, nothing in this item shall be construed as precluding

consideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for noncompliance if the health,

safety or environmental impacts of halting or reducing operations would be more serious than the impacts of continuing

operations.

TAPCR 1200-03-09-.02(11)(e)1(vi)(II)

A4. The permit. The permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a request

by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or

anticipated noncompliance does not stay any permit condition.

TAPCR 1200-03-09-.02(11)(e)1(vi)(III)

A5. Property rights. The permit does not convey any property rights of any sort, or any exclusive privilege.

TAPCR 1200-03-09-.02(11)(e)1(vi)(IV)

A6. Submittal of requested information. The permittee shall furnish to the Technical Secretary, within a reasonable time,

any information that the Technical Secretary may request in writing to determine whether cause exists for modifying, revoking

and reissuing, or termination of the permit or to determine compliance with the permit. Upon request, the permittee shall also

furnish to the Technical Secretary copies of records required to be kept by the permit. If the permittee claims that such

information is confidential, the Technical Secretary may review that claim and hold the information in protected status until such

time that the Board can hear any contested proceedings regarding confidentiality disputes. If the information is desired by EPA,

the permittee may mail the information directly to EPA. Any claims of confidentiality for federal purposes will be determined

by EPA.

TAPCR 1200-03-09-.02(11)(e)1(vi)(V)


2

A7. Severability clause. The requirements of this permit are severable. A dispute regarding one or more requirements of this

permit does not invalidate or otherwise excuse the permittee from their duty to comply with the remaining portion of the permit.

TAPCR 1200-03-09.02(11)(e)1(v)

A8. Fee payment.

(a) The permittee shall pay an annual Title V emission fee based upon the responsible official's choice of actual emissions,

allowable emissions, or a combination of actual and allowable emissions; and on the responsible official’s choice of annual

accounting period. An emission cap of 4,000 tons per year per regulated pollutant per major source SIC Code shall apply to

actual or allowable based emission fees. A Title V annual emission fee will not be charged for emissions in excess of the cap.

Title V annual emission fees will not be charged for carbon monoxide or for greenhouse gas pollutants solely because they are

greenhouse gases.

(b) Title V sources shall pay allowable based emission fees until the beginning of the next annual accounting period

following receipt of their initial Title V operating permit. At that time, the permittee shall begin paying their Title V fee based

upon their choice of actual or allowable based fees, or mixed actual and allowable based fees. Once permitted, the Responsible

Official may revise their existing fee choice by submitting a written request to the Division no later than December 31 of the

annual accounting period for which the fee is due.

(c) When paying annual Title V emission fees, the permittee shall comply with all provisions of 1200-03-26-.02 and 1200-

03-09-.02(11) applicable to such fees.

(d) Where more than one (1) allowable emission limit is applicable to a regulated pollutant, the allowable emissions for

the regulated pollutants shall not be double counted. Major sources subject to the provisions of paragraph 1200-03-26-.02(9)

shall apportion their emissions as follows to ensure that their fees are not double counted.

1. Sources that are subject to federally promulgated hazardous air pollutant under 40 CFR 60, 61, or 63 will

place such regulated emissions in the regulated hazardous air pollutant (HAP) category.

2. A category of miscellaneous HAPs shall be used for hazardous air pollutants listed at part 1200-03-26-

.02(2)(i)12 that are not subject to federally promulgated hazardous air pollutant standards under 40 CFR 60, 61, or

63.

3. HAPs that are also in the family of volatile organic compounds, particulate matter, or PM10 shall not be

placed in either the regulated HAP category or miscellaneous HAP category.

4. Sources that are subject to a provision of chapter 1200-03-16 New Source Performance Standards (NSPS) or

chapter 0400-30-39 Standards of Performance for New Stationary Sources for pollutants that are neither particulate

matter, PM10, sulfur dioxide (SO2), volatile organic compounds (VOC), nitrogen oxides (NOx), or hazardous air

pollutants (HAPs) will place such regulated emissions in an NSPS pollutant category.

5. The regulated HAP category, the miscellaneous HAP category, and the NSPS pollutant category are each

subject to the 4,000 ton cap provisions of subparagraph 1200-03-26-.02(2)(i).

6. Major sources that wish to pay annual emission fees for PM10 on an allowable emission basis may do so if

they have a specific PM10 allowable emission standard. If a major source has a total particulate emission standard,

but wishes to pay annual emission fees on an actual PM10 emission basis, it may do so if the PM10 actual emission

levels are proven to the satisfaction of the Technical Secretary. The method to demonstrate the actual PM10 emission

levels must be made as part of the source’s major source operating permit in advance in order to exercise this option.

The PM10 emissions reported under these options shall not be subject to fees under the family of particulate

emissions. The 4,000 ton cap provisions of subparagraph 1200-03-26-.02(2)(i) shall also apply to PM10 emissions.

.

TAPCR 1200-03-26-.02 and 1200-03-09-.02(11)(e)1(vii)

A9. Permit revision not required. A permit revision will not be required under any approved economic incentives, marketable

permits, emissions trading and other similar programs or process for changes that are provided for in the permit.

TAPCR 1200-03-09-.02(11)(e)1(viii)

A10. Inspection and entry. Upon presentation of credentials and other documents as may be required by law, the permittee shall

allow the Technical Secretary or an authorized representative to perform the following for the purposes of determining

compliance with the permit applicable requirements:

(a) Enter upon, at reasonable times, the permittee's premises where a source is located or emissions-related activity is

conducted, or where records must be kept under the conditions of the permit;


3

(b) Have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit;

(c) Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment),

practices, or operations regulated or required under the permit; and

(d) As authorized by the Clean Air Act and Chapter 1200-03-10 of TAPCR, sample or monitor at reasonable times

substances or parameters for the purpose of assuring compliance with the permit or applicable requirements.

(e) "Reasonable times" shall be considered to be customary business hours unless reasonable cause exists to suspect

noncompliance with the Act, Division 1200-03 or any permit issued pursuant thereto and the Technical Secretary specifically

authorizes an inspector to inspect a facility at any other time.

TAPCR 1200-03-09-.02(11)(e)3.(ii)

A11. Permit shield.

(a) Compliance with the conditions of this permit shall be deemed compliance with all applicable requirements as of the

date of permit issuance, provided that:

1. Such applicable requirements are included and are specifically identified in the permit; or

2. The Technical Secretary, in acting on the permit application or revision, determines in writing that other

requirements specifically identified are not applicable to the source, and the permit includes the determination or a

concise summary thereof.

(b) Nothing in this permit shall alter or affect the following:

1. The provisions of section 303 of the Federal Act (emergency orders), including the authority of the

Administrator under that section. Similarly, the provisions of T.C.A. §68-201-109 (emergency orders) including the

authority of the Governor under the section;

2. The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the

time of permit issuance;

3. The applicable requirements of the acid rain program, consistent with section 408(a) of the Federal Act; or

4. The ability of EPA to obtain information from a source pursuant to section 114 of the Federal Act.

(c) Permit shield is granted to the permittee.

TAPCR 1200-03-09-.02(11)(e)6

A12. Permit renewal and expiration.

(a) An application for permit renewal must be submitted at least 180 days, but no more than 270 days prior to the

expiration of this permit. Permit expiration terminates the source's right to operate unless a timely and complete renewal

application has been submitted.

(b) If the permittee submits a timely and complete application for permit renewal the source will not be considered to be

operating without a permit until the Technical Secretary takes final action on the permit application, except as otherwise

noted in paragraph 1200-03-09-.02(11).

(c) This permit, its shield provided in Condition A11, and its conditions will be extended and effective after its

expiration date provided that the source has submitted a timely, complete renewal application to the Technical Secretary.

TAPCR 1200-03-09-.02(11)(f)2 and 3, 1200-03-09-.02(11)(d)1(i)(III), and 1200-03-09-.02(11)(a)2

A13. Reopening for cause.

(a) A permit shall be reopened and revised prior to the expiration of the permit under any of the circumstances listed

below:

1. Additional applicable requirements under the Federal Act become applicable to the sources contained in this

permit provided the permit has a remaining term of 3 or more years. Such a reopening shall be completed not later than

18 months after promulgation of the applicable requirement. No such reopening is required if the effective date of the

requirement is later than the permit expiration date of this permit, unless the original has been extended pursuant to

1200-03-09-.02(11)(a)2.

2. Additional requirements become applicable to an affected source under the acid rain program.

3. The Technical Secretary or EPA determines that the permit contains a material mistake or that inaccurate

statements were made in establishing the emissions standards or other terms or conditions of the permit.

4. The Technical Secretary or EPA determines that the permit must be revised or revoked to assure compliance

with the applicable requirements.


4

(b) Proceedings to reopen and issue a permit shall follow the same proceedings as apply to initial permit issuance and shall

affect only those parts of the permit for which cause to reopen exists, and not the entire permit. Such reopening shall be made as

expeditiously as practicable.

(c) Reopenings for cause shall not be initiated before a notice of such intent is provided to the permittee by the Technical

Secretary at least 30 days in advance of the date that the permit is to be reopened except that the Technical Secretary may

provide a shorter time period in the case of an emergency. An emergency shall be established by the criteria of T.C.A.

68-201-109 or other compelling reasons that public welfare is being adversely affected by the operation of a source that is in

compliance with its permit requirements.

(d) If the Administrator finds that cause exists to terminate, modify, or revoke and reissue a permit as identified in A13, he

is required under federal rules to notify the Technical Secretary and the permittee of such findings in writing. Upon receipt of

such notification, the Technical Secretary shall investigate the matter in order to determine if he agrees or disagrees with the

Administrator's findings. If he agrees with the Administrator's findings, the Technical Secretary shall conduct the reopening in

the following manner:

1. The Technical Secretary shall, within 90 days after receipt of such notification, forward to EPA a proposed

determination of termination, modification, or revocation and reissuance, as appropriate. If the Administrator grants

additional time to secure permit applications or additional information from the permittee, the Technical Secretary shall

have the additional time period added to the standard 90 day time period.

2. EPA will evaluate the Technical Secretary's proposed revisions and respond as to their evaluation.

3. If EPA agrees with the proposed revisions, the Technical Secretary shall proceed with the reopening in the

same manner prescribed under Condition A13 (b) and Condition A13 (c).

4. If the Technical Secretary disagrees with either the findings or the Administrator that a permit should be

reopened or an objection of the Administrator to a proposed revision to a permit submitted pursuant to Condition

A13(d), he shall bring the matter to the Board at its next regularly scheduled meeting for instructions as to how he

should proceed. The permittee shall be required to file a written brief expressing their position relative to the

Administrator's objection and have a responsible official present at the meeting to answer questions for the Board. If

the Board agrees that EPA is wrong in their demand for a permit revision, they shall instruct the Technical Secretary to

conform to EPA's demand, but to issue the permit under protest preserving all rights available for litigation against

EPA.

TAPCR. 1200-03-09-.02(11)(f)6 and 7.

A14. Permit transference. An administrative permit amendment allows for a change of ownership or operational control of a

source where the Technical Secretary determines that no other change in the permit is necessary, provided that the following

requirements are met:

(a) Transfer of ownership permit application is filed consistent with the provisions of 1200-03-09-.03(6), and

(b) written agreement containing a specific date for transfer of permit responsibility, coverage, and liability between the

current and new permittee has been submitted to the Technical Secretary.

TAPCR 1200-03-09-.02(11)(f)4(i)(IV) and 1200-03-09-.03(6)

A15. Air pollution alert. When the Technical Secretary has declared that an air pollution alert, an air pollution warning, or an

air pollution emergency exists, the permittee must follow the requirements for that episode level as outlined in TAPCR 1200-03-

09-.03(1) and TAPCR 1200-03-15-.03.

A16. Construction permit required. Except as exempted in TAPCR 1200-03-09-.04, or excluded in subparagraph TAPCR

1200-03-02-.01(1)(aa) or subparagraph TAPCR 1200-03-02-.01(1)(cc), this facility shall not begin the construction of a new air

contaminant source or the modification of an air contaminant source which may result in the discharge of air contaminants

without first having applied for and received from the Technical Secretary a construction permit for the construction or

modification of such air contaminant source.

TAPCR 1200-03-09-.01(1)(a)

A17. Notification of changes. The permittee shall notify the Technical Secretary 30 days prior to commencement of any of the

following changes to an air contaminant source which would not be a modification requiring a construction permit.

(a) change in air pollution control equipment

(b) change in stack height or diameter


5

(c) change in exit velocity of more than 25 percent or exit temperature of more than 15 percent based on absolute

temperature.

TAPCR 1200-03-09-.02(7)

A18. Schedule of compliance. The permittee will comply with any applicable requirement that becomes effective during the permit

term on a timely basis. If the permittee is not in compliance the permittee must submit a schedule for coming into compliance

which must include a schedule of remedial measure(s), including an enforceable set of deadlines for specific actions.

TAPCR 1200-03-09-.02(11)(d)3 and 40 CFR Part 70.5(c)

A19. Title VI.

(a) The permittee shall comply with the standards for recycling and emissions reduction pursuant to 40 CFR, Part 82,

Subpart F, except as provided for motor vehicle air conditioners (MVACs) in Subpart B:

1. Persons opening appliances for maintenance, service, repair, or disposal must comply with the required

practices pursuant to Section 82.156.

2. Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the

standards for recycling and recovery equipment pursuant to Section 82.158.

3. Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved

technician certification program pursuant to Section 82.161.

(b) If the permittee performs a service on motor (fleet) vehicles when this service involves ozone depleting substance

refrigerant in the motor vehicle air conditioner (MVAC), the permittee is subject to all the applicable requirements as specified

in 40 CFR, Part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners.

(c) The permittee shall be allowed to switch from any ozone-depleting substance to any alternative that is listed in the

Significant New Alternatives Program (SNAP) promulgated pursuant to 40 CFR, Part 82, Subpart G, Significant New

Alternatives Policy Program.

A20. 112 (r). Sources which are subject to the provisions of Section 112(r) of the federal Clean Air Act or any federal

regulations promulgated thereunder, shall annually certify in writing to the Technical Secretary that they are properly

following their accidental release plan. The annual certification is due in the office of the Technical Secretary no later than

January 31 of each year. Said certification will be for the preceding calendar year.

TAPCR 1200-03-32-.03(3)


6

SECTION B

GENERAL CONDITIONS for MONITORING,

REPORTING, and ENFORCEMENT

B1. Recordkeeping. Monitoring and related record keeping shall be performed in accordance with the requirements specified in

the permit conditions for each individual permit unit. In no case shall reports of any required monitoring and record keeping

be submitted less frequently than every six months.

(a) Where applicable, records of required monitoring information include the following:

1. The date, place as defined in the permit, and time of sampling or measurements;

2. The date(s) analyses were performed;

3. The company or entity that performed the analysis;

4. The analytical techniques or methods used;

5. The results of such analyses; and

6. The operating conditions as existing at the time of sampling or measurement.

(b) Digital data accumulation which utilizes valid data compression techniques shall be acceptable for compliance

determination as long as such compression does not violate an applicable requirement and its use has been approved in

advance by the Technical Secretary.

TAPCR 1200-03-09-.02(11)(e)1(iii)

B2. Retention of monitoring data. The permittee shall retain records of all required monitoring data and support information

for a period of at least 5 years from the date of the monitoring sample, measurement, report, or application. Support

information includes all calibration and maintenance records and all original strip chart recordings for continuous monitoring

instrumentation, and copies of all reports required by the permit.

TAPCR 1200-03-09-.02(11)(e)1(iii)(II)II

B3. Reporting. Reports of any required monitoring and record keeping shall be submitted to the Technical Secretary in

accordance with the frequencies specified in the permit conditions for each individual permit unit. Reports shall be submitted

within 60 days of the close of the reporting period unless otherwise noted. All instances of deviations from permit

requirements must be clearly identified in such reports. All required reports must be certified by a responsible official.

Reports required under "State only requirements" are not required to be certified by a responsible official.

TAPCR 1200-03-09-.02(11)(e)1(iii)

B4. Certification. Except for reports required under “State Only” requirements, any application form, report or compliance

certification submitted pursuant to the requirements of this permit shall contain certification by a responsible official of truth,

accuracy and completeness. This certification shall state that, based on information and belief formed after reasonable

inquiry, the statements and information in the document are true, accurate and complete.

TAPCR 1200-03-09-.02(11)(d)4

B5. Annual compliance certification. The permittee shall submit annually compliance certifications with terms and conditions

contained in Sections A, B, D and E of this permit, including emission limitations, standards, or work practices. This

compliance certification shall include all of the following (provided that the identification of applicable information may

cross-reference the permit or previous reports, as applicable):

(a) The identification of each term or condition of the permit that is the basis of the certification;

(b) The identification of the method(s) or other means used by the owner or operator for determining the compliance

status with each term and condition during the certification period; such methods and other means shall include, at a

minimum, the methods and means required by this permit. If necessary, the owner or operator also shall identify any other

material information that must be included in the certification to comply with section 113(c)(2) of the Federal Act, which

prohibits knowingly making a false certification or omitting material information;

(c) The status of compliance with the terms and conditions of the permit for the period covered by the certification,

including whether compliance during the period was continuous or intermittent. The certification shall be based on the

method or means designated in B5(b) above. The certification shall identify each deviation and take it into account in the

compliance certification. The certification shall also identify as possible exceptions to compliance any periods during which

compliance is required and in which an excursion* or exceedance** as defined below occurred; and

(d) Such other facts as the Technical Secretary may require to determine the compliance status of the source.


7

* “Excursion” shall mean a departure from an indicator range established for monitoring under this paragraph, consistent

with any averaging period specified for averaging the results of the monitoring.

** “Exceedance” shall mean a condition that is detected by monitoring that provides data in terms of an emission limitation

or standard and that indicates that emissions (or opacity) are greater than the applicable emission limitation or standard (or

less than the applicable standard in the case of a percent reduction requirement) consistent with any averaging period

specified for averaging the results of the monitoring.

40 CFR Part 70.6(c)(5)(iii) as amended in the Federal Register Vol. 79, No.144, July 28, 2014, pages 43661 through 43667

B6. Submission of compliance certification. The compliance certification shall be submitted to:

The Tennessee Department of

Environment and Conservation

Environmental Field Office specified in

Section E of this permit

and Air Enforcement Branch

US EPA Region IV

61 Forsyth Street, SW

Atlanta, Georgia 30303

TAPCR 1200-03-09-.02(11)(e)3(v)(IV)

B7. Emergency provisions. An emergency constitutes an affirmative defense to an enforcement action brought against this

source for noncompliance with a technology based emission limitation due to unavoidable increases in emissions attributable

to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment,

lack of preventative maintenance, careless or improper operation, or operator error.

(a) The affirmative defense of the emergency shall be demonstrated through properly signed, contemporaneous

operating logs, or other relevant evidence that:

1. An emergency occurred and that the permittee can identify the probable cause(s) of the emergency.

"Probable" must be supported by a credible investigation into the incident that seeks to identify the causes and

results in an explanation supported by generally accepted engineering or scientific principles.

2. The permitted source was at the time being properly operated. In determining whether or not a source was

being properly operated, the Technical Secretary shall examine the source's written standard operating procedures

which were in effect at the time of the noncompliance and any other code as detailed below that would be relevant to

preventing the noncompliance. Adherence to the source's standard operating procedures will be the test of adequate

preventative maintenance, careless operation, improper operation or operator error to the extent that such adherence

would prevent noncompliance. The source's failure to follow recognized standards of practice to the extent that

adherence to such a standard would have prevented noncompliance will disqualify the source from any claim of an

emergency and an affirmative defense.

3. During the period of the emergency, the permittee took all reasonable steps to minimize levels of emissions

that exceeded the emission standards, or other requirements in the permit.

4. The permittee submitted notice of the emergency to the Technical Secretary according to the notification

criteria for malfunctions in rule 1200-03-20-.03. For the purposes of this condition, "emergency" shall be substituted

for "malfunction(s)" in rule 1200-03-20-.03 to determine the relevant notification threshold. The notice shall include

a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken.

(b) In any enforcement proceeding the permittee seeking to establish the occurrence of an emergency has the burden of

proof.

(c) The provisions of this condition are in addition to any emergency, malfunction or upset requirement

contained in Division 1200-03 or other applicable requirement.

TAPCR 1200-03-09-.02(11)(e)7

B8. Excess emissions reporting.

(a) The permittee shall promptly notify the Technical Secretary when any emission source, air pollution control

equipment, or related facility breaks down in such a manner to cause the emission of air contaminants in excess of the

applicable emission standards contained in Division 1200-03 or any permit issued thereto, or of sufficient duration to cause

damage to property or public health. The permittee must provide the Technical Secretary with a statement giving all

pertinent facts, including the estimated duration of the breakdown. Violations of the visible emission standard which occur

for less than 20 minutes in one day (midnight to midnight) need not be reported. Prompt notification will be within 24 hours

of the malfunction and shall be provided by telephone to the Division's Nashville office. The Technical Secretary shall be

notified when the condition causing the failure or breakdown has been corrected. In attainment and unclassified areas if

emissions other than from sources designated as significantly impacting on a nonattainment area in excess of the standards


8

will not and do not occur over more than a 24-hour period (or will not recur over more than a 24-hour period) and no damage

to property and or public health is anticipated, notification is not required.

(b) Any malfunction that creates an imminent hazard to health must be reported by telephone immediately to the

Division's Nashville office at (615) 532-0554 and to the State Civil Defense.

(c) A log of all malfunctions, startups, and shutdowns resulting in emissions in excess of the standards in Division

1200-03 or any permit issued thereto must be kept at the plant. All information shall be entered in the log no later than

twenty-four (24) hours after the startup or shutdown is complete, or the malfunction has ceased or has been corrected. Any later

discovered corrections can be added in the log as footnotes with the reason given for the change. This log must record at least

the following:

1. Stack or emission point involved

2. Time malfunction, startup, or shutdown began and/or when first noticed

3. Type of malfunction and/or reason for shutdown

4. Time startup or shutdown was complete or time the air contaminant source returned to normal operation

5. The company employee making entry on the log must sign, date, and indicate the time of each log entry

The information under items 1. and 2. must be entered into the log by the end of the shift during which the malfunction

or startup began. For any source utilizing continuous emission(s) monitoring, continuous emission(s) monitoring collection

satisfies the above log keeping requirement.

TAPCR 1200-03-20-.03 and .04

B9. Malfunctions, startups and shutdowns - reasonable measures required. The permittee must take all reasonable

measures to keep emissions to a minimum during startups, shutdowns, and malfunctions. These measures may include

installation and use of alternate control systems, changes in operating methods or procedures, cessation of operation until the

process equipment and/or air pollution control equipment is repaired, maintaining sufficient spare parts, use of overtime labor,

use of outside consultants and contractors, and other appropriate means. Failures that are caused by poor maintenance, careless

operation or any other preventable upset condition or preventable equipment breakdown shall not be considered malfunctions.

This provision does not apply to standards found in 40 CFR, Parts 60(Standards of performance for new stationary sources),

61(National emission standards for hazardous air pollutants) and 63(National emission standards for hazardous air pollutants for

source categories).

TAPCR 1200-03-20-.02

B10. Reserved.

B11. Report required upon the issuance of a notice of violation for excess emissions. The permittee must submit within

twenty (20) days after receipt of the notice of violation, the data required below. If this data has previously been available to the

Technical Secretary prior to the issuance of the notice of violation no further action is required of the violating source.

However, if the source desires to submit additional information, then this must be submitted within the same twenty (20) day

time period. The minimum data requirements are:

(a) The identity of the stack and/or other emission point where the excess emission(s) occurred;

(b) The magnitude of the excess emissions expressed in pounds per hour and the units of the applicable emission limitation

and the operating data and calculations used in determining the magnitude of the excess emissions;

(c) The time and duration of the emissions;

(d) The nature and cause of such emissions;

(e) For malfunctions, the steps taken to correct the situation and the action taken or planned to prevent the recurrence of

such malfunctions;

(f) The steps taken to limit the excess emissions during the occurrence reported, and

(g) If applicable, documentation that the air pollution control equipment, process equipment, or processes were at all times

maintained and operated in a manner consistent with good operating practices for minimizing emissions.

Failure to submit the required report within the twenty (20) day period specified shall preclude the admissibility of the

data for determination of potential enforcement action.

TAPCR 1200-03-20-.06(2), (3) and (4)


9

SECTION C

PERMIT CHANGES

C1. Operational flexibility changes. The source may make operational flexibility changes that are not addressed or prohibited by

the permit without a permit revision subject to the following requirements:

(a) The change cannot be subject to a requirement of Title IV of the Federal Act or Chapter 1200-03-30.

(b) The change cannot be a modification under any provision of Title I of the federal Act or Division 1200-03.

(c) Each change shall meet all applicable requirements and shall not violate any existing permit term or condition.

(d) The source must provide contemporaneous written notice to the Technical Secretary and EPA of each such change,

except for changes that are below the threshold of levels that are specified in Rule 1200-03-09-.04.

(e) Each change shall be described in the notice including the date, any change in emissions, pollutants emitted, and any

applicable requirements that would apply as a result of the change.

(f) The change shall not qualify for a permit shield under the provisions of part 1200-03-09-.02(11)(e)6.

(g) The permittee shall keep a record describing the changes made at the source that result in emissions of a regulated air

pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from

those changes. The records shall be retained until the changes are incorporated into subsequently issued permits.

TAPCR 1200-03-09-.02(11)(a)4 (ii)

C2. Section 502(b)(10) changes.

(a) The permittee can make certain changes without requiring a permit revision, if the changes are not modifications under

Title I of the Federal Act or Division 1200-03 and the changes do not exceed the emissions allowable under the permit. The

permittee must, however, provide the Administrator and Technical Secretary with written notification within a minimum of 7

days in advance of the proposed changes. The Technical Secretary may waive the 7 day advance notice in instances where the

source demonstrates in writing that an emergency necessitates the change. Emergency shall be demonstrated by the criteria of

TAPCR 1200-03-09-.02(11)(e)7 and in no way shall it include changes solely to take advantages of an unforeseen business

opportunity. The Technical Secretary and EPA shall attach each such notice to their copy of the relevant permit.

(b) The written notification must be signed by a facility Title V responsible official and include the following:

1. a brief description of the change within the permitted facility;

2. the date on which the change will occur;

3. a declaration and quantification of any change in emissions;

4. a declaration of any permit term or condition that is no longer applicable as a result of the change; and

5. a declaration that the requested change is not a Title I modification and will not exceed allowable emissions

under the permit.

(c) The permit shield provisions of TAPCR 1200-03-09-.02(11)(e)6 shall not apply to Section 502(b)(10) changes.

TAPCR 1200-03-09-.02(11)(a)4 (i)

C3. Administrative amendment.

(a) Administrative permit amendments to this permit shall be in accordance with 1200-03-09-.02(11)(f)4. The source may

implement the changes addressed in the request for an administrative amendment immediately upon submittal of the request.

(b) The permit shield shall be extended as part of an administrative permit amendment revision consistent with the

provisions of TAPCR 1200-03-09-.02(11)(e)6 for such revisions made pursuant to item (c) of this condition which meet the

relevant requirements of TAPCR 1200-03-09-.02(11)(e), TAPCR 1200-03-09-.02(11)(f) and TAPCR 1200-03-09-.02(11)(g) for

significant permit modifications.

(c) Proceedings to review and grant administrative permit amendments shall be limited to only those parts of the permit for

which cause to amend exists, and not the entire permit.

TAPCR 1200-03-09-.02(11)(f)4


10

C4. Minor permit modifications.

(a) The permittee may submit an application for a minor permit modification in accordance with TAPCR 1200-03-09-

.02(11)(f)5(ii).

(b) The permittee may make the change proposed in its minor permit modification immediately after an application is filed

with the Technical Secretary.

(c) Proceedings to review and modify permits shall be limited to only those parts of the permit for which cause to modify

exists, and not the entire permit.

(d) Minor permit modifications do not qualify for a permit shield.

TAPCR 1200-03-09-.02(11)(f)5(ii)

C5. Significant permit modifications.

(a) The permittee may submit an application for a significant modification in accordance with TAPCR 1200-03-09-

.02(11)(f)5(iv).

(b) Proceedings to review and modify permits shall be limited to only those parts of the permit for which cause to modify

exists, and not the entire permit.

TAPCR 1200-03-09-.02(11)(f)5(iv)

C6. New construction or modifications.

Future construction at this facility that is subject to the provisions of TAPCR 1200-03-09-.01 shall be governed by the

following:

(a) The permittee shall designate in their construction permit application the route that they desire to follow for the

purposes of incorporating the newly constructed or modified sources into their existing operating permit. The Technical

Secretary shall use that information to prepare the operating permit application submittal deadlines in their construction permit.

(b) Sources desiring the permit shield shall choose the administrative amendment route of TAPCR 1200-03-09-.02(11)(f)4

or the significant modification route of TAPCR 1200-03-09-.02(11)(f)5(iv).

(c) Sources desiring expediency instead of the permit shield shall choose the minor permit modification procedure route of

TAPCR 1200-03-09-.02(11)(f)5(ii) or group processing of minor modifications under the provisions of TAPCR 1200-03-09-

.02(11)(f)5(iii) as applicable to the magnitude of their construction.

TAPCR 1200-03-09-.02(11)(d) 1(i)(V)


11

SECTION D

GENERAL APPLICABLE REQUIREMENTS

D1. Visible emissions. With the exception of air emission sources exempt from the requirements of TAPCR

Chapter 1200-03-05 and air emission sources for which a different opacity standard is specifically provided elsewhere in this

permit, the permittee shall not cause, suffer, allow or permit discharge of a visible emission from any air contaminant source

with an opacity in excess of twenty (20) percent for an aggregate of more than five (5) minutes in any one (1)hour or more than

twenty (20) minutes in any twenty-four (24) hour period; provided, however, that for fuel burning installations with fuel burning

equipment of input capacity greater than 600 million btu per hour, the permittee shall not cause, suffer, allow, or permit

discharge of a visible emission from any fuel burning installation with an opacity in excess of twenty (20) percent (6-minute

average) except for one six minute period per one (1) hour of not more than forty (40) percent opacity. Sources constructed or

modified after July 7, 1992 shall utilize 6-minute averaging.

Consistent with the requirements of TAPCR Chapter 1200-03-20, due allowance may be made for visible emissions in

excess of that permitted under TAPCR 1200-03-05 which are necessary or unavoidable due to routine startup and shutdown

conditions. The facility shall maintain a continuous, current log of all excess visible emissions showing the time at which such

conditions began and ended and that such record shall be available to the Technical Secretary or an authorized representative

upon request.

TAPCR 1200-03-05-.01(1), TAPCR 1200-03-05-.03(6) and TAPCR 1200-03-05-.02(1)

D2. General provisions and applicability for non-process gaseous emissions. Any person constructing or otherwise

establishing a non-portable air contaminant source emitting gaseous air contaminants after April 3, 1972, or relocating an air

contaminant source more than 1.0 km from the previous position after November 6, 1988, shall install and utilize the best

equipment and technology currently available for controlling such gaseous emissions.

TAPCR 1200-03-06-.03(2)

D3. Non-process emission standards. The permittee shall not cause, suffer, allow, or permit particulate emissions from non-

process sources in excess of the standards in TAPCR 1200-03-06.

D4. General provisions and applicability for process gaseous emissions. Any person constructing or otherwise establishing an

air contaminant source emitting gaseous air contaminants after April 3, 1972, or relocating an air contaminant source more than

1.0 km from the previous position after November 6, 1988, shall install and utilize equipment and technology which is deemed

reasonable and proper by the Technical Secretary.

TAPCR 1200-03-07-.07(2)

D5. Particulate emissions from process emission sources. The permittee shall not cause, suffer, allow, or permit

particulate emissions from process sources in excess of the standards in TAPCR 1200-03-07.

D6. Sulfur dioxide emission standards. The permittee shall not cause, suffer, allow, or permit Sulfur dioxide emissions from

process and non-process sources in excess of the standards in TAPCR 1200-03-14. Regardless of the specific emission standard,

new process sources shall utilize the best available control technology as deemed appropriate by the Technical Secretary of the

Tennessee Air Pollution Control Board.

D7. Fugitive Dust.

(a) The permittee shall not cause, suffer, allow, or permit any materials to be handled, transported, or stored; or a building,

its appurtenances, or a road to be used, constructed, altered, repaired, or demolished without taking reasonable precautions to

prevent particulate matter from becoming airborne. Such reasonable precautions shall include, but not be limited to, the

following:

1. Use, where possible, of water or chemicals for control of dust in demolition of existing buildings or

structures, construction operations, grading of roads, or the clearing of land;

2. Application of asphalt, water, or suitable chemicals on dirt roads, material stock piles, and other surfaces

which can create airborne dusts;


12

3. Installation and use of hoods, fans, and fabric filters to enclose and vent the handling of dusty materials.

Adequate containment methods shall be employed during sandblasting or other similar operations.

(b) The permittee shall not cause, suffer, allow, or permit fugitive dust to be emitted in such manner to exceed five (5)

minutes per hour or twenty (20) minutes per day as to produce a visible emission beyond the property line of the property on

which the emission originates, excluding malfunction of equipment as provided in Chapter 1200-03-20.

TAPCR 1200-03-08

D8. Open burning. The permittee shall comply with the TAPCR 1200-03-04 for all open burning activities at the facility.

TAPCR 1200-03-04

D9. Asbestos. Where applicable, the permittee shall comply with the requirements of TAPCR 1200-03-11-.02(2)(d) when

conducting any renovation or demolition activities at the facility.

TAPCR 1200-03-11-.02(2)(d) and 40 CFR, Part 61

D10. Annual certification of compliance. The generally applicable requirements set forth in Section D of this permit are

intended to apply to activities and sources that are not subject to source-specific applicable requirements contained in State of

Tennessee and U.S. EPA regulations. By annual certification of compliance, the permittee shall be considered to meet the

monitoring and related record keeping and reporting requirements of TAPCR 1200-03-09-.02(11)(e)1.(iii) and 1200-03-10-

.04(2)(b)1 and compliance requirements of TAPCR 1200-03-09-.02(11)(e)3.(i). The permittee shall submit compliance

certification for these conditions annually.

D11. Emission Standards for Hazardous Air Pollutants. When applicable, the permittee shall comply with the TAPCR 0400-30-

38 for all emission sources subject to a requirement contained therein.

TAPCR 0400-30-38

D12. Standards of Performance for New Stationary Sources. When applicable, the permittee shall comply with the TAPCR

0400-30-39 for all emission sources subject to a requirement contained therein.

TAPCR 0400-30-39

D13. Gasoline Dispensing Facilities. When applicable, the permittee shall comply with the TAPCR 1200-03-18-.24 for all

emission sources subject to a requirement contained therein.

D14. Internal Combustion Engines.

(a) All stationary reciprocating internal combustion engines, including engines deemed insignificant activities and insignificant

emission units, shall comply with the applicable provisions of TAPCR 0400-30-38-.01.

(b) All stationary compression ignition internal combustion engines, including engines deemed insignificant activities and

insignificant emission units, shall comply with the applicable provisions of TAPCR 0400-30-39-.01.

(c) All stationary spark ignition internal combustion engines, including engines deemed insignificant activities and insignificant

emission units, shall comply with the applicable provisions of TAPCR 0400-30-39-.02.

TAPCR 0400-30-38 and 39


13

SECTION E

SOURCE SPECIFIC EMISSION STANDARDS, OPERATING LIMITATIONS, and

MONITORING, RECORDKEEPING and REPORTING REQUIREMENTS

54-0174 Facility Description:

Grey and Ductile Iron Foundry - Includes Mold Cooling, Cast Handling, Finishing,

Sand System, Preparation, Spent Dust Handling, Core Sand Handling, Core Curing, Air

Make-Up, Miscellaneous Natural Gas Usage, Iron Melting, Ductile Iron Treatment and

Desulfurization, Phenolic-urethane Core Making, and Waste Sand and Metal Recovery.

E1. Fee Payment:

FEE EMISSIONS SUMMARY TABLE FOR MAJOR SOURCE 54-0174

REGULATED POLLUTANTS

ALLOWABLE

EMISSIONS

(tons per AAP)

ACTUAL

EMISSIONS

(tons per AAP)

COMMENTS

PARTICULATE MATTER (PM)

301.75

AEAR Includes all fee emissions.

PM10 N/A N/A N/A

SO2 96.79


VOC

365.47 AEAR Includes all fee emissions.

NOX 200.58


CATEGORY OF MISCELLANEOUS HAZARDOUS AIR POLLUTANTS (HAP WITHOUT A STANDARD)*

VOC FAMILY GROUP N/A N/A Fee emissions are included in VOC above.

NON-VOC GASEOUS GROUP N/A N/A N/A

PM FAMILY GROUP N/A N/A Fee emissions are included in PM above.

CATEGORY OF SPECIFIC HAZARDOUS AIR POLLUTANTS (HAP WITH A STANDARD)**

VOC FAMILY GROUP N/A N/A NESHAP 40 CFR Part 63 Subpart EEEEE.

Fee emissions are included in VOC above.

NON-VOC GASEOUS GROUP N/A N/A N/A

PM FAMILY GROUP (Lead)

N/A N/A NESHAP 40 CFR Part 63 Subpart EEEEE

Fee emissions are included in PM above.

CATEGORY OF NSPS POLLUTANTS NOT LISTED ABOVE***

EACH NSPS POLLUTANT

NOT LISTED ABOVE

N/A N/A N/A

NOTES

AAP The Annual Accounting Period (AAP) is a 12 consecutive month period that either (a) begins each July 1st and

ends June 30th of the following year when fees are paid on a fiscal year basis, or (b) begins January 1st and

ends December 31st of the same year when paying on a calendar year basis. The Annual Accounting Period at

the time of permit renewal issuance began July 1, 2019 and ends June 30, 2020. The next Annual Accounting

Period begins July 1, 2020 and ends June 30, 2021 unless a request to change the annual accounting period is


14

submitted by the responsible official as required by subparagraph 1200-03-26-.02(9)(b) and approved by the

Technical Secretary. If the permittee wishes to revise their annual accounting period or their annual emission fee

basis as allowed by subparagraph 1200-03-26-.02(9)(b), the responsible official must submit the request to the

Division in writing on or before December 31 of the annual accounting period for which the fee is due. If a change

in fee basis from allowable emissions to actual emissions for any pollutant is requested, the request from the

responsible official must include the methods that will be used to determine actual emissions. Changes in fee bases

must be made using the Title V Fee Selection form, form number APC 36 (CN-1583), included as an attachment to

this permit and available on the Division of Air Pollution Control’s website.

N/A N/A indicates that no emissions are specified for fee computation.

AEAR If the permittee is paying annual emission fees on an actual emissions basis, AEAR indicates that an Actual Emissions

Analysis is Required to determine the actual emissions of:

(1) each regulated pollutant (Particulate matter, SO2, VOC, NOX and so forth. See TAPCR 1200-03-

26-.02(2)(i) for the definition of a regulated pollutant.),

(2) each pollutant group (VOC Family, Non-VOC Gaseous, and Particulate Family),

(3) the Miscellaneous HAP Category,

(4) the Specific HAP Category, and

(5) the NSPS Category

under consideration during the Annual Accounting Period.

* Category Of Miscellaneous HAP (HAP Without A Standard): This category is made-up of hazardous air

pollutants that do not have a federal or state standard. Each HAP is classified into one of three groups, the VOC

Family group, the Non-VOC Gaseous group, or the Particulate (PM) Family group. For fee computation, the

Miscellaneous HAP Category is subject to the 4,000 ton cap provisions of subparagraph 1200-03-26-.02(2)(i).

** Category Of Specific HAP (HAP With A Standard): This category is made-up of hazardous air pollutants

(HAP) that are subject to Federally promulgated Hazardous Air Pollutant Standards that can be imposed under Chapter

1200-03-11 or Chapter 1200-03-31. Each individual hazardous air pollutant is classified into one of three groups, the

VOC Family group, the Non-VOC Gaseous group, or the Particulate (PM) Family group. For fee computation,

each individual hazardous air pollutant of the Specific HAP Category is subject to the 4,000 ton cap provisions of

subparagraph 1200-03-26-.02(2)(I).

*** Category Of NSPS Pollutants Not Listed Above: This category is made-up of each New Source Performance

Standard (NSPS) pollutant whose emissions are not included in the PM, SO2, VOC or NOX emissions from each

source in this permit. For fee computation, each NSPS pollutant not listed above is subject to the 4,000 ton cap

provisions of subparagraph 1200-03-26-.02(2)(i).

END NOTES

The permittee shall: (1) Pay Title V annual emission fees, on the emissions and year bases requested by the

responsible official and approved by the Technical Secretary, for each annual accounting

period (AAP) by the payment deadline(s) established in TAPCR 1200-03-26-.02(9)(g).

Fees may be paid on an actual, allowable, or mixed emissions basis; and on either a

state fiscal year or a calendar year, provided the requirements of TAPCR 1200-03-26-

.02(9)(b) are met. If any part of any fee imposed under TAPCR 1200-03-26-.02 is not

paid within 15 days of the due date, penalties shall at once accrue as specified in TAPCR

1200-03-26-.02(8).

(2) Sources paying annual emissions fees on an allowable emissions basis: pay annual

allowable based emission fees for each annual accounting period no later than April 1 of

each year pursuant to TAPCR 1200-03-26-.02(9)(d).

(3) Sources paying annual emissions fees on an actual emissions basis: prepare an actual

emissions analysis for each AAP and pay actual based emission fees pursuant to

TAPCR 1200-03-26-.02(9)(d). The actual emissions analysis shall include:

(a) the completed Fee Emissions Summary Table,


15

(b) each actual emissions analysis required, and

(c) the actual emission records for each pollutant and each source as required for actual

emission fee determination, or a summary of the actual emission records required for

fee determination, as specified by the Technical Secretary or the Technical

Secretary’s representative. The summary must include sufficient information for the

Technical Secretary to determine the accuracy of the calculations. These calculations

must be based on the annual fee basis approved by the Technical Secretary (a state

fiscal year [July 1 through June 30] or a calendar year [January 1 through December

31]). These records shall be used to complete the actual emissions analyses required

by the above Fee Emissions Summary Table.

(4) Sources paying annual emissions fees on a mixed emissions basis: for all pollutants and

all sources for which the permittee has chosen an actual emissions basis, prepare an

actual emissions analysis for each AAP and pay actual based emission fees pursuant to

TAPCR 1200-03-26-.02(9)(d). The actual emissions analysis shall include:

(a) the completed Fee Emissions Summary Table,

(b) each actual emissions analysis required, and

(c) the actual emission records for each pollutant and each source as required for actual

emission fee determination, or a summary of the actual emission records required for

fee determination, as specified by the Technical Secretary or the Technical

Secretary’s representative. The summary must include sufficient information for the

Technical Secretary to determine the accuracy of the calculations. These calculations

must be based on the fee bases approved by the Technical Secretary (payment on an

actual or mixed emissions basis) and payment on a state fiscal year (July 1 through

June 30) or a calendar year (January 1 through December 31). These records shall be

used to complete the actual emissions analysis.

For all pollutants and all sources for which the permittee has chosen an allowable

emissions basis, pay allowable based emission fees pursuant to TAPCR 1200-03-26-

.02(9)(d).

(5) When paying on an actual or mixed emissions basis, submit the actual emissions

analyses at the time the fees are paid in full.

The annual emission fee due dates are specified in TAPCR 1200-03-26-.02(9)(g) and are dependent on the Responsible Official’s

choice of fee bases as described above. If any part of any fee imposed under TAPCR 1200-03-26-.02 is not paid within 15 days of the

due date, penalties shall at once accrue as specified in TAPCR 1200-03-26-.02(8). Emissions for regulated pollutants shall not be

double counted as specified in Condition A8(d) of this permit.

Payment of the fee due and the actual emissions analysis (if required) shall be submitted to The Technical Secretary at the

following address:

Payment of Fee to: Actual Emissions Analyses to:

The Tennessee Department of Environment and

Conservation

Division of Fiscal Services

Consolidated Fee Section – APC

William R. Snodgrass Tennessee Tower

312 Rosa L. Parks Avenue, 10th Floor

Nashville, Tennessee 37243

and The Tennessee Department of

Environment and Conservation


Emission Inventory Program

William R. Snodgrass Tennessee Tower

312 Rosa L. Parks Avenue, 15th Floor

Nashville, Tennessee 37243

or

An electronic copy (PDF) of actual emissions analysis can also

be submitted to: [email protected]



16

E2. Reporting Requirements

(a) Semiannual reports. Semiannual reports shall cover the six-month periods from April 1 through September 30 of each

calendar year and October 1 of each calendar year through March 31 of the following calendar year and shall be submitted

within 60 days after the end of each six-month period. Subsequent reports shall be submitted within 60 days after the end of

each six-month period following the first report. The first semiannual report following issuance of this permit shall cover the

following permits and reporting periods:

Permit Number Reporting Period Begins Reporting Period Ends

555968 April 1, 2020 TBD (day before new permit issuance (with year))

573114 TBD (Issuance Date of new permit (with year)) September 30, 2020

These semiannual reports shall include:

(1) Any monitoring and recordkeeping required by Conditions E5-1, E5-2, E5-4, E5-5, E5-6, E5-7, E6-1, E6-

2, E7-1, E7-2, E8-1, E8-2, E9-1, E10-1, E11-1, E11-2, E11-4, E11-6, E11-8, E11-9, E12-1, E12-3, E13-

1, E13-2, and E15-2(b) of this permit. However, a summary report of this data is acceptable provided

there is sufficient information to enable the Technical Secretary to evaluate compliance.

(2) The visible emission evaluation readings from Conditions E3-2, E3-4 and E15-2(c) of this permit if

required. However, a summary report of this data is acceptable provided there is sufficient information to

enable the Technical Secretary to evaluate compliance.

(3) Identification of all instances of deviations from ALL PERMIT REQUIREMENTS.

These reports must be certified by a responsible official consistent with condition B4 of this permit and shall be

submitted to The Technical Secretary at the address in Condition E2(b) of this permit.

TAPCR 1200-03-09-.02(11)(e)1.(iii)

(b) . Annual compliance certification. The permittee shall submit annually compliance certifications with terms and conditions

contained in Sections A, B, D and E of this permit, including emission limitations, standards, or work practices. This

compliance certification shall include all of the following (provided that the identification of applicable information may

cross-reference the permit or previous reports, as applicable):

(a) The identification of each term or condition of the permit that is the basis of the certification;

(b) The identification of the method(s) or other means used by the owner or operator for determining the compliance

status with each term and condition during the certification period; such methods and other means shall include, at a

minimum, the methods and means required by this permit. If necessary, the owner or operator also shall identify any other

material information that must be included in the certification to comply with section 113(c)(2) of the Federal Act, which

prohibits knowingly making a false certification or omitting material information;

(c) The status of compliance with the terms and conditions of the permit for the period covered by the certification,

including whether compliance during the period was continuous or intermittent. The certification shall be based on the

method or means designated in B5(b) above. The certification shall identify each deviation and take it into account in the

compliance certification. The certification shall also identify as possible exceptions to compliance any periods during which

compliance is required and in which an excursion* or exceedance** as defined below occurred; and

(d) Such other facts as the Technical Secretary may require to determine the compliance status of the source.

* “Excursion” shall mean a departure from an indicator range established for monitoring under this paragraph, consistent

with any averaging period specified for averaging the results of the monitoring.

** “Exceedance” shall mean a condition that is detected by monitoring that provides data in terms of an emission limitation

or standard and that indicates that emissions (or opacity) are greater than the applicable emission limitation or standard (or

less than the applicable standard in the case of a percent reduction requirement) consistent with any averaging period

specified for averaging the results of the monitoring.



17

Annual compliance certifications shall cover the 12-month period from October 1 of each calendar year to September 30 of

the following calendar year and shall be submitted within 60 days after the end of each 12-month period. The first annual

compliance certification following issuance of this permit shall cover the following permits and reporting periods:


555968 October 1, 2019 TBD (day before new permit issuance (with year))

573114 TBD (Issuance Date of new permit (with year))

September 30, 2020

These certifications shall be submitted to: TN APCD and EPA


Chattanooga Environmental Field Office

1301 Riverfront Parkway, Suite 206

Chattanooga, TN 37402

or

via Email Address:

Adobe Portable Document Format (PDF)

Copy to: [email protected]

and Air Enforcement Branch US EPA Region IV


Atlanta, Georgia 30303


TAPCR 1200-03-09-.02(11)(e)3.(v)

(c) MACT Reporting Requirements

Semiannual reports required by 40 CFR 63 Subpart §63.7751(a): Semiannual reports shall cover the six-month periods from April 1 through September 30 of each calendar year and October 1 of each calendar year through March 31 of the following calendar year and shall be submitted within 60 days after the end of each six-month period. Subsequent reports shall be submitted within 60 days after the end of each six-month period following the first report. The first semiannual report following issuance of this permit shall cover the following permits and reporting periods:


555968 April 1, 2020 TBD (day before new permit issuance (with year))

573114 TBD (Issuance Date of new permit (with year)) September 30, 2020

These reports must be certified by a responsible official consistent with Condition B4 of this permit and shall be

submitted to The Technical Secretary and US EPA Region IV at the addresses as indicated below:

TN Department of Environment & Conservation


William R. Snodgrass Tennessee Tower Or via e-mail at Adobe Portable Document Format (PDF)

15th Floor [email protected]

312 Rosa L. Parks Avenue

Nashville, TN 37243

And

Air Enforcement Branch

US EPA Region IV





18

Atlanta, GA 30303

TAPCR 1200-03-09-.02(11)(e)1.(iii)

Note that each MACT Report, Title V Semiannual Report (SAR) and each Title V Annual Compliance

Certification (ACC) must be submitted under separate cover and each report must be accompanied by a

separate compliance certification statement.

(d) Retention of Records All records required by any condition in Section E of this permit must be retained for a period of not

less than five years. Additionally, these records shall be kept available for inspection by the Technical Secretary or an authorized

representative.

TAPCR 1200-03-09-.02(11)(e)1.(iii)(II)II

E3. General Permit Requirements

Unless otherwise specified, the following Conditions shall apply to all sources in section E of this permit.

E3-1. Identification of Responsible Official, Technical Contact, and Billing Contact of the permitted facility:

a) The application that was utilized in the preparation of this permit is dated December 11, 2018, and signed by Kenley

Hansen, Plant 6 Manager, who is the Responsible Official of the permitted facility. Additional information and permit

applications that were utilized in the preparation of this permit are dated November 20, 2017, December 12, 2017, December

20, 2017, February 9, 2018, and May 28, 2019. If this person terminates employment or is assigned different duties and is no

longer a Responsible Official for this facility as defined in part 1200-03-09-.02(11)(b)21 of the Tennessee Air Pollution

Control Regulations, the owner or operator of this air contaminant source shall notify the Technical Secretary of the change.

Said notification must be in writing and must be submitted within 30 days of the change. The notification shall include the

name and title of the new Responsible Official and certification of truth and accuracy. All representations, agreement to terms

and conditions, and covenants made by the former Responsible Official that were used in the establishment of the permit

terms and conditions will continue to be binding on the facility until such time that a revision to this permit is obtained that

would change said representations, agreements, and/or covenants.

b) The application that was utilized in the preparation of this permit is dated December 11, 2018, and identifies Bryant Esch,

Director of Environmental Engineering, as the Principal Technical Contact for the permitted facility. If this person terminates

employment or is assigned different duties and is no longer the Principal Technical Contact for this facility, the owner or

operator of this air contaminant source shall notify the Technical Secretary of the change. Said notification must be in writing

and must be submitted within 30 days of the change. The notification shall include the name and title of the new Principal

Technical Contact and certification of truth and accuracy.

c) The application that was utilized in the preparation of this permit is dated December 11, 2018, and identifies Bryant Esch,

Director of Environmental Engineering, as the Billing Contact for the permitted facility. If this person terminates

employment or is assigned different duties and is no longer the Billing Contact for this facility, the owner or operator of this

air contaminant source shall notify the Technical Secretary of the change. Said notification must be in writing and must be

submitted within 30 days of the change. The notification shall include the name and title of the new Billing Contact and

certification of truth and accuracy.

TAPCR 1200-03-09-.03(8);

E3-2. Visible emissions from the sources at this facility unless otherwise noted (including stacks, building openings, doorways,

windows, vents, etc.) shall not exhibit greater than 10% opacity as determined by EPA Method 9, as published in the current

40 CFR 60, Appendix A (6 minute average). TAPCR 1200-03-05-.03(6) and TAPCR 1200-03-05-.01(1).

PSD Requirement, TAPCR 1200-03-09-.01(4). Note that this opacity condition is more stringent than the provisions of

the MACT opacity requirement found at 40 CFR 63.7690(a)(7) – Opacity Restriction, and therefore supersedes the

MACT requirement.


19

Compliance Method: The permittee shall assure compliance with the opacity standard by utilizing the opacity matrix dated

June 18, 1996 and amended September 11, 2013 that is enclosed as Attachment 1.

If the magnitude and frequency of excursions reported by the permittee in the periodic monitoring for emissions is

unsatisfactory to the Technical Secretary, this permit may be reopened to impose additional opacity monitoring

requirements.

E3-3. No person shall cause, suffer, allow, or permit fugitive dust to be emitted in such manner to exceed five minutes per hour or

20 minutes per day as to produce a visible emission beyond the property line of the property on which the emission

originates, excluding malfunction of equipment as provided in Chapter 1200-03-20.

TAPCR 1200-03-08

E3-4. Visible emissions from roads and parking areas shall not exhibit greater than 10% opacity as determined by Tennessee Visible

Emission Evaluation (TVEE) Method 1, as adopted by the Tennessee Air Pollution Control Board on April 29, 1982, as

amended on September 15, 1982 and August 24, 1984. TAPCR 1200-03-08-.03.

Compliance Method: The permittee shall assure compliance with the opacity standard by utilizing the opacity matrix dated

June 18, 1996 and amended September 11, 2013 that is enclosed as Attachment 1.

If the magnitude and frequency of excursions reported by the permittee in the periodic monitoring for emissions is

unsatisfactory to the Technical Secretary, this permit may be reopened to impose additional opacity monitoring

requirements.

E3-5. Routine maintenance, as required to maintain specified emission limits, shall be performed on the air pollution control device(s).

Maintenance records shall be recorded in a suitable permanent form and kept available for inspection by the Division. These

records must be retained for a period of not less than five years.

TAPCR 1200-03-10-.02(2)(a)

E3-6. Upon the malfunction/failure of any emission control device(s) serving this source, the operation of the process(es) served by the

device(s) shall be regulated by Chapter 1200-03-20 of the Tennessee Air Pollution Control Regulations.

TAPCR 1200-03-09-.03(8)

E3-7. Reasonable precautions must be taken to prevent the generation of fugitive dust as these precautions are defined in Rule

1200-03-08-.01 of the Tennessee Air Pollution Control Regulations.

TAPCR 1200-03-09-.03(8)

E3-8. The associated air pollution control equipment shall be in place and operational during all times of source operation.

TAPCR 1200-03-09-.03(8)

E3-9. All data, including all required calculations, must be entered in the required logs no later than 30 days from the end of the

month for which the data is required. For sources required to maintain daily logs, all data, including all required calculations,

must be entered in the log no later than seven days from the end of the day for which the data is required.

TAPCR 1200-03-10-.02(2)(a)

E3-10. This source shall comply with all applicable state and federal air pollution regulations. This includes, but is not limited to, all

applicable provisions of the Tennessee Air Pollution Control Regulations federal regulations published under 40 CFR 61 and

40 CFR 63 for sources of hazardous air pollutants, and federal regulations published under 40 CFR 60, New Source

Performance Standards.


20

TAPCR 1200-03-09-.03(8)

E3-11. This source shall operate in accordance with the terms of this permit, the information submitted in the approved permit

application referenced in Condition E3-1, and any documented agreements made with the Technical Secretary.

TAPCR 1200-03-09-.02(6)

E3-12. Within 90 days of issuance of this permit the permittee shall submit a compliance assurance monitoring (CAM) plan for the

applicable sources at the facility in accordance with 40 CFR Part 64:

The plan shall be submitted to the Technical Secretary of the Division of Air Pollution Control at the address in condition

E2(c) of this permit.


21

E4. MACT Provisions

This facility is subject to all applicable requirements of 40 CFR Part 63, Subpart EEEEE - National Emission Standards

for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries as incorporated into this permit in Attachment 2

of this permit. Section 63.7710 of 40 CFR Part 63 Subpart EEEEE establishes requirements to demonstrate initial and

continuous compliance with the emissions limitations, work practice standards, and operation and maintenance procedures.

This requirement is incorporated into this permit as Attachment 3. The final rule for 40 CFR Subpart EEEEE was published

in the Federal Register on April 22, 2004. This includes, but is not limited to the following:

(a) Per 40 CFR §63.7710(a), as required by 40 CFR §63.6(e)(1)(i), you must always operate and maintain your iron and steel

foundry, including air pollution control and monitoring equipment, in a manner consistent with good air pollution control

practices for minimizing emissions at least to the levels required by 40 CFR Part 63 Subpart EEEEE.

(b) You must prepare and operate at all times according to a written operation and maintenance plan for each capture and

collection system and control device for an emissions source subject to a particulate matter (PM), metal hazardous air

pollutant (HAP), triethylamine (TEA), or volatile organic hazardous air pollutant (VOHAP) emissions limit in 40 CFR

§63.7690(a). Your operation and maintenance plan also must include procedures for igniting gases from mold vents in

pouring areas and pouring stations that use a sand mold system. This operation and maintenance plan is subject to approval

by the Administrator. Each plan must contain the elements described in 40 CFR §§63.7710(b)(1) through (6).

TAPCR 1200-03-09-.03(8) and 40 CFR §63.7710


22

SOURCE SPECIFIC CONDITIONS

PHASE I OPERATIONS:

54-0174-01- Phase I – EXISTING SOURCE

Phase I Casting Lines 1 (P01), 2 (P03), 3 (P05), and 4 (P07)

Emissions from Pouring Stations are Uncontrolled (fugitive), but emissions from Shakeout, Cooling and Handling

Operations are Controlled by Baghouse (as indicated below)– Exhausting to Stack S01.

Note- Each Casting Line includes Pouring, Cooling, Shakeout and Handling Operations – Pouring stations at this

facility are open to the air to allow access, are not ducted through conveyances and are therefore not subject to

§63.7690(a)(5) of the MACT standard for pouring stations. However, the mold vents of sand mold systems in each

pouring area and pouring station are subject to ignitability requirements as specified at 40 CFR §63.7710 (b)(6) and

as described in the Operation and Maintenance Plan at Attachment 3.

E5-1. This permit is valid for the following operations and control system and shall not exceed the following maximum material

throughput rates averaged over daily total operating time:

Process I.D.

Process Weight Rate

(Iron)*

Control Device(s)

Line 1 (P01)

Controlled by Baghouses

C03, C08, C09

20.0

Tons per hour

Emissions from Pouring Stations are uncontrolled

(Fugitive)

Emissions from Shakeout, Cooling and Handling

operations are Controlled by their Respective

Baghouses as indicated

All Exhaust to Stack S01

Line 2 (P03)


C03, C08, C09, C10

20.0

Tons per hour

Line 3 (P05)


C05, C10, C11

35.0

Tons per hour

Line 4 (P07)


C06, C10, C12

35.0

Tons per hour

(PSD/BACT permit

966272P -12/26/2012)

Total Limit

90.0

Tons per hour , Maximum

throughput from Cupola

TAPCR1200-03-09-.01(4); PSD permits 960724P (7/19/2007) and 966272P (12/26/2012)

* The permittee has indicated that these are nominal rated capacities, and even though the hourly throughput rate peaks may

occur, in no case will production be greater than Cupola melt capacity of 90 tons per hour, daily average basis.

90 Tons per hour x 24 hours per day = maximum 2,160 tons per day.


23

Compliance Method: A log of production on an average daily basis, in a form that readily assures compliance with this

Condition (E5-1), must be maintained at the source location and kept available for inspection by the Technical Secretary or

an authorized representative. This log must be retained for a period of not less than five years. The production records must

be maintained for each line. All data shall be recorded in accordance with condition E3-9.

E5-2. Total particulate matter (PM) emitted from this source shall not exceed the following limits in grains per dry standard cubic

feet and in pounds per hour on a three-hour average basis.

Casting Line I.D.

LIMITATION(S) PM Emissions

lbs/hr (3-hour average)

Applicable Rule

Line 1(P01)

0.005 gr/dscf*

8.8

1200-03-09-.01(4)

BACT

Line 2 (P03)

0.005 gr/dscf

8.6

1200-03-09-.01(4)

BACT

Line 3 (P05)

0.005 gr/dscf

8.9

1200-03-09-.01(4)

BACT

Line 4 (P07)

0.005 gr/dscf

8.9

1200-03-09-.01(4)

BACT

* gr/dscf refers to grains per dry standard cubic foot - TAPCR 1200-03-09-.01(4); PSD permit 951431P (9/24/2001)

Compliance Method: Compliance with this requirement shall be assured by maintaining a minimum pressure drop of 0.5

inches of water across each baghouse. The pressure drop for the baghouses shall be recorded once daily when the source is in

operation. The days when the source does not operate shall be noted. For lower pressure drop reading(s) resulting from

replacement of bags, the permittee shall record the deviation(s) as such in their daily records. Due allowance will be made

for lower pressure drop reading(s) which follow replacement of bags provided the permittee establishes to the satisfaction of

the Technical Secretary that these lower readings resulted from the replacement of bags. A record of the daily pressure drop

readings including above- mentioned information must be reported in accordance with condition E2 of this permit. All data

shall be recorded in accordance with condition E3-9.

E5-3. Lead (Pb) emitted from this source shall not exceed the following limits in pounds per hour on a three-hour average

basis. TAPCR 1200-03-09-.01(4); PSD permit 951431P (9/24/2001)

Casting Line I.D.

Lead Emissions

Lbs/hr (3-hour average)

Line 1 (P01)

0.0027

Line 2 (P03)

0.0027

Line 3 (P05)

0.0028

Line 4 (P07)

0.0028

Compliance Method: Compliance with condition E5-2 shall be deemed compliance with Condition E5-3.


24

E5-4. Volatile Organic Compounds (VOC) emitted from this source shall not exceed the following limits:

Casting Line I.D.

BACT Limit

1200-03-09-.01(4)

(based on 2007 PSD /BACT determination,

except for Line 4, as indicated below)

Pounds per Hour

Allowable VOC Emissions, based

on BACT limit and Maximum

Process Weight Rate from

Condition E5-1

Line 1 (P01)

0.6 pounds per ton of metal

12.0

Line 2 (P03)


12.0

Line 3 (P05)


21.0

Line 4 (P07)

0.6 pounds per ton of metal (total)

Cooling: 0.5 pounds per ton of metal

Shakeout: 0.1 pounds per ton of metal

(PSD/BACT permit 966272P - 12/26/2012)

21.0 pounds per hour (total)

Cooling: 17.5 pounds per hour

Shakeout: 3.5 pounds per hour

(PSD/BACT permit 966272P -

12/26/2012)

Total Limit

54.0 *

Daily Average Basis

(unchanged per PSD/BACT permit

966272P – 12/26/2012)

* This total emission limit for all phase 1 Casting Lines is based on the VOC pounds per ton of metal emission limit, the stated

pounds per hour emission limits for processes which do not have the pounds per ton of metal emission limit, and the Cupola

daily average production limit of 90.0 tons per hour.

TAPCR 1200-03-09-.01(4); PSD permits 960724P (7/19/2007) and 966272P (12/26/2012)

Compliance Method: Compliance is based on an emission factor of 0.6 pounds per ton for iron, the same as the uncontrolled

emission factor for other operations (0.5 lb/ton for pouring/mold cooling and 0.1 lb/ton for shakeout operation). This value is

also used as BACT allowable. Assurance of compliance must be reported in accordance with condition E2 of this permit.

Compliance is based on the above cited emission factor and compliance with the daily average maximum throughput rate of

material as specified in condition E5-1. All data shall be recorded in accordance with condition E3-9.


25

E5-5. Sulfur Dioxide (SO2) emitted from this source shall not exceed the following limits:

Casting Line I.D.

Allowable SO2 Emission

lbs/hr

(based on 2007 PSD /BACT

determination, except for Line 4, as

indicated below)

Applicable Rule

TAPCR

Line 1 (P01)

0.4

1200-03-09-.01(4)

Line 2 (P03)

0.4

1200-03-09-.01(4)

Line 3 (P05)

0.7

1200-03-09-.01(4)

Line 4 (P07)

0.70

BACT Limit 1200-03-09-.01(4)

( PSD/BACT permit 966272P –

12/26/2012))


Compliance Method: Compliance with these emission limitations is based on compliance with the process weight limits

specified in condition E5-1 and the emission factor of 0.02 pounds per ton of iron processed. Assurance of compliance must be

reported in accordance with condition of E2 of this permit.

E5-6. Nitrogen oxides (NOx) emitted from this source shall not exceed the following limits:

Casting Line I.D.

Allowable pounds per hour of NOx Emissions

(based on 2007 PSD /BACT determination,

except for Line 4, as indicated below)

Rule Citation

TAPCR

Line 1 (P01)

0.2

1200-03-09-.01(4)

Line 2 (P03)

0.2

1200-03-09-.01(4)

Line 3 (P05)

0.35

1200-03-09-.01(4)

Line 4 (P07)

0.35

(PSD/BACT permit 966272P – 12/26/2012)

BACT Limit 1200-03-09-.01(4)

(PSD/BACT permit 966272P –

12/26/2012)



26

Compliance Method: Compliance with these emission limitations is based on compliance with the process weight limits

specified in condition E5-1 and the emission factor of 0.01 pounds of NOx emissions per ton for iron. Assurance of

compliance must be reported in accordance with condition of E2 of this permit.

E5-7. Carbon Monoxide (CO) emitted from this source shall not exceed the following limits:

Casting Line

I.D.

Allowable CO Emissions, Pounds

per ton of Metal Processed (unless

otherwise noted) PSD- BACT

Limit - 1200-03-09-.01(4)

(based on 2007 PSD /BACT

determination, except for Line 4,

as indicated below)

Pounds per Hour Allowable CO Emissions, based on

BACT limit and Maximum Process Weight Limit from

Condition E5-1

Line 1 (P01)

6.0

120

Line 2 (P03)

6.0

120

Line 3 (P05)

6.0

210

Line 4

(P07)

6.0 (total)

Cooling: 5.0 pounds per ton of

metal

Shakeout: 1.0 pound per ton of

metal

(PSD/BACT permit 966272P –

12/26/2012)

210 (total)

Cooling: 175

Shakeout: 35

(PSD/BACT permit 966272P – 12/26/2012)

Total Limit

*540 Daily Average Basis

* This total emission limit for all phase 1 Casting Lines is based on the CO pounds per ton of metal emission limit, the stated

pounds per hour emission limits for processes which do not have the pounds per ton of metal emission limit, and the Cupola

daily average production limit of 90.0 tons per hour


Compliance Method: Compliance is based on compliance with the process weight limits specified in condition E5-1 and the

factor of 6.0 pounds of CO per ton of iron (5.0 pounds per ton for pouring /mold cooling and 1.0 pound per ton for shakeout). A

summary of emission calculations for assurance of compliance must be reported in accordance with condition of E2 of this

permit. All data shall be recorded in accordance with condition E3-9.

E5-8. In accordance with MACT Rule 40 CFR 63.7710(b) Operation and Maintenance Requirements the permittee must

prepare and operate at all times according to a written operation and maintenance plan. The current plan is included as

Attachment 3 of this permit. Copies of this plan when updated shall be submitted to the Division.


27

TAPCR 1200-03-09-.03(8) and 40 CFR 63.7710(b)

54-0174-02

Phase I -Sand System

Sand Preparation System including Conveying, Handling, Mulling, Screening and

Cooling Operation (P09) - Baghouses C01- C04 in Parallel, Exhausting to Stack S01

E6-1. The maximum material throughput rate for this source shall not exceed 750 tons of sand per hour in total, averaged over daily

total operating time, excluding down time.

Permit 952928P - Amended September 24, 2001

TAPCR1200-03-09-.01(4)

Compliance Method:

A log of all material used, in a form that readily assures compliance with Condition E6-1 must be maintained at the source

location and kept available for inspection by the Technical Secretary or an authorized representative. This log must be

retained for a period of not less than five years. All data shall be recorded in accordance with condition E3-9.

E6-2. Total particulate matter (PM) emitted from this source shall not exceed 0.005 grains per dry standard cubic foot of exhaust

gases (14.9 pounds per hour) on a three-hour average basis.

TAPCR1200-03-09-.01(4)


inches of water across the baghouse. The pressure drop for the baghouse shall be recorded once daily when the source is in





readings including above- mentioned information must be reported in accordance with condition of E2 of this permit. All

data shall be recorded in accordance with condition E3-9.

E6-3. Lead (Pb) emitted from this source shall not exceed 0.0047 pounds per hour on a three-hour average basis.


TAPCR1200-03-09-.01(4)

Compliance Method: Compliance with condition E6-2 will be deemed compliance with Condition E6-3.

E6-4. The exhaust gases from the control device associated with this process shall exhaust through Stack S 01.


TAPCR 1200-03-09-.01(4)


28

Compliance Method: Compliance shall be assured by meeting the requirements as described in the condition.

E6-5. Volatile Organic Compounds (VOC) emitted from this source shall not exceed the following limits:

Sand System VOC Emission Limit

Lb/hr

VOC Emission Limit

Tons per Month based on a 12 months rolling average

P09 3.08 1.12

TAPCR1200-03-09-.01(4); Permit 952928P - Amended September 24, 2001

Compliance Method: Compliance with condition E6-1 shall be deemed to indicate compliance with condition E6-5.

54-0174-03 - Phase I –Return Metal Handling (P12) - Baghouses C01- C04 in Parallel, Exhausting to Stack S01

E7-1. The maximum material throughput rate for this source shall not exceed 46 tons of metal per hour in total, averaged over daily


TAPCR 1200-03-09-.03(8); Permit 952929P - Amended September 24, 2001

Compliance Method: A log of all material used, in a form that readily assures compliance with this Condition (E7-1) must

be maintained at the source location and kept available for inspection by the Technical Secretary or an authorized

representative. This log must be retained for a period of not less than five years. All data shall be recorded in accordance

with condition E3-9.

E7-2. Total particulate matter (TSP) emitted from this source shall not exceed 0.005 grains per dry standard cubic foot of exhaust

gases and 1.5 pounds per hour on a three-hour average basis.








readings including above- mentioned information must be reported in accordance with condition E2 of this permit. All data

shall be recorded in accordance with condition E3-9.



Compliance Method: Compliance with condition E7-2 shall be deemed to indicate compliance with Condition E7-3.

E7-4. The exhaust gases from the control device associated with this process shall exhaust through Stack S01.



29


54-0174-04 Phase I –Spent Dust Handling (P13) - Baghouses C01- C04 in Parallel, Exhausting to Stack S01

E8-1. The maximum material throughput rate for this source shall not exceed 80 tons of sand per hour in total, averaged over daily



Compliance Method: A log of all material used, in a form that readily assures compliance with this Condition (E8-1), must

be maintained at the source location and kept available for inspection by the Technical Secretary or an authorized



E8-2. Total particulate matter (TSP) emitted from this source shall not exceed 0.005 grains per dry standard cubic foot of exhaust

gases and 1.0 pound per hour on a three-hour average basis.










E8-3. Lead (Pb) emitted from this source shall not exceed 0.0003 pound per hour on a three-hour average basis.



E8-4. The exhaust gases from the control device associated with this process shall exhaust through Stack S 01.



54-0174-08 - Phase I – Air Make-Up (P50)

E9-1. The maximum fuel usage rate for this source shall not exceed 0.1 million cubic feet of natural gas per hour in total, averaged

over daily total operating time, excluding down time.

TAPCR 1200-03-09-.03(8); Permit 952934P

Compliance Method: A log of fuel usage, in a form that readily demonstrates compliance with this Condition E9-1, must be

maintained at the source location and kept available for inspection by the Technical Secretary or an authorized representative.


30

This log must be retained for a period of not less than five years. All data shall be recorded in accordance with condition E3-

9.

E9-2. Only Natural gas or Propane shall be used as fuel for this source.

TAPCR 1200-03-09-.03(8); Permit 952934P

Compliance Method: The design of the fuel burning equipment used at this source limits the fuel type to natural gas or propane

only.

E9-3. The emissions from Air Make -Up (P50) shall not exceed the following limits:

Pollutant Emissions

Lb/hr

Emissions

tons per month during any

period of 12-consecutive

months rolling average

VOC 0.55 0.2

SO2 0.06 0.02

NOx 4.55 1.66

CO 5.5 2.01

TAPCR 1200-03-09-.01(4); Permit 952934P

Compliance Method: Compliance with condition E9-1 will be deemed compliance with Condition E9-3.

E9-4. The exhaust gases from this process shall exhaust through Stack S 01.

TAPCR 1200-03-09-.03(8); Permit 952934P


54-0174-09 - Phase I –Miscellaneous Natural Gas or Propane Usage (P51)

E10-1. The maximum fuel usage rate for this source shall not exceed 0.015 million cubic feet of natural gas per hour in total, averaged

over daily total operating time, excluding down time.

TAPCR 1200-03-09-.03(8); Permit 952935P

Compliance Method: A log of fuel usage, in a form that readily demonstrates compliance with this Condition E10-1 must be

maintained at the source location and kept available for inspection by the Technical Secretary or an authorized representative.

This log must be retained for a period of not less than five years. All data shall be recorded in accordance with condition E3-

9.

E10-2. Only Natural gas or Propane shall be used as fuel for this source.

TAPCR 1200-03-09-.03(8); Permit 952935P

Compliance Method: The design of the fuel burning equipment used at this source limits the fuel type to natural gas only.

E10-3. The emissions from Miscellaneous Natural Gas or Propane Usage (P51) shall not exceed the following limits:


31

Pollutant Emissions

Lb/hr

Emissionstons per month

during any period of 12-

consecutive months rolling

average

VOC 0.08 0.03

SO2 0.01 0.04

NOx 1.5 0.55

CO 1.26 0.46

These emission limitations are established pursuant to the information contained in the permit application dated July 16, 1999

from the permittee.

TAPCR1200-03-09-.01(4); Permit 952935P


E10-4. The exhaust gases from this process shall exhaust through Stack S 01.

TAPCR 1200-03-09-.03(8); Permit 952935P


54-0174-17 - Phase I - Cupola (P30)

Three Existing Low-NOx Natural Gas-Fired Burners for Thermal Incinerator for the control of the CO, & VOCs emissions- One

with 6.0 MM Btu/hr, Two with 15 MM Btu/hr, each, Total Heat Input Rate for all three Burners: 36 MM Btu/hr.Control devices:

incinerator C10A (for VOC and CO control), dry alkaline scrubber C10B (for SO2 neutralization), & baghouse C10C (for the

control of the particulate and Lead emissions), Exhausting to Stack S10.

SO2 CEMs.

E11-1. The maximum input rate of iron to the Cupola shall not exceed 90.0 tons averaged over daily total operating time, excluding

down time.

TAPCR 1200-03-09-.03(8); permit 952943P

Compliance Method: A log of the iron input rate, in a form that readily demonstrates compliance with this Condition (E11-

1), must be maintained at the source location and kept available for inspection by the Technical Secretary or an authorized



E11-2. The maximum natural gas heat input to the thermal incinerator for this source shall not exceed 36,000,000 British Thermal Units

per hour (36.0 MMBTU/hr) in total.

TAPCR 1200-03-09-.03(8); permit 958476P

Compliance Method: A log of natural gas usage, in a form that readily demonstrates compliance with this Condition (E11-

2), must be maintained at the source location and kept available for inspection by the Technical Secretary or an authorized




32

E11-3. Only natural gas shall be used as fuel for the thermal incinerator for this source.

TAPCR 1200-03-09-.03(8); permit 952943P

Compliance Method: The design of the thermal incinerator limits the type of fuel used at this source to natural gas only.

E11-4. Particulate emissions from this process must comply with the emission limits as specified at both “A” and “B” as specified in

this condition.

A) Particulate matter (TSP/PM10) emitted from this source shall not exceed 0.007 grains/dry standard cubic foot of exhaust

gases (7.2 pounds per hour).

TAPCR 1200-03-09-.01(4); permit 958476P

Compliance Method (A) : Compliance with this requirement shall be assured by maintaining a minimum pressure drop of

0.5 inches of water across the baghouse. The pressure drop for the baghouse shall be recorded once daily when the source is

in operation. The days when the source does not operate shall be noted. For lower pressure drop reading(s) resulting from






B) 40 CFR 63.7690(a)(2)

(2) For each cupola metal melting furnace at an existing iron and steel foundry, you must not discharge emissions through a

conveyance to the atmosphere that exceed either the limit for PM in 40 CFR 63.7690(a)(2)(i) or (ii) or, alternatively the limit

for total metal HAP in 40 CFR 63.7690(a)(2)(iii) or (iv):

(i) 0.006 gr/dscf of exhaust gas, for PM; or

(ii) 0.10 pound of PM per ton (lb/ton) of metal charged, or

(iii) 0.0005 gr/dscf of exhaust gas , for total metal HAP; or

(iv) 0.008 pound of total metal HAP per ton (lb/ton) of metal charged.

TAPCR1200-03-09-.03(8); 40 CFR 63.7690(a)(2)

Compliance Method (B): The baghouse controlling the cupola is required to be equipped with a Bag Leak Detection (BLD)

system. Operating parameters for the BLD have been established and are contained in the MACT operation and maintenance

plan required by 40 CFR § 63.7710(b) as indicated in Attachment 3 of this permit. All data shall be recorded in accordance



TAPCR 1200-03-09-.01(4); permit 958476P

Compliance Method: Compliance with conditions E11-1 and E11-4 (both Part A and Part B) shall be deemed to indicate

compliance with condition E11-5.

E11-6. Volatile Organic Compounds (VOCs) emitted from this source shall not exceed 0.02 pounds per ton of iron melted (1.8 pounds

per hour).


33

TAPCR 1200-03-09-.01(4); permit 952943P

For each cupola metal melting furnace at a new or existing iron and steel foundry, you must not discharge emissions of

volatile organic hazardous air pollutants (VOHAP) through a conveyance to the atmosphere that exceed 20 parts per million

by volume (ppmv) corrected to 10 percent oxygen. Compliance with MACT standards (40 CFR 63.7690) shall be deemed to

indicate compliance with the above VOC limit.

40 CFR 63.7690 (a)(8)

Compliance Method: VOHAP Emission Limit - The limit under 40 CFR 63.7690 (a)(8) for VOHAP is applicable to this

existing cupola. The stack test of August 7, 2008 demonstrated compliance with the MACT limit of 20 parts per million by

volume (ppmv) corrected to 10 percent oxygen. Compliance with NESHAP/MACT 40 CFR 63.7690 shall be deemed to

indicate compliance with the above VOC limit stated as 0.02 pounds VOC per ton of iron melted.

You must install, operate, and maintain a capture and collection system for all emissions sources subject to an emissions limit

for VOHAP in paragraphs (a)(8) through (11) of 40 CFR 63.7690.

(i) Each capture and collection system must meet accepted engineering standards, such as those published by the American

Conference of Governmental Industrial Hygienists.

(ii) You must operate each capture system at or above the lowest value or settings established as operating limits in your

operation and maintenance plan.

40 CFR 63.7690(b)(1)

(3) You must operate each combustion device applied to emissions from a cupola metal melting furnace subject to the

emissions limit for VOHAP in 40 CFR 63.7690(a)(8) , such that the 15-minute average combustion zone temperature does

not fall below 1,300* degrees Fahrenheit. Periods when the cupola is off blast and for 15 minutes after going on blast from an

off blast condition are not included in the 15-minute average.

40 CFR 63.7690(b)(3)

* For purposes of submittal of Semiannual Reports required by condition E2(a) of this permit, the permittee shall

maintain records of the combustion zone temperature required by this condition and include a summary of these

records, including notification of any excursions or violations of the temperature requirement.

Note that the above-specified minimum 1300 °F temperature requirement supersedes the minimum recuperation combustion

temperature of 1200 °F as specified by condition 19 of Permit 958476P.

For each combustion device subject to the operating limit in 40 CFR § 63.7690(b)(3), you must at all times monitor the 15-

minute average combustion zone temperature using a continuous parametric monitoring system (CPMS) according to the

requirements of 40 CFR § 63.7741(d).

40 CFR 63.7740(e)

E11-7. Carbon Monoxide (CO) emitted from this source shall not exceed 0.4 pound per ton of iron (36.0 pounds per hour).

TAPCR1200-03-09-.01(4); permit 952943P

Compliance Method:

Compliance with the control device minimum combustion temperature requirement of 1,300 degrees F of condition E11-6 shall

be deemed compliance with condition E11-7.

E11-8. Sulfur Dioxide (SO2) emitted from this source shall not exceed 0.22 pound per ton of iron and 19.8 pounds per hour utilizing

a 30 day rolling average.


34

TAPCR1200-03-09-.01(4); permit 952943P

Compliance Method:

(a) The source owner or operator shall maintain, operate, and submit reports of excess emissions from continuous in-stack

monitoring systems for sulfur dioxide (SO2) and flow. The sensors of these monitoring systems shall be located in representative

areas of the effluent gas stream of this source. Electronic signal combining systems shall be installed to convert the output of the

pollutant monitors into units of the applicable emission standards. The in-stack sulfur dioxide monitoring system shall meet all

the requirements of Performance Specification 2 as outlined in the current 40 CFR 60, Appendix B. The in-stack flow

monitoring system shall meet all the requirements of performance specification 6 as outlined in the current 40 CFR 60,

Appendix B. Also, the dry alkaline injection scrubber system shall be used as a control system for the SO2 emitted from this

source.

(b) Operational requirements for Sulfur Dioxide (SO2), and Flow Monitoring Systems:

The use of continuous in-stack monitoring for sulfur dioxide, and flow is the method by which this source proves continual

compliance with the applicable sulfur dioxide emission limitations. Therefore, for the source to demonstrate continual

compliance with the applicable sulfur dioxide emission limitations, the in-stack sulfur dioxide, and flow monitoring systems

shall each be fully operational for at least 95 percent of the operational time of the monitored source during each calendar

quarter. An operational availability of less than this amount may be considered the basis for declaring the source to be in non-

compliance with the applicable monitoring requirements, unless the reasons for the failure to maintain this level of operational

availability are accepted by this Division as being legitimate malfunctions of the instruments. TAPCR 1200-03-10-.02;

permits 958476P and 976951

(c) Quality Assurance Requirements for the Sulfur Dioxide (SO2), and Flow Monitoring Systems:

The continuous in-stack sulfur dioxide monitoring system shall meet all of the requirements of Appendix F as published in the

current 40 CFR 60. TAPCR1200-03-10-.02; permits 952943P and 976951

For purposes of submittal of semiannual compliance data for this condition in accordance with condition E2(a) of this

permit, the permittee shall certify that the quarterly reports required by condition E11-13 have been submitted to the

Division.

E11-9. Nitrogen Oxides (NOx) emitted from this source shall not exceed 0.44 pound per ton of iron and 39.6 pounds per hour

utilizing a 30 day rolling average.

TAPCR1200-03-09-.01(4); permits 952943P and 976951

Compliance Method: Compliance with this condition shall be determined by calculating: 1) an emission factor in units of

pounds of NOx per ton of iron from historical CEM measurements or compliance stack test results, and 2) an average

emission rate in units of pounds of NOx per hour using the emission factor of 0.44 pound of NOx per ton of iron and the iron

input calculated from the recordkeeping data required by condition E11-1 of this permit. Reporting for this condition shall be

in accordance with condition E2(a) of this permit. The permittee has proposed periodic stack testing for confirmation of the

NOx emission factor calculated in 1) above. The permittee shall conduct a stack test for NOx each calendar year and submit a

performance test report with the annual compliance certification required by condition E2(b).

E11-10. Low-NOx burners or the equivalent shall be used as a control device for the NOx emitted from the recuperative incinerator

for this source. The nitrogen oxides emissions from the two new replacement burners, rated at 15 MMBTU per hour each, for

the recuperative incinerator (thermal incinerator) shall not exceed 59.0 pounds per million standard cubic feet of natural gas

combusted.

TAPCR1200-03-09-.03(8) and 1200-03-06-.03(2); permits 958476P and 976951


35

Compliance Method: Compliance with this condition shall be determined by maintaining documentation of the burner

specifications including the burner low-NOx design, NOx emission factor in units of pounds per million standard cubic feet,

and heat input capacity.

E11-11. [Reserved]

E11-12. [Reserved]

E11-13. The owner or operator shall submit excess emission reports and continuous emission monitoring system (CEMS) downtime

reports to this Division at the address in condition E2(c) for each calendar quarter within 30 days of the end of each calendar

quarter in accordance with Rule 1200-03-10-.02(2). If there are no excess emissions or CEMS downtime during this quarter, the

owner or operator shall submit a report to that effect.

TAPCR1200-03-10-.02; permit 952943P

Compliance Method: The compliance method is stated above with the requirements of this condition.

E11-14. [Reserved]

E11-15. [Reserved]

E11-16. The exhaust gases from the control device for this source shall exhaust through stack S10.

TAPCR 1200-03-09-.03(8); permit 952943P


54-0174-18- Phase I – Ductile Iron Treatment Operation:

Ductile Iron Treatment (P31), Desulfurization (P32) with Baghouse Control (C31) exhaust through Stack S12 and Two 3.0 MM

Btu/hr Natural Gas Fired Core Ovens (P33) are designated as insignificant emission units.

E12-1. This permit is valid for the following equipment/ processes listed in Table 1 below. The specified process weight rate limits

shall not be exceeded for the Ductile Treatment Process (Tundish Ladle Method P31), and the Desulfurization process (P32).

TAPCR 1200-03-09-.03(8); permit 964099P

Table 1 – Process Equipment for Ductile Iron Treatment

Process Equipment Description Process Weight Rate or Capacity Control Device

Ductile Treatment

(Tundish Ladle Method)

(P31)

91.5 tons of iron per hour, averaged over daily


Baghouse C31

222,610 dscfm

(Nominal Value)

Desulfurization

(P32)

90.0 tons per hour, averaged over daily total

operating time, excluding down time.

Compliance Method:

A log of all material used at this source in a form that readily demonstrates compliance with the limits specified in Table 1

above on a daily average basis, must be maintained at the source location and kept available for inspection by the Technical

Secretary or an authorized representative. All data shall be recorded in accordance with condition E3-9.


36

E12-2. Natural gas only shall be used as fuel at this source.

TAPCR 1200-03-09-.03(8); permit 964099P

Compliance Method: The design of the source’s fuel burning equipment limits the type of fuel used at this source to natural

gas only.

E12-3. Particulate Matter emissions from Phase I Ductile Iron Treatment Operations (including desulfurization (P32) and Ductile

Iron Treatment (P31) Operations as exhausting through Baghouse C31 and Stack S12) shall not exceed a concentration of

0.005 grains per dry standard cubic foot of exhaust gases and 10.3 pounds per hour. Additionally, particulate matter

emissions from this source shall not exceed an emission rate of 29.2 tons per consecutive 12-month period. The limits of

0.005 grains per dry standard cubic foot of exhaust gases and 10.3 pounds per hour were established in Construction permit

No.952944P issued on April 28, 2000, amended on September 24, 2001.

TAPCR 1200-03-09-.01(4) ; permits 952944P (amendment 9/24/2001) and 964099P









Note: the basis of this compliance method is based on the August 7 – 10, 2012 test from this source that resulted in a

concentration of 0.0047 gr/dscf and 5.9 pounds of PM per hour.

E12-4. The exhaust gases from the control device (Baghouse C31) shall exhaust through Stack S12.

TAPCR 1200-03-09-.03(8); permit 952944P (amendment 9/24/2001)


54-0174-20- Phenolic – Urethane Core Making Operations

Coldbox Core Making Process (P23A – One Machine and One Oven)

Coldbox Core Making Process (P23B – One Machine and One Oven)

Coldbox Core Making Process (P24 – One Machine and Two Ovens)

Coldbox Core Making Process (P25 – Two Machines and One Oven)

Coldbox Core Making Process (P26 – One Machine )

Coldbox Core Making Process (P27A and 27B – Two Machines and Two Ovens)

Sulfuric Acid Scrubber Control (C23) for all Core Machines - (See condition E13-1 for description)

Note: The permittee stated that no triethylamine (TEA) is utilized at this operation; therefore, the source is not subject to the

provisions of 40 CFR Part 63 Subpart EEEEE.

E13-1. The process equipment at this source consists of the following Phenolic-Urethane Core Making machines and each

of these units must comply with the specified total process weight rates and VOC emissions limitations as indicated

below with a total capacity of 20.75 tons per hour. These processes include handling and storage of resin and sand.

All of the following specified core machines shall be controlled by common packed bed scrubber (C23) with

circulation of sulfuric acid liquor.


37

TAPCR 1200-03-09-.03(8) ; permit 968599P (7/10/2014)

Source 54-0174 -20 - Phenolic – Urethane Core Making Operations

Existing

Phenolic-Urethane

Core Making

Machines

I.D.

Number

of

Units

Process Weight

per Unit

tons per Hour

Total Process

Weight Rate,

Tons per Hour

VOC Emission

Factor

pounds per ton of

Sand Processed

Allowable VOC

Emissions Rates

Applicable

Rule (s)

TAPCR

P23A

One Core Machine

1 1.25 1.25 1.02

1.275 pounds per

hour

and

5.58 tons during

any consecutive 12-

month period

1200-03-07-

.07(2)

P23B

One Core Machine

1 3.0 3.0 1.02

3.06 pounds per hour

and

13.40 tons during

any consecutive 12-

month period

1200-03-07-

.07(2)

P24

One Core Machine

1 3.0

3.0 1.02

Based on

Maximum Resin

Content of 1.75%

by Weight

3.06 pounds per hour

and

13.40 tons during

any consecutive 12-

month period

1200-03-09-

.01(4)

PSD-BACT

P25

Two Core Machines

2 2.25

4.5

1.23 (controlled)

Based on

Maximum Resin

Content of 1.75%

by Weight

24.24 tons during

any consecutive 12-

month period

1200-03-07-

.07(2)

P26

One Core Machine

Permitted under

Construction Permit

No. 967169

1 3.0 3.0 1.23 (controlled)

Based on

Maximum Resin

Content of 1.75%

by Weight

16.16 tons during

any consecutive 12-

month period

1200-03-07-

.07(2)

P27A

One Core Machine

Permitted under

Construction Permit

No. 968599

1 3.0 3.0 1.23 (controlled)

Based on

Maximum Resin

Content of 1.75%

by Weight

16.16 tons during

any consecutive 12-

month period

1200-03-07-

.07(2)

P27B

One Core Machine

Permitted under

Construction Permit

No. 968599

1 3.0 3.0 1.23 (controlled)

Based on

Maximum Resin

Content of 1.75%

by Weight

16.16 tons during

any consecutive 12-

month period

1200-03-07-

.07(2)

Total 8 20.75 105.10


38

Compliance Method: A monthly log of the process weight rate and hours of operation for all core making units covered by

Condition No. E13-1 shall be maintained in Logs No. 1 and No. 2 or another log format that readily demonstrates

compliance with their corresponding limits, at the source location and kept available for inspection by the Technical

Secretary or an authorized representative. A monthly calculation of average hourly process weight rate, average monthly

pounds of VOC emissions per ton of sand processed shall be prepared. This data shall be calculated using information dated

September 21, 2011, that was provided by the permittee from the “2011 Core Machine Project - Emission Calculations for

Core Machines”, which uses Ohio Cast Metals Association (OCMA) data. Monthly calculation procedures shall be provided

to and approved by the Division. These logs must be retained for a period of not less than five (5) years.

Based on the results of the performance test of August 29, 2017, for control of VOC emissions from core making catalyst, a

VOC capture efficiency of 100%, a scrubber control device VOC removal efficiency of 98.6%, and an overall VOC removal

efficiency of 98.6% were determined for this source.

Monthly Log No. 1 For Core Making Machines with VOC lb/hr limits Core Machine I.D._____

Month Production

tons

Hours of

Operation

Average

Process

Weight

rate,

tons per

hour

Allowable

(Average)

Process

Weight rate,

tons per hour

VOC

emission

factor,

pounds per

ton of sand

processed

Actual VOC

emission rate

pounds per hour*

Allowable VOC

emission rate,

pounds per

hour

* Actual VOC emission rate, lb/hr = VOC emissions, tons /month

hours per month of operation

Monthly Log No. 2 For Core Making Machines with 12- consecutive month period VOC limit Core Machine I.D.___

Month Tons of

Production

Hours of

Operation

Average

Process

Weight

rate,

tons per

hour

Allowable

(Average)

Process

Weight rate,

tons per hour

VOC

emission

factor,

pounds per

ton of sand

processed

Actual VOC

emission rate,

pounds per

month

Allowable VOC

emission rate, tons

per 12-month period

TAPCR 1200-03-10-.02(2)(a)

E13-2. The VOC emission limits (hourly limits and 12-month limits, for all core making machines, as specified in condition E13-1

shall be assured through compliance with the daily average maximum process weight rate limits and through compliance

with the following acid scrubber control requirements:

a. Emissions from all Core making Machines must be ducted through the existing acid scrubber (C23) that exhausts

through designated stack S23.

b. The acid scrubber (C23) shall be operating anytime that any core making machine is operating.

TAPCR 1200-03-09-.03(8); permit 968599P (7/10/2014)


39

Compliance Method: Compliance with the VOC emission limits shall be assured by maintaining a minimum scrubber liquid

(sulfuric acid) flow rate of 180 gallons per minute and a maximum pH of 4.5 in the scrubber liquid. Also, compliance shall

be determined by maintaining a minimum pressure drop value of 0.1 inches of the gas stream across the scrubber. These

parameters shall be monitored and recorded once daily when these processes are operational. The days when these processes

are not in operation shall be noted. The permittee shall note any relevant scrubber conditions/problems/concerns when

recording these parameters. All data, including all required calculations for process weight rate, must be entered in the log no

later than 30 days from the end of the day for which the data is required.

TAPCR 1200-03-10-.04

E13-3. Reserved.

E13-4 . This permit is valid for the following core ovens listed in the table below:

Description of

Oven

Number of Core Ovens

Maximum

Heat Input per Oven

Total Heat Input

P23A

One Oven

2.5 mmbtu/hr

2.5 mmbtu/hr

P23B

One Oven

2.7 mmbtu/hr

2.7 mmbtu/hr

P24

Two Ovens

2.4 mmbtu/hr

5.0 mmbtu/hr

7.4 mmbtu per hour

P25

One Oven

5.0 mmbtu/hr

5.0 mmbtu/hr

P33

Two Ovens

3.0 mmbtu/hr

6.0 mmbtu/hr

Total Heat Input Rate:

23.6 mm btu/hr.

Note- These core ovens are natural gas fired only. Emissions from individual ovens are insignificant. Therefore, no air

pollutant allowable emission limits are established for these units in this permit for fees.

TAPCR 1200-03-09-.03(8); permit 968599P (7/10/2014)

Compliance Method: By annual certification per condition E2(b) the permittee shall certify that the status of the heat input

rating and number of ovens specified in the table above has not changed.


40

E13-5. This permit is valid for the mixers associated with the core machines as indicated in the table below, with each mixer providing

material exclusively for one core machine.

TAPCR 1200-03-09; permit 968599P (7/10/2014)

Description of

Mixers

Number of Mixers

P23A

1

P23B

1

P24

3

P25

2

Compliance Method: By annual certification per condition E2(b) the permittee shall certify that the status of the number of

mixers specified in the table above has not changed.

E13-6. Particulate matter emitted from the mixers shall not exceed 0.02 grains per dry standard cubic foot of exhaust gas and 1.4

pounds per hour. Also, emissions from all mixers shall be exhausted to one baghouse, which shall exhaust to the interior of

the building, exclusively.

TAPCR: 1200-03-09-.01(4) PSD-BACT; permit 968599P (7/10/2014)

Compliance Method: Use of the baghouse and exhaust to the interior of the building when the source is in operation shall be

deemed to indicate compliance with this limit. The permittee shall maintain a record of daily inspections to verify operation of

the baghouse during process operations and shall conduct semiannual maintenance inspections of the baghouse filter media,

housing, and associated equipment (blower and ductwork) to verify the integrity of the dust collection system. The results of

these maintenance inspections and any repairs which are made shall be recorded in a log to be kept available at the facility for

inspection by the Technical Secretary or an authorized representative.

Note- The permittee has indicated that the particulate emissions from the core making (scrubber) are negligible. The scrubbers

exhaust the core machines which process a mixture of sand and resin which should not generate dust when processed or handled.

Therefore, no particulate emission allowable rate is set for the core making operations which exhaust through the (common

VOC control for all core machines) packed bed scrubber C23.

E13-7. Only natural gas shall be used as fuel for the drying ovens at this source.

TAPCR 1200-03-09-.03(8)

Compliance Method: The design of the ovens used at this source limits the fuel type to natural gas only.

54-0174-21: One (1) Natural Gas, Propane (as backup) Fired Internal Combustion Emergency Generator (50 kW), 82.1 hp Spark

Ignition Engine. This source is subject to the requirements of 40 CFR part 60 Subpart JJJJ (NSPS) and NESHAP 40 CFR Part 63 Subpart

ZZZZ. This source is designated as an insignificant activity and removed from the Title V permit per TAPCR 1200-03-09-.04(5)(a)4(i),

1200-03-09-.04(5)(c)1, 0400-30-38-.01(2), and 0400-30-39-.02(2). The permittee is responsible for reporting of recordkeeping

requirements of 40 CFR Part 60 Subpart JJJJ and 40 CFR Part 63 Subpart ZZZZ. Reports shall be sent to EPA at the address listed in

condition E2(b).

E14-1. The permittee is responsible for reporting recordkeeping requirements of federal rules 40 CFR Part 60 Subpart JJJJ and 40 CFR

Part 63 Subpart ZZZZ for this source. Reports shall be sent to EPA at the address listed in condition E2(c).


41

TAPCR 1200-03-09-.03(8), 40 CFR Part 60 Subpart JJJJ, and 40 CFR Part 63 Subpart ZZZZ

54-0174-24 Source Identification:

Waste Sand and Metal Recovery Operation

Processing Steps: Front End loader transfer to storage bunker

Front End loader transfer from bunker to screen hopper

Transfer from screen hopper to screen

Screening

Transfer from Screen to conveyor

Transfer from conveyor to stockpile or roll-off container

Stack(s): None

Control Equipment: Wet Suppression

E15-1. The maximum input capacity for this source of waste sand and metal shall not exceed 35 tons per hour on a daily average per

the permit application dated November 20, 2017.

TAPCR 1200-03-09-.03(8); permit 973233

Compliance Method: This condition is a statement of the maximum input capacity for the waste sand and metal recovery

operation. Should the permittee need to modify this source in a manner that increases the maximum input capacity, a

construction permit or Title V modification shall first be applied for in accordance with TAPCR 1200-03-09-.01 or 1200-03-

09-.02(11)(d)1.(i)(V) prior to making the change.

E15-2. Particulate matter (PM) emitted from this source shall not exceed 1.03 pounds per hour on a daily average basis.

TAPCR 1200-03-07-.01(5), agreement letter dated February 9, 2018 (for avoidance of prevention of significant deterioration

(PSD) new source review - enclosed as Attachment 5); permit 973233

Compliance Method: Compliance with this emission limit shall be assured by the following:

(a) Compliance is assured by reference to EPA emission factors, Table 13.2.4 Aggregate Handling and Storage Piles

(November 2006) and Table 11.19.2-2, Emission Factors for Crushed Stone Processing, August 2004, and the emission

calculations in the permit application dated December 20, 2017.

(b) Wet suppression water sprays shall be used continuously to apply water to the waste sand and metal mixture in the

foundry sand preparation area before it is transported by front-end loader to the screening hopper. The amount of water

applied in the preparation area shall be sufficient to control fugitive dust throughout the waste sand and metal handling

operations. A log shall be maintained for daily verification for each day of operation that water sprays were used for dust

control for this source. The log shall include the name and title of the person performing the daily verification of water spray

usage. In addition, routine inspections shall be performed on the wet suppression system. Appropriate maintenance records


42

including inspections and dates on which maintenance is performed shall be recorded in a suitable permanent form and kept

available for inspection by Division personnel.

(c) Daily observations for the presence of visible (fugitive) emissions at the property line of the facility shall be performed,

and the presence of visible emissions shall be determined by a modified Tennessee Visible Emissions Evaluation Method 4

(TVEE 4) as adopted by the Tennessee Air Pollution Control Board on April 16, 1986. The observational time period shall be

at least five minutes. If during the observation, visible emissions are observed, the facility shall initiate corrective action to

determine the source of the emissions and mitigate the source of emissions. A log/ record of these daily visible emission

observations shall be maintained at the facility and made available for inspection by Tennessee Division of Air Pollution

Control personnel. The daily visible emission record shall include the name of the person conducting the observation, the

date and time of the observation, and the date and time of any corrective actions taken to control/ mitigate any observed

visible emissions at the property line. These records must be retained on-site for a period of not less than five years. At least

one person at the facility or a contractor must have current valid certification as a visible emission observer. That person can

conduct the training required for the people that routinely conduct these observations, thus meeting the “trained and

knowledgeable” requirements of Section No. 1 of TVEE 4. The selected location for the daily visible emission observations

shall represent the closest distance from the facility’s property line to the waste sand and metal recovery operation. Within 90

days of issuance of this permit 573114, the permittee shall submit a plan to the Division for conducting the daily visible

(fugitive) emission observations. The plan shall include a plan view of the location of the waste sand and metal recovery

operation in relation to the property line of the facility, the distances to the property boundaries from the waste sand and

metal recovery operation, and the proposed location for conducting the visible emission evaluations. In addition, the plan

shall include a protocol for conducting the daily visible emission observations. This plan shall be added to the operating

permit for the facility via Title V permit program minor modification procedures. The plan and a minor modification permit

application shall be submitted to the Division at the following address or via email:

Compliance Validation Program or Adobe Portable Document Format (PDF) Copy to:

Tennessee Division of Air Pollution Control [email protected]

William R. Snodgrass Tennessee Tower, 15th Floor

312 Rosa L. Parks Avenue

Nashville, TN 37243

(end of conditions)

ATTACHMENT 1

OPACITY MATRIX DECISION TREE for

VISIBLE EMISSION EVALUATION METHODS 1, 2 and 9

dated JUNE 18, 1996 and amended September 11, 2013 (3 Pages)

Notes:

The use of Tennessee Visible Emission

Evaluation (TVEE) Method 1 is only applicable where the use of the method

is specified as a permit condition.

PM = Periodic Monitoring required by

1200-03-09-.02(11)(e)(1)(iii).

This Decision Tree outlines the criteria

by which major sources can meet the

PM requirements of Title V for demonstrating compliance with the

visible emissions standard for

nontraditional sources (roads and parking areas). It is not intended to

determine compliance requirements for

EPA’s Compliance Assurance Monitoring (CAM) Rule (formerly

referred to as Enhanced Monitoring –

Proposed 40 CFR 64).

Visible Emissions Evaluations (VEEs)

are to be conducted utilizing TVEE Method 1. The observer must be

properly certified according to criteria

specified in TVEE Method 1 to conduct Method 1 evaluations.

Initial observations are to be repeated within 90 days of startup of a modified

source if a new construction permit is

issued for modification of the source.

A VEE conducted by TDAPC personnel

after the Title V permit is issued will also constitute an initial reading.

Reader Error

For TVEE Method 1, the TDAPC

declares non-compliance when the highest two-minute average exceeds the

standard plus 10% opacity for sources

having this standard applied prior to August 24, 1984 or 8.8% for sources

having this standard applied on or after

August 24, 1984.

Dated June 18, 1996 Amended September 11, 2013

Decision Tree PM for Opacity from

Nontraditional Sources (Roads and Parking Areas)

Utilizing TVEE Method 1

Within one year following Title V permit issuance date conduct an initial 30-Minute VEE

during normal operation

Is the Highest 2-minute average

less than 5% opacity?

Is the Highest 2-minute average greater than 5% opacity and less

than 10% opacity?

Has a Semiannual VEE highest 2-minute average been equal to or

greater than 10% opacity?

Is the highest 2-Minute Average

Greater than or equal to the 10%

opacity standard and out of compliance taking both round and

reader error into consideration?

Report Deviations from Permit

Requirements in Periodic Reports and

Periodic Compliance Certifications as Required by the Major Source

Operating Permit.

Within one year prior to Title V permit expiration

date conduct another 30-

minute VEE during normal process operation

Conduct VEEs Semiannually

Conduct 30-minute VEEs Monthly Have 3 Consecutive Months Highest 2-minute averages

been less than 10% opacity?

Yes

Yes

No

No

Yes

Yes

No

No

Yes

No

Is Emission Unit an

Equipment Leak?

Natural Gas or No. 2 Oil-fired Combustion Source?

Is Each Allowable Emission

less than or equal to 10 TPY?

Is Each Allowable Emission greater than

10 TPY from Colorless Pollutants (e.g. Colorless VOCs, CO, HCl, HF,

Ammonia, or Methane)?

Within one year following Title V permit issuance

date conduct an initial 30-minute VEE during normal

process operation

Is the highest individual reading greater

than or equal to the applicable opacity

standard plus 15% opacity (e.g. 35% for a

20% standard)?

Conduct a one-hour VEE

Are there 3 or less individual

readings greater than or equal to the

opacity standard plus 15% opacity (e.g. 35% for a 20% standard)?*

Conduct VEEs monthly

One hour duration

Are there 21 or more individual readings greater than or equal to the

applicable opacity standard plus 15%

opacity (e.g. 35% for a 20% standard)?

Report deviations from Permit requirements in periodic reports and

periodic compliance certifications as

required in Major Source Operating Permits. (1200-9-.02(11)(e))

No opacity reading required



No opacity reading

required

Within one year prior to Title V

permit expiration

date conduct

another 30-minute

VEE during normal

process operation

Has a semi-annual VEE yielded 4 or more individual readings greater than or

equal to the applicable opacity standard

plus 15% opacity (e.g. 35% for a 20% standard)?

Have 3 consecutive month VEEs yielded 3 or less individual

readings per evaluation that are

greater than or equal to the applicable opacity standard plus

15% opacity (e.g. 35% for a 20%

standard)?

Yes

Yes

Yes

Yes

No

No

No

No

No

Yes

Yes

Yes

No No

Yes No

Yes

Conduct VEEs

Semi-annually

No

Notes:

PM = Periodic Monitoring required by 1200-3-9-.02(11)(e)(iii).

This Decision Tree outlines the criteria by which major sources can meet the

periodic monitoring and testing

requirements of Title V for demonstrating compliance with the

visible emission standards in paragraph

1200-3-5-.01. It is not intended to determine compliance requirements for

EPA’s Compliance Assurance Monitoring (CAM) Rule (formerly

referred to as Enhanced Monitoring –

Proposed 40 CFR 64).

Examine each emission unit using this

Decision Tree to determine the PMT required.

Use of continuous emission monitoring systems eliminates the need to do any

additional periodic monitoring.

Visible Emission Evaluations (VEEs)

are to be conducted utilizing Tennessee

Visible Emission Evaluation Method 2. The observer must be properly certified

according to the criteria specified in

EPA Method 9 to conduct TVEE Method 2 evaluations.

Typical Pollutants Particulates, VOC, CO, SO2, NOx, HCl,

HF, HBr, Ammonia, and Methane.

Initial observations are to be repeated

within 90 days of startup of a modified

source, if a new construction permit is issued for modification of the source.

A VEE conducted by TAPCD personnel after the Title V permit is issued will

also constitute an initial reading.

Reader Error

TVEE Method 2: The TAPCD declares

non-compliance when 21 observations are read at the standard plus 15%

opacity (e.g. 35% for a 20% standard).

*The rationale for this is the fact that

Rule 1200-3-5-.01 allows for an

exemption of 5 minutes (20 readings) per hour and up to 20 minutes (80

readings) per day. With 4 or more

excessive individual readings per hour the possibility of a daily exceedance

exists.

Note: A company could mutually agree

to have all of its sources regulated by EPA Method 9. Caution: Agreement to

use Method 9 could potentially place

some sources in non-compliance with visible emission standards. Please be

sure before you agree.

Dated June 18, 1996

Amended September 11, 2013

Decision Tree PM for Opacity for

Sources Subject to Rule 1200-3-5-.01


Yes

No

Is the highest 6-minute average**greater

than 50% of the applicable opacity standard (e.g. 11% opacity for a source

having a 20% standard) and less than

100% of the applicable opacity standard?

Is the highest 6-minute average**

greater than or equal to the

applicable opacity standard & out of compliance taking both round

& reader error into consideration?

Yes

No

Is Emission Unit an

Equipment Leak?

Natural Gas or No. 2 Oil-fired Combustion Source?

Is Each Allowable Emission less than or equal to 10 TPY?

Is Each Allowable Emission greater than 10 TPY from Colorless Pollutants

(e.g. Colorless VOCs, CO, HCl, HF,

Ammonia, or Methane)?

Within one year following Title V permit issuance

date conduct an initial 30-minute VEE during

normal process operation

Is the highest 6-minute average** less than or equal to 50% of the applicable

opacity standard (e.g. 10% opacity for

a source having a 20% standard)?

Within one year prior to

Title V permit expiration date conduct another 30-

minute VEE during normal

process operation

Conduct 30-minute VEEs

monthly

Report deviations from Permit requirements in periodic reports and periodic compliance

certifications as required by the Major Source Operating Permit.





Has a semi-annual VEE highest 6-

minute average** been greater than or equal to the applicable

opacity standard?

Have 3 consecutive month VEEs highest 6-minute average** been

less than the applicable opacity

standard?

Yes

No

No

No

No

No

Yes

Yes

No

No

Yes

Conduct VEEs Semi-annually

Yes

Yes

Yes

Decision Tree PM for Opacity for

Sources Subject to Rule 1200-03-05-.01


Notes:

PM = Periodic Monitoring required by

1200-03-09-.02(11)(e)(iii).

This Decision Tree outlines the criteria by

which major sources can meet the periodic monitoring and testing requirements of

Title V for demonstrating compliance with

the visible emission standards set forth in the permit. It is not intended to determine

compliance requirements for EPA’s

Compliance Assurance Monitoring (CAM) Rule (formerly referred to as Enhanced

Monitoring – Proposed 40 CFR 64).

Examine each emission unit using this

Decision Tree to determine the PM

required.*

Use of continuous emission monitoring

systems eliminates the need to do any additional periodic monitoring.

Visible Emission Evaluations (VEEs) are to be conducted utilizing EPA Method 9.

The observer must be properly certified to conduct valid evaluations.

Typical Pollutants Particulates, VOC, CO, SO2, NOx, HCl,

HF, HBr, Ammonia, and Methane.

Initial observations are to be repeated

within 90 days of startup of a modified

source, if a new construction permit is issued for modification of the source.

A VEE conducted by TAPCD personnel after the Title V permit is issued will also

constitute an initial reading.

Reader Error

EPA Method 9, Non-NSPS or NESHAPS

stipulated opacity standards: The TAPCD guidance is to declares non-

compliance when the highest six-minute

average** exceeds the standard plus 6.8% opacity (e.g. 26.8% for a 20% standard).

EPA Method 9, NSPS or NESHAPS stipulate opacity standards:

EPA guidance is to allow only engineering

round. No allowance for reader error is given.

*Not applicable to Asbestos manufacturing subject to 40 CFR 61.142

**Or second highest six-minute average, if the source has an exemption period

stipulated in either the regulations or in the

permit.

Dated June 18, 1996

Amended September 11, 2013

ATTACHMENT 2

Requirements of 40 CFR Part 63, Subpart EEEEE - National Emission Standards for

Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries

Subpart EEEEE—National Emission Standards for Hazardous Air Pollutants for Iron and Steel

Foundries

Source: 69 FR 21923, Apr. 22, 2004, unless otherwise noted.

What this Subpart Covers

§ 63.7680 What is the purpose of this subpart?

This subpart establishes national emission standards for hazardous air pollutants (NESHAP) for iron and steel foundries. This subpart also establishes

requirements to demonstrate initial and continuous compliance with the emissions limitations, work practice standards, and operation and

maintenance requirements in this subpart.

§ 63.7681 Am I subject to this subpart?

You are subject to this subpart if you own or operate an iron and steel foundry that is (or is part of) a major source of hazardous air pollutant (HAP)

emissions. Your iron and steel foundry is a major source of HAP for purposes of this subpart if it emits or has the potential to emit any single HAP at

a rate of 10 tons or more per year or any combination of HAP at a rate of 25 tons or more per year or if it is located at a facility that emits or has the

potential to emit any single HAP at a rate of 10 tons or more per year or any combination of HAP at a rate of 25 tons or more per year as defined in

§63.2.

[69 FR 21923, Apr. 22, 2004, as amended at 73 FR 7218, Feb. 7, 2008]

§ 63.7682 What parts of my foundry does this subpart cover?

(a) The affected source is each new or existing iron and steel foundry.

(b) This subpart covers emissions from metal melting furnaces, scrap preheaters, pouring areas, pouring stations, automated conveyor and pallet

cooling lines, automated shakeout lines, and mold and core making lines. This subpart also covers fugitive emissions from foundry operations.

(c) An affected source is existing if you commenced construction or reconstruction of the affected source before December 23, 2002.

(d) An affected source is new if you commenced construction or reconstruction of the affected source on or after December 23, 2002. An affected

source is reconstructed if it meets the definition of “reconstruction” in §63.2.

§ 63.7683 When do I have to comply with this subpart?

(a) Except as specified in paragraph (b) of this section, if you have an existing affected source, you must comply with each emissions limitation,

work practice standard, and operation and maintenance requirement in this subpart that applies to you no later than April 23, 2007. Major source

status for existing affected sources must be determined no later than April 23, 2007.

(b) If you have an existing affected source, you must comply with the work practice standards in §63.7700(b) or (c), as applicable, no later than April

22, 2005.

(c) If you have a new affected source for which the initial startup date is on or before April 22, 2004, you must comply with each emissions

limitation, work practice standard, and operation and maintenance requirement in this subpart that applies to you by April 22, 2004.

(d) If you have a new affected source for which the initial startup date is after April 22, 2004, you must comply with each emissions limitation, work

practice standard, and operation and maintenance requirement in this subpart that applies to you upon initial startup.

(e) If your iron and steel foundry is an area source that becomes a major source of HAP, you must meet the requirements of §63.6(c)(5).

(f) You must meet the notification and schedule requirements in §63.7750. Note that several of these notifications must be submitted before the

compliance date for your affected source.

Emissions Limitations

§ 63.7690 What emissions limitations must I meet?

(a) You must meet the emissions limits or standards in paragraphs (a)(1) through (11) of this section that apply to you. When alternative emissions

limitations are provided for a given emissions source, you are not restricted in the selection of which applicable alternative emissions limitation is

used to demonstrate compliance.

(1) For each electric arc metal melting furnace, electric induction metal melting furnace, or scrap preheater at an existing iron and steel foundry, you

must not discharge emissions through a conveyance to the atmosphere that exceed either the limit for particulate matter (PM) in paragraph (a)(1)(i) of

this section or, alternatively the limit for total metal HAP in paragraph (a)(1)(ii) of this section:

(i) 0.005 grains of PM per dry standard cubic foot (gr/dscf), or

(ii) 0.0004 gr/dscf of total metal HAP.

(2) For each cupola metal melting furnace at an existing iron and steel foundry, you must not discharge emissions through a conveyance to the

atmosphere that exceed either the limit for PM in paragraph (a)(2)(i) or (ii) of this section or, alternatively the limit for total metal HAP in paragraph

(a)(2)(iii) or (iv) of this section:

(i) 0.006 gr/dscf of PM; or

(ii) 0.10 pound of PM per ton (lb/ton) of metal charged, or

(iii) 0.0005 gr/dscf of total metal HAP; or

(iv) 0.008 pound of total metal HAP per ton (lb/ton) of metal charged.

(3) For each cupola metal melting furnace or electric arc metal melting furnace at a new iron and steel foundry, you must not discharge emissions

through a conveyance to the atmosphere that exceed either the limit for PM in paragraph (a)(3)(i) of this section or, alternatively the limit for total

metal HAP in paragraph (a)(3)(ii) of this section:

(i) 0.002 gr/dscf of PM, or


(4) For each electric induction metal melting furnace or scrap preheater at a new iron and steel foundry, you must not discharge emissions through a

conveyance to the atmosphere that exceed either the limit for PM in paragraph (a)(4)(i) of this section or, alternatively the limit for total metal HAP

in paragraph (a)(4)(ii) of this section:



(5) For each pouring station at an existing iron and steel foundry, you must not discharge emissions through a conveyance to the atmosphere that

exceed either the limit for PM in paragraph (a)(5)(i) of this section or, alternatively the limit for total metal HAP in paragraph (a)(5)(ii) of this

section:



(6) For each pouring area or pouring station at a new iron and steel foundry, you must not discharge emissions through a conveyance to the

atmosphere that exceed either the limit for PM in paragraph (a)(6)(i) of this section or, alternatively the limit for total metal HAP in paragraph

(a)(6)(ii) of this section:



(7) For each building or structure housing any iron and steel foundry emissions source at the iron and steel foundry, you must not discharge any

fugitive emissions to the atmosphere 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 27 percent opacity.

(8) For each cupola metal melting furnace at a new or existing iron and steel foundry, you must not discharge emissions of volatile organic hazardous

air pollutants (VOHAP) through a conveyance to the atmosphere that exceed 20 parts per million by volume (ppmv) corrected to 10 percent oxygen.

(9) As an alternative to the work practice standard in §63.7700(e) for a scrap preheater at an existing iron and steel foundry or in §63.7700(f) for a

scrap preheater at a new iron and steel foundry, you must not discharge emissions of VOHAP through a conveyance to the atmosphere that exceed 20

ppmv.

(10) For one or more automated conveyor and pallet cooling lines that use a sand mold system or automated shakeout lines that use a sand mold

system at a new iron and steel foundry, you must not discharge emissions of VOHAP through a conveyance to the atmosphere that exceed a flow-

weighted average of 20 ppmv.

(11) For each triethylamine (TEA) cold box mold or core making line at a new or existing iron and steel foundry, you must meet either the emissions

limit in paragraph (a)(11)(i) of this section or, alternatively the emissions standard in paragraph (a)(11)(ii) of this section:

(i) You must not discharge emissions of TEA through a conveyance to the atmosphere that exceed 1 ppmv, as determined according to the

performance test procedures in §63.7732(g); or

(ii) You must reduce emissions of TEA from each TEA cold box mold or core making line by at least 99 percent, as determined according to the

performance test procedures in §63.7732(g).

(b) You must meet each operating limit in paragraphs (b)(1) through (5) of this section that applies to you.

(1) You must install, operate, and maintain a capture and collection system for all emissions sources subject to an emissions limit for VOHAP or

TEA in paragraphs (a)(8) through (11) of this section.

(i) Each capture and collection system must meet accepted engineering standards, such as those published by the American Conference of

Governmental Industrial Hygienists.

(ii) You must operate each capture system at or above the lowest value or settings established as operating limits in your operation and maintenance

plan.

(2) You must operate each wet scrubber applied to emissions from a metal melting furnace, scrap preheater, pouring area, or pouring station subject

to an emissions limit for PM or total metal HAP in paragraphs (a)(1) through (6) of this section such that the 3-hour average pressure drop and

scrubber water flow rate does not fall below the minimum levels established during the initial or subsequent performance test.

(3) You must operate each combustion device applied to emissions from a cupola metal melting furnace subject to the emissions limit for VOHAP in

paragraph (a)(8) of this section, such that the 15-minute average combustion zone temperature does not fall below 1,300 degrees Fahrenheit ((

°deg;F). Periods when the cupola is off blast and for 15 minutes after going on blast from an off blast condition are not included in the 15-minute

average.

(4) You must operate each combustion device applied to emissions from a scrap preheater subject to the emissions limit for VOHAP in paragraph

(a)(9) of this section or from a TEA cold box mold or core making line subject to the emissions limit for TEA in paragraph (a)(11) of this section,

such that the 3-hour average combustion zone temperature does not fall below the minimum level established during the initial or subsequent

performance test.

(5) You must operate each wet acid scrubber applied to emissions from a TEA cold box mold or core making line subject to the emissions limit for

TEA in paragraph (a)(11) of this section such that:

(i) The 3-hour average scrubbing liquid flow rate does not fall below the minimum level established during the initial or subsequent performance test;

and

(ii) The 3-hour average pH of the scrubber blowdown, as measured by a continuous parameter monitoring system (CPMS), does not exceed 4.5 or the

pH of the scrubber blowdown, as measured once every 8 hours during process operations, does not exceed 4.5.

(c) If you use a control device other than a baghouse, wet scrubber, wet acid scrubber, or combustion device, you must prepare and submit a

monitoring plan containing the information listed in paragraphs (c)(1) through (5) of this section. The monitoring plan is subject to approval by the

Administrator.

(1) A description of the device;

(2) Test results collected in accordance with §63.7732 verifying the performance of the device for reducing emissions of PM, total metal HAP,

VOHAP, or TEA to the levels required by this subpart;

(3) A copy of the operation and maintenance plan required by §63.7710(b);

(4) A list of appropriate operating parameters that will be monitored to maintain continuous compliance with the applicable emissions limitation(s);

and

(5) Operating parameter limits based on monitoring data collected during the performance test.


Work Practice Standards

§ 63.7700 What work practice standards must I meet?

(a) For each segregated scrap storage area, bin or pile, you must either comply with the certification requirements in paragraph (b) of this section, or

prepare and implement a plan for the selection and inspection of scrap according to the requirements in paragraph (c) of this section. You may have

certain scrap subject to paragraph (b) of this section and other scrap subject to paragraph (c) of this section at your facility provided the scrap remains

segregated until charge make-up.

(b) You must prepare and operate at all times according to a written certification that the foundry purchases and uses 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, mercury switches, plastics, or free organic liquids. For the purpose of this paragraph (b), “free organic liquids” is defined

as material that fails the paint filter test by EPA Method 9095A, “Paint Filter Liquids Test” (Revision 1, December 1996), as published in EPA

Publication SW–846 “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods” (incorporated by reference—see §63.14). Any post-

consumer engine blocks, post-consumer oil filters, or oily turnings that are processed and/or cleaned to the extent practicable such that the materials

do not include lead components, mercury switches, chlorinated plastics, or free organic liquids can be included in this certification.

(c) You must prepare and operate at all times according to a written plan for the selection and inspection of iron and steel scrap to minimize, to the

extent practicable, the amount of organics and HAP metals in the charge materials used by the iron and steel foundry. This scrap selection and

inspection plan is subject to approval by the Administrator. You must keep a copy of the plan onsite and readily available to all plant personnel with

materials acquisition or inspection duties. You must provide a copy of the material specifications to each of your scrap vendors. Each plan must

include the information specified in paragraphs (c)(1) through (3) of this section.

(1) A materials acquisition program to limit organic contaminants according to the requirements in paragraph (c)(1)(i) or (ii) of this section, as

applicable.

(i) For scrap charged to a scrap preheater, electric arc metal melting furnace, or electric induction metal melting furnace, specifications for scrap

materials to be depleted (to the extent practicable) of the presence of used oil filters, chlorinated plastic parts, organic liquids, and a program to

ensure the scrap materials are drained of free liquids; or

(ii) For scrap charged to a cupola metal melting furnace, specifications for scrap materials to be depleted (to the extent practicable) of the presence of

chlorinated plastic, and a program to ensure the scrap materials are drained of free liquids.

(2) A materials acquisition program specifying that the scrap supplier remove accessible mercury switches from the trunks and hoods of any

automotive bodies contained in the scrap and remove accessible lead components such as batteries and wheel weights. You must either obtain and

maintain onsite a copy of the procedures used by the scrap supplier for either removing accessible mercury switches or for purchasing automobile

bodies that have had mercury switches removed, as applicable, or document your attempts to obtain a copy of these procedures from the scrap

suppliers servicing your area.

(3) Procedures for visual inspection of a representative portion, but not less than 10 percent, of all incoming scrap shipments to ensure the materials

meet the specifications.

(i) The inspection procedures must identify the location(s) where inspections are to be performed for each type of shipment. Inspections may be

performed at the scrap supplier's facility. The selected location(s) must provide a reasonable vantage point, considering worker safety, for visual

inspection.

(ii) The inspection procedures must include recordkeeping requirements that document each visual inspection and the results.

(iii) The inspection procedures must include provisions for rejecting or returning entire or partial scrap shipments that do not meet specifications and

limiting purchases from vendors whose shipments fail to meet specifications for more than three inspections in one calendar year.

(iv) If the inspections are performed at the scrap supplier's facility, the inspection procedures must include an explanation of how the periodic

inspections ensure that not less than 10 percent of scrap purchased from each supplier is subject to inspection.

(d) For each furan warm box mold or core making line in a new or existing iron and steel foundry, you must use a binder chemical formulation that

does not contain methanol as a specific ingredient of the catalyst formulation as determined by the Material Safety Data Sheet. This requirement does

not apply to the resin portion of the binder system.

(e) For each scrap preheater at an existing iron and steel foundry, you must meet either the requirement in paragraph (e)(1) or (2) of this section. As

an alternative to the requirement in paragraph (e)(1) or (2) of this section, you must meet the VOHAP emissions limit in §63.7690(a)(9).

(1) You must operate and maintain a gas-fired preheater where the flame directly contacts the scrap charged; or

(2) You must charge only material that is subject to and in compliance with the scrap certification requirement in paragraph (b) of this section.

(f) For each scrap preheater at a new iron and steel foundry, you must charge only material that is subject to and in compliance with the scrap

certification requirement in paragraph (b) of this section. As an alternative to this requirement, you must meet the VOHAP emissions limit in

§63.7690(a)(9).

[69 FR 21923, Apr. 22, 2004, as amended at 70 FR 29404, May 20, 2005; 73 FR 7218, Feb. 7, 2008]

Operation and Maintenance Requirements

§ 63.7710 What are my operation and maintenance requirements?

(a) As required by §63.6(e)(1)(i), you must always operate and maintain your iron and steel foundry, including air pollution control and monitoring

equipment, in a manner consistent with good air pollution control practices for minimizing emissions at least to the levels required by this subpart.

(b) You must prepare and operate at all times according to a written operation and maintenance plan for each capture and collection system and

control device for an emissions source subject to a PM, metal HAP, TEA, or VOHAP emissions limit in §63.7690(a). Your operation and

maintenance plan also must include procedures for igniting gases from mold vents in pouring areas and pouring stations that use a sand mold system.

This operation and maintenance plan is subject to approval by the Administrator. Each plan must contain the elements described in paragraphs (b)(1)

through (6) of this section.

(1) 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 operation and maintenance plan must also

include requirements to repair the defect or deficiency as soon as practicable.

(2) Operating limits for each capture system for an emissions source subject to an emissions limit or standard for VOHAP or TEA in §63.7690(a)(8)

through (11). You must establish the operating according to the requirements in paragraphs (b)(2)(i) through (iii) of this section.

(i) Select operating limit parameters appropriate for the capture system design that are representative and reliable indicators of the performance of the

capture system. At a minimum, you must use appropriate operating limit parameters that indicate the level of the ventilation draft and damper

position settings for the capture system when operating to collect emissions, including revised settings for seasonal variations. Appropriate operating

limit parameters for ventilation draft include, but are not limited to: volumetric flow rate through each separately ducted hood, total volumetric flow

rate at the inlet to the control device to which the capture system is vented, fan motor amperage, or static pressure. Any parameter for damper

position setting may be used that indicates the duct damper position related to the fully open setting.

(ii) For each operating limit parameter selected in paragraph (b)(2)(i) of this section, designate the value or setting for the parameter at which the

capture system operates during the process operation. If your operation allows for more than one process to be operating simultaneously, designate

the value or setting for the parameter at which the capture system operates during each possible configuration that you may operate ( i.e., the

operating limits with one furnace melting, two melting, as applicable to your plant).

(iii) Include documentation in your plan to support your selection of the operating limits established for your capture system. This documentation

must include a description of the capture system design, a description of the capture system operating during production, a description of each

selected operating limit parameter, a rationale for why you chose the parameter, a description of the method used to monitor the parameter according

to the requirements of §63.7740(a), and the data used to set the value or setting for the parameter for each of your process configurations.

(3) Preventative maintenance plan for each control device, including a preventative maintenance schedule that is consistent with the manufacturer's

instructions for routine and long-term maintenance.

(4) A site-specific monitoring plan for each bag leak detection system. For each bag leak detection system that operates on the triboelectric effect, the

monitoring plan must be consistent with the recommendations contained in the U.S. Environmental Protection Agency guidance document “Fabric

Filter Bag Leak Detection Guidance” (EPA–454/R–98–015). This baghouse monitoring plan is subject to approval by the Administrator. The owner

or operator shall operate and maintain the bag leak detection system according to the site-specific monitoring plan at all times. The plan must address

all of the items identified in paragraphs (b)(4)(i) through (v) of this section.

(i) Installation of the bag leak detection system.

(ii) Initial and periodic adjustment of the bag leak detection system including how the alarm set-point will be established.

(iii) Operation of the bag leak detection system including quality assurance procedures.

(iv) How the bag leak detection system will be maintained including a routine maintenance schedule and spare parts inventory list.

(v) How the bag leak detection system output will be recorded and stored.

(5) Corrective action plan for each baghouse. The plan must include the requirement that, in the event a bag leak detection system alarm is triggered,

you 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 the corrective action as soon as practicable. Corrective actions taken may include, but are not

limited to:

(i) Inspecting the baghouse for air leaks, torn or broken bags or filter media, or any other condition that may cause an increase in emissions.

(ii) Sealing off defective bags or filter media.

(iii) Replacing defective bags or filter media or otherwise repairing the control device.

(iv) Sealing off a defective baghouse compartment.

(v) Cleaning the bag leak detection system probe or otherwise repairing the bag leak detection system.

(vi) Making process changes.

(vii) Shutting down the process producing the PM emissions.

(6) Procedures for providing an ignition source to mold vents of sand mold systems in each pouring area and pouring station unless you determine the

mold vent gases either are not ignitable, ignite automatically, or cannot be ignited due to accessibility or safety issues. You must document and

maintain records of this determination. The determination of ignitability, accessibility, and safety may encompass multiple casting patterns provided

the castings utilize similar sand-to-metal ratios, binder formulations, and coating materials. The determination of ignitability must be based on

observations of the mold vents within 5 minutes of pouring, and the flame must be present for at least 15 seconds for the mold vent to be considered

ignited. For the purpose of this determination:

(i) Mold vents that ignite more than 75 percent of the time without the presence of an auxiliary ignition source are considered to ignite automatically;

and

(ii) Mold vents that do not ignite automatically and cannot be ignited in the presence of an auxiliary ignition source more than 25 percent of the time

are considered to be not ignitable.


General Compliance Requirements

§ 63.7720 What are my general requirements for complying with this subpart?

(a) You must be in compliance with the emissions limitations, work practice standards, and operation and maintenance requirements in this subpart at

all times, except during periods of startup, shutdown, or malfunction.

(b) During the period between the compliance date specified for your iron and steel foundry in §63.7683 and the date when applicable operating

limits have been established during the initial performance test, you must maintain a log detailing the operation and maintenance of the process and

emissions control equipment.

(c) You must develop a written startup, shutdown, and malfunction plan according to the provisions in §63.6(e)(3). The startup, shutdown, and

malfunction plan also must specify what constitutes a shutdown of a cupola and how to determine that operating conditions are normal following

startup of a cupola.

[69 FR 21923, Apr. 22, 2004, as amended at 71 FR 20468, Apr. 20, 2006]

Initial Compliance Requirements

§ 63.7730 By what date must I conduct performance tests or other initial compliance demonstrations?

(a) As required by §63.7(a)(2), you must conduct a performance test no later than 180 calendar days after the compliance date that is specified in

§63.7683 for your iron and steel foundry to demonstrate initial compliance with each emissions limitation in §63.7690 that applies to you.

(b) For each work practice standard in §63.7700 and each operation and maintenance requirement in §63.7710 that applies to you where initial

compliance is not demonstrated using a performance test, you must demonstrate initial compliance no later than 30 calendar days after the

compliance date that is specified for your iron and steel foundry in §63.7683.

(c) If you commenced construction or reconstruction between December 23, 2002 and April 22, 2004, you must demonstrate initial compliance with

either the proposed emissions limit or the promulgated emissions limit no later than October 19, 2004 or no later than 180 calendar days after startup

of the source, whichever is later, according to §63.7(a)(2)(ix).

(d) If you commenced construction or reconstruction between December 23, 2002 and April 22, 2004, and you chose to comply with the proposed

emissions limit when demonstrating initial compliance, you must conduct a second performance test to demonstrate compliance with the

promulgated emissions limit by October 19, 2007 or after startup of the source, whichever is later, according to §63.7(a)(2)(ix).

§ 63.7731 When must I conduct subsequent performance tests?

(a) You must conduct subsequent performance tests to demonstrate compliance with all applicable PM or total metal HAP, VOHAP, and TEA

emissions limitations in §63.7690 for your iron and steel foundry no less frequently than every 5 years and each time you elect to change an operating

limit or to comply with a different alternative emissions limit, if applicable. The requirement to conduct performance tests every 5 years does not

apply to an emissions source for which a continuous emissions monitoring system (CEMS) is used to demonstrate continuous compliance.

(b) You must conduct subsequent performance tests to demonstrate compliance with the opacity limit in §63.7690(a)(7) for your iron and steel

foundry no less frequently than once every 6 months.


§ 63.7732 What test methods and other procedures must I use to demonstrate initial compliance with the emissions

limitations?

(a) You must conduct each performance test that applies to your iron and steel foundry based on your selected compliance alternative, if applicable,

according to the requirements in §63.7(e)(1) and the conditions specified in paragraphs (b) through (i) of this section.

(b) To determine compliance with the applicable emissions limit for PM in §63.7690(a)(1) through (6) for a metal melting furnace, scrap preheater,

pouring station, or pouring area, follow the test methods and procedures in paragraphs (b)(1) through (6) of this section.

(1) Determine the concentration of PM according to the test methods in 40 CFR part 60, appendix A that are specified in paragraphs (b)(1)(i) through

(v) of this section.

(i) Method 1 or 1A to select sampling port locations and the number of traverse points in each stack or duct. Sampling sites must be located at the

outlet of the control device (or at the outlet of the emissions source if no control device is present) prior to any releases to the atmosphere.

(ii) Method 2, 2A, 2C, 2D, 2F, or 2G to determine the volumetric flow rate of the stack gas.

(iii) Method 3, 3A, or 3B to determine the dry molecular weight of the stack gas.

(iv) Method 4 to determine the moisture content of the stack gas.

(v) Method 5, 5B, 5D, 5F, or 5I, as applicable, to determine the PM concentration. The PM concentration is determined using only the front-half

(probe rinse and filter) of the PM catch.

(2) Collect a minimum sample volume of 60 dscf of gas during each PM sampling run. A minimum of three valid test runs are needed to comprise a

performance test.

(3) For cupola metal melting furnaces, sample only during times when the cupola is on blast.

(4) For electric arc and electric induction metal melting furnaces, sample only during normal production conditions, which may include, but are not

limited to the following cycles: Charging, melting, alloying, refining, slagging, and tapping.

(5) For scrap preheaters, sample only during normal production conditions, which may include, but are not limited to the following cycles: Charging,

heating, and discharging.

(6) Determine the total mass of metal charged to the furnace or scrap preheater. For a cupola metal melting furnace at an existing iron and steel

foundry that is subject to the PM emissions limit in §63.7690(a)(ii), calculate the PM emissions rate in pounds of PM per ton (lb/ton) of metal

charged using Equation 1 of this section:

Where:

EFPM= Mass emissions rate of PM, pounds of PM per ton (lb/ton) of metal charged;

CPM= Concentration of PM measured during performance test run, gr/dscf;

Q = Volumetric flow rate of exhaust gas, dry standard cubic feet per minute (dscfm);

Mcharge= Mass of metal charged during performance test run, tons;

ttest= Duration of performance test run, minutes; and

7,000 = Unit conversion factor, grains per pound (gr/lb).

(c) To determine compliance with the applicable emissions limit for total metal HAP in §63.7690(a)(1) through (6) for a metal melting furnace, scrap

preheater, pouring station, or pouring area, follow the test methods and procedures in paragraphs (c)(1) through (6) of this section.

(1) Determine the concentration of total metal HAP according to the test methods in 40 CFR part 60, appendix A that are specified in paragraphs

(c)(1)(i) through (v) of this section.






(v) Method 29 to determine the total metal HAP concentration.

(2) A minimum of three valid test runs are needed to comprise a performance test.

(3) For cupola metal melting furnaces, sample only during times when the cupola is on blast.

(4) For electric arc and electric induction metal melting furnaces, sample only during normal production conditions, which may include, but are not

limited to the following cycles: Charging, melting, alloying, refining, slagging, and tapping.

(5) For scrap preheaters, sample only during normal production conditions, which may include, but are not limited to the following cycles: Charging,

heating, and discharging.

(6) Determine the total mass of metal charged to the furnace or scrap preheater during each performance test run and calculate the total metal HAP

emissions rate (pounds of total metal HAP per ton (lb/ton) of metal charged) using Equation 2 of this section:

Where:

EFTMHAP= Emissions rate of total metal HAP, pounds of total metal HAP per ton (lb/ton) of metal charged;

CTMHAP= Concentration of total metal HAP measured during performance test run, gr/dscf;

Q = Volumetric flow rate of exhaust gas, dscfm;

Mcharge= Mass of metal charged during performance test run, tons;

ttest= Duration of performance test run, minutes; and

7,000 = Unit conversion factor, gr/lb.

(d) To determine compliance with the opacity limit in §63.7690(a)(7) for fugitive emissions from buildings or structures housing any iron and steel

foundry emissions source at the iron and steel foundry, follow the procedures in paragraphs (d)(1) and (2) of this section.

(1) Using a certified observer, conduct each opacity test according to the requirements in EPA Method 9 (40 CFR part 60, appendix A) and

§63.6(h)(5). The certified observer may identify a limited number of openings or vents that appear to have the highest opacities and perform opacity

observations on the identified openings or vents in lieu of performing observations for each opening or vent from the building or structure.

Alternatively, a single opacity observation for the entire building or structure may be performed, if the fugitive release points afford such an

observation.

(2) During testing intervals when PM performance tests, if applicable, are being conducted, conduct the opacity test such the opacity observations are

recorded during the PM performance tests.

(e) To determine compliance with the applicable VOHAP emissions limit in §63.7690(a)(8) for a cupola metal melting furnace or in §63.7690(a)(9)

for a scrap preheater, follow the test methods and procedures in paragraphs (e)(1) through (4) of this section.

(1) Determine the VOHAP concentration for each test run according to the test methods in 40 CFR part 60, appendix A that are specified in

paragraphs (b)(1)(i) through (v) of this section.






(v) Method 18 to determine the VOHAP concentration. Alternatively, you may use Method 25 to determine the concentration of total gaseous

nonmethane organics (TGNMO) or Method 25A to determine the concentration of total organic compounds (TOC), using hexane as the calibration

gas.

(2) Determine the average VOHAP, TGNMO, or TOC concentration using a minimum of three valid test runs. Each test run must include a minimum

of 60 continuous operating minutes.

(3) For a cupola metal melting furnace, correct the measured concentration of VOHAP, TGNMO, or TOC for oxygen content in the gas stream using

Equation 3 of this section:

Where:

CVOHAP= Concentration of VOHAP in ppmv as measured by Method 18 in 40 CFR part 60, appendix A or the concentration of

TGNMO or TOC in ppmv as hexane as measured by Method 25 or 25A in 40 CFR part 60, appendix A; and

%O2= Oxygen concentration in gas stream, percent by volume (dry basis).

(4) For a cupola metal melting furnace, measure the combustion zone temperature of the combustion device with the CPMS required in §63.7740(d)

during each sampling run in 15-minute intervals. Determine and record the 15-minute average of the three runs.

(f) Follow the applicable procedures in paragraphs (f)(1) through (3) of this section to determine compliance with the VOHAP emissions limit in

§63.7690(a)(10) for automated pallet cooling lines or automated shakeout lines.

(1) Follow these procedures to demonstrate compliance by direct measurement of total hydrocarbons (a surrogate for VOHAP) using a volatile

organic compound (VOC) CEMS.

(i) Using the VOC CEMS required in §63.7740(g), measure and record the concentration of total hydrocarbons (as hexane) for 180 continuous

operating minutes. You must measure emissions at the outlet of the control device (or at the outlet of the emissions source if no control device is

present) prior to any releases to the atmosphere.

(ii) Reduce the monitoring data to hourly averages as specified in §63.8(g)(2).

(iii) Compute and record the 3-hour average of the monitoring data.

(2) As an alternative to the procedures in paragraph (f)(1) of this section, you may demonstrate compliance with the VOHAP emissions limit in

§63.7690(a)(10) by establishing a site-specific TOC emissions limit that is correlated to the VOHAP emissions limit according to the procedures in

paragraph (f)(2)(i) through (ix) of this section.

(i) Determine the VOHAP concentration for each test run according to the test methods in 40 CFR part 60, appendix A that are specified in paragraph

(f)(2)(ii) through (vi) of this section.

(ii) Method 1 or 1A to select sampling port locations and the number of traverse points in each stack or duct. Sampling sites must be located at the


(iii) Method 2, 2A, 2C, 2D, 2F, or 2G to determine the volumetric flow rate of the stack gas.

(iv) Method 3, 3A, or 3B to determine the dry molecular weight of the stack gas.

(v) Method 4 to determine the moisture content of the stack gas.

(vi) Method 18 to determine the VOHAP concentration. Alternatively, you may use Method 25 to determine the concentration of TGNMO using

hexane as the calibration gas.

(vii) Using the CEMS required in §63.7740(g), measure and record the concentration of total hydrocarbons (as hexane) during each of the Method 18

(or Method 25) sampling runs. You must measure emissions at the outlet of the control device (or at the outlet of the emissions source if no control

device is present) prior to any releases to the atmosphere.

(viii) Calculate the average VOHAP (or TGNMO) concentration for the source test as the arithmetic average of the concentrations measured for the

individual test runs, and determine the average concentration of total hydrocarbon (as hexane) as measured by the CEMS during all test runs.

(ix) Calculate the site-specific VOC emissions limit using Equation 4 of this section:

Where:

CVOHAP,avg= Average concentration of VOHAP for the source test in ppmv as measured by Method 18 in 40 CFR part 60,

appendix A or the average concentration of TGNMO for the source test in ppmv as hexane as measured by Method 25 in 40 CFR part

60, appendix A; and

CCEM= Average concentration of total hydrocarbons in ppmv as hexane as measured using the CEMS during the source test.

(3) For two or more exhaust streams from one or more automated conveyor and pallet cooling lines or automated shakeout lines, compute the flow-

weighted average concentration of VOHAP emissions for each combination of exhaust streams using Equation 5 of this section:

Where:

Cw= Flow-weighted concentration of VOHAP or VOC, ppmv (as hexane);

Ci= Concentration of VOHAP or VOC from exhaust stream “i”, ppmv (as hexane);

n = Number of exhaust streams sampled; and

Qi= Volumetric flow rate of effluent gas from exhaust stream “i,”, dscfm.

(g) To determine compliance with the emissions limit or standard in §63.7690(a)(11) for a TEA cold box mold or core making line, follow the test

methods in 40 CFR part 60, appendix A, specified in paragraphs (g)(1) through (4) of this section.

(1) Determine the TEA concentration for each test run according to the test methods in 40 CFR part 60, appendix A that are specified in paragraphs

(g)(1)(i) through (v) of this section.

(i) Method 1 or 1A to select sampling port locations and the number of traverse points in each stack or duct. If you elect to meet the 99 percent

reduction standard, sampling sites must be located both at the inlet to the control device and at the outlet of the control device prior to any releases to

the atmosphere. If you elect to meet the concentration limit, the sampling site must be located at the outlet of the control device (or at the outlet of the

emissions source if no control device is present) prior to any releases to the atmosphere.




(v) Method 18 to determine the TEA concentration. Alternatively, you may use NIOSH Method 2010 (incorporated by reference—see §63.14) to

determine the TEA concentration provided the performance requirements outlined in section 13.1 of EPA Method 18 are satisfied. The sampling

option and time must be sufficiently long such that either the TEA concentration in the field sample is at least 5 times the limit of detection for the

analytical method or the test results calculated using the laboratory's reported analytical detection limit for the specific field samples are less

than1/5of the applicable emissions limit. When using Method 18, the adsorbent tube approach, as described in section 8.2.4 of Method 18, may be

required to achieve the necessary analytical detection limits. The sampling time must be at least 1 hour in all cases.

(2) If you use a wet acid scrubber, conduct the test as soon as practicable after adding fresh acid solution and the system has reached normal

operating conditions.

(3) If you use a wet acid scrubber that is subject to the operating limit in §63.7690(b)(5)(ii) for pH level, determine the pH of the scrubber blowdown

using the procedures in paragraph (g)(3)(i) or (ii) of this section.

(i) Measure the pH of the scrubber blowdown with the CPMS required in §63.7740(f)(2) during each TEA sampling run in intervals of no more than

15 minutes. Determine and record the 3-hour average; or

(ii) Measure and record the pH level using the probe and meter required in §63.7740(f)(2) once each sampling run. Determine and record the average

pH level for the three runs.

(4) If you are subject to the 99 percent reduction standard, calculate the mass emissions reduction using Equation 6 of this section:

Where:

Ei= Mass emissions rate of TEA at control device inlet, kilograms per hour (kg/hr); and

Eo= Mass emissions rate of TEA at control device outlet, kg/hr.

(h) To determine compliance with the PM or total metal HAP emissions limits in §63.7690(a)(1) through (6) when one or more regulated emissions

sources are combined with either another regulated emissions source subject to a different emissions limit or other non-regulated emissions sources,

you may demonstrate compliance using one of the procedures in paragraphs (h)(1) through (3) of this section.

(1) Meet the most stringent applicable emissions limit for the regulated emissions sources included in the combined emissions stream for the

combined emissions stream.

(2) Use the procedures in paragraphs (h)(2)(i) through (iii) of this section.

(i) Determine the volumetric flow rate of the individual regulated streams for which emissions limits apply.

(ii) Calculate the flow-weighted average emissions limit, considering only the regulated streams, using Equation 5 of this section, except Cwis the

flow-weighted average emissions limit for PM or total metal HAP in the exhaust stream, gr/dscf; and Ciis the concentration of PM or total metal

HAP in exhaust stream “i”, gr/dscf.

(iii) Meet the calculated flow-weighted average emissions limit for the regulated emissions sources included in the combined emissions stream for

the combined emissions stream.

(3) Use the procedures in paragraphs (h)(3)(i) through (iii) of this section.

(i) Determine the PM or total metal HAP concentration of 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 Equation 6 of this section, except Eiis the mass emissions rate of PM or total metal

HAP at the control device inlet, lb/hr and Eois the 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 concentration for the regulated emissions sources using

Equation 7 of this section:

Where:

Creleased= Calculated concentration of PM (or total metal HAP) predicted to be released to the atmosphere from the regulated

emissions source, gr/dscf; and

Ci= Concentration of PM (or total metal HAP) in the uncontrolled regulated exhaust stream, gr/dscf.

(i) 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 paragraphs (b) through (h) of this section, a site-specific test plan

should be submitted to the Administrator for approval according to the requirements in §63.7(c)(2) and (3).


§ 63.7733 What procedures must I use to establish operating limits?

(a) For each capture system subject to operating limits in §63.7690(b)(1)(ii), you must establish site-specific operating limits in your operation and

maintenance plan according to the procedures in paragraphs (a)(1) through (3) of this section.

(1) Concurrent with applicable emissions and opacity tests, measure and record values for each of the operating limit parameters in your capture

system operation and maintenance plan according to the monitoring requirements in §63.7740(a).

(2) For any dampers that are manually set and remain at the same position at all times the capture system is operating, the damper position must be

visually checked and recorded at the beginning and end of each run.

(3) Review and record the monitoring data. Identify and explain any times the capture system operated outside the applicable operating limits.

(b) For each wet scrubber subject to the operating limits in §63.7690(b)(2) for pressure drop and scrubber water flow rate, you must establish site-

specific operating limits according to the procedures specified in paragraphs (b)(1) and (2) of this section.

(1) Using the CPMS required in §63.7740(c), measure and record the pressure drop and scrubber water flow rate in intervals of no more than 15

minutes during each PM test run.

(2) Compute and record the average pressure drop and average scrubber water flow rate for each valid sampling run in which the applicable

emissions limit is met.

(c) For each combustion device applied to emissions from a scrap preheater or TEA cold box mold or core making line subject to the operating limit

in §63.7690(b)(4) for combustion zone temperature, you must establish a site-specific operating limit according to the procedures specified in

paragraphs (c)(1) and (2) of this section.

(1) Using the CPMS required in §63.7740(e), measure and record the combustion zone temperature during each sampling run in intervals of no more

than 15 minutes.

(2) Compute and record the average combustion zone temperature for each valid sampling run in which the applicable emissions limit is met.

(d) For each acid wet scrubber subject to the operating limit in §63.7690(b)(5), you must establish a site-specific operating limit for scrubbing liquid

flow rate according to the procedures specified in paragraphs (d)(1) and (2) of this section.

(1) Using the CPMS required in §63.7740(f), measure and record the scrubbing liquid flow rate during each TEA sampling run in intervals of no

more than 15 minutes.

(2) Compute and record the average scrubbing liquid flow rate for each valid sampling run in which the applicable emissions limit is met.

(e) You may change the operating limits for a capture system, wet scrubber, acid wet scrubber, or combustion device if you meet the requirements in

paragraphs (e)(1) through (3) of this section.

(1) Submit a written notification to the Administrator of your request to conduct a new performance test to revise the operating limit.

(2) Conduct a performance test to demonstrate compliance with the applicable emissions limitation in §63.7690.

(3) Establish revised operating limits according to the applicable procedures in paragraphs (a) through (d) of this section.

(f) You may use a previous performance test (conducted since December 22, 2002) to establish an operating limit provided the test meets the

requirements of this subpart.


§ 63.7734 How do I demonstrate initial compliance with the emissions limitations that apply to me?

(a) You have demonstrated initial compliance with the emissions limits in §63.7690(a) by meeting the applicable conditions in paragraphs (a)(1)

through (11) of this section. When alternative emissions limitations are provided for a given emissions source, you are not restricted in the selection

of which applicable alternative emissions limitation is used to demonstrate compliance.

(1) For each electric arc metal melting furnace, electric induction metal melting furnace, or scrap preheater at an existing iron and steel foundry,

(i) The average PM concentration in the exhaust stream, determined according to the performance test procedures in §63.7732(b), did not exceed

0.005 gr/dscf; or

(ii) The average total metal HAP concentration in the exhaust stream, determined according to the performance test procedures in §63.7732(c), did

not exceed 0.0004 gr/dscf.

(2) For each cupola metal melting furnace at an existing iron and steel foundry,


0.006 gr/dscf; or


not exceed 0.0005 gr/dscf; or

(iii) The average PM mass emissions rate, determined according to the performance test procedures in §63.7732(b), did not exceed 0.10 pound of PM

per ton (lb/ton) of metal charged; or

(iv) The average total metal HAP mass emissions rate, determined according to the performance test procedures in §63.7732(c), did not exceed 0.008

pound of total metal HAP per ton (lb/ton) of metal charged.

(3) For each cupola metal melting furnace or electric arc metal melting furnace at a new iron and steel foundry,


0.002 gr/dscf; or



(4) For each electric induction metal melting furnace or scrap preheater at a new iron and steel foundry,


0.001 gr/dscf; or



(5) For each pouring station at an existing iron and steel foundry,

(i) The average PM concentration in the exhaust stream, measured according to the performance test procedures in §63.7732(b), did not exceed 0.010

gr/dscf; or



(6) For each pouring area or pouring station at a new iron and steel foundry,

(i) The average PM concentration in the exhaust stream, measured according to the performance test procedures in §63.7732(b), did not exceed 0.002

gr/dscf; or



(7) For each building or structure housing any iron and steel foundry emissions source at the iron and steel foundry, the opacity of fugitive emissions

from foundry operations discharged to the atmosphere, determined according to the performance test procedures in §63.7732(d), did not exceed 20

percent (6-minute average), except for one 6-minute average per hour that did not exceed 27 percent opacity.

(8) For each cupola metal melting furnace at a new or existing iron and steel foundry, the average VOHAP concentration, determined according to

the performance test procedures in §63.7732(e), did not exceed 20 ppmv corrected to 10 percent oxygen.

(9) For each scrap preheater at an existing iron and steel foundry that does not meet the work practice standards in §63.7700(e)(1) or (2) and for each

scrap preheater at a new iron and steel foundry that does not meet the work practice standard in §63.7700(f), the average VOHAP concentration

determined according to the performance test procedures in §63.7732(e), did not exceed 20 ppmv.

(10) For one or more automated conveyor and pallet cooling lines that use a sand mold system or automated shakeout lines that use a sand mold

system at a new foundry,

(i) You have reduced the data from the CEMS to 3-hour averages according to the performance test procedures in §63.7732(f)(1) or (2); and

(ii) The 3-hour flow-weighted average VOHAP concentration, measured according to the performance test procedures in §63.7332(f)(1) or (2), did

not exceed 20 ppmv.

(11) For each TEA cold box mold or core making line in a new or existing iron and steel foundry, the average TEA concentration, determined

according to the performance test procedures in §63.7732(g), did not exceed 1 ppmv or was reduced by 99 percent.

(b) You have demonstrated initial compliance with the operating limits in §63.7690(b) if:

(1) For each capture system subject to the operating limit in §63.7690(b)(1)(ii),

(i) You have established appropriate site-specific operating limits in your operation and maintenance plan according to the requirements in

§63.7710(b); and

(ii) You have a record of the operating parameter data measured during the performance test in accordance with §63.7733(a); and

(2) For each wet scrubber subject to the operating limits in §63.7690(b)(2) for pressure drop and scrubber water flow rate, you have established

appropriate site-specific operating limits and have a record of the pressure drop and scrubber water flow rate measured during the performance test in

accordance with §63.7733(b).

(3) For each combustion device subject to the operating limit in §63.7690(b)(3) for combustion zone temperature, you have a record of the

combustion zone temperature measured during the performance test in accordance with §63.7732(e)(4).

(4) For each combustion device subject to the operating limit in §63.7690(b)(4) for combustion zone temperature, you have established appropriate

site-specific operating limits and have a record of the combustion zone temperature measured during the performance test in accordance with

§63.7733(c).

(5) For each acid wet scrubber subject to the operating limits in §63.7690(b)(5) for scrubbing liquid flow rate and scrubber blowdown pH,

(i) You have established appropriate site-specific operating limits for the scrubbing liquid flow rate and have a record of the scrubbing liquid flow

rate measured during the performance test in accordance with §63.7733(d); and

(ii) You have a record of the pH of the scrubbing liquid blowdown measured during the performance test in accordance with §63.7732(g)(3).


§ 63.7735 How do I demonstrate initial compliance with the work practice standards that apply to me?

(a) For each iron and steel foundry subject to the certification requirement in §63.7700(b), you have demonstrated initial compliance if you have

certified in your notification of compliance status that: “At all times, your foundry will purchase and use 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, mercury switches, plastics, or free organic liquids.”

(b) For each iron and steel foundry subject to the requirements in §63.7700(c) for a scrap inspection and selection plan, you have demonstrated initial

compliance if you have certified in your notification of compliance status that:

(1) You have submitted a written plan to the Administrator for approval according to the requirements in §63.7700(c); and

(2) You will operate at all times according to the plan requirements.

(c) For each furan warm box mold or core making line in a new or existing foundry subject to the work practice standard in §63.7700(d), you have

demonstrated initial compliance if you have certified in your notification of compliance status that:

(1) You will meet the no methanol requirement for the catalyst portion of each binder chemical formulation; and

(2) You have records documenting your certification of compliance, such as a material safety data sheet (provided that it contains appropriate

information), a certified product data sheet, or a manufacturer's hazardous air pollutant data sheet, onsite and available for inspection.

(d) For each scrap preheater at an existing iron and steel foundry subject to the work practice standard in §63.7700(e)(1) or (2), you have

demonstrated initial compliance if you have certified in your notification of compliance status that:

(1) You have installed a gas-fired preheater where the flame directly contacts the scrap charged, you will operate and maintain each gas-fired scrap

preheater such that the flame directly contacts the scrap charged, and you have records documenting your certification of compliance that are onsite

and available for inspection; or

(2) You will charge only material that is subject to and in compliance with the scrap certification requirements in §63.7700(b) and you have records

documenting your certification of compliance that are onsite and available for inspection.

(e) For each scrap preheater at a new iron and steel foundry subject to the work practice standard in §63.7700(f), you have demonstrated initial

compliance if you have certified in your notification of compliance status that you will charge only material that is subject to and in compliance with

the scrap certification requirements in §63.7700(b) and you have records documenting your certification of compliance that are onsite and available

for inspection.

[69 FR 21923, Apr. 22, 2004, as amended at 70 FR 29404, May 20, 2005]

§ 63.7736 How do I demonstrate initial compliance with the operation and maintenance requirements that apply to me?

(a) For each capture system subject to an operating limit in §63.7690(b), you have demonstrated initial compliance if you have met the conditions in

paragraphs (a)(1) and (2) of this section.

(1) You have certified in your notification of compliance status that:

(i) You have submitted the capture system operation and maintenance plan to the Administrator for approval according to the requirements of

§63.7710(b); and

(ii) You will inspect, operate, and maintain each capture system according to the procedures in the plan.

(2) You have certified in your performance test report that the system operated during the test at the operating limits established in your operation and

maintenance plan.

(b) For each control device subject to an operating limit in §63.7690(b), you have demonstrated initial compliance if you have certified in your

notification of compliance status that:

(1) You have submitted the control device operation and maintenance plan to the Administrator for approval according to the requirements of

§63.7710(b); and

(2) You will inspect, operate, and maintain each control device according to the procedures in the plan.

(c) For each bag leak detection system, you have demonstrated initial compliance if you have certified in your notification of compliance status that:

(1) You have submitted the bag leak detection system monitoring information to the Administrator within the written O&M plan for approval

according to the requirements of §63.7710(b);

(2) You will inspect, operate, and maintain each bag leak detection system according to the procedures in the plan; and

(3) You will follow the corrective action procedures for bag leak detection system alarms according to the requirements in the plan.

(d) For each pouring area and pouring station in a new or existing foundry, you have demonstrated initial compliance if you have certified in your

notification of compliance status report that:

(1) You have submitted the mold vent ignition plan to the Administrator for approval according to the requirements in §63.7710(b); and

(2) You will follow the procedures for igniting mold vent gases according to the requirements in the plan.


Continuous Compliance Requirements

§ 63.7740 What are my monitoring requirements?

(a) For each capture system subject to an operating limit in §63.7690(b)(1), you must install, operate, and maintain a CPMS according to the

requirements in §63.7741(a) and the requirements in paragraphs (a)(1) and (2) of this section.

(1) If you use a flow measurement device to monitor the operating limit parameter, you must at all times monitor the hourly average rate ( e.g., the

hourly average actual volumetric flow rate through each separately ducted hood or the average hourly total volumetric flow rate at the inlet to the

control device).

(2) Dampers that are manually set and remain in the same position are exempt from the requirement to install and operate a CPMS. If dampers are

not manually set and remain in the same position, you must make a visual check at least once every 24 hours to verify that each damper for the

capture system is in the same position as during the initial performance test.

(b) For each negative pressure baghouse or positive pressure baghouse equipped with a stack that is applied to meet any PM or total metal HAP

emissions limitation in this subpart, you must at all times monitor the relative change in PM loadings using a bag leak detection system according to

the requirements in §63.7741(b).

(c) For each baghouse, regardless of type, that is applied to meet any PM or total metal HAP emissions limitation in this subpart, you must conduct

inspections at their specified frequencies according to the requirements specified in paragraphs (c)(1) through (8) of this section.

(1) Monitor the pressure drop across each baghouse cell each day to ensure pressure drop is within the normal operating range identified in the

manual.

(2) Confirm that dust is being removed from hoppers through weekly visual inspections or other means of ensuring the proper functioning of removal

mechanisms.

(3) Check the compressed air supply for pulse-jet baghouses each day.

(4) Monitor cleaning cycles to ensure proper operation using an appropriate methodology.

(5) Check bag cleaning mechanisms for proper functioning through monthly visual inspections or equivalent means.

(6) Make monthly visual checks of bag tension on reverse air and shaker-type baghouses to ensure that bags are not kinked (kneed or bent) or lying

on their sides. You do not have to make this check for shaker-type baghouses using self-tensioning (spring-loaded) devices.

(7) Confirm the physical integrity of the baghouse through quarterly visual inspections of the baghouse interior for air leaks.

(8) Inspect fans for wear, material buildup, and corrosion through quarterly visual inspections, vibration detectors, or equivalent means.

(d) For each wet scrubber subject to the operating limits in §63.7690(b)(2), you must at all times monitor the 3-hour average pressure drop and

scrubber water flow rate using CPMS according to the requirements in §63.7741(c).

(e) For each combustion device subject to the operating limit in §63.7690(b)(3), you must at all times monitor the 15-minute average combustion

zone temperature using a CPMS according to the requirements of §63.7741(d).

(f) For each combustion device subject to the operating limit in §63.7690(b)(4), you must at all times monitor the 3-hour average combustion zone

temperature using CPMS according to the requirements in §63.7741(d).

(g) For each wet acid scrubber subject to the operating limits in §63.7690(b)(5),

(1) You must at all times monitor the 3-hour average scrubbing liquid flow rate using CPMS according to the requirements of §63.7741(e)(1); and

(2) You must at all times monitor the 3-hour average pH of the scrubber blowdown using CPMS according to the requirements in §63.7741(e)(2) or

measure and record the pH of the scrubber blowdown once per production cycle using a pH probe and meter according to the requirements in

§63.7741(e)(3).

(h) For one or more automated conveyor and pallet cooling lines and automated shakeout lines at a new iron and steel foundry subject to the VOHAP

emissions limit in §63.7690(a)(10), you must at all times monitor the 3-hour average VOHAP concentration using a CEMS according to the

requirements of §63.7741(g).


§ 63.7741 What are the installation, operation, and maintenance requirements for my monitors?

(a) For each capture system subject to an operating limit in §63.7690(b)(1), you must install, operate, and maintain each CPMS according to the

requirements in paragraphs (a)(1) through (3) of this section.

(1) If you use a flow measurement device to monitor an operating limit parameter for a capture system, you must meet the requirements in

paragraphs (a)(1)(i) through (iv) of this section.

(i) Locate the flow sensor and other necessary equipment such as straightening vanes in a position that provides a representative flow and that

reduces swirling flow or abnormal velocity distributions due to upstream and downstream disturbances.

(ii) Use a flow sensor with a minimum measurement sensitivity of 2 percent of the flow rate.

(iii) Conduct a flow sensor calibration check at least semiannually.

(iv) At least monthly, visually inspect all components, including all electrical and mechanical connections, for proper functioning.

(2) If you use a pressure measurement device to monitor the operating limit parameter for a capture system, you must meet the requirements in

paragraphs (a)(2)(i) through (vi) of this section.

(i) Locate the pressure sensor(s) in or as close as possible to a position that provides a representative measurement of the pressure and that minimizes

or eliminates pulsating pressure, vibration, and internal and external corrosion.

(ii) Use a gauge with a minimum measurement sensitivity of 0.5 inch of water or a transducer with a minimum measurement sensitivity of 1 percent

of the pressure range.

(iii) Check the pressure tap for pluggage daily. If a “non-clogging” pressure tap is used, check for pluggage monthly.

(iv) Using a manometer or equivalent device such as a magnahelic or other pressure indicating transmitter, check gauge and transducer calibration

quarterly.

(v) Conduct calibration checks any time the sensor exceeds the manufacturer's specified maximum operating pressure range, or install a new pressure

sensor.

(vi) At least monthly, visually inspect all components, including all electrical and mechanical connections, for proper functioning.

(3) Record the results of each inspection, calibration, and validation check.

(b) For each negative pressure baghouse or positive pressure baghouse equipped with a stack that is applied to meet any PM or total metal HAP

emissions limitation in this subpart, you must install, operate, and maintain a bag leak detection system according to the requirements in paragraphs

(b)(1) through (7) of this section.

(1) 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 (0.0044 grains per actual cubic foot) or less.

(2) 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 electronic or other means ( e.g., using a strip chart recorder or a data logger).

(3) 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.

(4) 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 and the alarm delay time (if applicable).

(5) Following the initial adjustment, do not adjust the sensitivity or range, averaging period, alarm set point, or alarm delay time without approval

from the Administrator. Except, once per quarter, you 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 operation and maintenance plan required by §63.7710(b).

(6) For negative pressure, 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.

(7) Where multiple detectors are required, the system's instrumentation and alarm may be shared among detectors.

(c) For each wet scrubber subject to the operating limits in §63.7690(b)(2), you must install and maintain CPMS to measure and record the pressure

drop and scrubber water flow rate according to the requirements in paragraphs (c)(1) and (2) of this section.

(1) For each CPMS for pressure drop you must:

(i) Locate the pressure sensor in or as close as possible to a position that provides a representative measurement of the pressure drop and that

minimizes or eliminates pulsating pressure, vibration, and internal and external corrosion.

(ii) Use a gauge with a minimum measurement sensitivity of 0.5 inch of water or a transducer with a minimum measurement sensitivity of 1 percent

of the pressure range.

(iii) Check the pressure tap for pluggage daily. If a “non-clogging” pressure tap is used, check for pluggage monthly.

(iv) Using a manometer or equivalent device such as a magnahelic or other pressure indicating transmitter, check gauge and transducer calibration

quarterly.

(v) Conduct calibration checks any time the sensor exceeds the manufacturer's specified maximum operating pressure range, or install a new pressure

sensor.

(vi) At least monthly, visually inspect all components, including all electrical and mechanical connections, for proper functioning.

(2) For each CPMS for scrubber liquid flow rate, you must:

(i) Locate the flow sensor and other necessary equipment in a position that provides a representative flow and that reduces swirling flow or abnormal

velocity distributions due to upstream and downstream disturbances.

(ii) Use a flow sensor with a minimum measurement sensitivity of 2 percent of the flow rate.

(iii) Conduct a flow sensor calibration check at least semiannually according to the manufacturer's instructions.


(d) For each combustion device subject to the operating limit in §63.7690(b)(3) or (4), you must install and maintain a CPMS to measure and record

the combustion zone temperature according to the requirements in paragraphs (d)(1) through (8) of this section.

(1) Locate the temperature sensor in a position that provides a representative temperature.

(2) For a noncryogenic temperature range, use a temperature sensor with a minimum tolerance of 2.2 °C or 0.75 percent of the temperature value,

whichever is larger.

(3) For a cryogenic temperature range, use a temperature sensor with a minimum tolerance of 2.2 °C or 2 percent of the temperature value, whichever

is larger.

(4) Shield the temperature sensor system from electromagnetic interference and chemical contaminants.

(5) If you use a chart recorder, it must have a sensitivity in the minor division of at least 20 °F.

(6) Perform an electronic calibration at least semiannually according to the procedures in the manufacturer's owners manual. Following the electronic

calibration, conduct a temperature sensor validation check, in which a second or redundant temperature sensor placed nearby the process temperature

sensor must yield a reading within 16.7 °C of the process temperature sensor's reading.

(7) Conduct calibration and validation checks any time the sensor exceeds the manufacturer's specified maximum operating temperature range, or

install a new temperature sensor.

(8) At least monthly, visually inspect all components, including all electrical and mechanical connections, for proper functioning.

(e) For each wet acid scrubber subject to the operating limits in §63.7690(b)(5), you must:

(1) Install and maintain CPMS to measure and record the scrubbing liquid flow rate according to the requirements in paragraph (c)(2) of this section;

and

(2) Install and maintain CPMS to measure and record the pH of the scrubber blowdown according to the requirements in paragraph (e)(2)(i) through

(iv) of this section.

(i) Locate the pH sensor in a position that provides a representative measurement of the pH and that minimizes or eliminates internal and external

corrosion.

(ii) Use a gauge with a minimum measurement sensitivity of 0.1 pH or a transducer with a minimum measurement sensitivity of 5 percent of the pH

range.

(iii) Check gauge calibration quarterly and transducer calibration monthly using a manual pH gauge.


(3) As an alternative to the CPMS required in paragraph (e)(2) of this section, you may use a pH probe to extract a sample for analysis by a pH meter

that meets the requirements in paragraphs (e)(3)(i) through (iii) of this section.

(i) The pH meter must have a range of at least 1 to 5 or more;

(ii) The pH meter must have an accuracy of ±0.1; and

(iii) The pH meter must have a resolution of at least 0.1 pH.

(f) You must operate each CPMS used to meet the requirements of this subpart according to the requirements specified in paragraphs (f)(1) through

(3) of this section.

(1) Each CPMS must complete a minimum of one cycle of operation for each successive 15-minute period. You must have a minimum of three of the

required four data points to constitute a valid hour of data.

(2) Each CPMS must have valid hourly data for 100 percent of every averaging period.

(3) Each CPMS must determine and record the hourly average of all recorded readings and the 3-hour average of all recorded readings.

(g) For each automated conveyor and pallet cooling line and automated shakeout line at a new iron and steel foundry subject to the VOHAP

emissions limit in §63.7690(a)(10), you must install, operate, and maintain a CEMS to measure and record the concentration of VOHAP emissions

according to the requirements in paragraphs (g)(1) through (3) of this section.

(1) You must install, operate, and maintain each CEMS according to Performance Specification 8 in 40 CFR part 60, appendix B.

(2) You must conduct a performance evaluation of each CEMS according to the requirements of §63.8 and Performance Specification 8 in 40 CFR

part 60, appendix B.

(3) You must operate each CEMS according to the requirements specified in paragraph (g)(3)(i) through (iv) of this section.

(i) As specified in §63.8(c)(4)(ii), each CEMS must complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for

each successive 15-minute period.

(ii) You must reduce CEMS data as specified in §63.8(g)(2).

(iii) Each CEMS must determine and record the 3-hour average emissions using all the hourly averages collected for periods during which the CEMS

is not out-of-control.

(iv) Record the results of each inspection, calibration, and validation check.


§ 63.7742 How do I monitor and collect data to demonstrate continuous compliance?

(a) Except for monitoring malfunctions, associated repairs, and required quality assurance or control activities (including as applicable, calibration

checks and required zero and span adjustments), you must monitor continuously (or collect data at all required intervals) any time a source of

emissions is operating.

(b) You may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data

averages and calculations used to report emissions or operating levels or to fulfill a minimum data availability requirement, if applicable. You must

use all the data collected during all other periods in assessing compliance.

(c) A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring system to provide valid data.

Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions.

§ 63.7743 How do I demonstrate continuous compliance with the emissions limitations that apply to me?

(a) You must demonstrate continuous compliance by meeting the applicable conditions in paragraphs (a)(1) through (12) of this section. When

alternative emissions limitations are provided for a given emissions source, you must comply with the alternative emissions limitation most recently

selected as your compliance alternative.

(1) For each electric arc metal melting furnace, electric induction metal melting furnace, or scrap preheater at an existing iron and steel foundry,

(i) Maintaining the average PM concentration in the exhaust stream at or below 0.005 gr/dscf; or

(ii) Maintaining the average total metal HAP concentration in the exhaust stream at or below 0.0004 gr/dscf.

(2) For each cupola metal melting furnace at an existing iron and steel foundry,


(ii) Maintaining the average total metal HAP concentration in the exhaust stream at or below 0.0005 gr/dscf; or

(iii) Maintaining the average PM mass emissions rate at or below 0.10 pound of PM per ton (lb/ton) of metal charged; or

(iv) Maintaining the average total metal HAP mass emissions rate at or below 0.008 pound of total metal HAP per ton (lb/ton) of metal charged.

(3) For each cupola metal melting furnace or electric arc metal melting furnace at new iron and steel foundry, (i) Maintaining the average PM

concentration in the exhaust stream at or below 0.002 gr/dscf; or


(4) For each electric induction metal melting furnace or scrap preheater at a new iron and steel foundry,



(5) For each pouring station at an existing iron and steel foundry,



(6) For each pouring area or pouring station at a new iron and steel foundry,



(7) For each building or structure housing any iron and steel foundry emissions source at the iron and steel foundry, maintaining the opacity of any

fugitive emissions from foundry operations discharged to the atmosphere at or below 20 percent opacity (6-minute average), except for one 6-minute

average per hour that does not exceed 27 percent opacity.

(8) For each cupola metal melting furnace at a new or existing iron and steel foundry, maintaining the average VOHAP concentration in the exhaust

stream at or below 20 ppmv corrected to 10 percent oxygen.

(9) For each scrap preheater at an existing new iron and steel foundry that does not comply with the work practice standard in §63.7700(e)(1) or (2)

and for each scrap preheater at a new iron and steel foundry that does not comply with the work practice standard in §63.7700(f), maintaining the

average VOHAP concentration in the exhaust stream at or below 20 ppmv.

(10) For one or more automated conveyor and pallet cooling lines or automated shakeout lines that use a sand mold system at a new iron and steel

foundry,

(i) Maintaining the 3-hour flow-weighted average VOHAP concentration in the exhaust stream at or below 20 ppmv;

(ii) Inspecting and maintaining each CEMS according to the requirements of §63.7741(g) and recording all information needed to document

conformance with these requirements; and

(iii) Collecting and reducing monitoring data for according to the requirements of §63.7741(g) and recording all information needed to document

conformance with these requirements.

(11) For each TEA cold box mold or core making line at a new or existing iron and steel foundry, maintaining a 99 percent reduction in the VOHAP

concentration in the exhaust stream or maintaining the average VOHAP concentration in the exhaust stream at or below 1 ppmv.

(12) Conducting subsequent performance tests at least every 5 years for each emissions source subject to an emissions limit for PM, total metal HAP,

VOHAP, or TEA in §63.7690(a) and subsequent performance tests at least every 6 months for each building or structure subject to the opacity limit

in §63.7690(a)(7).

(b) You must demonstrate continuous compliance for each capture system subject to an operating limit in §63.7690(b)(1) by meeting the

requirements in paragraphs (b)(1) and (2) of this section.

(1) Operating the capture system at or above the lowest values or settings established for the operating limits in your operation and maintenance plan;

and

(2) Monitoring the capture system according to the requirements in §63.7740(a) and collecting, reducing, and recording the monitoring data for each

of the operating limit parameters according to the applicable requirements in this subpart.

(c) For each baghouse,

(1) Inspecting and maintaining each baghouse according to the requirements of §63.7740(c)(1) through (8) and recording all information needed to

document conformance with these requirements; and

(2) If the baghouse is equipped with a bag leak detection system, maintaining records of the times the bag leak detection system sounded, and for

each valid alarm, the time you initiated corrective action, the corrective action taken, and the date on which corrective action was completed.

(d) For each wet scrubber that is subject to the operating limits in §63.7690(b)(2), you must demonstrate continuous compliance by:

(1) Maintaining the 3-hour average pressure drop and 3-hour average scrubber water flow rate at levels no lower than those established during the

initial or subsequent performance test;

(2) Inspecting and maintaining each CPMS according to the requirements of §63.7741(c) and recording all information needed to document


(3) Collecting and reducing monitoring data for pressure drop and scrubber water flow rate according to the requirements of §63.7741(f) and

recording all information needed to document conformance with these requirements.

(e) For each combustion device that is subject to the operating limit in §63.7690(b)(3), you must demonstrate continuous compliance by:

(1) Maintaining the 15-minute average combustion zone temperature at a level no lower than 1,300 °F;

(2) Inspecting and maintaining each CPMS according to the requirements of §63.7741(d) and recording all information needed to document


(3) Collecting and reducing monitoring data for combustion zone temperature according to the requirements of §63.7741(f) and recording all

information needed to document conformance with these requirements.

(f) For each combustion device that is subject to the operating limit in §63.7690(b)(4), you must demonstrate continuous compliance by:

(1) Maintaining the 3-hour average combustion zone temperature at a level no lower that established during the initial or subsequent performance

test;

(2) Inspecting and maintaining each CPMS according to the requirements of §63.7741(d) and recording all information needed to document


(3) Collecting and reducing monitoring data for combustion zone temperature according to the requirements of §63.7741(f) and recording all

information needed to document conformance with these requirements.

(g) For each acid wet scrubber subject to the operating limits in §63.7690(b)(5), you must demonstrate continuous compliance by:

(1) Maintaining the 3-hour average scrubbing liquid flow rate at a level no lower than the level established during the initial or subsequent

performance test;

(2) Maintaining the 3-hour average pH of the scrubber blowdown at a level no higher than 4.5 (if measured by a CPMS) or maintaining the pH level

of the scrubber blowdown during each production shift no higher than 4.5;

(3) Inspecting and maintaining each CPMS according to the requirements of §63.7741(e) and recording all information needed to document


(4) Collecting and reducing monitoring data for scrubbing liquid flow rate and scrubber blowdown pH according to the requirements of §63.7741(f)

and recording all information needed to document conformance with these requirements. If the pH level of the scrubber blowdown is measured by a

probe and meter, you must demonstrate continuous compliance by maintaining records that document the date, time, and results of each sample taken

for each production shift.


§ 63.7744 How do I demonstrate continuous compliance with the work practice standards that apply to me?

(a) You must maintain records that document continuous compliance with the certification requirements in §63.7700(b) or with the procedures in

your scrap selection and inspection plan required in §63.7700(c). Your records documenting compliance with the scrap selection and inspection plan

must include a copy (kept onsite) of the procedures used by the scrap supplier for either removing accessible mercury switches or for purchasing

automobile bodies that have had mercury switches removed, as applicable.

(b) You must keep records of the chemical composition of all catalyst binder formulations applied in each furan warm box mold or core making line

at a new or existing iron and steel foundry to demonstrate continuous compliance with the requirements in §63.7700(d).

(c) For a scrap preheater at an existing iron and steel foundry, you must operate and maintain each gas-fired preheater such that the flame directly

contacts the scrap charged to demonstrate continuous compliance with the requirement §63.7700(e)(1). If you choose to meet the work practice

standard in §63.7700(e)(2), you must keep records to document that the scrap preheater charges only material that is subject to and in compliance

with the scrap certification requirements in §63.7700(b).

(d) For a scrap preheater at a new iron and steel foundry, you must keep records to document that each scrap preheater charges only material that is

subject to and in compliance with the scrap certification requirements in §63.7700(b) to demonstrate continuous compliance with the requirement in

§63.7700(f).

§ 63.7745 How do I demonstrate continuous compliance with the operation and maintenance requirements that apply to me?

(a) For each capture system and control device for an emissions source subject to an emissions limit in §63.7690(a), you must demonstrate

continuous compliance with the operation and maintenance requirements of §63.7710 by:

(1) Making monthly inspections of capture systems and initiating corrective action according to §63.7710(b)(1) and recording all information needed

to document conformance with these requirements;

(2) Performing preventative maintenance for each control device according to the preventive maintenance plan required by §63.7710(b)(3) and

recording all information needed to document conformance with these requirements;

(3) Operating and maintaining each bag leak detection system according to the site-specific monitoring plan required by §63.7710(b)(4) and

recording all information needed to demonstrate conformance with these requirements;

(4) Initiating and completing corrective action for a bag leak detection system alarm according to the corrective action plan required by

§63.7710(b)(5) and recording all information needed to document conformance with these requirements; and

(5) Igniting gases from mold vents according to the procedures in the plan required by §63.7710(b)(6). (Any instance where you fail to follow the

procedures is a deviation that must be included in your semiannual compliance report.)

(b) You must maintain a current copy of the operation and maintenance plans required by §63.7710(b) onsite and available for inspection upon

request. You must keep the plans for the life of the iron and steel foundry or until the iron and steel foundry is no longer subject to the requirements

of this subpart.

§ 63.7746 What other requirements must I meet to demonstrate continuous compliance?

(a) Deviations. You must report each instance in which you did not meet each emissions limitation in §63.7690 (including each operating limit) that

applies to you. This requirement includes periods of startup, shutdown, and malfunction. You also must report each instance in which you did not

meet each work practice standard in §63.7700 and each operation and maintenance requirement of §63.7710 that applies to you. These instances are

deviations from the emissions limitations, work practice standards, and operation and maintenance requirements in this subpart. These deviations

must be reported according to the requirements of §63.7751.

(b) Startups, shutdowns, and malfunctions. (1) Consistent with the requirements of §§63.6(e) and 63.7(e)(1), deviations that occur during a period of

startup, shutdown, or malfunction are not violations if you demonstrate to the Administrator's satisfaction that you were operating in accordance with

§63.6(e)(1).

(2) The Administrator will determine whether deviations that occur during a period of startup, shutdown, or malfunction are violations according to

the provisions in §63.6(e).

[69 FR 21923, Apr. 22, 2004, as amended at 71 FR 20468, Apr. 20, 2006]

§ 63.7747 How do I apply for alternative monitoring requirements for a continuous emissions monitoring system?

(a) You may request an alternative monitoring method to demonstrate compliance with the VOHAP emissions limits in §63.7690(a)(10) for

automated pallet cooling lines or automated shakeout lines at a new iron and steel foundry according to the procedures in this section.

(b) You can request approval to use an alternative monitoring method in the notification of construction or reconstruction for new sources, or at any

time.

(c) You must submit a monitoring plan that includes a description of the control technique or pollution prevention technique, a description of the

continuous monitoring system or method including appropriate operating parameters that will be monitored, test results demonstrating compliance

with the emissions limit, operating limit(s) (if applicable) determined according to the test results, and the frequency of measuring and recording to

establish continuous compliance. If applicable, you must also include operation and maintenance requirements for the monitors.

(d) The monitoring plan is subject to approval by the Administrator. Use of the alternative monitoring method must not begin until approval is

granted by the Administrator.

Notifications, Reports, and Records

§ 63.7750 What notifications must I submit and when?

(a) You must submit all of the notifications required by §§63.6(h)(4) and (5), 63.7(b) and (c); 63.8(e); 63.8(f)(4) and (6); 63.9(b) through (h) that

apply to you by the specified dates.

(b) As specified in §63.9(b)(2), if you start up your iron and steel foundry before April 22, 2004, you must submit your initial notification no later

than August 20, 2004.

(c) If you start up your new iron and steel foundry on or after April 22, 2004, you must submit your initial notification no later than 120 calendar days

after you become subject to this subpart.

(d) If you are required to conduct a performance test, you must submit a notification of intent to conduct a performance test at least 60 calendar days

before the performance test is scheduled to begin as required by §63.7(b)(1).

(e) If you are required to conduct a performance test or other initial compliance demonstration, you must submit a notification of compliance status

according to the requirements of §63.9(h)(2)(ii). For opacity performance tests, the notification of compliance status may be submitted with the

semiannual compliance report in §63.7751(a) and (b) or the semiannual part 70 monitoring report in §63.7551(d).

(1) For each initial compliance demonstration that does not include a performance test, you must submit the notification of compliance status before

the close of business on the 30th calendar day following completion of the initial compliance demonstration.

(2) For each initial compliance demonstration that does include a performance test, you must submit the notification of compliance status, including

the performance test results, before the close of business on the 60th calendar day following the completion of the performance test according to the

requirement specified in §63.10(d)(2).


§ 63.7751 What reports must I submit and when?

(a) Compliance report due dates. Unless the Administrator has approved a different schedule, you must submit a semiannual compliance report to

your permitting authority according to the requirements specified in paragraphs (a)(1) through (5) of this section.

(1) The first compliance report must cover the period beginning on the compliance date that is specified for your iron and steel foundry by §63.7683

and ending on June 30 or December 31, whichever date comes first after the compliance date that is specified for your iron and steel foundry.

(2) The first compliance report must be postmarked or delivered no later than July 31 or January 31, whichever date comes first after your first

compliance report is due.

(3) Each subsequent compliance report must cover the semiannual reporting period from January 1 through June 30 or the semiannual reporting

period from July 1 through December 31.

(4) Each subsequent compliance report must be postmarked or delivered no later than July 31 or January 31, whichever date comes first after the end

of the semiannual reporting period.

(5) For each iron and steel foundry that is subject to permitting regulations pursuant to 40 CFR part 70 or 40 CFR part 71, and if the permitting

authority has established dates for submitting semiannual reports pursuant to 40 CFR 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A), you may submit

the first and subsequent compliance reports according to the dates the permitting authority has established instead of the dates specified in paragraphs

(a)(1) through (4) of this section.

(b) Compliance report contents. Each compliance report must include the information specified in paragraphs (b)(1) through (3) of this section and,

as applicable, paragraphs (b)(4) through (8) of this section.

(1) Company name and address.

(2) Statement by a responsible official, with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of

the report.

(3) Date of report and beginning and ending dates of the reporting period.

(4) If you had a startup, shutdown, or malfunction during the reporting period and you took action consistent with your startup, shutdown, and

malfunction plan, the compliance report must include the information in §63.10(d)(5)(i).

(5) If there were no deviations from any emissions limitations (including operating limit), work practice standards, or operation and maintenance

requirements, a statement that there were no deviations from the emissions limitations, work practice standards, or operation and maintenance

requirements during the reporting period.

(6) If there were no periods during which a continuous monitoring system (including a CPMS or CEMS) was out-of-control as specified by

§63.8(c)(7), a statement that there were no periods during which the CPMS was out-of-control during the reporting period.

(7) For each deviation from an emissions limitation (including an operating limit) that occurs at an iron and steel foundry for which you are not using

a continuous monitoring system (including a CPMS or CEMS) to comply with an emissions limitation or work practice standard required in this

subpart, the compliance report must contain the information specified in paragraphs (b)(1) through (4) and (b)(7)(i) and (ii) of this section. This

requirement includes periods of startup, shutdown, and malfunction.

(i) The total operating time of each emissions source during the reporting period.

(ii) Information on the number, duration, and cause of deviations (including unknown cause) as applicable and the corrective action taken.

(8) For each deviation from an emissions limitation (including an operating limit) or work practice standard occurring at an iron and steel foundry

where you are using a continuous monitoring system (including a CPMS or CEMS) to comply with the emissions limitation or work practice

standard in this subpart, you must include the information specified in paragraphs (b)(1) through (4) and (b)(8)(i) through (xi) of this section. This

requirement includes periods of startup, shutdown, and malfunction.

(i) The date and time that each malfunction started and stopped.

(ii) The date and time that each continuous monitoring system was inoperative, except for zero (low-level) and high-level checks.

(iii) The date, time, and duration that each continuous monitoring system was out-of-control, including the information in §63.8(c)(8).

(iv) The date and time that each deviation started and stopped, and whether each deviation occurred during a period of startup, shutdown, or

malfunction or during another period.

(v) A summary of the total duration of the deviations during the reporting period and the total duration as a percent of the total source operating time

during that reporting period.

(vi) A breakdown of the total duration of the deviations during the reporting period into those that are due to startup, shutdown, control equipment

problems, process problems, other known causes, and unknown causes.

(vii) A summary of the total duration of continuous monitoring system downtime during the reporting period and the total duration of continuous

monitoring system downtime as a percent of the total source operating time during the reporting period.

(viii) A brief description of the process units.

(ix) A brief description of the continuous monitoring system.

(x) The date of the latest continuous monitoring system certification or audit.

(xi) A description of any changes in continuous monitoring systems, processes, or controls since the last reporting period.

(c) Immediate startup, shutdown, and malfunction report. If you had a startup, shutdown, or malfunction during the semiannual reporting period that

was not consistent with your startup, shutdown, and malfunction plan and the source exceeds any applicable emissions limitation in §63.7690, you

must submit an immediate startup, shutdown, and malfunction report according to the requirements of §63.10(d)(5)(ii).

(d) Part 70 monitoring report. If you have obtained a title V operating permit for an iron and steel foundry pursuant to 40 CFR part 70 or 40 CFR part

71, you must report all deviations as defined in this subpart in the semiannual monitoring report required by 40 CFR 70.6(a)(3)(iii)(A) or 40 CFR

71.6(a)(3)(iii)(A). If you submit a compliance report for an iron and steel foundry along with, or as part of, the semiannual monitoring report required

by 40 CFR 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A), and the compliance report includes all the required information concerning deviations

from any emissions limitation or operation and maintenance requirement in this subpart, submission of the compliance report satisfies any obligation

to report the same deviations in the semiannual monitoring report. However, submission of a compliance report does not otherwise affect any

obligation you may have to report deviations from permit requirements for an iron and steel foundry to your permitting authority.


§ 63.7752 What records must I keep?

(a) You must keep the records specified in paragraphs (a)(1) through (4) of this section:

(1) A copy of each notification and report that you submitted to comply with this subpart, including all documentation supporting any initial

notification or notification of compliance status that you submitted, according to the requirements of §63.10(b)(2)(xiv).

(2) The records specified in §63.6(e)(3)(iii) through (v) related to startup, shutdown, and malfunction.

(3) Records of performance tests and performance evaluations as required by §63.10(b)(2)(viii).

(4) Records of the annual quantity of each chemical binder or coating material used to coat or make molds and cores, the Material Data Safety Sheet

or other documentation that provides the chemical composition of each component, and the annual quantity of HAP used in these chemical binder or

coating materials at the foundry as calculated from the recorded quantities and chemical compositions (from Material Data Safety Sheets or other

documentation).

(b) You must keep the following records for each CEMS.

(1) Records described in §63.10(b)(2)(vi) through (xi).

(2) Previous ( i.e., superseded) versions of the performance evaluation plan as required in §63.8(d)(3).

(3) Request for alternatives to relative accuracy tests for CEMS as required in §63.8(f)(6)(i).

(4) Records of the date and time that each deviation started and stopped, and whether the deviation occurred during a period of startup, shutdown, or

malfunction or during another period.

(c) You must keep the records required by §§63.7743, 63.7744, and 63.7745 to show continuous compliance with each emissions limitation, work

practice standard, and operation and maintenance requirement that applies to you.


§ 63.7753 In what form and for how long must I keep my records?

(a) You must keep your records in a form suitable and readily available for expeditious review, according to the requirements of §63.10(b)(1).

(b) As specified in §63.10(b)(1), you must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective

action, report, or record.

(c) You must keep each record onsite for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or

record according to the requirements in §63.10(b)(1). You can keep the records for the previous 3 years offsite.

Other Requirements and Information

§ 63.7760 What parts of the General Provisions apply to me?

Table 1 to this subpart shows which parts of the General Provisions in §§63.1 through 63.15 apply to you.

§ 63.7761 Who implements and enforces this subpart?

(a) This subpart can be implemented and enforced by us, the U.S. Environmental Protection Agency (EPA), or a delegated authority such as your

State, local, or tribal agency. If the U.S. EPA Administrator has delegated authority to your State, local, or tribal agency, then that agency, in addition

to the U.S. EPA, has the authority to implement and enforce this subpart. You should contact your U.S. EPA Regional Office to find out if

implementation and enforcement of this subpart is delegated to your State, local, or tribal agency.

(b) In delegating implementation and enforcement authority of this subpart to a State, local, or tribal agency under 40 CFR part 63, subpart E, the

authorities contained in paragraph (c) of this section are retained by the Administrator of the U.S. EPA and are not transferred to the State, local, or

tribal agency.

(c) The authorities that cannot be delegated to State, local, or tribal agencies are specified in paragraphs (c)(1) through (4) of this section.

(1) Approval of alternatives to non-opacity emissions limitations in §63.7690 and work practice standards in §63.7700 under §63.6(g).

(2) Approval of major alternatives to test methods under §63.7(e)(2)(ii) and (f) and as defined in §63.90.

(3) Approval of major alternatives to monitoring under §63.8(f) and as defined in §63.90.

(4) Approval of major alternatives to recordkeeping and reporting under §63.10(f) and as defined in §63.90.

Definitions

§ 63.7765 What definitions apply to this subpart?

Terms used in this subpart are defined in the Clean Air Act (CAA), in §63.2, and in this section.

Automated conveyor and pallet cooling line means any dedicated conveyor line or area used for cooling molds received from pouring stations.

Automated shakeout line means any mechanical process unit designed for and dedicated to separating a casting from a mold. These mechanical

processes include, but are not limited to, shaker decks, rotary separators, and high-frequency vibration units. Automated shakeout lines do not include

manual processes for separating a casting from a mold, such as personnel using a hammer, chisel, pick ax, sledge hammer, or jackhammer.

Bag leak detection system means a system that is capable of continuously monitoring relative particulate matter (dust) loadings in the exhaust of a

baghouse to detect bag leaks and other upset conditions. A bag leak detection system includes, but is not limited to, an instrument that operates on

triboelectric, electrodynamic, light scattering, light transmittance, or other effect to continuously monitor relative particulate matter loadings.

Binder chemical means a component of a system of chemicals used to bind sand together into molds, mold sections, and cores through chemical

reaction as opposed to pressure.

Capture system means the collection of components used to capture gases and fumes released from one or more emissions points and then convey the

captured gas stream to a control device or to the atmosphere. A capture system may include, but is not limited to, the following components as

applicable to a given capture system design: duct intake devices, hoods, enclosures, ductwork, dampers, manifolds, plenums, and fans.

Cold box mold or core making line means a mold or core making line in which the formed aggregate is hardened by catalysis with a gas.

Combustion device means an afterburner, thermal incinerator, or scrap preheater.

Conveyance means the system of equipment that is designed to capture pollutants at the source, convey them through ductwork, and exhaust them

using forced ventilation. A conveyance may, but does not necessarily include, control equipment designed to reduce emissions of the pollutants.

Emissions that are released through windows, vents, or other general building ventilation or exhaust systems are not considered to be discharged

through a conveyance.

Cooling means the process of molten metal solidification within the mold and subsequent temperature reduction prior to shakeout.

Cupola means a vertical cylindrical shaft furnace that uses coke and forms of iron and steel such as scrap and foundry returns as the primary charge

components and melts the iron and steel through combustion of the coke by a forced upward flow of heated air.

Deviation means any instance in which an affected source or an owner or operator of such an affected source:

(1) Fails to meet any requirement or obligation established by this subpart including, but not limited to, any emissions limitation (including operating

limits), work practice standard, or operation and maintenance requirement;

(2) Fails to meet any term or condition that is adopted to implement an applicable requirement in this subpart and that is included in the operating

permit for any iron and steel foundry required to obtain such a permit; or

(3) Fails to meet any emissions limitation (including operating limits) or work practice standard in this subpart during startup, shutdown, or

malfunction, regardless of whether or not such failure is permitted by this subpart.

A deviation is not always a violation. The determination of whether a deviation constitutes a violation of the standard is up to the discretion of the

entity responsible for enforcement of the standards.

Electric arc furnace means a vessel in which forms of iron and steel such as scrap and foundry returns are melted through resistance heating by an

electric current flowing through the arcs formed between the electrodes and the surface of the metal and also flowing through the metal between the

arc paths.

Electric induction furnace means a vessel in which forms of iron and steel such as scrap and foundry returns are melted though resistance heating by

an electric current that is induced in the metal by passing an alternating current through a coil surrounding the metal charge or surrounding a pool of

molten metal at the bottom of the vessel.

Emissions limitation means any emissions limit or operating limit.

Exhaust stream means gases emitted from a process through a conveyance as defined in this subpart.

Free organic liquids means material that fails the paint filter test by EPA Method 9095A (incorporated by reference—see §63.14). That is, if any

portion of the material passes through and drops from the filter within the 5-minute test period, the material contains free liquids.

Fresh acid solution means a sulfuric acid solution used for the control of triethylamine emissions that has a pH of 2.0 or less.

Fugitive emissions means any pollutant released to the atmosphere that is not discharged through a conveyance as defined in this subpart.

Furan warm box mold or core making line means a mold or core making line in which the binder chemical system used is that system commonly

designated as a furan warm box system by the foundry industry.

Hazardous air pollutant means any substance on the list originally established in 112(b)(1) of the CAA and subsequently amended as published in

the Code of Federal Regulations.

Iron and steel foundry means a facility or portion of a facility that melts scrap, ingot, and/or other forms of iron and/or steel and pours the

resulting molten metal into molds to produce final or near final shape products for introduction into commerce. Research and development

facilities and operations that only produce non-commercial castings are not included in this definition.

Metal melting furnace means a cupola, electric arc furnace, or electric induction furnace that converts scrap, foundry returns, and/or other

solid forms of iron and/or steel to a liquid state. This definition does not include a holding furnace, an argon oxygen decarburization vessel,

or ladle that receives molten metal from a metal melting furnace, to which metal ingots or other material may be added to adjust the metal

chemistry.

Mold or core making line means the collection of equipment that is used to mix an aggregate of sand and binder chemicals, form the

aggregate into final shape, and harden the formed aggregate. This definition does not include a line for making green sand molds or cores.

Mold vent means an intentional opening in a mold through which gases containing pyrolysis products of organic mold and core constituents produced

by contact with or proximity to molten metal normally escape the mold during and after metal pouring.

Off blast means those periods of cupola operation when the cupola is not actively being used to produce molten metal. Off blast conditions include

cupola startup when air is introduced to the cupola to preheat the sand bed and other cupola startup procedures as defined in the startup, shutdown,

and malfunction plan. Off blast conditions also include idling conditions when the blast air is turned off or down to the point that the cupola does not

produce additional molten metal.

On blast means those periods of cupola operation when combustion (blast) air is introduced to the cupola furnace and the furnace is capable of

producing molten metal. On blast conditions are characterized by both blast air introduction and molten metal production.

Pouring area means an area, generally associated with floor and pit molding operations, in which molten metal is brought to each individual mold.

Pouring areas include all pouring operations that do not meet the definition of a pouring station.

Pouring station means the fixed location to which molds are brought in a continuous or semicontinuous manner to receive molten metal, after which

the molds are moved to a cooling area.

Responsible official means responsible official as defined in §63.2.

Scrap preheater means a vessel or other piece of equipment in which metal scrap that is to be used as melting furnace feed is heated to a temperature

high enough to eliminate volatile impurities or other tramp materials by direct flame heating or similar means of heating. Scrap dryers, which solely

remove moisture from metal scrap, are not considered to be scrap preheaters for purposes of this subpart.

Scrubber blowdown means liquor or slurry discharged from a wet scrubber that is either removed as a waste stream or processed to remove

impurities or adjust its composition or pH before being returned to the scrubber.

Total metal HAP means, for the purposes of this subpart, the sum of the concentrations of antimony, arsenic, beryllium, cadmium, chromium, cobalt,

lead, manganese, mercury, nickel, and selenium as measured by EPA Method 29 (40 CFR part 60, appendix A). Only the measured concentration of

the listed analytes that are present at concentrations exceeding one-half the quantitation limit of the analytical method are to be used in the sum. If

any of the analytes are not detected or are detected at concentrations less than one-half the quantitation limit of the analytical method, the

concentration of those analytes will be assumed to be zero for the purposes of calculating the total metal HAP for this subpart.

Work practice standard means any design, equipment, work practice, or operational standard, or combination thereof, that is promulgated pursuant to

section 112(h) of the CAA.

[69 FR 21923, Apr. 22, 2004, as amended at 70 FR 29404, May 20, 2005; 73 FR 7222, Feb. 7, 2008]

Table 1 to Subpart EEEEE of Part 63—Applicability of General Provisions to Subpart EEEEE

[As stated in §63.7760, you must meet each requirement in the following table that applies to you.]

Citation Subject

Applies to

Subpart

EEEEE? Explanation

63.1 Applicability Yes

63.2 Definitions Yes

63.3 Units and abbreviations Yes

63.4 Prohibited activities Yes

63.5 Construction/reconstruction Yes

63.6(a)–(g) Compliance with standards and maintenance Yes

requirements

63.6(h) Opacity and visible emissions standards Yes

63.6(i)–(j) Compliance extension and Presidential

compliance exemption

Yes

63.7(a)(1)–(a)(2) Applicability and performance test dates No Subpart EEEEE specifies applicability and

performance test dates.

63.7(a)(3), (b)–(h) Performance testing requirements Yes

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 Subpart EEEEE specifies requirements for

alternative monitoring systems.

63.8(a)(4) Additional monitoring requirements for control

devices in §63.11

No Subpart EEEEE does not require flares.

63.8(c)(4) Continuous monitoring system (CMS)

requirements

No Subpart EEEEE specifies requirements for

operation of CMS and CEMS.

63.8(c)(5) Continuous opacity monitoring system

(COMS) Minimum Procedures

No Subpart EEEEE does not require COMS.

63.8(g)(5) Data reduction No Subpart EEEEE specifies data reduction

requirements.

63.9 Notification requirements Yes Except: for opacity performance tests,

Subpart EEEEE allows the notification of

compliance status to be submitted with the

semiannual compliance report or the

semiannual part 70 monitoring report.

63.10(a)–(b), (c)(1)–(6),

(c)(9)–(15), (d)(1)–(2),

(e)(1)–(2), (f)

Recordkeeping and reporting requirements Yes Additional records for CMS in §63.10(c)(1)–

(6), (9)–(15) apply only to CEMS.

63.10(c)(7)–(8) Records of excess emissions and parameter

monitoring exceedances for CMS

No Subpart EEEEE specifies records

requirements.

63.10(d)(3) Reporting opacity or visible emissions

observations

Yes

63.10(e)(3) Excess emissions reports No Subpart EEEEE specifies reporting

requirements.

63.10(e)(4) Reporting COMS data No Subpart EEEEE data does not require

COMS.

63.11 Control device requirements No Subpart EEEEE does not require flares.

63.12 State authority and delegations Yes

63.13–63.15 Addresses of State air pollution control

agencies and EPA regional offices.

Incorporation by reference. Availability of

information and confidentiality

Yes


ATTACHMENT 3

Requirements of Section §63.7710 of CFR Part 63, Subpart EEEEE - National Emission

Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries

Details Operation and Maintenance Plans: Cupola Capture System Operation and Maintenance Plan

Cupola Combustor System Monitoring and Maintenance Plan

Cupola Baghouse Control Device Preventive Maintenance Plan

Broken Bag Leak Detection System Plan

Mold Vent Ignition / Determination of Ignitability Plan

ATTACHMENT 4

TITLE V FEE SELECTION FORM: FORM APC 36

ATTACHMENT 5

LETTER DATED FEBRUARY 9, 2018

Title V Permit Statement

Page 1 of 8

TITLE V PERMIT STATEMENT OF BASIS

Revised for Renewal Permit 573114

Facility Name: Waupaca Foundry, Inc.

City: Etowah

County: McMinn

Date of Title V Application: December 11, 2018 (Revision)

Date Application deemed Complete: December 27, 2018

Emission Source Reference No.: 54-0174

Title V Permit No. 573114

Introduction:

This narrative is being provided to assist the reader in understanding the content of the attached Title V operating permit.

This Title V Permit Statement is written pursuant to Tennessee Air Pollution Control Rule 1200-03-09-.02(11)(f)1.(v).

The primary purpose of the Title V operating permit is to consolidate and identify existing state and federal air

requirements applicable to Waupaca Foundry, Inc. formerly known as ThyssenKrupp Waupaca, Inc. and to provide

practical methods for determining compliance with these requirements. The following narrative is designed to accompany

the Title V Operating Permit. It describes the facility receiving the permit, the applicable air permitting requirements and

their significance, and the compliance status of the facility with those applicable requirements. This narrative is intended

only as an adjunct for the reviewer and has no legal standing. Any revisions made to the permit in response to comments

received during the public participation process will be described in an addendum to this narrative.

Company’s Background Information

Waupaca Foundry, Inc. operates its Plant 6 iron foundry in Etowah, Tennessee. The foundry produces iron castings such

as brake drums and rotors, which are used by automobile manufacturers. Plant 6 was originally issued PSD permits for

Phase 1 and 2 in 2000. Phase 1 consists of a 90 tons per hour iron melting cupola and four casting production lines 1

through 4. Construction of Phase 1 was completed in 2002 and is currently in operation. Phase 2 was permitted with a

second 90 tons per hour cupola and four casting production lines 5 to 8. Phase 2 was never constructed and its

construction permit has expired.

On June 3, 1981, the State of Tennessee adopted Rule 1200-03-09-.01(4), Prevention of Significant Air Quality Deterioration.

This Rule has been subsequently amended, with the latest amendments effective June 26, 1993. Under these regulations, a

source that is included in one of 28 source categories and has the potential or increased potential to emit 100 tons per year

(TPY) or more of any air pollutant regulated in the Clean Air Act must be reviewed with regard to significant deterioration

prior to construction. Waupaca Foundry, Inc. is a major source and one of the 28 source categories.

On February 27, 2007, the company proposed modifications to phase 1 and 2 projects. Projected emissions exceeded

thresholds for Particulate Matter (PM10), Carbon Monoxide (CO), and Volatile Organic Compounds (VOC) at which a

Prevention of Significant Deterioration (PSD) review under TAPCD 1200-03-09-.01(4) was applied.


Page 2 of 8

On July 19, 2007, PSD Construction permit 960724 was issued to this facility for modification of Casting Lines 1, 2, and

3. At that time, casting line 4 was to remain unchanged. However, on July 17, 2012 a PSD application to modify casting

line 4 was submitted, and permit 966272P was issued on December 26, 2012.

Acronyms PSD - Prevention of Significant Deterioration

NESHAP - National Emission Standards for Hazardous Air Pollutants

NSPS - New Source Performance Standards

MACT - Maximum Achievable Control Technology

NSR - New Source Review

I. Identification Information

A. Source Description : Grey and Ductile Iron Foundry

The following listed sources are included in the Title V renewal permit 573114:

54-0174-01- Phase I

Phase I Casting Lines 1 (P01), 2 (P03), 3 (P05), and 4 (P07) – Baghouses C03, C05, C06, C08, C09, C10, C11, C12

Emissions from Pouring Stations are Uncontrolled (fugitive), but emissions from Shakeout, Cooling and Handling

Operations are Controlled by Baghouse, Exhausting to Stack S01.

Each Casting Line includes Pouring, Cooling, Shakeout and Handling Operations – Pouring stations at this facility are

open to the air to allow access, and are not ducted through conveyances and are therefore not subject to provisions of 40

CFR Part 63, Subpart EEEEE, National Emission for hazardous air pollutants (NESHAP) for iron and steel foundries.

A PSD permit for modification of Casting Line 4 was issued on December 26, 2012.

54-0174-02- Phase I

Phase I -Sand System

Sand Preparation System including Conveying, Handling, Mulling, Screening and Cooling Operation (P09) - Baghouses

C01- C04 in Parallel, Exhausting to Stack S01.

54-0174-03 - Phase I –

Return Metal Handling (P12) - Baghouses C01- C04 in Parallel, Exhausting to Stack S01.

54-0174-04 Phase I –

Spent Dust Handling (P13) - Baghouses C01- C04 in Parallel, Exhausting to Stack S01


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54-0174-08 - Phase I – Air Make-Up (P50)

Natural Gas or Propane fired heaters to supply heated air to foundry area.

54-0174-09 - Phase I –

Miscellaneous Natural Gas or Propane Usage (P51) to pre-heat ladles in foundry area

54-0174-17 - Phase I - Cupola (P30)

Iron melting furnace with three Existing Low-NOx Natural Gas-Fired Burners for Thermal Incinerator for the control of

the CO, & VOCs emissions- One with 6.0 MM Btu/hr, Two with 15 MM Btu/hr, each, Total Heat Input Rate for all three

Burners: 36 MM Btu/hr.- Control devices: incinerator C10A (for VOC and CO control), dry alkaline scrubber C10B (for

SO2 neutralization), & baghouse C10C (for the control of the particulate and Lead emissions), Exhausting to Stack S10..

54-0174-18- Phase I –

Ductile Iron Treatment Operation:

Ductile Iron Treatment (P31), Desulfurization (P32) with Baghouse Control (C31) exhaust through Stack S12 and Two 3.0

MM Btu/hr Natural Gas Fired Core Ovens (P33)

54-0174-20- Phase I- Phenolic – Urethane Core Making Operations

Isocure Core Making Process (P23A – One Machine and One Oven)

Isocure Core Making Process (P23B – One Machine and One Oven)

Isocure Core Making Process (P24 – One Machine and Two Ovens)

Isocure Core Making Process (P25 – Two Machines and One Oven)

Isocure Core Making Process (P26 – One Machine)

Isocure Core Making Process (P27A and P27B – Two Machines and Two Ovens)

Sulfuric Acid Scrubber Control

Note: The permittee stated that no triethylamine (TEA) gas is utilized at this operation and therefore these units are not

subject to the provision of MACT Subpart EEEEE.

54-0174-24: Waste Sand and Metal Recovery Operation Material transfer to storage bunker and screen hopper, material screening, conveying to stockpile or roll-off container; wet

suppression control (authorized by construction permit 973233 issued May 22, 2018).

B. Facility Classification

1. Attainment or Non-Attainment Area Location

Area is designated as an attainment area for all criteria pollutants.

2. Company is located in a Class II area (this means that the facility is not located within a national park or national

wilderness area (see 40 CFR 52.21 (e) for complete definition.) Waupaca Foundry, Inc. is located just north of Etowah,


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Tennessee in McMinn County, and is 55 miles southwest of Knoxville, TN. The closest Class I areas are the Great Smoky

Mountain National Park (GSMNP) in east Tennessee (52km), Cohutta National Wilderness Area in northern Georgia (40km),

Joyce Kilmer/Slick Rock National Wilderness Area in western North Carolina (46km) and Shining Rock National Wilderness

Area in North Carolina (146km).

C. Regulatory Status PSD/NSR

1. This facility is one of 28 source categories and has the potential to emit 100 tons per year (TPY) or more of criteria air

pollutant regulated in the Clean Air Act and therefore, subject to Prevention of Significant Deterioration regulations

(PSD). In addition, any source having the potential or increased potential to emit 250 tons per year or more of any of these air

pollutants must be reviewed with the same regard. This facility is also a major source for Greenhouse Gas emissions.

2. Title V Major Source Status by Pollutant are listed below:

If emitted, what is the facility’s status?

Pollutant

Is the pollutant

emitted?

Major Source

Status

Non-Major Source Status

PM

Yes

X

PM10 Yes N/A N/A

SO2 Yes X

VOC Yes X

NOX Yes X

CO Yes X

Individual HAP Yes X

Total HAPs Yes X

Greenhouse Gases

(GHG)

Yes X

3. MACT Standards

This facility is subject to the requirements of 40 CFR Part 63, Subpart EEEEE - National Emission Standards for

hazardous air pollutants (NESHAP) for iron and steel foundries. Section §63.7710 of this Subpart establishes

requirements to demonstrate initial and continuous compliance with the emissions limitations, work practice standards,

and operation and maintenance if required. The final rule for 40 CFR Subpart EEEEE was published in the Federal

Register on April 22, 2004.

4. Program Applicability

Are the following programs applicable to the facility?

PSD Yes

NESHAP Yes


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NSPS No

II. Compliance Information

A. Compliance Status

Is the facility currently in compliance with all applicable requirements? Yes

Are there any applicable requirements that will become effective during the permit term? No

III. Other Requirements

A. Emissions Trading

The facility is not involved in an emission trading program.

B. Acid Rain Requirements

This facility is not subject to any requirements in Title IV of the Clean Air Act.

C. Prevention of Accidental Releases

This facility is not subject to provisions of 1200-03-32 (Prevention of Accidental Releases) or Section 112(r) of the Clean

Air Act.

IV. General Information

A. Potential emissions of criteria air pollutants are listed below:

Facility-wide Potential Emissions

REGULATED POLLUTANTS POTENTIAL EMISSIONS

TONS PER 12-MONTH BASIS

PARTICULATE MATTER (PM) 301.75

SO2 96.79

VOC 365.47

NOX 200.58

CO 2,548.98

Lead 1.43

GHG 321,735


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Allowable Emissions per Renewal Permit 573114:

V. Public Participation Procedures

A. Notification of this draft permit was mailed to the following environmental agencies:

▪ State of Georgia, Atlanta

▪ EPA Region 4, Atlanta

▪ State of North Carolina

▪ Knox County (Local Air Pollution Agency)

▪ Chattanooga (Local Air Pollution Agency)

▪ Cherokee Nation

▪ Chattanooga Environmental Field Office (APC)


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VI. Renewal Title V permit 573114

Changes to previous permit 555968 for renewal permit 573114:

Cover page: added renewal application revision date of December 11, 2018, and added additional applications and

information dated November 20, 2017, December 12, 2017, December 20, 2017, February 9, 2018, and May 28, 2019.

The listing of permitted sources was revised to include source 24 (waste sand and metal recovery operation) and identified

source 21 (emergency generator) as an insignificant activity removed from permit.

Table of Contents: added general conditions D11- D14 for Emission Standards for Hazardous Air Pollutants (D11),

Standards of Performance for New Stationary Sources (D12), Gasoline Dispensing Facilities (D13), and Internal

Combustion Engines (D14); Section E – added source 24, Attachment 4 (Title V fee choice form APC 36), and

Attachment 5 (letter dated February 9, 2018); indicated removal of source 21

General conditions: sections A-D: revised per current condition language and included addition of general conditions

D11- D14 for Emission Standards for Hazardous Air Pollutants (D11), Standards of Performance for New Stationary

Sources (D12), Gasoline Dispensing Facilities (D13), and Internal Combustion Engines (D14)

Section E: updated facility description

Condition E1: revised fee table emissions and updated fee payment text to current Division phrasing.

Condition E2(a), (b), (c): revised language for semiannual reporting, annual compliance certification, and MACT reports

and added table of reporting requirements for permits 555968 and 573114.

Condition E3-1: Updated Responsible Official name and added permit renewal application date of December 11, 2018,

and additional applications and information dated November 20, 2017, December 12, 2017, December 20, 2017, February

9, 2018, and May 28, 2019.

Conditions E3-10 & E3-11: revised conditions per current Division phrasing

Condition E3-12: added condition for Compliance Assurance Monitoring (CAM) Plan submittal for several sources (54-

0174-01, 02, 03, 04, 17, 18, and 20)

Condition E4: revised condition language for MACT subpart EEEEE and federal rule citations

Condition E5-1: revised line 4 (P07) process weight rate per permit 966272P (added reference)

Condition E5-4: revised line 4 (P07) VOC emission limits per permit 966272P

Condition E5-5: revised line 4 (P07) SO2 emission limit per permit 966272P

Condition E5-6: revised line 4 (P07) NOx emission limit per permit 966272P

Condition E5-7: revised line 4 (P07) CO emission limit per permit 966272P

Condition E6-5: corrected VOC emission limit (tons per month on a 12 month average) from 1.2 tons per month to 1.12

tons per month

Condition E7-1: added rule citation





Condition E11-3: added compliance method (equipment design)

Conditions E11-8, E11-11, and E11-12: removed references to NOx continuous emission monitoring system per permit

976951

Conditions E11-11 and E11-12: contents of conditions moved to condition E11-8 compliance method and conditions E11-

11 and E11-12 marked as “Reserved”

Conditions E11-9 and E11-10: removed continuous nitrogen oxide monitoring system requirements and provided alternate

compliance methods per permit 976951

Conditions E11-14 and E11-15: removed continuous opacity monitoring system requirements and marked conditions

“reserved” per permit 976951

Condition E12-2: added compliance method (equipment design)

Condition E13-1: corrected equipment inventory description and corrected VOC emission limits for core making machine

P23A (changed to 1.275 pounds per hour vs. 1.27 pounds per hour) and core making machines P26, P27A and P27B


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(changed to 16.16 tons per 12-consecutive months vs. 16.6 tons per 12-consecutive months); for compliance method

added reference to 8/29/2017, performance test for control device VOC removal efficiency.

Condition E13-6: added compliance method requirement for recordkeeping of control device inspections.

Conditions E14-1 through E14-21: removed conditions for emergency generator source 54-0174-21 and designated unit as

an insignificant activity. Condition E14-1 was revised to state that the facility must continue recordkeeping and reporting

in accordance with MACT subpart ZZZZ and NSPS subpart JJJJ.

Conditions E15-1 and E15-2: added conditions for source 54-0174-24 for a waste sand and metal recovery operation

which was added to permit

Conditions E5-2, E5-3, E6-2, E6-3, E7-2, E7-3, E8-2, E8-3, and E11-5: added averaging period to particulate matter &

lead emission limits.

Attachment 1: added visible emission method 1 opacity matrix

Attachment 4: added Title V fee choice form APC 36

Attachment 5: added letter dated February 9, 2018

TITLE V PERMIT STATEMENT: PUBLIC COMMENTS (Title V Renewal 573114)

Company/ Facility Name: Waupaca Foundry, Inc.

City: Etowah

County: McMinn

Date Application Received: December 12, 2018 (revision)

Date Application Deemed Complete: December 27, 2018

Emission Source Reference No.: 54-0174

Permit No.: 573114

Date of Public Notice: TBD

Date of Public Hearing:

Comment Summary

Commenter Comment Response

Changes to permit after public notice period:

public notice...public notice waupaca foundry, inc. has applied to the tennessee department of...

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