COMMONWEALTH OF PENNSYLVANIA Department ofenvironmental Protection Southwest Regional Office

Transcription

1 I ' OfFlOIAL FILE COpy COMMONWEALTH OF PENNSYLVANIA Department ofenvironmental Protection Southwest Regional Office TO FROM THROUGH DATE AQ Case File TVOP NoorNahar A. Air Quality March 27, 2014 Ma~~p.E. Program Manager Air Quality RE Review oftitle V Operating Permit Application Allegheny Ludlum LLC. Bagdad Facility Leechburg Boro, Armstrong County APS AUTH PF Background Allegheny Ludlum LLC is a producer bfspecialty steels located in Leechburg Boro, Armstrong County. This is a finishing mill and there are no melting activities. The Bagdad facility is a cold metalworking operation and utilizes cold rolling mills, normalizing furnaces, and heat & flatten operations in the productionof grain-oriented electrical steel. Both Bagdad and West Leechburg facility operated under the authorization oftvop that was issued on February 28, Allegheny Ludlum shutdown the West Leechburg facility in July, On March 2, 2012, company submitted a revised Title V application for Bagdad facility. A new permit number was generated under the same primary facility. Bagdad facility was transferred to new permit number. No sources were moved from West Leechburg to Bagdad facility. Some sources (boilers, pickling lines, shot blasts) have been deactivated and removed from Bagdad facility. There is no Maintenance Plan for any sources at Bagdad facility. Company has generated 30 tons oferc from the shutdown ofthe West Leechburg plant.

2 Emissions and Control Equipment Major emissions at this facility are from the furnaces, bliss mill and roadways. Bliss mill is a grandfather source at this facility which is a major contributor to pa11iculate and VOC emissions. It is equipped with a mist eliminator. CO and NOx emissions at this facility are from the use of natural gas in the furnaces. A RACT Operating Permit was issued to this facility on March 23, The applicable conditions from RACT permit for the sources at Bagdad facility have been copied and included in this permit. Silicon Steel coils are run through bliss mill to reduce and shape the roll. The rolls are then sent through the normalizer furnace lines. Afterwards coils are coated with Magnesium Oxide in the #3 or #4 MgO furnace lines. Product specifications and quality demands determine which furnace is utilized. The process then takes the roll to the #66 or #67 cleaning and coating line. There are two baghouses on cleaning lines to control particulate emissions. The rolls are washed with water and brush. After cleaning, Mono Magnesium Phosphate is applied to the roll and passed through drying oven to dry. The rolls are then sent to the tunnel kiln which is electric heated and have a hydrogen atmosphere. The rolls are then cut to customer specifications. Compliance with emissions may be established through stack testing, the appropriate AP-42 emission factors and/or material balance. The Facility-wide PTE (tpy) and actual emissions are summarized as follows: ALLEGHENY LUDLUM. LLC BAGDAD FACILITY POTENTIAL EMISSIONS 2014 DEP PTE (lonslyear) 10 No. Source PM S02 CO NOx vae 112A 66 Line Coil Cleaning C 66 Line Strip Dryer Une Annealina Furnace E 66 Line Curing Furnace A 67 Line Coil Cleaning C 67 Line Sirip Dryer G Line Annealing Furnace E 67 line Curing Furnace MoO Line Furnace l1sa 4 MoO Line Furnace Bliss Mill Nonnalizer Normalizer Misc Space Healers Insignificant Misc Painls (inslqniticanl arts lileaners (tnolvloualfll InSI mlcant) Paved Roads 43.8 Insignificant AST 064A (BGD) 0.43 TOTAL (tonslvear): I 1.3 I

3 BAGDAD facility ANNUAl INVENTORY AND EMISSION STATEMENT 2013 OfP Anooal Oper.lling Actual Emissions (tooslyear) 10 No. Sou-ce llvoolhlut MaIeri.1l UM. Hours an\olol'ia PM2.5 PM10 PMoon 502 CO NOx VDC PI> lila 66 Line Coil Cfe311ioo steel Ions C 66 line Slrio """" 9.1 NG MMCf 4, Line Anoe.1tino F~n3ce 61.2 NG MMCf E 66 Lioo CIXino Fumate 72.7 NG MMCf A 67 Une Coil CIe3flino steel Ions C 6lUneStrio Of\'er 16.5 NG MMCF Une AnneallM fl.ltlaoo 96.9 NG MMCF E 67 line Cuino Fulll.l«l NG MMCF t.4no line Fum3ce 10.6 NG MMCF lisa 4 t.1no line Furnace 26.5 NG MMCF 2.5~ BKssMlll steel Ions NOOllalizer NG MMCF 4~ Normalizer NG MMCF Mise Sooce Heaters 25.6 NG MMCF mise AST 064A (BGO) 9,743 IQ3SOIine IQalions Misc. Paint Usaq6 367 POinl IQallofls 6, Paved Roods 7344 VMT 6, P3Its Cleaners solvent I callons TOTAL ttonsjvear : Regulatol)' Analysis... ~. Per.Pa. Code Title.25 Section..121A02(a),.a..nermitis..requiredJo.operate.a.stationary. ail.... contamination source. The usual requirements ofpa. Code Title 25 Sections 123.1,123.2,123.11,123.13,123.21, , and have been included in this TVOP. All ofthe conditions under the sources located in Bagdad plant have been copied from Title V permit and included in this TVOP. Bagdad plant is considered a finishing mill; no steel is produced at this location. On March 2, 2007, Company submitted application for 30 tons ofnox ERCs created by the permanent shutdown ofthe following sources: No. 71 A&P Line Annealing Furnace, rated capacity 62 MMBtu/hour, AIMS Source ID 105A. No. 71 A&P Line HF/HN03 Pickling, rated capacity 30 tons ofsteel/hour, AIMS Source ID 105E. No.2 B&P Line Shotblaster, AIMS Source ID 103A. No.2 B&P Line HF/HN03 Pickling, rated capacity 18.8 tons of steel/hour, AIMS Source ID 103C. No. 19 Wet Grinder AIMS Source ID 130.

4 Lee Wilson Anneal Furnaces, rated capacity 54 MMBtu/hour combined for 15 units, AIMS Source ID 126. Package Boiler No. II, rated capacity 34.5 MMBtu/hour, AIMS Source ID 037. The application for ERCs was reviewed and approved by Jesse Parihar on February 28, The approved 30 tons ofnox ERCs shall be made enforceable by their inclusion in this TVOP Since the reductions meet all ofthe requirements ofpa Code Title , the TVOP has been revised to memorialize include the following conditions: "Due to the shutdown ofthe sources, Source IDs: 105A, 105E, 103A, 103C, 130, 126, and 037, West Leechburg Plant has generated 30 tons ofnox ERCs. In accordance with PA Code Title , these ERCs have been determined to be surplus, permanent, quantified and enforceable". "In accordance with 25 Pa Code (7), "The reduced emissions limitation ofthe new or modified permit ofthe source or facility generating the creditable emissions decrease or ERC shall be continuously verified by Department, local air pollution control agency or other State approved compliance monitoring and reporti\1g programs. Onsite inspections will be made to verify shutdowns. Ifequipment has not been dismantled or removed, the owner or operator shall on an annual basis certify in writing to the Department the continuance ofthe shutdown." There are no NSPSs or NESHAPs that are applicable to this facility. The applicability of40 CFR 63, Subpali YYYYY - National Emission Standards for Hazardous Air Pollutants for Area Sources: Electric Arc Furnace Steelmaking Facilities has been evaluated. In accordance with 40 CFR Am I subject to this subpart?, (a) You are subject to this subpart ifyou own or operate an electric arc furnace (EAF) steelmaking facility that is an area source ofhazardous air pollutant (HAP) emissions. There are no electric arc furnaces at this facility, so this regulation does not apply. The applicability of40 CFR 63, Subpart ZZZZZ - National Emission Standards for Hazardous Air Pollutants for Iron and Steel Foundries Area Sources has been evaluated. In accordance with 40 CFR Am I subject to this subpali?, (a) You are subject to this subpmi ifyou own or operate an iron and steel foundry that is an area source ofhazardous air pollutant (HAP) emissions and (b) This subpart applies to each new or existing affected source. The affected source is each iron and steel foundry. In accordance with 40 CFR What definitions apply to this subpmi?, Foundry operations mean all process equipment and practices used to produce metal castings for shipment. Foundry operations include: Mold or core making and coating; scrap handling and preheating; metal melting and inoculation; pouring, cooling, and shakeout; shotblasting, grinding, and other metal finishing operations; and sand handling. Metal is not melted at this facility, so this regulation does not apply. The Compliance Assurance Monitoring (CAM) provisions of40 CFR 64 applies when all ofthe following are true:

5 1. The source is located at a Title V facility, 2. The source is subject to an emission standard, 3. The source uses a control device to achieve compliance with the emission standard, and 4. Emissions from the source, without the control device, exceed major source tln esholds. Bagdad facility has identified the following sources and associated control devices to be subject to CAM: Source ID 113A No. 67 line coil cleaning / baghouse Source Bliss Mill / oil mist eliminator Bagdad facility has proposed the use ofexisting testing, monitoring and recordkeeping requirements as CAM. Appropriate conditions have been added to the TVOP. Additional conditions included in this TVOP are appropriate testing, emission reduction, work practice standards, monitoring, recordkeeping and reporting requirements. Conclusions and Recommendations I have completed my review ofthe TVOP application for Allegheny Ludlum LLC. Bagdad facility has met the regulatory requirements associated with this application submittal. The attached permit reflects terms and conditions as described in permit application. It is my recommendation to issue a Title V Operating Permit for this facility.