MEMORANDUM June 22, Phillip Fielder, P.E., Permits and Engineering Group Manager. Kendal Stegmann, Senior Environmental Manager

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1 DRAFT OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION MEMORANDUM June 22, 2009 TO: THROUGH: THROUGH: THROUGH: FROM: SUBJECT: Phillip Fielder, P.E., Permits and Engineering Group Manager Kendal Stegmann, Senior Environmental Manager Phil Martin, P.E., Engineering Section Peer Review, Herb Neumann/Hal Wright, ROAT David Pollard, ROAT Evaluation of Permit Application Number TVR American Castings, LLC Pryor Foundry Pryor, Mayes County, Oklahoma Located at Mid-America Industrial Park (Lat /Long ) Directions: From US Highway 412 in Mayes County, travel east from the Chouteau exit on Highway 69 to Highway 412B, travel north for approximately 4 miles into the Mid-America Industrial Park. Facility is on the east side of the highway. SECTION I. INTRODUCTION American Castings, LLC (applicant), American Castings, LLC (applicant), a steel foundry that manufactures ductile iron and gray iron castings (SIC 3321), submitted an application received on May 11, 2006, with the required fee of $1,000 for a Title V operating permit renewal. The facility is currently operating under Permit No TV, issued to Grede-Pryor Foundries, Inc. on November 8, 2001 and the modifications outlined in the following table. Additional detail and the rationale for these modifications can be found in the referenced permits. Date Permit No. Purpose 11/08/ TV Initial Title V 11/02/ TV (M-1) Change binders; increase VOC content of glycol ether; incorporate OCMA emissions factor 3/22/ TV (M-2) Construct sand cooler 3/22/ TV (M-3) Construct Laempe-40 core-making machine; change method of accounting for VOC emissions and the emission factor 5/01/ TV (M-4) Construct Beardsley & Piper SF6 shell core-making machine and Shalco U-180 core-making machine 6/12/ TV (M-5) Add Laempe-120 core-making machine addressed in AD

2 PERMIT MEMORANDUM TVR DRAFT 2 Permit No TV (M-3) replaced core machines C-9 (CB-26) and C-10 & C-11 (CB-15) with a new Laempe-40 core-making machine. Included with this change were a change in the method of accounting for VOC emissions and the emission factor. Permit No TV (M-4) replaced core machines C-1 through C-6 with a Beardsley & Piper SF6 shell core-making machine and a Shalco U-180 core-making machine. Permit No TV (M-5) increased the core-making throughput with the addition of the new Laempe Core Machine core-making machine, equipped with its own emissions scrubber. SECTION II. FACILITY DESCRIPTION The facility currently includes three 23-ton coreless induction furnaces for melting ductile iron. The facility-wide pouring rate is limited to 26 tons per hour and 187,200 tons per year from the previous permit and the limits are PSD (Prevention Of Significant Deterioration) limits. Operating all three furnaces simultaneously provides for a maximum melting rate of 26 TPH allowing for slagging and charging. Also included are facilities for receiving, forming, recovering, and disposing of sand used to make molds for the melted metals. A painting operation places weatherproofing coating on some products. A detailed description of each area in the foundry follows. Scrap Handling/Preheating/Metal Melting/Refining Low-manganese steel, foundry returns, and pig iron are loaded into storage bins from railroad cars and other sources. Approximately 25 percent of this operation occurs outdoors and 75 percent occurs inside the foundry building. A typical charge weighs approximately 10 tons and consists of 53 percent foundry returns, 5 percent pig iron, and 42 percent low manganese steel. The charge composition can change with material price consideration and/or availability. The charge is weighed in scaled hoppers and transferred to a preheat conveyor. A natural gas fired preheater with a maximum heat input of MMBTU/hr heats the scrap to approximately 800 degrees Fahrenheit to remove oil and moisture from the scrap. The preheat charge is then loaded into a charge bucket which is lifted by crane, and the charge is put into a melt furnace. Initial metal melting is done in the three, 23-ton coreless electric induction furnaces. The melting operations are divided between the melt furnaces and the holding furnaces. The melt furnaces melt solid metals into a molten stage so that alloys may be added. The composition of the charge depends upon the specific metal characteristics required. Addition of alloys is done to improve properties of the castings. Alloying generally consists of 500 to 600 pounds of graphite, 50 pounds of silicon carbide, 15 to 20 pounds of ferrosilicon, and pounds of ferromanganese. Molten metal is tapped by tilting the furnace and pouring through a spout of the furnace to one of three, 42-ton or one 45-ton holding furnaces. The holding furnaces maintain the temperature and the chemical consistency of the molten metal at the desired pouring temperature of 2,750 o F. Slag removal is done as part of normal operations of both the melt furnaces and the holding furnaces. Slag removal reduces the amount of melted metal that reaches the rest of the sources in the foundry by 6%. However, to be conservative emissions are based on 26 tons/hour.

3 PERMIT MEMORANDUM TVR DRAFT 3 When a holding furnace is full and the charge attains the desired temperature the metal is tapped into a ladle containing magnesium ferrosilicon. The introduction of magnesium into the iron improves its crystalline properties and facilitates the transition from gray to ductile iron. Ductile iron is formed as a steel matrix containing spheroidal particles (or nodules) of graphite. Ordinary cast iron contains flakes of graphite. Each flake acts as a crack, which makes cast iron brittle. Ductile irons have high tensile strength and are silvery in appearance. The metal is then transferred to pouring ladles and ferrosilicon is added for further refining. Such refining further improves the properties of the ductile iron. Both the transfer and pouring ladles are heated by natural gas-fired heaters. Mold Making Green Sand Mold Making The green sand molding process is used to make forms used to shape the exterior of the castings. The green sand molding process uses sand from the green sand shake-out. Sand separated by shake-out is passed through the rotary screens and a sand cooler before it is recycled to the core or mold lines. The Simpson Multi-cooler Sand Cooler was authorized by Permit No TV (M-2) for the Line 6 Green Sand Molding line. The sand cooler is used to condition the sand prior to reuse. It enables the molding sand to be controlled at a constant temperature, while also controlling the sand moisture content. This includes blending out the fluctuations in temperature, moisture, and additives. Variations in these sand properties are a primary contributor to unacceptable quality control problems in the sand mold process. Benefits to the conditioning process include bentonite tempering; improvements in Muller consistency, efficiency, and capacity; reduction of additive consumption; improvements in sand handling; and reduction of sand scrap. The sand cooler system is installed in-line with the existing sand mold handling system, at a point after mold shake-out has occurred. From shakeout, hot sand travels down a conveyor belt underneath a cross-belt magnetic separator, dumps onto another conveyor belt, which is covered, where the sand is then transported outside the main building to a sand tower which houses the sand cooler. Inside the sand tower, the sand drops into a bucket elevator and is conveyed upwards to a rotary screen. The sand passes through the rotary screen to a storage silo. Sand exits the storage silo via a vibratory feeder and enters into the sand cooler. The sand cooler is an enclosed tank with paddles to lift and drop the sand to allow cooling by heat transfer to the air, which is being drawn through the cooler by a fan. Air discharging from the sand cooler is directed into a baghouse, along with other pick-up air points within the sand tower. Particulate fines collected in the baghouse are returned to the process stream by a new conveyor, installed to eliminate the trucking and disposal of this material. Cooled sand exits the cooler onto another conveyor belt which transports the sand back into the sand handling system inside the main building and dumps the sand onto another conveyor belt. This transfer point is covered, under vacuum, and pulls any particulate to an existing wet scrubber. The emissions associated with such are minimal. Reclaimed sand, new silica sand, bentonite clay, sea coal, and water are used to make forms used to shape the exterior of the castings. Additional conditioning occurs in sand mullers and mixers which prepare the sand and binders for the cores and molds. Bentonite clay and water are used

4 PERMIT MEMORANDUM TVR DRAFT 4 as the binding agents. Particulate matter emissions from the rotary screens, sand mullers, and shake-out are controlled by wet dust collection systems at 95% efficiency. After mixing, the sand mixture is transferred to the molding machines, where it is simultaneously packed mechanically over the top and bottom portions of the pattern. Once the sand mixture has been properly molded, the patterns are withdrawn from the forms, using a release agent to facilitate release. Removal of the pattern leaves a cavity inside the mold, that forms the outside of the casting. Cores (described below) are then set to produce the internal voids in the castings. After the finished mold (exterior form and core) is prepared, a conveyor transports the mold to pouring where molten metal from the melt shop is poured into molds. PUNB Mold Making Phenolic urethane no-bake (PUNB) molding utilizes a three-part, phenolic urethane binding system where chemical reactions take place at ambient temperatures. The first part of the PUNB process uses a phenolic resin, the second part contains an isocyanate component, and part three is a liquid catalyst. PUNB parts 1, 2, and 3 are mixed with silica sand in a mixer. Silica sand consists of reclaimed sand from the shake-out process and fresh silica from the sand bin. From the sand bin, the sand is sent through a preheater and into the mixer. A typical charge consists of 80 percent reclaimed sand and 20 percent fresh silica sand. Resins (PUNB parts 1 and 2), PUNB catalyst, and iron oxide are also added to the mixer. After mixing, the sand mixture is conveyed to the mold line where the molds are formed manually. The cope (top half) is assembled first, followed by the drag (bottom). After assembly, the molds are rotated to allow separation from the pattern using a release agent. Some of the molds are then washed with a water-based graphite refractory slurry, cured, and dried with an electric infrared heater. After drying, cores from the core room are set into place in the drag, and the cope is rotated and set in place on top of the drag. A weight is then added to the mold to prevent cope lift due to metal pressure during pouring. The weighted molds are then routed to the pouring lines for casting. Core Making Operations Cores are molded sand shapes used to make the internal voids in castings. The Core Room uses three different processes to make cores: a) shell, b) phenolic urethane cold box (PUCB), and c) phenolic urethane no-bake (PUNB). Sand is recycled from the mold lines shakeouts and reused in the core room in the PUCB and PUNB processes. Part of the cores from the PUCB and the PUNB core processes are given a protective wash. This is accomplished by dipping the cores into a graphite refractory water-based slurry. The washed cores are then dried in two natural gas-fired drying ovens. Core mud may be used to repair damaged portions of a core. The cores from all three processes, each described following, are transferred to molding lines for insertion into the mold. Phenolic Urethane Cold Box (PUCB) Process The PUCB process utilizes a phenolic cold box binding system. With this system, sand is mixed with the three different parts of the organic binder chemicals. The first part is the phenolic resin, the second part is an isocyanate, and the third is the catalyst (gaseous dimethylethylamine or DMEA). The sand is mixed with the phenolic and isocyanate resins in a mixer. There are eleven core machines. The mixed sand with resin is then put into core boxes which are gassed with the catalyst, causing the resin to bind to the sand and to make the core. DMEA emissions are

5 PERMIT MEMORANDUM TVR DRAFT 5 controlled by an acid/caustic scrubber with a 95% control efficiency which uses caustic soda and sulfuric acid to neutralize the DMEA emissions. A release agent is applied to the core boxes to allow removal of the core from the core box after the core is made. Some of the cores are then sent to the core wash process. Core mud is utilized, as needed, to finish out the cores. The cores are then baked by a 2.5 MMBTUH natural gas fired oven and then sent to the mold lines for insertion. Particulate matter emissions from the mixers and the sand storage are captured by a 95% efficient wet dust collector. Phenolic Urethane No-Bake (PUNB) Process The PUNB process is a three-part, phenolic urethane no-bake binding system where chemical reactions take place at ambient temperatures. The first part of the PUNB process uses a phenolic resin, the second part contains an isocyanate component, and part three is a liquid catalyst. PUNB parts 1, 2, and 3 are mixed with silica sand in a mixer. After mixing, the sand is sent to the core box to be molded into the proper core shapes. A release agent is used to facilitate removal of the finished cores. Some of the cores are then sent to the core wash process. Core mud is applied as needed to finish the cores. The cores are then dried by a 2.5 MMBTUH natural gas oven and sent to the mold lines for insertion. The facility currently operates one PUNB core machine. Particulate matter emissions from the mixer are captured by a 95% efficient wet dust collector. Chemical binders for the mold and core making processes are stored in two 6,000 gallon bulk storage tanks. Shell Process As noted earlier, the old shell core machines, C-1 through C-6, have been removed from the site and machines C-26 and C-27 were added by Permit No TV (M-4). The shell process utilizes sand coated with phenolic resin and hexamethylenetetramine. The sand is charged into the shell machines and heat is applied from combustion of natural gas. The resin coating is a thermosetting type, which bonds together when the heat is applied. The pattern or core box temperature usually varies between 350 o and 450 o F. A release agent is used to allow separation of the core from the pattern. The shell cores are then sent to the mold lines for insertion into the molds. Pouring, Cooling, and Shakeout After the molten metal has solidified in the molds, the hot castings are routed through cooling tunnels. When cooling is finished, the castings are separated from the form/core mold sand via a shake-out process. Castings are then routed to the finishing and cleaning area. Any remaining sand is cleaned off the castings by a shot-blast machine in the finishing area. A screening conveyor reclaims the sand and recycles it through a rotoclaim bin into the sand bin. Particulate matter emissions from the shake-out and sand handling are controlled by a dry dust collection system at 98% efficiency. Finishing

6 PERMIT MEMORANDUM TVR DRAFT 6 Metal finishing removes sand and unwanted appendages, prepares the castings surface, and includes a quality assurance step. Castings from the Green Sand lines and the PUNB line are sent to the finishing area. Despuring, blasting, and grinding are all performed in this area. Despuring removes unwanted appendages such as spurs, gates, and risers by hitting with a sledge hammer. Remaining sand is cleaned off the castings by a shot-blast machine. The abrasive blast cleans the castings by removing any remaining mold sand and scale. Additional touch-up including grinding and surface repair is performed, and castings are then sent for final inspection. Particulate matter is controlled with a dry collection system at 98% efficiency. Painting Some finished castings are painted based on product requirements. The castings undergo rinsing in a multistage bath consisting of detergent wash, tap water rinse, phosphoric acid rinse, tap water rinse, and a final deionized water rinse. Two natural gas-fired burners, 2.5 MMBTUH, are used to warm the soap and first water baths. Thoroughly rinsed castings are sent to a 5,000 gallon water-based, electrodeposition paint dip system. The paint consists of a paste that provides the color, an epoxy paint resin that provides the medium, and the solvents butyl cellosolve, diethanolamine, and hexyl cellosolve. Formaldehyde has been discussed in previous permit memorandums for use as a biocide. The facility has discontinued the use of formaldehyde. Components and deionized water are pumped into the tank and mixed. Paint is added from a replenishing tank to maintain a constant level. The painted castings undergo a post rinsing and are sent to a 4.0 MMBTUH natural gas-fired oven to cure at 450 o F. Following the oven, the castings are cooled by the chiller s water sprays. SECTION III. EQUIPMENT AP-42, Chapter 12.10, Gray Iron Foundries, groups operations related to lump knockout, magnetic separation, aeration/cooling, screening, and accumulation, into a category called Sand Handling. EUG A - Sand Handling System includes all emissions units downstream of the shakeout process and upstream of the core/mold making process, having emissions (mostly particulate matter) as a result of conditioning and transferring sand. EUG A - Sand Handling System EU Point Description Size/Rating Construct Date A-3 131C Simpson Multi-cooler MC-200, GSML # TPH/26,200 dscfh July 2005 M Vulcan Sand Reclamation NA 1985 AP-42, Chapter 12.10, Gray Iron Foundries, groups operations related to mixing/mulling, core/mold forming, and core/mold washing into a category called Core and Mold Preparation. EUG C Core and Mold Operations, formerly known as Core Operations has been modified to include emissions from core and mold making due to the similarities in processes and emissions and now includes all emissions units involved in these operations.

7 PERMIT MEMORANDUM TVR DRAFT 7 EUG C - Core and Mold Operations EU EP Description Size/ Rating Construct Date A-1 131B Simpson 23G Sand Muller 2, GSML # TPH Removed A-2 131A Simpson 23G Sand Muller 1, GSML # TPH ,000 dscfh C Dependable Speed Twin MK1, PUCB Core 15 TPH 1979 Sand Mixer C Shalco U-321, PUCB Core Machine NA 1994 C-12, C Shalco U-180, PUCB Core Machines O.O.S C-14, C Shalco U-180, PUCB Core Machines NA 1979 C Beardsley/Piper CB-30, Core Machine NA 1977 C Beardsley/Piper CB-40, Core Machine NA 1980 C Shalco U-360, Core Machine NA 1990 C A PUCB, Core Wash NA 1974 C Dependable Pacemaster 250, PUNB Core Sand NA 1991 Mixer C PUNB, Core Box Area NA 1974 C B PUNB, Core Wash NA 1974 C CB-22, PUCB Core Machine NA 1999 C Laempe 120, Core Machine 4.2 TPH 2003 C Laempe 40, Core Machine 4.2 TPH 2005 C Beardsley/Piper SF6, Shell Core Machine NA 2006 C Shalco U-180, Shell Core Machine NA 2006 M-1 132B Molding EMI Osborn, GSML #405 NA Removed M-5 132C Molding Herman Moldmaster, GSML #406 NA Removed M Molding Vulcan Vibrating Table, NBML 60 molds/8 hr 1985 M PUNB Sand Mixer Dependable Pacemaster 2,000 lbs/min 1998 O.O.S. - Out-Of-Service EU - Emissions Unit EP - Emissions Point NA - Not Available PUCB - Phenolic Urethane Cold Box PUNB - Phenolic Urethane No-bake Box AP-42, Chapter 12.10, Gray Iron Foundries, groups processes related to melting, inoculation (refining), pouring and cooling into a category called Melting and Casting. EUG F Melting, Holding and Refining, previously known as Melting/Holding Furnaces and Ladles, includes only the melting furnaces, holding furnaces, and ladles. For this memorandum discussion and permit, pouring and cooling is included in EUG M. Because emissions factors are typically available for these separate operations, it is convenient to have these separate EUG subcategories. EUG F Melting, Holding and Refining EU Point Description Size Construct Date F Brown-Bovari Electric Induction Melt Furnace 23-ton 1974 F Brown-Bovari Electric Induction Melt Furnace 23-ton 1974 F Brown-Bovari Electric Induction Melt Furnace 23-ton 1974 F Brown-Bovari Electric Induction Holding Furnace 42-ton 1974 F Brown-Bovari Electric Induction Holding Furnace 42-ton 1974 F Brown-Bovari Electric Induction Holding Furnace 42-ton 1974

8 PERMIT MEMORANDUM TVR DRAFT 8 EUG F Melting, Holding and Refining F Whiting Electric Induction Holding Furnace 45-ton 1984 F Tapping/Transfer Ladles NA 1974 F Refining/Pouring Ladles NA 1974 EUG H - Material Handling/Preheating, includes equipment related to the handling and preheating of metal scrap to be used in the melting furnaces. AP-42, Chapter 12.10, Gray Iron Foundries, groups these operations into a category called Furnace Charge Preparation. EUG H - Material Handling/Preheating EU Point Description Construction Date H Pre-heating 1985 H Charge Make-up 1974 H Material Handling 1974 EUG I includes equipment that combusts natural gas. Note that I-1, the Venetta Furnace, is the source of heat for H-1, Pre-heating. EUG I - Combustion Equipment EU/Point Description Size/Rating Construction Date I-1 (H-1) Venetta Furnace MMBTU/HR 1985 I-2 I-11 Ladle Heaters 1.0 MMBTU/HR 1974 I-12 I-13 Tank Heaters 5.0 MMBTU/HR 1974 I-14 Paint Oven 4.0 MMBTU/HR 1974 I-15 I-20 Shell Core Heaters 0.5 MMBTU/HR 1974 I-21 I-22 Core Ovens 2.5 MMBTU/HR 1974 EUG M, previously known as Molding, Pouring, Cooling, and Shakeout, now includes only emission points associated with pouring and cooling. As noted above, AP-42 would typically group these operations in the category of Melting and Casting. However, because emissions factors are typically available for these separate operations, it is convenient to have these separate EUG subcategories. EUG M - Pouring and Cooling EU Point Description Size/Rating Construct Date M-2 133B Pouring Schneible Side Draft Hood, GSML NA Removed #405 M-6 133C Pouring Schneible Side Draft Hood, GSML NA 1974 #406 M Pouring Schneible Side Draft Hood, NBML NA 1974 M-3 134B Cooling Kirk and Blum Tunnel, GSML #405 NA Removed M-7 134C Cooling Kirk and Blum Tunnel NA 1974 M B Cooling Vulcan Cooling Room, NBML NA Removed GSML - Green Sand Molding Line; NBML - No Bake Molding Line

9 PERMIT MEMORANDUM TVR DRAFT 9 EUG N Shakeout, is a new EUG added to separate equipment related to shakeout operations from EUG M, which previously included Molding, Pouring, Cooling, and Shakeout. AP-42, Chapter 12.10, Gray Iron Foundries, groups shakeout processes into a category called Cleaning and Finishing. However, because emissions factors are typically available for both shakeout operations and also for other cleaning/finishing operations, EUG S, formerly known as Shotblast and Grinding is renamed as Cleaning and Finishing. EUG N Shakeout EU Point Description Size/Rating Construct Date M-4 135B Shakeout Dideon Rotary Drum, GSML #405 NA Removed M-8 135C Shakeout Carrier Barrelhorse, GSML #406 NA 1993 M Shakeout General Kinematic Table, NBML NA 1985 EUG P Paint System, includes various sources of painting that emit primarily VOC and also PM emissions. EUG P - Paint System EU Point Description Construction Date P-1 171B Water-based Electrodeposition Dip System 1974 As noted above, EUG S has been renamed from Shotblast and Grinding to Cleaning and Finishing. EUG S Cleaning and Finishing EU Point Description Size/Rating Construct Date S PUNB 4-Wheel Shotblast NA 1974 S Wheelabrator/tumblast Shotblast 200 ton/day 1989 S Wheelabrator/tumblast Shotblast 200 ton/day 1989 S Wheelabrator/tumblast Shotblast 200 ton/day 1995 S Pangborn/Rotoblast Shotblast 200 ton/day 1990 S Grinding EUG W - Facility Wide EU Point Description Construction Date All All Points Fugitives Various SECTION IV. EMISSIONS Emissions of criteria pollutants are directly proportional to the melt rates and the associated raw material handling to supply the melters and produce molds and cores. In general, these emissions can be calculated using available throughput-based emissions factors, in units of lbs/ton-metal poured or lbs/ton-sand used. Individual throughput rates for most emissions units are listed in the equipment section. Actual throughput rates may be less, depending on demand. Steel throughput is generally reduced by about 6% past the melting area due to slagging and

10 PERMIT MEMORANDUM TVR DRAFT 10 charging. Material usages are based on facility requirements for processing 26 ton/hr of metal melt. Combustion emissions from natural gas-fueled equipment are based on AP-42 (7/98), Tables and The pouring process also generates combustion-like emissions, for which emissions factors are taken from a variety of technical sources detailed in later discussion. EUG A - Sand Handling System Particulate Emissions from Sand Handling PM 10 emissions from sand handling and reclamation are based on a total PM emission factor of 3.6 lb/ton-sand handled from AP-42 (5/03), Table and an assumption that PM 10 can be calculated as 70% of PM, from AP-42, Table , (rev. 1/95) Particle Size Distribution Data, Shakeout. Annual sand usage is based on an average sand-to-metal ratio of 6.78 and annual metal pouring of 175,968 tons per year (187,200 tons adjusted for 6% slagging). As illustrated in the tables that follow, the facility is not operating at full equipment capacity. EUG A - Sand Handling EU Point Description Control Device Control Efficiency Exhaust/ Stack(s) A-3 131C Simpson Multi-cooler MC-200, Baghouse 95% SC1 GSML #406 M Vulcan Sand Reclamation Wet Collector 95% S53 A/B Stack/Exhaust Flow (acfm) Height (feet) Diameter (feet) Temperature ( o F) S53 A/B 66, SC1 26, x EU Point Description Sand Throughput PM 10 Emissions TPH TPY Lbs/hr TPY A-3 131C Simpson Multi-cooler MC-200, GSML # ,193,063 M Vulcan Sand Reclamation EUG C - Core and Mold Operations VOC Emissions from Core and Mold Operations The method for calculating emissions of VOCs generated from the mixing and curing of cores and molds in the Title V permit was a mass balance based on 50% evaporation of the VOC content of the core binders. Permit No TV (M-3) changed the 50% evaporation factor to that determined from a test procedure developed and conducted by the Ohio Cast Metals Association (OCMA) as part of a Memorandum of Understanding between OCMA and the Ohio Environmental Protection Agency. This test procedure is a simple mass balance method which involves weighing the pre-mix ingredients, mixing them and then recording incremental weight measurements and time. The specifics of the method are in the permit conditions. The tests will be conducted by the vendor(s) of the binder material(s). The permit also allows for EPA Method 24 or EPA Method 24A.

11 PERMIT MEMORANDUM TVR DRAFT 11 Limits on material usage rates were eliminated from previous permits because compliance with the VOC limit now depends on the emission factor specific to the product, which can change from one product to the next. Emission factors are not specified in this permit because they will be specific to each product. Therefore material usage can change with changes in the product emission factor. Hourly rates were eliminated in the last permit modifications to accommodate elimination of certain requirements to comply with OAC 252:100-41, Part 5 that are no longer needed. However, they are being restored in this permit because it is believed that they were utilized in the PSD and Title V permits in the air dispersion modeling that was used to check compliance with the NAAQS. From permit No C (PSD), VOC is not limited directly by NAAQS. Rather, it is regulated as an ozone precursor. EPA developed a method for predicting ozone concentrations based on VOC and NO X concentrations in an area. The ambient impacts analysis utilized these tables from "VOC/NO X Point Source Screening Tables" (Richard Scheffe, OAQPS, September, 1988). The Scheffe tables utilize increases in NO X and VOC emissions to predict increases in ozone concentrations. Based on this method, incremental ozone impacts for added emissions were conservatively estimated at µg/m 3. Therefore, VOC limits, in pounds per hour and tons per year, are restored from the Title V permit, but as modified in permit No TV (M-1). The derivation of these limits dates back to the Title V permit. It was based on a simple mass balance calculated from material usage and the above stated assumption that 50% of the VOC content evaporates. That analysis is obsolete and is not repeated, but only a summary is presented. EUG C Core and Mold Operations EU VOC Emissions lb/hr TPY PUNB Part PUNB Part PUNB Catalyst PUCB Part PUCB Part PUCB Catalyst 0.78 * 2.82 Release Agent TOTALS * 95% scrubber efficiency NA - Not Applicable Particulate Emissions from Core and Mold Operations PM 10 emissions from core and mold operations are based on a total PM emission factor of 1.1 lb/ton-metal handled from AP-42 (5/03), Table , of which 70% is PM 10 from AP-42, Table , (rev. 1/95) Particle Size Distribution Data, Shakeout. An annual pouring rate of 175,968 tons per year is based on 187,200 tons adjusted for 6% slagging. As illustrated in the tables that follow, the facility is not operating at full equipment capacity.

12 PERMIT MEMORANDUM TVR DRAFT 12 EUG C Core and Mold Operations EU Point Description Control Device Control Efficiency Exhaust/ Stack(s) A A Sand Muller 1, GSML #406 Wet Collector 95% S31 B/C/E M Molding Vulcan Vibrating Table, NBML None 95% * E51 A-F M PUNB Sand Mixer Wet Collector 95% S53 A/B C Dependable Speed Twin MK1, PUCB Core Wet Collector 95% S31A Sand Mixer C Shalco U-321, PUCB Core Machine Acid Scrubber 95% S11 C-12, Shalco U-180, PUCB Core Machines Acid Scrubber 95% S11 C-13 C-14, Shalco U-180, PUCB Core Machines Acid Scrubber 95% S11 C-15 C Beardsley/Piper CB-30, Core Machine Acid Scrubber 95% S11 C Beardsley/Piper CB-40, Core Machine Acid Scrubber 95% S11 C Shalco U-360, Core Machine Acid Scrubber 95% S11 C A PUCB, Core Wash None No Emissions S1, S11, E1, E11 A/B, E21 A-C C Dependable Pacemaster 250, PUNB Core Wet Collector 95% S31A Sand Mixer C PUNB, Core Box Area Wet Collector 95% S1, S11, E1, E11 A/B, E21 A-C S1, S11, E1, E11 A/B, E21 A-C C B PUNB, Core Wash None No Emissions C CB-22, PUCB Core Machine Acid Scrubber 95% S11 C Laempe 120, Core Machine Acid Scrubber 95% S11 C Laempe 40, Core Machine Acid Scrubber 95% S11 C Beardsley/Piper SF6, Shell Core Machine None 95% * S1, S11, E1, E11 A/B, E21 A-C C Shalco U-180, Shell Core Machine None 95% * S1, S11, E1, E11 A/B, E21 A-C * Shell core machines C-26 and C-27 are not routed through controls. Control efficiency was estimated to be 95% because of the effect of the binders. The same assumption is made for the Vulcan Vibrating Table, M-9. Stack/Exhaust Flow (acfm) Height (feet) Diameter (feet) Temperature ( o F) S31 B/C/E 42, E51 A-F 40, S31 A/B 42, S11 11, S1 42, S31A 42, E1 30, E11 A/B 30, E21 A-C 30, E31 A/B* 30, E31 C-G* 30, E32 A-C* 40, * S31A/B, E31 C-G, and E32 A-C previously served Lines 5 and 6, which included M-1 Molding EMI Osborn, GSML #405; and M-5, Molding Herman Moldmaster, GSML #406.

13 PERMIT MEMORANDUM TVR DRAFT 13 EU EP Description Metal Throughput A-2 131A Simpson 23G Sand Muller 1, GSML #406 C Dependable Speed Twin MK1, PUCB Core Sand Mixer C Shalco U-321, PUCB Core Machine C-12, C Shalco U-180, PUCB Core Machines C-14, C Shalco U-180, PUCB Core Machines C Beardsley/Piper CB-30, Core Machine C Beardsley/Piper CB-40, Core Machine C Shalco U-360, Core Machine C A PUCB, Core Wash C Dependable Pacemaster 250, PUNB Core Sand Mixer C PUNB, Core Box Area C B PUNB, Core Wash C CB-22, PUCB Core Machine C Laempe 120, Core Machine C Laempe 40, Core Machine C Beardsley/Piper SF6, Shell Core Machine C Shalco U-180, Shell Core Machine M PUNB Sand Mixer Dependable Pacemaster EUG F Melting, Holding, Refining and EUG Fa - Magnesium Treatment PM 10 Emissions 175, Particulate Emissions from Melting, Holding, and Refining Melting is accomplished using electric induction. No fuel combustion is involved and grease and oils imported with the scrap are removed in the preheating process (discussed below). Therefore, emissions associated with melting, holding, and refining primarily include particulate matter (PM). Calculations for these emissions are carried forward from the Title V memorandum, with revisions for clarification. PM 10 emissions for melting and holding were calculated using the total PM emission factor from AP-42 (1/95), Table , Electric Induction Furnaces, with an assumption that 95.6% is PM 10, based on Table AP , (1/95) Particle Size Distribution Data, Shakeout. PM 10 emissions for tapping/refining were calculated at 80% of the total PM emission obtained from the FIRE emission factors Version 5.0 (8/95). All sources are uncontrolled. EU Point Operation EUG F Melting, Holding and Refining PM 10 Emission Factor Source of Emission Factor Metal Throughput Annual Emissions Exhaust/ Stack(s) F Induction Melt Furnace E42A F Induction Melt Furnace E42B F Induction Melt Furnace lbs/ton AP , E42C F Induction Holding Furnace E42A F Induction Holding Furnace E42B

14 PERMIT MEMORANDUM TVR DRAFT 14 EU Point Operation EUG F Melting, Holding and Refining PM 10 Emission Factor Source of Emission Factor Metal Throughput Annual Emissions Exhaust/ Stack(s) F Induction Holding Furnace E42C F Induction Holding Furnace E42A F Tapping Ladles FIRE E41A-D F Refining Ladles emission E41A-D 0.80 lb/ton factors Version 5.0 (8/95) Particulate Emissions from Magnesium Treatment PM 10 emissions for magnesium treatment were calculated using the total PM emission factor from AP-42 (1/95), Table , Magnesium treatment, with an assumption that 100% is PM 10, based on 100% being emitted to work environment. All sources are uncontrolled. EU Point Operation EUG Fa Magnesium Treatment PM 10 Metal Emission Pour Factor Annual Emissions Exhaust/ Stack(s) F Induction Melt Furnace E42A F Induction Melt Furnace E42B F Induction Melt Furnace E42C F Induction Holding Furnace E42A F Induction Holding Furnace , E42B F Induction Holding Furnace E42C F Induction Holding Furnace E42A F Tapping Ladles E41A-D F Refining Ladles E41A-D Stack/Exhaust Flow (acfm) Height (feet) Diameter (feet) Temperature ( o F) E42A-C 35, E41A-D 35, The following hourly emission rates are estimated using the above PM 10 emissions factor of lbs-pm 10 /ton-metal to assist in comparing the PTE to the standards of 40 CFR Part 63, Subpart EEEEE for potential future use in determining compliance or the need for stack testing. However, it should be noted that as discussed in the Federal Regulations, the melt furnaces are not subject to Subpart EEEEE at this time. EU Point Description Metal Throughput (TPH) PM 10 Emissions (lbs/hr) F Brown-Bovari Electric Induction Melt Furnace F Brown-Bovari Electric Induction Melt Furnace

15 PERMIT MEMORANDUM TVR DRAFT 15 EU Point Description Metal Throughput (TPH) PM 10 Emissions (lbs/hr) F Brown-Bovari Electric Induction Melt Furnace F Brown-Bovari Electric Induction Holding Furnace F Brown-Bovari Electric Induction Holding Furnace F Brown-Bovari Electric Induction Holding Furnace F Whiting Electric Induction Holding Furnace F Tapping/Transfer Ladles NA NA F Refining/Pouring Ladles NA NA According to the data in the above tables, if each furnace were contributing a proportionate amount of PM to the exhaust flow, then each would be emitting at the following estimated concentration: Total hourly PM rate = (3 x 19.79) + (3 x 36.14) lbs = lbs/hr lbs x 7,000 grains x minute x hour x 560 R-acf = 0.73 gr/scf hr 35,720 acf lb 60 minutes 520 R-scf Being that the first calculation is likely an overestimate as the holding furnaces have higher capacity ratings than could be met by the melting furnaces, then the following estimate might be a more reasonable representation of the PM emissions concentration. Total hourly PM rate = 3 x = lbs/hr lbs x 7,000 grains x minute x hour x 560 R-acf = 0.21 gr/scf hr 35,720 acf lb 60 minutes 520 R-scf EUG H - Material Handling/Preheating Particulate Emissions from Material Handling/Preheating Calculations for emissions of particulate matter from material handling and preheating are taken from the Title V permit memorandum which states: Associated emissions include PM 10 from material handling, 25% outdoor and 75% indoor, and pre-heating which also results in combustion gases. Emission factors are based on An Inventory of Iron Foundry Emissions, Modern Castings, An emission factor for PM 30 was given and an engineering estimate that 15% was PM 10 from handling and make-up and 45% from charge pre-heating was used. All sources are uncontrolled. Based on the factors given in the table shown below, apparently the 75% factor was applied to Charge Make-up emissions. EUG H - Material Handling/Preheating EU Point Operation PM 10 Factor (lbs/ton-metal) Metal Throughput Emissions H Charge Pre-heating , H Charge Make-up ,

16 PERMIT MEMORANDUM TVR DRAFT 16 EUG H - Material Handling/Preheating EU Point Operation PM 10 Factor (lbs/ton-metal) Metal Throughput Emissions H Material Handling , Stack/Exhaust Point Flow (acfm) Height (feet) Diameter (feet) Temperature ( F) S , E51F , E41A , EUG I - Combustion Equipment Criteria Pollutants (NO X, CO, VOC, and SO 2 ) Emissions from Combustion Equipment Criteria pollutants are generated as a result of combustion of natural gas fuel in process heaters. Emissions were calculated using AP for boilers/heaters less than 100 MMBTU/hr and the total combined heat input rating. Individual equipment items and their heat input ratings are detailed in the Equipment section above. The total combined rating of combustion equipment is MMBTUH. This combined calculation is applicable because all heaters are rated less than 100 MMBTUH and therefore have the same emissions factors. The results of the calculation for each pollutant are tabulated below. EUG I - Combustion Equipment EU NO X CO SO 2 VOC lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY I-1 I EUG M - Pouring and Cooling Criteria Pollutant (NO X, CO, VOC, and SO 2 ) Emissions from Combustion Equipment Emissions during pouring are generated from the decomposition of binders and other organic compounds contained in the molds and cores. Emissions are related to mold size, mold composition, sand to metal ratio, pouring temperature, and pouring rate. Emissions include particulate matter, volatile organic compounds, carbon monoxide, nitrogen oxides, sulfur dioxide, and hazardous air pollutants. Hazardous air pollutant (HAP) emissions are characterized in a separate section below. Emissions calculations for pouring and cooling processes discussed in previous permits were based on stack test data from foundries that utilized the same green sand mold and core production processes as this facility (known as Grede at that time) with the average PM factor of the three stack tests multiplied by a 34% contingency factor and PM 10 based on 49% of total PM. For this permit memorandum, the applicant requests that emissions of VOC and CO be based on data from studies conducted by the Castings Emissions Reduction Program (CERP) at another facility having green sand mold, no bake mold, and core production processes. The applicant states that the processes from which these factors were derived are the same as those conducted at American Castings. NO X and SO X are calculated using Fire 6.25 ( ).

17 PERMIT MEMORANDUM TVR DRAFT 17 Hourly emission rates are not calculated as there is really no maximum capacity rating for the pouring process other than limitations imposed by other bottlenecks in the manufacturing process such as the speed of conveyor belts, cooling process time, shakeout time, etc. The standards for emissions measurements found in NESHAP EEEEE are based on exhaust pollutant concentrations in units of grains/dscf. Also, note that in calculating VOC emissions, if the metal pour rates for the three categories of VOC emissions (Green Sand Molds, PUNB Molds/Cores, PUCB Cores) were summed, the total would be considerably more than the facility-wide pour rate of 175,968. This was done to account for the generation of VOC emissions as a result of exposure of both the molds and the cores to the poured metal. Additionally, this category of emissions is the only one to include shakeout. PM emissions from shakeout are included in the discussion for EUG N Shakeout. EUG M Pouring and Cooling EU Point Operation PM 10 Emission Factor (lbs/ton-metal) M-6 133C Pouring GSML #406 Metal Poured Emissions , M A Pouring NBML M-7 134C Cooling , Total PM 10 Emissions CO Emission Factor (lbs/ton-metal) M-6 M-10 M-7 133C 153A 134C Pouring GSML #406 Pouring NBML Cooling , Total CO Emissions 6.01 NO X Emission Factor (lbs/ton-metal) M-6 M-10 M-7 133C 153A 134C Pouring GSML #406 Pouring NBML Cooling , Total NO X Emissions 0.88 EU Point Operation SO 2 Emission Factor (lbs/ton-metal) Metal Poured M-6 M-10 M-7 133C 153A 134C Pouring GSML #406 Pouring NBML Cooling Emissions , Total SO 2 Emissions 1.76

18 PERMIT MEMORANDUM TVR DRAFT 18 EU Point Operation VOC Emission Factor (lbs/ton-metal) Metal Poured Emissions Green Sand Molds Pouring/Cooling/Shakeout , PUNB Molds/Cores Pouring/Cooling/Shakeout , PUCB Cores Pouring/Cooling/Shakeout , Total VOC Emissions EU Point Description Control Device Control Efficiency Exhaust/ Stack(s) M-6 133C Pouring GSML #406 None 0% S32 A-C, S34 A-B* M A Pouring NBML None 0% S51 A-D M-7 134C Cooling None 0% S33 A-G Stack/Exhaust Flow (acfm) Height (feet) Diameter (feet) Temperature ( o F) S34 A/B* 26, S32 A-C 39, S51 A-D 29, S35 A-G** 8, S33 A-G 5, S52 A/B*** 32, * S34A-B previously served Pouring Line 5, which included M-2 pouring, Schneible Side Draft Hood, GSML #405; and M-3 cooling, Kirk and Blum Tunnel, GSML #405. ** S35 A-G previously served Cooling Line 5 M-3, Cooling Kirk and Blum Tunnel, GSML #405 *** S52 A/B previously served the No-Bake Molding Line, which included M-11, Vulcan Cooling Room, NBML. EUG N - Shakeout Particulate Emissions from Shakeout PM 10 emissions from mold and core shakeout are based on a total PM emission factor of 3.2 lb/ton-metal handled from AP-42 (5/03), Table and an assumption that PM 10 can be calculated as 70% of PM, from AP-42, Table , (rev. 1/95) Particle Size Distribution Data, Shakeout. The annual metal pouring rate of 175,968 tons per year (187,200 tons adjusted for 6% slagging) is prorated for the two separate shakeout lines. EUG N Shakeout EU Point Description Control Device Control Effic. Exhaust/ Stack(s) M-8 135C Shakeout Carrier Barrelhorse, GSML #406 Wet Collector 95% S31 A/B M Shakeout General Kinematic Table, NBML Baghouse 98% S53 A/B

19 PERMIT MEMORANDUM TVR DRAFT 19 EU Point Operation PM 10 Factor (lbs/tonmetal) M-8 135C Shakeout Carrier Barrelhorse, GSML #406 M Shakeout General Kinematic 2.24 Table, NBML Metal Throughput Emissions 123, , Total PM 10 Emissions 9.86 Stack/Exhaust Flow (acfm) Height (feet) Diameter (feet) Temperature ( o F) S31 A/B 42, S53 A/B 66, S31 D* 42, * S31 D previously served Shakeout Lines 5 and 6, which included M-4 Dideon Rotary Drum, GSML #405; and M- 8, Carrier Barrelhorse, GSML #406. EUG P - Paint System VOC Emissions from Dip Coating Emissions of VOC generated from coating (painting) operations are based on the VOC content of the coating and 100% evaporation. Because coatings are applied by a dip method, emissions of particulate matter do not occur from this process. However, an insignificant amount of PM and VOC emissions are generated from spray coating using water-based (low VOC) coatings. EU EUG P - Paint System Throughput (gal/yr) Coating Density (lb/gal) VOC Content (lbs/gal) VOC Emissions Hexyl Cellosolve , Diethanolamine Low Freeze , Epoxy Paste , Epoxy Resin , Glycol Ether , Total VOC Emissions EUG S - Cleaning and Finishing Particulate Emissions from Shotblasting and Grinding PM 10 emissions from shotblasting and grinding are based on a total PM emission factor of 17 lb/ton-metal handled from AP-42 (5/03), Table , Cleaning, Finishing, and an assumption that PM 10 can be calculated as 10% of PM. This method replaces the one from the

20 PERMIT MEMORANDUM TVR DRAFT 20 previous permit where emissions from shotblasting were taken from An Inventory of Iron Foundry Emissions, Modern Castings, 1972, and from EPA-600/ , U.S. EPA, EU Point Operation Control Device Control Efficiency Exhaust/ Stack(s) S PUNB 4-Wheel Shotblast Baghouse 98% S53 A/B S Wheelabrator/tumblast Shotblast S Wheelabrator/tumblast Shotblast E61 A-E, Baghouse 98% S Wheelabrator/tumblast Shotblast E62 A-E S Pangborn/Rotoblast Shotblast S Grinding Baghouse 98% S61 A-D EU Point Operation PM 10 Factor (lbs/tonmetal) S PUNB 4-Wheel Shotblast S Wheelabrator/tumblast Shotblast S Wheelabrator/tumblast Shotblast S Wheelabrator/tumblast Shotblast S Pangborn/Rotoblast Shotblast S Grinding Metal Pour Emissions , Stack/Exhaust Flow (acfm) Height (feet) Diameter (feet) Temperature ( F) S53 A/B 66, E61 A-E 40, E62 A-E 40, S61 A-D 86, EUG W - Facility Wide EUG W - Facility Wide EU Point Description Construction Date All All Points Fugitives Various Hazardous Air Pollutant Emissions Emissions of hazardous air pollutant (HAP) were calculated for melting; pouring, cooling, and shakeout; PUNB core and mold making; and PUCB core making using emissions factors from various documents published by the Casting Emissions Reduction Program (CERP) data for similar mold and core mixtures. Lead emissions are included in the melting category due to the possibility of lead in scrap. Emissions and the specific CERP document from which the emission factors were taken are summarized in the following table.

21 PERMIT MEMORANDUM TVR DRAFT 21 Process Pollutant Metal Pour Melting Melting CERP Test Report # GSA.3 CO Pouring, Cooling, Shakeout Acetaldehyde Green Sand Molds CERP Test Report # PUNB Molds and Cores CERP Test Report # EG and RV EG PUCB Cores CERP Test Report # FB Emissions Factor Control Efficiency Emissions Antimony lbs/ton-metal 0% Arsenic lbs/ton-metal 0% Beryllium lbs/ton-metal 0% Cadmium lbs/ton-metal 0% Chromium lbs/ton-metal 0% Cobalt 187, lbs/ton-metal 0% Lead lbs/ton-metal 0% Manganese lbs/ton-metal 0% Mercury 0.0 lbs/ton-metal 0% Nickel lbs/ton-metal 0% Selenium lbs/ton-metal 0% lbs/ton-metal Aniline lbs/ton-metal 0% Benzene lbs/ton-metal 0% o, m, p-cresol lbs/ton-metal 0% Dimethylnaphthalenes lbs/ton-metal 0% Ethylbenzene lbs/ton-metal 0% Formaldehyde 112, lbs/ton-metal 0% Hexane lbs/ton-metal 0% Methylnaphthalenes lbs/ton-metal 0% Naphthalene lbs/ton-metal 0% Phenol lbs/ton-metal 0% Toluene lbs/ton-metal 0% o, m, p-xylene lbs/ton-metal 0% Benzene lbs/ton-metal 0% o,m,p-cresol lbs/ton-metal 0% Dimethylnapthalenes lbs/ton-metal 0% Formaldehyde 74, lbs/ton-metal 0% Naphthalene lbs/ton-metal 0% Phenol lbs/ton-metal 0% Toluene lbs/ton-metal 0% o,m,p-xylene lbs/ton-metal 0% Aniline lbs/ton-metal 0% Benzene lbs/ton-metal 0% o, m, p-cresol lbs/ton-metal 0% Hexane lbs/ton-metal 0% Naphthalene 147, lbs/ton-metal 0% Phenol lbs/ton-metal 0% POMs lbs/ton-metal 0% Toluene lbs/ton-metal 0% o, m, p-xylene lbs/ton-metal 0% Process Pollutant Binder Used (lb/yr) Emissions Factor Control Efficiency Emissions Core and Mold Making PUNB Molds Formaldehyde lbs/lb-binder 0% Methylnaphthalene 4,847, lbs/lb-binder 0% CERP Test Report Naphthalene lbs/lb-binder 0% 1.212