AIR EMISSION PERMIT NO IS ISSUED TO GERDAU AMERISTEEL US INC

Transcription

1 AIR EMISSION PERMIT NO IS ISSUED TO GERDAU AMERISTEEL US INC 1678 Red Rock Road St. Paul, Ramsey County, MN The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date Total Facility Operating Permit 06/15/1995 Revisions to Application 11/21/1997, 12/16/1999 Major Amendment 06/16/1999 Revisions to Insignificant Activities 07/06/2000, 03/09/2001 Administrative Amendment 11/4/04 This permit authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: Federal; Pt 70/Incorporates Existing NSR Conditions Administrative Amendment: Issue Date: 10/28/2002 Issue Date: December 6, 2004 Expiration: 10/28/2007 All Title I Conditions do not expire. Richard J. Sandberg, Manager Air Quality Permits Section Industrial Division for Sheryl A. Corrigan Commissioner Minnesota Pollution Control Agency TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

2 TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Table C: not used in this permit Appendix A: not used in this permit Appendix B: Modeling Parameters Appendix C: Insignificant Activities

3 NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area (651) Outside Metro Area TTY (651) The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements.

4 FACILITY DESCRIPTION: Total Facility Permit (Permit Action 001): The Permittee operates a steel mini-mill in St. Paul, Minnesota. The mill receives recycled automobile bodies, tin cans from refuse-derived fuel recycling operations, recycled white goods, and other grades of scrap steel, by truck and by rail. The automobile bodies, tin cans, and white goods are run through a hammermill and the shredded steel is separated from non-ferrous materials. The scrap steel is refined and converted into a large number of steel alloys in the electric arc furnace and ladle refining station. During melting and refining, emissions are exhausted through a direct evacuation duct into a fabric filter baghouse. Dust collected in the baghouses falls into hoppers under each compartment, and is removed by augers. A pneumatic conveying system transports the dust from the augers to a storage silo. From the silo it is transferred to railroad hopper cars or trucks for shipment to a recycling facility. Molten steel is cast into billets by a continuous casting machine. The billets are sold as such or are reheated in a reheat furnace and hot-rolled into various structural shapes in a rolling mill. The facility is located in an area that was previously designated as non-attainment for PM 10. However, the area currently meets the ambient air quality standards, and was officially redesignated as attainment on September 24, The facility has been subject to an administrative order (part of Minnesota s state implementation plan, or SIP, for attaining ambient air quality standards) containing requirements contributing to the correction of the nonattainment problem and the ultimate redesignation. The requirements of that order have been incorporated into this permit as non-expiring Title I conditions. This permit will ultimately replace the administrative order and be incorporated into the SIP (separately from the permit issuance process). The facility is a major source under federal New Source Review and the Part 70 permit program. Administrative Amendment (Permit Action 002): This permit action is for a change of ownership at the facility. The new owners are Gerdau Ameristeel US, Inc. (previously was North Star Steel owned by Cargill).

5 Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do FACILITY-SPECIFIC REQUIREMENTS Why to do it Parameters Used in Modeling: The stack heights, emission rates, and other parameters used in the most recently approved modeling are listed in Appendix B of this permit. Before making any physical changes or changes in the method of operation which may affect parameters listed in Appendix B, the Permittee shall demonstrate to the MPCA that the PM10 plume dispersion characteristics following the physical change or change in method of operation will be equivalent to or better than the PM10 dispersion characteristics modeled using the parameters in Appendix B. The information submitted must include, at a minimum, the locations, heights, and diameters of the stacks; locations and dimensions of nearby buildings; the velocity and temperature of the gasses emitted; and the emission rates. If the information does not demonstrate equivalent or better dispersion characteristics, or if a conclusion cannot readily be made about the dispersion, the Permittee must remodel. (continued from above) For changes that do not involve an increase in a PM10 emission rate and that do not require a permit amendment, this proposal must be submitted as soon as practicable, but no less than 60 days before beginning actual construction of the stack or associated emission unit. For changes involving increases in PM10 emission rates and that require a minor permit amendment, the proposal must be sumitted as soon as practicable, but no less than 60 days before beginning actual construction of the stack or associated emission unit. For changes involving increases in PM10 emission rates and that require a permit amendment other than a minor amendment, the proposal must be submitted with the permit application. Production: less than or equal to 3000 tons/day of steel billet tons cast. Production: less than or equal to tons/year using 365-day Rolling Sum, of steel billet tons cast. Once each day record the steel production for the previous day, and calculate and record the steel production for the previous 365 days. The Permittee shall cover all shredder residue haul trucks and flue dust (K061) railcars leaving the facility. Recordkeeping: Unless otherwise noted in the permit, retain all records at the stationary source for a period of six (6) years from the date of monitoring, sample, measurement, or report. Records must conform to the requirements listed in Minn. R , subp. 5(A) unless otherwise noted. Required Records: The following records must be retained at the facility: a. all calibration and maintenance records for control equipment and associated monitoring devices; b. all original recordings for continuous monitoring instrumentation (if any); c. copies of all reports required by the permit; d. date, time, and cause of each unscheduled startup and shutdown, bypass, or breakdown of process equipment, control equipment, fuel supply system, stack, and monitoring system, if it may cause an increase in emissions of a regulated pollutant; e. the cause, magnitude, and date and time of commencement and cessation, for each exceedance of an emission or opacity limit, steel production limit, or shredder material limit, and any noncompliance with an operational requirement; f. the records of water application described in this permit; and g. other records described in this permit. TItle I Condition: Limit to avoid classification of a previous modification as major under 40 CFR Section and Minn. R ; Minn. R , subp. 5(C) A-1

6 Permanent Recordkeeping: The Permittee shall permanently maintain the following records: a. Design, Construction, and Operation Information. The Permittee shall maintain a file or files of the information on the design, construction, and operation of each emission source, fuel system, stack, structures pertinent to modeling for downwash, and any other information required to conduct PM10 ambient air quality modeling. The file or files shall also include all information required to demonstrate that the equipment identified in this permit is installed and operated as described. If the Permittee makes changes or modifications that do not require amendments to this permit, the file or files shall include a description of that change or modification and all information required to demonstrate that the change or modification did not require a permit amendment. Permanent Recordkeeping, continued. b. PM10 Emission Compliance and Operational Requirement Demonstration Plans. The Permittee shall maintain a file at the facility which includes this permit and all attachments or items incorporated by reference, and any plans which upon approval by the MPCA or EPA become integral and enforceable parts of this permit. The Permittee shall conduct maintenance as necessary to ensure that all equipment is in proper operating condition. GENERAL REQUIREMENTS (continued from above) Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and shall include a preventative maintenance program for that equipment, a description of the minimum (but not necessarily the only) corrective actions to be taken to restore the equipment to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment, and the records kept to demonstrate plan implementation. Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A, B, and/or C. Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as specified by Minn. R following formal review of a subsequent performance test on the same unit. Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment (any requirements applying to continuous emission monitors are listed separately in this permit). Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. Minn. R , subp. 14 and Minn. R , subp. 16(J) Minn. R. ch Minn. R Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. R Minn. R , subp. 3 Minn. R , subp. 2 At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. A-2

7 Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R subp. 2), including records of the emissions resulting from those changes. Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). Emission Inventory Report: due 91 days after end of each calendar year following permit issuance (April 1). To be submitted on a form approved by the Commissioner. Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 4 Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R Minn. R through Minn. R Minn. R , subp. 1(H) Minn. R , subp. 5(B) Minn. R Minn. R , subp. 16 Minn. R , subp. 9(A) Minn. R through Minn. R Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R through Minn. R A-3

8 Subject Item: Associated Items: GP 001 Slag Handling Facility CE 011 Dust Suppression by Water Spray FS 012 Slag handling - screening FS 013 Slag handling - conveying FS 014 Slag handling - dumping FS 015 Slag handling - loading to process FS 016 Slag handling - loadout to storage FS 017 Slag handling - truck loading FS 018 Slag handling - dump conveyors 1-3 FS 026 IMS slag crushing OPERATING REQUIREMENTS What to do Why to do it The Permittee shall not operate the crusher (FS026) from November 1 through March 31. Crusher Operating Hours: less than or equal to 8 hours/day The Permittee shall water the unpaved roads at the IMS slag facility. Watering shall comply with the following conditions: a. The water application rate shall be at least 3 gallons for each 100 square feet every 24 hours. b. A 0.1 inch rainfall during the previous 24 hours shall substitute for one water application. c. Water application is not required when the air temperature is below 32 degrees Fahrenheit or on any day that has no traffic on the roads. d. Following any day when water is not applied based on absence of traffic, water shall be applied within 3 hours of recommencement of traffic. The Permittee shall apply water, at a rate of at least 2.4 gallons at least every minute, to all material entering the IMS slag facility prior to screening and conveying. The Permittee shall apply water, at a rate of at least 0.5 gallons at least every minute, to all material exiting the IMS crusher conveyor at all times that the crusher is operating. RECORDKEEPING REQUIREMENTS The Permittee shall retain daily water application records for a minimum of six (6) years following the date on which the information is recorded. The record shall include the following: a. the roads watered, the amount of water applied, the time watered, and the method of application for each application. If water was not applied because of no traffic on the roads, or because there was a 0.1 inch or greater rainfall within the previous 24 hours, it must be noted in the record along with the sources of measurement (i.e. National Weather Service or on-site rain gauge). b. the amount of water applied to all material entering the IMS slag facility prior to screening and conveying, and the method of water application. c. the amount of water applied to all material exiting the IMS crusher conveyor during operation of the crusher, and the method of water application. d. records of watering equipment breakdowns and repairs. Operating Record: The Permittee shall record and maintain records of the following: a. the date and time of each daily inspection of the slag handling equipment, and any maintenance performed as a result of the inspection b. the date and total hours that the crusher is operated each day. A-4

9 Subject Item: Associated Items: GP 002 Melting/Refining combined limits EU 001 Ladle Refining Station EU 002 Electric Arc Furnace SV 001 AAF Baghouse, vent #1 SV 002 Amerex Baghouse SV 010 AAF Baghouse, Vent #2 SV 011 North-end meltshop roof monitor (louvers) EMISSION LIMITS What to do Why to do it Nitrogen Oxides: less than or equal to 12.5 lbs/hour from the two emission units combined. Sulfur Dioxide: less than or equal to 62.5 lbs/hour from the two emission units combined. Carbon Monoxide: less than or equal to lbs/hour from the two emission units combined Volatile Organic Compounds: less than or equal to 37.5 lbs/hour from the two emission units combined. TESTING REQUIREMENTS Performance Test: due 180 days after 10/28/2002 to measure SO2, NOX, CO, and VOC emissions from EU001 and EU002. Performance Test Notifications and Submittals: Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements. Title I Condition: Limit to avoid classification of a previous modification as major under 40 CFR Section and Minn. R Title I Condition: Limit to avoid classification of a previous modification as major under 40 CFR Section and Minn. R Title I Condition: Limit to avoid classification of a previous modification as major under 40 CFR Section and Minn. R Title I Condition: Limit to avoid classification of a previous modification as major under 40 CFR Section and Minn. R Title I Condition: Testing of Title I limit; Minn. R , subp. 1 Minn. R , subp. 1-4 and Minn. R , subp. 1-2 Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test A-5

10 Subject Item: EU 001 Ladle Refining Station Associated Items: CE 001 Fabric Filter - Medium Temperature i.e., 180 F<T<250 F GP 002 Melting/Refining combined limits SV 001 AAF Baghouse, vent #1 SV 010 AAF Baghouse, Vent #2 SV 011 North-end meltshop roof monitor (louvers) EMISSION LIMITS What to do Why to do it Total Particulate Matter: less than or equal to grains/dry standard cubic foot of exhaust gas from the control device. Particulate Matter < 10 micron: less than or equal to grains/dry standard cubic foot of exhaust gas from the control device. Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity (SV001 and SV010). CONTROL EQUIPMENT REQUIREMENTS (CE001) Title I Condition - To avoid classification of a previous modification as major under 40 CFR Section and Minn. R ; Minn. R , subp. 1(A)(1) Minn. R , subp. 1(A)(2) The Permittee shall operate the baghouse at all times that the associated process equipment is in operation, in such a manner as to achieve and maintain compliance with the PM10 emission limit. Total Particulate Matter: greater than or equal to 99 percent collection efficiency Total Particulate Matter: greater than or equal to 99 percent capture efficiency Particulate Matter < 10 micron: greater than or equal to 99 percent collection efficiency Particulate Matter < 10 micron: greater than or equal to 99 percent capture efficiency Hood Certification and Evaluation: The control device hood (point(s) where generated emissions are drawn into the control device) capture efficiency shall be certified as specified in Minn. R , subp. 3. The Permittee shall maintain a copy of the certification on site, as well as an annual record of fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow indication method. Pressure Drop: greater than or equal to 2.5 inches of water column and less than or equal to 8.0 inches of water column across each baghouse compartment during the collection cycle, unless a new range is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA approved performance test where compliance was demonstrated. Once every 24 hours when in operation, the Permittee shall record the pressure drop across the baghouse compartments during the collection cycle. Daily Inspections: Once per operating day, the Permittee shall inspect the control equipment to check for compartment air emissions characteristic of a broken bag. When emissions characteristic of a broken bag are observed, the broken bag will be identified, tied off immediately, and replaced at a later time. The Permittee shall maintain a written record of these inspections. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. EMISSIONS MONITORING AND TESTING Title I Condition: Control required for limit used to avoid classification as a major modification under 40 CFR Section and Minn. R Title I Condition: Control required for limit used to avoid classification as a major modification under 40 CFR Section and Minn. R Title I Condition: Control required for PM10 SIP limit Title I Condition: Control required for PM10 SIP limit Minn. R , subp. 4, 5 and 14 Minn. R , subp. 4, 5, and 14 Visible Emissions: The Permittee shall check SV001, SV010, and SV011 for any visible emissions once each day of operation during daylight hours. The readings shall be done at the same time as the opacity readings at SV002. Minn. R , subp. 4 and 5 A-6

11 Performance Test: due before year starting 10/28/2002 to measure PM-10 emissions from SV001 and SV010. Annual tests shall not be less than 10 months apart. Performance Test Notifications and Submittals: Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements. Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test RECORDKEEPING REQUIREMENTS Operating Record: The Permittee shall record and maintain records of the following: ; Minn. R , subp. 1 Minn. R , subp. 1-4 and Minn. R , subp. 1-2 a. the date, time, and duration that a fabric filter fan is inoperative. b. the date and time that baghouse bags are replaced or tied off. c. the date and time of each daily inspection of the baghouse, and any maintenance performed as a result of the inspection d. once each day, the pressure drop across the baghouse, in inches of water column e. the date and time of visible emission observations of SV001, SV010, and SV011, and whether or not visible emissions were observed A-7

12 Subject Item: EU 002 Electric Arc Furnace Associated Items: CE 002 Fabric Filter - Medium Temperature i.e., 180 F<T<250 F GP 002 Melting/Refining combined limits SV 002 Amerex Baghouse EMISSION LIMITS What to do Why to do it Total Particulate Matter: less than or equal to grains/dry standard cubic foot of exhaust gas from the control device. Particulate Matter < 10 micron: less than or equal to grains/dry standard cubic foot of exhaust gas from the control device. Opacity: less than or equal to 3 percent opacity from the control device (SV002). CONTROL EQUIPMENT REQUIREMENTS (CE002) 40 CFR Section a(a)(1) 40 CFR Section a(a)(2) The Permittee shall operate the baghouse in such a manner as to achieve and maintain compliance with the PM10 emission limit. Particulate Matter < 10 micron: greater than or equal to 99 percent collection efficiency Particulate Matter < 10 micron: greater than or equal to 99 percent capture efficiency during melting and refining Particulate Matter < 10 micron: greater than or equal to 95 percent capture efficiency during charging and tapping Hood Certification and Evaluation: The control device hood (point(s) where generated emissions are drawn into the control device) capture efficiency shall be certified as specified in Minn. R , subp. 3. The Permittee shall maintain a copy of the certification on site, as well as an annual record of fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow indication method. Pressure Drop: greater than or equal to 2.5 inches of water column and less than or equal to 8.0 inches of water column across each baghouse compartment during the collection cycle, unless a new range is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA approved performance test where compliance was demonstrated. Once every 24 hours when in operation, the Permittee shall record the pressure drop across the baghouse compartments during the collection cycle. DEC System Fan Motor Amps: greater than or equal to 160 amps and less than or equal to 175 amps during electric arc furnace operation, unless a new range is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA approved performance test where compliance was demonstrated. Once each operating day, read and record the pressure drop across the baghouse compartments during the collection cycle. Once per shift, check and record the control system fan motor amps and damper position. Daily Inspections: Once per operating day, the Permittee shall inspect the control equipment to check for compartment air emissions characteristic of a broken bag. When emissions characteristic of a broken bag are observed, the broken bag will be identified, tied off immediately, and replaced at a later time. The Permittee shall maintain a written record of these inspections. Monthly Inspections: The Permittee shall perform monthly operational status 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 shall include observations of the physical appearance of the equipment. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. EMISSIONS MONITORING AND TESTING Title I Condition: Control required for PM10 SIP limit Title I Condition: Control required for PM10 SIP limit Title I Condition: Control required for PM10 SIP limit Minn. R , subp. 4, 5 and 14 ; 40 CFR Section a(b) 40 CFR Section a(c) Title I Condition: Monitoring required to maintain limit under State Implementation Plan for PM10; Minn. R ; monitoring for PM limit of 40 CFR Section a(a)(1) 40 CFR Section a(b) 40 CFR Section a(d) Minn. R , subp. 4, 5, and 14 A-8

13 SV002 Visible Emission Observations: At least once each day while the furnace is operating in the melting and refining period, a Certified Visible Emission Observer shall take visible emission observations at SV002. These observations shall be taken in accordance with Method 9, and, for at least three 6-minute periods, the opacity shall be recorded for any point(s) where visble emissions are observed. Where it is possible to determine that a number of visible emission sites relate only to one incident of the visible emissions, only one set of three 6-minute observations will be required, for the site of highest opacity that directly relates to the cause or location of visible emissions observed during a single incident. Records shall be maintained of all opacity observations. If at any time the opacity of the baghouse emissions (SV002) is determined by the Permittee to be greater than 3% opacity, the Permittee shall correct the cause within two days from the time of the observation. The MPCA may require the Permittee to conduct a performance test for PM10 from the baghouse within 30 days of the observation. If the MPCA determines that the baghouse emissions exceed 3% opacity, the MPCA shall issue a certified letter stating such. The Permittee shall be required to investigate and correct the cause, and may be required to conduct a performance test for PM10 within 30 days of receiving the letter. Performance Test: due before end of each calendar year starting 10/28/2002 to measure PM-10 emissions from SV002. Annual tests shall not be less than 10 months apart. Performance Test Notifications and Submittals: Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements. Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test RECORDKEEPING REQUIREMENTS Operating Record: The Permittee shall record and maintain records of the following: a. the date, time, and duration that fewer than two (2) fabric filter fans are operating; b. the date and time that baghouse bags are replaced or tied off. c. the date and time of each daily inspection of the baghouse and EAF and associated duct work, and any maintenance performed as a result of the inspection d. once each day, the pressure drop across the baghouse, in inches of water column e. the date, time, and duration of any down time of the electric arc furnace f. the date and time of each opacity reading g. once per shift, the date, time, and baghouse fan motor amps and the DEC damper position. 40 CFR Section a(c) ; Minn. R , subp. 1 Minn. R , subp. 1-4 and Minn. R , subp. 1-2 A-9

14 Subject Item: EU 003 Auto Shredding Associated Items: CE 010 Wet Scrubber/Cyclone/Z-box SV 003 Shredder scrubber system stack What to do EMISSION & OPERATING LIMITS Why to do it Particulate Matter < 10 micron: less than or equal to grains/dry standard cubic foot Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 20 percent opacity Minn. R , subp. 1(A) Minn. R , subp. 1(B) Production: less than or equal to 2000 tons/day of shredded material CONTROL EQUIPMENT REQUIREMENTS (CE010) The Permittee shall operate the control equipment in such a manner as to achieve and maintain compliance with the PM10 emission limit. Particulate Matter < 10 micron: greater than or equal to 90 percent collection efficiency Total Particulate Matter: greater than or equal to 90 percent collection efficiency Particulate Matter < 10 micron: greater than or equal to 90 percent capture efficiency Total Particulate Matter: greater than or equal to 90 percent capture efficiency Hood Certification and Evaluation: The control device hood (point(s) where generated emissions are drawn into the control device) capture efficiency shall be certified as specified in Minn. R , subp. 3. The Permittee shall maintain a copy of the certification on site, as well as an annual record of fan rotation speed, fan power draw, or face velocity of each hood, or other comparable air flow indication method. Main Hammermill spray line pressure: greater than or equal to 4 psi, unless a new range is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA approved performance test where compliance was demonstrated. The Permittee shall record the hammermill spray line pressure once every 24 hours when in operation. Main Hammermill spray line flow: greater than or equal to 6 gallons/minute, unless a new range is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA approved performance test where compliance was demonstrated. The Permittee shall record the hammermill spray line flow once every 24 hours when in operation. Venturi water pressure: greater than or equal to 17 psi, unless a new range is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA approved performance test where compliance was demonstrated. The Permittee shall record the venturi water pressure once every 24 hours when in operation. Venturi flow rate: greater than or equal to 200 gallons/minute, unless a new range is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA approved performance test where compliance was demonstrated. The Permittee shall record the venturi flow rate once every 24 hours when in operation. Demister flow rate: greater than or equal to 225 gallons/minute, unless a new range is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA approved performance test where compliance was demonstrated. The Permittee shall record the demister flow rate once every 24 hours when in operation. Demister water pressure: greater than or equal to 19 psi, unless a new range is set pursuant to Minn. R , subp. 3, based on the values recorded during the most recent MPCA approved performance test where compliance was demonstrated. The Permittee shall record the demister water pressure once every 24 hours when in operation. Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Title I Condition: To achieve the SIP limit for PM10 Minn. R , subp. 1(A) (control equipment required to meet emission limits) Title I Condition: To achieve the SIP limit for PM10 Minn. R , subp. 1(A) (control equipment required to meet emission limits) Minn. R , subp. 4, 5 and 14 Title I Condition: Limit to maintain emission limits of PM10 SIP; Minn. R , subp. 2 and 14 Title I Condition: Limit to maintain emission limits of PM10 SIP; Minn. R , subp. 2 and 14 Title I Condition: Limit to maintain emission limits of PM10 SIP; Minn. R , subp. 2 and 14 Title I Condition: Limit to maintain emission limits of PM10 SIP; Minn. R , subp. 2 and 14 Title I Condition: Limit to maintain emission limits of PM10 SIP; Minn. R , subp. 2 and 14 Title I Condition: Limit to maintain emission limits of PM10 SIP; Minn. R , subp. 2 and 14 Minn. R , subp. 4, 5 and 14 A-10

15 Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - any recorded water flow rate is below the required minimum rate; - any recorded pressure is below the required minimum rate; or - the scrubber system or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure and/or water flow rate to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the scrubber system. The Permittee shall keep a record of the type and date of any corrective action taken for the scrubber system. EMISSIONS MONITORING AND TESTING Performance Test: due 180 days after 10/28/2002 to measure PM and opacity from SV003. Performance Test: due 180 days after 10/28/2002 to measure PM-10 emissions from SV003. Performance Test Notifications and Submittals: Performance Tests are due as outlined in Tables A and B of the permit. See Table B for additional testing requirements. Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test RECORDKEEPING REQUIREMENTS Operating Record: The Permittee shall record and maintain records of the following: Minn. R , subp. 4, 5, and 14 Minn. R , subp. 1; testing for Minn. R. emission limit Title I Condition: Testing for SIP limit for PM10; Minn. R , subp. 1 Minn. R , subp. 1-4 and Minn. R , subp. 1-2 a. the date and time of each daily inspection of the shredder, and any maintenance performed as a result of the inspection b. the date, time, and duration of any fires at the shredder c. the date and total tons of material shredded each day A-11

16 Subject Item: EU 004 Reheat Furnace Associated Items: SV 004 Reheat Furnace EMISSION LIMITS What to do Why to do it Particulate Matter < 10 micron: less than or equal to grains/dry standard cubic foot Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. Minn. R , subp. 1(A)(1) Minn. R , subp. 1(A)(2) Fuel use: Limited to natural gas and no. 2 fuel oil, by design. Minn. Stat. Section , subd. 4a; Minn. R , subp. 2 Sulfur Content of Fuel: less than or equal to 0.5 percent by weight Minn. Stat. Section , subd. 4a; Minn. R , subp. 2 Recordkeeping: Record and maintain records of the amounts of each fuel Minn. R , subp. 4 combusted on a monthly basis. These records may consist of purchase records or receipts, but must include the sulfur content of fuel oil purchased. A-12

17 Subject Item: EU 005 Baghouse Dust Silo Associated Items: CE 002 Fabric Filter - Medium Temperature i.e., 180 F<T<250 F SV 002 Amerex Baghouse EMISSION LIMITS What to do Why to do it Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Emissions from this unit are collected by CE002, and cannot be isolated from the EU002 emissions. Therefore, the emissions from this unit are included in the limit set at EU002. See Subject Item EU002 for control equipment operation requirements. Particulate Matter < 10 micron: less than or equal to grains/dry standard cubic foot Emissions from this unit are collected by CE002, and cannot be isolated from the EU002 emissions. Therefore, the emissions from this unit are included in the limit set at EU002. See Subject Item EU002 for control equipment operation requirements. Opacity: less than or equal to 10 percent opacity from the control device (CE002). Minn. R , subp. 1(A) 40 CFR Section a(b) Emissions from this unit are collected by CE002, and cannot be isolated from the EU002 emissions. Therefore, the emissions from this unit are included in the limit set at EU002. See Subject Item EU002 for control equipment operation requirements. A-13

18 Subject Item: EU 006 Railcar Loading Associated Items: CE 005 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 006 Railcar Bin Vent Baghouse EMISSION LIMITS What to do Why to do it Particulate Matter < 10 micron: less than or equal to grains/dry standard cubic foot. This is equivalent to 0.85 lb/hour at maximum equipment capacity; maximum controlled emissions at maximum capacity are approximately 0.06 lb/hour. Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 10 percent opacity from the control device (CE005). CONTROL EQUIPMENT REQUIREMENTS (CE005) Particulate Matter < 10 micron: greater than or equal to 99 percent control efficiency Total Particulate Matter: greater than or equal to 99 percent control efficiency Visible Emissions: The Permittee shall check the fabric filter stack (SV006) for any visible emissions once each day of operation during daylight hours. During inclement weather, the Permittee shall read and record the pressure drop across the fabric filter, once each day of operation. Pressure Drop: greater than or equal to 2 inches of water column and less than or equal to 14 inches of water column Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored fabric filter is in operation. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection or pressure drop reading, and whether or not any visible emissions were observed, or whether or not the observed pressure drop was within the range specified in this permit Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - visible emissions are observed; - the recorded pressure drop is outside the required operating range; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 1(A) 40 CFR Section a(b) Title I Condition: To achieve the SIP limit for PM10 Minn. R , subp. 1(A) (control equipment required to meet emission limits) Title I Condition: Monitoring for emission limits of PM10 SIP; Minn. R , subp. 2 and 14 Title I Condition: Monitoring for emission limits of PM10 SIP; Minn. R , subp. 2 and 14 Minn. R , subp. 4 Title I Condition: Monitoring for emission limits of PM10 SIP; Minn. R , subp. 2 and 14 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 4, 5, and 14 A-14

19 Subject Item: EU 009 Additive Silo (north) Associated Items: CE 008 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 008 Additive Bin Vent Baghouse (N) EMISSION LIMITS What to do Why to do it Particulate Matter < 10 micron: less than or equal to grains/dry standard cubic foot Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 20 percent opacity from control device (CE008) CONTROL EQUIPMENT REQUIREMENTS (CE008) Particulate Matter < 10 micron: greater than or equal to 99 percent control efficiency Total Particulate Matter: greater than or equal to 99 percent control efficiency Visible Emissions: The Permittee shall check the fabric filter stack (SV008) for any visible emissions once each day of operation during daylight hours. Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection, and whether or not any visible emissions were observed. Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. Corrective Actions: The Permittee shall take corrective action as soon as possible if either of the following occur: - visible emissions are observed; or - the fabric filter or any of its components are found during the inspections to need repair. Corrective actions shall include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the fabric filter. The Permittee shall keep a record of the type and date of any corrective action taken for each filter. Minn. R , subp. 1(A) Minn. R , subp. 1(B) Title I Condition: To achieve the SIP limit for PM10 Minn. R , subp. 1(A) (control equipment required to meet emission limits) Title I Condition: Monitoring for emission limits of PM10 SIP; Minn. R , subp. 2 and 14 Title I Condition: Monitoring for emission limits of PM10 SIP; Minn. R , subp. 2 and 14 Minn. R , subp. 4, 5 and 14 Minn. R , subp. 4, 5, and 14 A-15