Air Emission Permit No. 03700066-001 Is Issued to Spectro ...TABLE A: LIMITS AND OTHER REQUIREMENTS...

TDD (for hearing and speech impaired only): (651) 282-5332 Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

AIR EMISSION PERMIT NO. 03700066- 001

IS ISSUED TO

FFS Incorporated

SPECTRO ALLOYS CORPORATION 13220 Doyle Path

Rosemount, Dakota County, MN 55068 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 6/15/1995 Major Amendment Application 10/04/1999 Minor Amendment Application 6/17/2003 This permit authorizes the Permittee to modify and operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. 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/Major for Part 63 Hazardous Air Pollutants

Issue Date: April 22, 2005

Expiration: April 22, 2010 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

TABLE OF CONTENTS

Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals

Appendices: Attached and Referenced in Table A

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) 296-6300 Outside Metro Area 1-800-657-3864 TTY (651) 282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota 55155-4194. 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. 7007.1800, 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. 7007.1800 and 7017.0100, 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.

FACILITY DESCRIPTION: Spectro Alloys is a secondary aluminum processing plant. Emission sources include the hammer mill, the scrap dryer, and two furnaces. Also included as emission sources are natural gas heaters for heating molds. The facility is subject to National Emission Standards for Hazardous Air Pollutants, 40 CFR pt. 63, subp. RRR. That regulation sets emission limits for the scrap dryers, the hammer mill, and the furnaces. To comply with the regulation, Spectro Alloys has controlled the hammermill with a baghouse, the scrap dryer with a thermal oxidizer and alkaline reagent injected baghouse, and the furnaces with a lime injected baghouse. This permit is a total facility Part 70 operating permit that authorizes the rebuilding of refactory of Furnace #1, modification of the hood of Furnace #1 such that it will become an enclosed process and the installation of a second scrap dryer and dross crusher. The emissions from the second scrap dryer will be controlled with a thermal oxidizer and alkaline reagent injected baghouse, as are the emissions from the existing scrap dryer. The modifications qualify under Minnesota Rules as a minor air permit amendment. Previously, Spectro was permitted as a synthetic minor source for federal new source review purposes. To maintain minor source status, this permit contains annual limits on process throughput. However, Spectro plans to modify the hood for the charging well for Furnace #3 such that emissions will be more effectively captured. Those modifications are scheduled to be completed sometime in 2004. With the emission limits set by the now promulgated regulation, and the new modifications to the Furnace #3 capture hood, potential emissions at maximum physical capacity will not exceed major source thresholds as defined under new source review. Therefore, the limits on throughput shall expire once the modifications are complete.

TABLE A: LIMITS AND OTHER REQUIREMENTS 04/22/05Spectro Alloys Corp

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Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column ofthe table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you musttake 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 facilityrequirements.

Subject Item: Total Facility

What to do Why to do itNESHAP REQUIREMENTS

This source is subject to 40 CFR Section 63, Subp. RRR, National EmissionStandards for Hazardous Air Pollutants for Secondary Aluminum Production.

For all 40 CFR Section 63 requirements, the MPCA Commissioner is theAdministrator.

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At all times, including periods of startup, shutdown, and malfunction, the owner oroperator must operate and maintain any affected source, including associated airpollution control equipment and monitoring equipment, in a manner consistent withsafety and good air pollution control practices for minimizing emissions. During aperiod of startup, shutdown, or malfunction, this general duty to minimize emissionsrequires that the owner or operator reduce emissions from the affected source tothe greatest extent which is consistent with safety and good air pollution controlpractices.

40 CFR Section 63.6(e)(1)(i)

The general duty to minimize emissions during a period of startup, shutdown, ormalfunction does not require the owner or operator to achieve emission levels thatwould be required by the applicable standard at other times if this is not consistentwith safety and good air pollution control practices, nor does it require the owner oroperator to make any further efforts to reduce emissions if levels required by theapplicable standard have been achieved. Determination of whether such operationand maintenance procedures are being used will be based on information availableto the Administrator which may include, but is not limited to, monitoring results,review of operation and maintenance procedures (including the startup, shutdown,and malfunction plan required in paragraph (e)(3) of this section), review ofoperation and maintenance records, and inspection of the source.

continued from above

Malfunctions must be corrected as soon as practicable after their occurrence inaccordance with the startup, shutdown, and malfunction plan required in paragraph(e)(3) of this section. To the extent that an unexpected event arises during astartup, shutdown, or malfunction, an owner or operator must comply by minimizingemissions during such a startup, shutdown, and malfunction event consistent withsafety and good air pollution control practices.

No emissions units that have an unreasonable shutdown or breakdown frequencyof process or control equipment shall be permitted to operate.

40 CFR Section 63.6(e)(1)(ii) andMinn. R. 7019.1000, subp. 4

Operation and maintenance requirements established pursuant to section 112 ofthe Clean Air Act are enforceable independent of emissions limitations or otherrequirements in relevant standards.

40 CFR Section 63.6(e)(1)(iii)

(i) The owner or operator of an affected source must develop and implement awritten startup, shutdown, and malfunction plan that describes, in detail, proceduresfor operating and maintaining the source during periods of startup, shutdown, andmalfunction, and a program of corrective action for malfunctioning process and airpollution control and monitoring equipment used to comply with the relevantstandard. This plan must be developed by the owner or operator by the source'scompliance date for that relevant standard. The purpose of the startup, shutdown,and malfunction plan is to --

(A) Ensure that, at all times, the owner or operator operates and maintains eachaffected source, including associated air pollution control and monitoringequipment, in a manner which satisfies the general duty to minimize emissionsestablished by paragraph (e)(1)(i) of this section;

40 CFR Section 63.6(e)(3)(i)

(B) Ensure that owners or operators are prepared to correct malfunctions as soonas practicable after their occurrence in order to minimize excess emissions ofhazardous air pollutants; and

(C) Reduce the reporting burden associated with periods of startup, shutdown, andmalfunction (including corrective action taken to restore malfunctioning process andair pollution control equipment to its normal or usual manner of operation).


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(ii) During periods of startup, shutdown, and malfunction, the owner or operator ofan affected source must operate and maintain such source (including associatedair pollution control and monitoring equipment) in accordance with the proceduresspecified in the startup, shutdown, and malfunction plan developed underparagraph (e)(3)(i) of this section.

40 CFR Section 63.6(e)(3)(ii)

(iii) When actions taken by the owner or operator during a startup, shutdown, ormalfunction (including actions taken to correct a malfunction) are consistent withthe procedures specified in the affected source's startup, shutdown, andmalfunction plan, the owner or operator must keep records for that event whichdemonstrate that the procedures specified in the plan were followed. These recordsmay take the form of a "checklist," or other effective form of recordkeeping thatconfirms conformance with the startup, shutdown, and malfunction plan for thatevent. In addition, the owner or operator must keep records of these events asspecified in 40 CFR Section 63.10(b), including records of the occurrence andduration of each startup, shutdown, or malfunction of operation and eachmalfunction of the air pollution control and monitoring equipment.


Furthermore, the owner or operator shall confirm that actions taken during therelevant reporting period during periods of startup, shutdown, and malfunction wereconsistent with the affected source's startup, shutdown and malfunction plan in thesemiannual (or more frequent) startup, shutdown, and malfunction report requiredin 40 CFR Section 63.10(d)(5).


(iv) If an action taken by the owner or operator during a startup, shutdown, ormalfunction (including an action taken to correct a malfunction) is not consistentwith the procedures specified in the affected source's startup, shutdown, andmalfunction plan, and the source exceeds any applicable emission limitation in therelevant emission standard, then the owner or operator must record the actionstaken for that event and must report such actions with 2 working days aftercommencing actions inconsistent with the plan, followed by a letter within 7 workingdays after the end of the event, in accordance with 40 CFR Section 63.10(d)(5)(unless alternative arrangements are made in advance).

Note that Minn. R. 7019.1000, subps. 1, 2, and 3 have notification requirements forshutdowns and breakdowns that increase emissions, and for deviations thatendanger human health. Please see the requirements underREPORTING/SUBMITTALS.

40 CFR Section 63.6(e)(3)(iv)

v) The owner or operator must maintain at the affected source a current startup,shutdown, and malfunction plan and must make the plan available upon request forinspection and copying by the Administrator. In addition, if the startup, shutdown,and malfunction plan is subsequently revised as provided in paragraph (e)(3)(viii) ofthis section, the owner or operator must maintain at the affected source eachprevious (i.e., superseded) version of the startup, shutdown, and malfunction plan,and must make each such previous version available for inspection and copying bythe Administrator for a period of 5 years after revision of the plan.

40 CFR Section 63.6(e)(3)(v)

If at any time after adoption of a startup, shutdown, and malfunction plan theaffected source ceases operation or is otherwise no longer subject to the provisionsof this part, the owner or operator must retain a copy of the most recent plan for 5years from the date the source ceases operation or is no longer subject to this partand must make the plan available upon request for inspection and copying by theAdministrator. The Administrator may at any time request in writing that the owneror operator submit a copy of any startup, shutdown, and malfunction plan (or aportion thereof) which is maintained at the affected source or in the possession ofthe owner or operator.


Upon receipt of such a request, the owner or operator must promptly submit a copyof the requested plan (or a portion thereof) to the Administrator. The Administratormust request that the owner or operator submit a particular startup, shutdown, ormalfunction plan (or a portion thereof) whenever a member of the public submits aspecific and reasonable request to examine or to receive a copy of that plan orportion of a plan. The owner or operator may elect to submit the required copy ofany startup, shutdown, and malfunction plan to the Administrator in an electronicformat. If the owner or operator claims that any portion of such a startup, shutdown,and malfunction plan is confidential business information entitled to protection fromdisclosure under section 114(c) of the Act or 40 CFR 2.301, the material which isclaimed as confidential must be clearly designated in the submission.


vi) To satisfy the requirements of this section to develop a startup, shutdown, andmalfunction plan, the owner or operator may use the affected source's standardoperating procedures (SOP) manual, or an Occupational Safety and HealthAdministration (OSHA) or other plan, provided the alternative plans meet all therequirements of this section and are made available for inspection or submittedwhen requested by the Administrator.

40 CFR Section 63.6(e)(3)(vi)

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vii) Based on the results of a determination made under paragraph (e)(1)(i) of thissection, the Administrator may require that an owner or operator of an affectedsource make changes to the startup, shutdown, and malfunction plan for thatsource. The Administrator must require appropriate revisions to a startup,shutdown, and malfunction plan, if the Administrator finds that the plan:

(A) Does not address a startup, shutdown, or malfunction event that has occurred;

(B) Fails to provide for the operation of the source (including associated airpollution control and monitoring equipment) during a startup, shutdown, ormalfunction event in a manner consistent with the general duty to minimizeemissions established by paragraph (e)(1)(i) of this section;

(C) Does not provide adequate procedures for correcting malfunctioning processand/or air pollution control and monitoring equipment as quickly as practicable; or

40 CFR Section 63.6(e)(3)(vii)

D) Includes an event that does not meet the definition of startup, shutdown, ormalfunction listed in ¿ 63.2.


viii) The owner or operator may periodically revise the startup, shutdown, andmalfunction plan for the affected source as necessary to satisfy the requirements ofthis part or to reflect changes in equipment or procedures at the affected source.Unless the permitting authority provides otherwise, the owner or operator maymake such revisions to the startup, shutdown, and malfunction plan without priorapproval by the Administrator or the permitting authority. However, each suchrevision to a startup, shutdown, and malfunction plan must be reported in thesemiannual report required by ¿ 63.10(d)(5).

40 CFR Section 63.6(e)(3)(viii)

(ix) The title V permit for an affected source must require that the owner or operatoradopt a startup, shutdown, and malfunction plan which conforms to the provisionsof this part, and that the owner or operator operate and maintain the source inaccordance with the procedures specified in the current startup, shutdown, andmalfunction plan. However, any revisions made to the startup, shutdown, andmalfunction plan in accordance with the procedures established by this part shallnot be deemed to constitute permit revisions under part 70 or part 71 of thischapter. Moreover, none of the procedures specified by the startup, shutdown, andmalfunction plan for an affected source shall be deemed to fall within the permitshield provision in section 504(f) of the Act.

40 CFR Section 63.6(e)(3)(ix)

Labeling: Provide and maintain easily visible labels posted at each furnace andscrap dryer that identifies the applicable emission limits and means of compliance,including:

1. The type of emission unit,2. The applicable operational standards and control methods, and3. The afterburner operating temperature and design residence for the afterburnercontrolling the dryer emissions.

40 CFR Section 63.1506(b)

Capture and Collection Systems: For each affected source or emission unitequipped with an add-on air pollution control device:

1. Design and install a system for the capture and collection of emissions to meetthe engineering standards for minimum exhaust rates as published by theAmerican Conference of Governmental Industrial Hygienists in chapters 3 and 5 of"Industrial Ventilation: A Manual of Recommended Practice."

2. Vent captured emissions through a closed system, except that dilution air maybe added to emission streams for the purpose of controlling temperature at the inletto a fabric filter, and

3. Operate each capture/collection system according to the procedures andrequirements in the OM&M plan.

40 CFR Section 63.1506(c)

Feed Charge Weight: Install and operate a device that measures and records orotherwise determines the weight of feed/charge (or throughput) for each operatingcycle or time period used in the performance test for each affected source/unit.

Operate each weight measurement system or other weight determinationprocedure in accordance with the OM&M plan.

You may choose to measure and record aluminum production weight from anaffected source or emission unit rather than feed/charge weight provided that:

1. The aluminum production weight, rather than the feed/charge weight ismeasured and recorded for all emission units in a SAPU; and

2. All calculations to demonstrate compliance with the emission limits for SAPUsare based on aluminum production weight rather than feed/charge weight.

40 CFR Section 63.1506(d)

OPERATIONAL REQUIREMENTS hdr

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Circumvention: Do not install or use a device or means that conceals or dilutesemissions, which would otherwise violate a federal or state air pollution control rule,without reducing the total amount of pollutant emitted.

Minn. R. 7011.0020

Air Pollution Control Equipment: Operate all pollution control equipment wheneverthe corresponding process equipment and emission units are operated, unlessotherwise noted in Table A.

Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800,subp. 16(J)

Operation and Maintenance Plan: Retain at the stationary source an operation andmaintenance plan for all air pollution control equipment. At a minimum, the O & Mplan shall identify all air pollution control equipment and shall include a preventativemaintenance program for that equipment, a description of (the minimum but notnecessarily the only) corrective actions to be taken to restore the equipment toproper operation to meet applicable permit conditions, a description of theemployee training program for proper operation and maintenance of the controlequipment, and the records kept to demonstrate plan implementation.

Minn. R. 7007.0800, subp. 14 and Minn. R. 7007.0800,subp. 16(J)

Fugitive Emissions: Do not cause or permit the handling, use, transporting, orstorage of any material in a manner which may allow avoidable amounts ofparticulate matter to become airborne. Comply with all other requirements listed inMinn. R. 7011.0150.

Minn. R. 7011.0150

Noise: The Permittee shall comply with the noise standards set forth in Minn. R.7030.0010 to 7030.0080 at all times during the operation of any emission units.This is a state only requirement and is not enforceable by the EPA Administrator orcitizens under the Clean Air Act.

Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures andrequirements as found in Minn. R. 7007.0800, subp. 9(A).

Minn. R. 7007.0800, subp. 9(A)

The Permittee shall comply with the General Conditions listed in Minn. R.7007.0800, subp. 16.

Minn. R. 7007.0800, subp. 16

PERFORMANCE TESTING hdr

Performance Testing: Conduct all performance tests in accordance with Minn. R.ch. 7017 unless otherwise noted in Tables A, B, and/or C.

Also conduct all performance tests in accordance with 40 CFR Section 63.1511,Performance Test Compliance Demonstration General Requirements.

Use the following equations to determine compliance:

1. THC emission limit:

E = C x MW x Q x K1 x K2---------------------------------Mv x P x 10^6

where: THC = total hydrocarbons

Minn. R. ch. 7017 and 40 CFR Section 63.1511 -.1513

E = the emission rate of the measured pollutant (lb/ton) of feed;C = measured volume fraction of pollutant, ppmv;MW = molecular weight of measured pollutant (lb/lb-mole) (44.11 for propane)Q = volumetric flow rate of exhaust gases (dscf/hr)K1 = conversion factor (1 lb/lb)K2 = conversion factor (1 cf/1 cf)Mv = molar volume (385.3 cf/lb-mole) andP = production rate (ton/hr)


2. For PM, HCl, or Dioxin/Furan (D/F) emissions use:

E = C x Q x K1----------------P

Where:

E = emission rate of PM, HCl, or D/F (lb/ton) of feedC = concentration (gr/dscf)Q = volumetric flow rate of exhaust gases (dscf/hr)K1 = conversion factor (1 lb/7000 gr)P = production rate (ton/hr)


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3. For the HCl percent reduction standard, use:

%R = Li - Lo x 100------------------Li

Where,

%R = percent reduction of the control deviceLi = inlet loading of pollutant (lb/ton)Lo = outlet loading of pollutant (lb/ton)


To convert D/F measurements to TEQ (toxic equivalent) units, use the proceduresand equations in "Interim Procedures for Estimating Risks Associated withExposures to Mixtures of Chlorinated Dibenzo-p-Dioxins and -Dibenzofurans(CDDs and CDFs) and 1989 Update" (EPA 625/3-89-016)


Performance Test Notifications and Submittals:

Performance Tests are due as outlined in Tables A and B of the permit.

Performance Test Notification (written): due 60 days before each Performance TestPerformance Test Plan: due 60 days before each Performance TestPerformance Test Pre-test Meeting: due 7 days before each Performance TestPerformance Test Report: due 45 days after each Performance TestPerformance Test Report - Microfiche Copy: due 105 days after each PerformanceTest

The Notification, Test Plan, and Test Report may be submitted in alternative formatas allowed by Minn. R. 7017.2018.

Minn. Rs. 7017.2030, subp. 1-4, 7017.2018 and Minn.R. 7017.2035, subp. 1-240 CFR Section 63.1511(a) and 40 CFR Section63.7(c)

Limits set as a result of a performance test (conducted before or after permitissuance) apply until superseded as specified by Minn. R. 7017.2025 followingformal review of a subsequent performance test on the same unit.

Minn. R. 7017.2025

MONITORING REQUIREMENTS hdr

Monitoring Equipment Calibration: Annually calibrate all required monitoringequipment (any requirements applying to continuous emission monitors are listedseparately in this permit).

Minn. R. 7007.0800, subp. 4(D)

Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/orC, monitoring a process or control equipment connected to that process is notnecessary during periods when the process is shutdown, or during checks of themonitoring systems, such as calibration checks and zero and span adjustments. Ifmonitoring records are required, they should reflect any such periods of processshutdown or checks of the monitoring system.

Minn. R. 7007.0800, subp. 4(D)

RECORDKEEPING hdr

Record keeping: Retain all records at the stationary source for a period of five (5)years from the date of monitoring, sample, measurement, or report. Records whichmust be retained at this location include all calibration and maintenance records, alloriginal recordings for continuous monitoring instrumentation, and copies of allreports required by the permit. Records must conform to the requirements listed inMinn. R. 7007.0800, subp. 5(A).

Minn. R. 7007.0800, subp. 5(C)40 CFR Section 63.1517(a)

Recordkeeping: Maintain records describing any insignificant modifications (asrequired by Minn. R. 7007. 1250, subp. 3) or changes contravening permit terms(as required by Minn. R. 7007.1350 subp. 2), including records of the emissionsresulting from those changes.

Minn. R. 7007. 0800, subp. 5(B)

REPORTING/SUBMITTALS HDR

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of aplanned shutdown of any control equipment or process equipment if the shutdownwould cause any increase in the emissions of any regulated air pollutant. If theowner or operator does not have advance knowledge of the shutdown, notificationshall be made to the Commissioner as soon as possible after the shutdown.However, notification is not required in the circumstances outlined in Items A, Band C of Minn. R. 7019.1000, subp. 3.

At the time of notification, the owner or operator shall inform the Commissioner ofthe cause of the shutdown and the estimated duration. The owner or operator shallnotify the Commissioner when the shutdown is over.

Minn. R. 7019.1000, subp. 3

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Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdownof more than one hour duration of any control equipment or process equipment ifthe breakdown causes any increase in the emissions of any regulated air pollutant.The 24-hour time period starts when the breakdown was discovered or reasonablyshould have been discovered by the owner or operator. However, notification is notrequired in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000,subp. 2.

At the time of notification or as soon as possible thereafter, the owner or operatorshall inform the Commissioner of the cause of the breakdown and the estimatedduration. The owner or operator shall notify the Commissioner when thebreakdown is over.

Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: As soonas possible after discovery, notify the Commissioner or the state duty officer, eitherorally or by facsimile, of any deviation from permit conditions which could endangerhuman health or the environment.

Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report:Within 2 working days of discovery, notify the Commissioner in writing of anydeviation from permit conditions which could endanger human health or theenvironment. 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 yetcorrected; and5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of thedeviation.

Minn. R. 7019.1000, subp. 1

Application for Permit Amendment: If a permit amendment is needed, submit anapplication in accordance with the requirements of Minn. R. 7007.1150 throughMinn. R. 7007.1500. Submittal dates vary, depending on the type of amendmentneeded.

Minn. R. 7007.1150 through Minn. R. 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendmentto extend a deadline in a permit by no more than 120 days, provided the proposeddeadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H).

Minn. R. 7007.1400, subp. 1(H)

A report must be submitted if any of these conditions occur during a 6-monthreporting period:

1. The corrective action specified in the OM&M plan for a bag leak detectionsystem alarm was not initiated within 1 hour.2. An excursion of a compliant process or operating parameter value or range (e.g.,lime injection rate or screw feeder setting, total reactive chlorine flux injection rate,afterburner operating temperature, etc.)3. An action taken during a startup, shudown, or malfunction was not consistentwith the procedures in the plan as described in 40 CFR Section 63.6(e)(3).

40 CFR Section 63.6(e)(3) contains the requirement for a developing a startup,shutdown, and malfunction plan that outlines procedures for operating andmaintaining the source during periods of startup, shutdown, and malfunction.

40 CFR Section 63.1516(b), and Minn. R. 7007.0800,subp. 6(A)(2)

4. An affected source was not operated according to the requirements of 40 CFR63, Subp. RRR.

5. Each report must include each of the following certifications:

a. Each furnace was operated such that the level of molten metal remained abovethe top of the passage between the sidewell and hearth during reactive fluxing, andreactive flux, except for cover flux, was added only to the sidewell or to a furnacehearth equipped with an add-on air pollution control device for PM, HCl, and D/Femissions during this reporting period.


Submit the results of any performance test conducted during the reporting period,including one complete report documenting test methods and procedures, processoperation, and monitoring parameter ranges or values for each test method usedfor a particular type of emission point tested.


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Subject Item: GP 001 Furnace 1 and 3 and Control Equipment

Associated Items: CE 001 Fabric Filter - Medium Temperature i.e., 180 F


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Install, calibrate, operate, and maintain a device to continuously measure andrecord the weight of gaseous or liquid reactive flux injected to each affected sourceor emission unit.

1. The monitoring system must record the weight for each 15-minute block period,during which reactive fluxing occurs, over the same operating cycle or time periodused in the performance test.

2. The accuracy of the weight measurement device must be +/-1% of the weight ofthe reactive component of the flux being measured.

3. Verify the calibration of the weight measurement device in accordance with theschedule specified by the manufacturer, or if no calibration schedule is specified, atleast once every 6 months.

40 CFR Section 63.1510(j)(1)(i-iii)

Calculate and record the gaseous or liquid reactive flux injection rate (lb/ton) foreach operating cycle or time period used in the performance test.

40 CFR Section 63.1510(j)(2)

Record, for each 15-minute block period during each operating cycle or time periodused in the performance test during which reactive fluxing occurs, the time, weight,and type of flux for each addition of:

1. Gaseous or liquid reactive flux other than chlorine; and

2. Solid reactive flux.

40 CFR Section 63.1510(j)(3)(i-ii)

Calculate and record the total reactive flux injection rate for each operating cycle ortime period used in the performance test.

40 CFR Section 63.1510(j)(4)

Record in an operating log for each charge of a sidewell furnace that the level ofmolten metal was above the top of the passage between the sidewell and hearthduring reactive flux injection, unless the furnace hearth was also equipped with anadd on control device.

40 CFR Section 63.1510(n)(1-2)40 CFR Section 63.1517(b)(10)

Keep records of the 15-minute block average weights of gaseous or liquid reactiveflux injection, total reactive flux injection rate and calculations (including records ofthe identity, composition, and weight of each addition of gaseous, liquid or solidreactive flux), including records of any period the rate exceeds the compliantoperating parameter value and corrective action taken.

40 CFR 63.1517(b)(5)

PERFORMANCE TESTINGSee Table B

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Performance Test: due before end of each calendar 60 months starting 02/14/2003for HCl, D/F TEQ, and particulate matter. Test methods are specified in 40 CFRSection 63.1511(c).

40 CFR Section 63.1511(b), and Minn. R. 7007.0800,subp. 2

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Subject Item: GP 003 Baghouses

Associated Items: CE 001 Fabric Filter - Medium Temperature i.e., 180 F


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Subject Item: GP 004 Bag Leak Detectors

Associated Items: MR 001 Bag Leak Detection

MR 002 Bag Leak Detection



What to do Why to do itEach triboelectric bag leak detection system must be installed, calibrated,operated, and maintained according to the "Fabric Filter Bag Leak DetectionGuidance," (September 1997).

Other bag leak detection systems must be installed, operated, calibrated, andmaintained in a manner consistent with the manufacturer's written specificationsand recommendations.

40 CFR Section 63.1510(f)(1)(ii)

The bag leak detection system must be certified by the manufacturer to be capableof detecting PM emissions at concentrations of 0.0044 gr/acf or less.

40 CFR Section 63.1510(f)(1)(iii)

The bag leak detection system sensor must provide output of relative or absolutePM loadings.

40 CFR Section 63.1510(f)(1)(iv)

The bag leak detection system must be equipped with a device to continuouslyrecord the output signal from the sensor.

40 CFR Section 63.1510(f)(1)(v)

The bag leak detection system must be equipped with an alarm system that willsound automatically when an increase in relative PM emissions over a preset levelis detected. The alarm must be located where it is easily heard by plant operatingpersonel.

40 CFR Section 63.1510(f)(1)(vi)

For positive pressure fabric filter systems, a bag leak detection system must beinstalled in each baghouse compartment or cell. For negative pressure or inducedair fabric filters, the bag leak detector must be installed downstream of the fabricfilter.

40 CFR Section 63.1510(f)(1)(vii)

When multiple detectors are required, the system's instrumentation and alarm maybe shared among detectors.

40 CFR Section 63.1510(f)(1)(viii)

The baseline output must be established by adjusting the range and the averagingperiod of the device and establishing the alarm set points and the alarm delay time.

40 CFR Section 63.1510(f)(1)(ix)

A-10


03700066 - 001

Facility Name:

Permit Number:

Subject Item: GP 005 Afterburners

Associated Items: CE 003 Direct Flame Afterburner

CE 007 Direct Flame Afterburner

MR 005 Temperature Monitor

MR 006 Temperature Monitor

What to do Why to do itTEMPERATURE MONITOR REQUIREMENTS hdr

Calibrate, maintain, and operate a device to continuously monitor and record theoperating temperature of the afterburners consistent with the requirements forcontinous monitoring system in 40 CFR Part 63, Subp. A.

40 CFR Section 63.1510(g)(1)

The temperature monitoring device must meet the following performancespecifications:

1. The temperature monitoring device must be installed at the exit of the afterburner2. The monitoring system must record the temperature in 15-minute block averagesand determine and record the average temperature for each 3-hour block period.3. The recorder response range must include zero and 1.5 times the averagetemperature.4. The reference method must be a National Institute of Standards and Technologycalibrated reference thermocouple-potentiometer system or alternate reference,subject to approval by the Administrator.

40 CFR Section 63.1510(g)(2)

INSPECTION AND MAINTENANCE REQUIREMENTS hdr

Conduct an inspection of each afterburner at least once a year and record theresults. At a minimum, an inspection must include:

1. Inspection of all burners, pilot assemblies, and pilot sensing devices for properoperation and clean pilot sensor;

2. Inspection for proper adjustment of combustion air;

3. Inspection of internal structures (e.g., baffles) to ensure structural integrity;

4. Inspection of dampers, fans, and blowers for proper operation;

5. Inspection for proper sealing;

40 CFR Section 63.1510(g)(3)(i-xi)

6. Inspection of motors for proper operation;

7. Inspection of combustion chamber refractory lining and clean and replace liningas necessary;

8. Inspection of afterburner shell for corrosion and/or hot spots;

9. Documentation, for the burn cycle that follows the inspection, that the afterburneris operating properly and any necessary adjustments have been made; and

10. Verification that the equipment is maintained in good operating condition.

Following the inspection, all necessary repairs must be completed in accordancewith the requirements in the OM&M plan.


RECORDKEEPING hdr

Keep records of the 15-minute block average afterburner operating temperature,including any period when the average temperature in any 3-hour block period fallsbelow the compliant operating parameter value with a brief explanation of thecause of the excursion and the corrective action taken.

Also keep records of the annual afterburner inspections.

40 CFR 63.1517(b)(2)(i-ii)

A-11


03700066 - 001

Facility Name:

Permit Number:

Subject Item: GP 007 Natural gas heaters

Associated Items: EU 004 Furnace 1 Casting Mold Heater

EU 005 Furnace 1 Star Wheel Box Heater

EU 009 Furnace 3 Casting Mold Heater

EU 010 Furnace 3 Star Wheel Box Heater

EU 016 Sow Mold and Tondish Heaters

What to do Why to do itEMISSION LIMITS hdr

Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic footunless required to reduce further to the less stringent limit given in either Minn. R.7011.0730 or Minn. R. 7011.0735. This limit applies to each unit individually.

Minn. R. 7011.0610, subp. 1.(A)(1)

Opacity: less than or equal to 20 percent except for one six-minute period per hourof not more than 60 percent opacity. An exceedance of this opacity standardoccurswhenever any one-hour period contains two or more six-minuteperiods during which the average opacity exceeds 20 percent orwhenever any one-hour period contains one or more six-minuteperiods during which the average opacity exceeds 60 percent.

Minn. R. 7011.0610, subp. 1.(A)(2)

OPERATIONAL REQUIREMENTS hdr

Fuels allowed: Natural gas only Minn. R. 7007.0800, subp. 2

A-12


03700066 - 001

Facility Name:

Permit Number:

Subject Item: EU 011 Furnace 3 Scrap Dryer

Associated Items: CE 003 Direct Flame Afterburner

CE 004 Fabric Filter - High Temperature, i.e., T>250 Degrees F

GP 002 Scrap Dryers



THC (Total Hydrocarbons): less than or equal to 0.20 lbs/ton (as propane) per tonof feed/charge.

40 CFR Section 63.1505(e)(1)(i)

Total Particulate Matter: less than or equal to 0.3 lbs/ton of feed/charge. 40 CFR Section 63.1505(e)(1)(ii)

Dioxin/Furan Toxic Equivalent: less than or equal to 7.0 x 10^-5 grain/ton offeed/charge


Hydrochloric acid: less than or equal to 1.50 lbs/ton of feed/charge 40 CFR Section 63.1505(e)(1)(iv)

OPERATING CONDITIONS hdr

Fuels Allowed: Natural Gas only. Title I Condition: to limit potential emissions to lessthan major source levels as defined by 40 CFR Section52.21

Vent all emissions to a thermal oxidizer, and a baghouse with lime injection. Minn. R. 7007.0800, subp. 2

For the thermal oxidizer:

1. Maintain the 3-hour block average operating temperature at or above 1456 F; and

2. Operate the oxidizer according to the OM&M plan.

40 CFR Section 63.1506(g)(1)(i) and (ii)

For the baghouse: Maintain the 3-hour block average inlet temperature at or below395 degrees F, maintain free-flowing lime in the hopper to the feed device at alltimes and maintain the lime feeder setting at 12%.

40 CFR Section 63.1506(g)(4)


Inspect the label required by 40 CFR Section 63.1506(b) at least once per calendarmonth to confirm that the posted label is intact and legible.


Install, operate, and maintain a capture/collection system. Inspect thecapture/collection and closed vent system at least once each calendar year toensure that each system is operating in accordance with the operatingrequirements in 40 CFR Section 63.1506(c) and record the results of theinspection.

40 CFR 63.1510(d)

Install, calibrate, operate, and maintain a device to measure and record the totalweight of feed/charge to, or the aluminum production from, the unit over the sameoperating cycle or time period used in the performance test.

The accuracy of the weight measurement device or procedure must be +/-1% of theweight being measured.

Verify the calibration of the weight measurement device in accordance with theschedule specified by the manufacturer, or if no calibration schedule is specified, atleast once every 6 months.

40 CFR Section 63.1510(e)

RECORDKEEPING hdr

Record the total number of operating hours for the sources during each 6-monthreporting period, records of each alarm of the bag leak detection system, the timeof the alarm, the time the corrective action was initiated and completed, and a briefdescription of the cause of the alarm.

40 CFR Section 63.1517

PERFORMANCE TESTSee Table B

hdr

Performance Test: due before end of each calendar 60 months starting 02/14/2003for HCl, D/F TEQ, THC, and Particulate Matter. Test methods are specified in 40CFR Section 63.1511(c).


A-13


03700066 - 001

Facility Name:

Permit Number:

Subject Item: EU 012 Hammermill

Associated Items: CE 005 Fabric Filter - Low Temperature, i.e., T


03700066 - 001

Facility Name:

Permit Number:

Subject Item: EU 015 Furnace 1 Scrap Dryer

Associated Items: CE 006 Fabric Filter - High Temperature, i.e., T>250 Degrees F

CE 007 Direct Flame Afterburner

GP 002 Scrap Dryers


SV 025 Furnace 1 scrap dryer


THC (Total Hydrocarbons): less than or equal to 0.20 lbs/ton (as propane) per tonof feed/charge.

40 CFR Section 63.1505(e)(1)(i)

Total Particulate Matter: less than or equal to 0.30 lbs/ton of feed/charge. 40 CFR Section 63.1505(e)(1)(ii)

Dioxin/Furan Toxic Equivalent: less than or equal to 7.0 x 10^-5 grain/ton offeed/charge


Hydrochloric acid: less than or equal to 1.50 lbs/ton of feed/charge 40 CFR Section 63.1505(e)(1)(iv)

OPERATING CONDITIONS hdr

Fuels Allowed: Natural Gas only. Title I Condition: to limit potential emissions to lessthan major source levels as defined by 40 CFR Section52.21

Vent all emissions to a thermal oxidizer, and a baghouse with lime injection. Minn. R. 7007.0800, subp. 2

For the thermal oxidizer:

1. Maintain the 3-hour block average operating temperature at or above 1499decrees F; and

2. Operate the oxidizer according to the OM&M plan.

40 CFR Section 63.1506(g)(1)(i) and (ii)

For the baghouse: Maintain the 3-hour block average inlet temperature at or below404 degrees F, maintain free-flowing lime in the hopper to the feed device at alltimes and maintain the lime feeder setting at the same level established during theperformance test.

40 CFR Section 63.1506(g)(4)


Inspect the label required by 40 CFR Section 63.1506(b) at least once per calendarmonth to confirm that the posted label is intact and legible.


Install, operate, and maintain a capture/collection system. Inspect thecapture/collection and closed vent system at least once each calendar year toensure that each system is operating in accordance with the operatingrequirements in 40 CFR Section 63.1506(c) and record the results of theinspection.

40 CFR Section 63.1510(d)

Install, calibrate, operate, and maintain a device to measure and record the totalweight of feed/charge to, or the aluminum production from, the unit over the sameoperating cycle or time period used in the performance test.

The accuracy of the weight measurement device or procedure must be +/-1% of theweight being measured.

Verify the calibration of the weight measurement device in accordance with theschedule specified by the manufacturer, or if no calibration schedule is specified, atleast once every 6 months.

40 CFR Section 63.1510(e)

RECORDKEEPING hdr

Record the total number of operating hours for the sources during each 6-monthreporting period, records of each alarm of the bag leak detection system, the timeof the alarm, the time the corrective action was initiated and completed, and a briefdescription of the cause of the alarm.

40 CFR Section 63.1517

PERFORMANCE TESTING hdr

Performance Test: due before end of each 60 months starting 02/14/2003 for THC,D/F TEQ, HCl and Particulate Matter. Test methods are specified in 40 CFRSection 63.1511(c).

40 CFR Section 63.1511(b)

A-15


03700066 - 001

Facility Name:

Permit Number:

Subject Item: EU 017 Dross Crusher

Associated Items: SV 026 Dross Crusher

What to do Why to do itTotal Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot ofexhaust gas unless required to further reduce emissions to comply with the lessstringent limit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735.

Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent Minn. R. 7011.0715, subp. 1(B)

A-16

TABLE B: SUBMITTALSFacility Name: Spectro Alloys Corp

Permit Number: 03700066 - 001

04/22/05

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table Aor, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately listone-time only and recurrent submittal requirements.

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shallbe certified as appropriate if certification is required by an applicable rule or permit condition.

Send any application for a permit or permit amendment to:

Permit Technical AdvisorPermit SectionAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Technical Advisor notices of:- accumulated insignificant activities,- installation of control equipment,- replacement of an emissions unit, and- changes that contravene a permit term.

Unless another person is identified in the applicable Table, send all other submittals to:

SupervisorCompliance Determination UnitAir Quality DivisionMinnesota Pollution Control Agency520 Lafayette Road NorthSt. Paul, Minnesota 55155-4194

Send submittals that are required to be submitted to the U.S. EPA regional office to:

Mr. George CzerniakAir and Radiation BranchEPA Region V77 West Jackson BoulevardChicago, Illinois 60604

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection AgencyClean Air Markets Division1200 Pennsylvania Avenue NW (6204N)Washington, D.C. 20460

B-1

TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONSFacility Name: Spectro Alloys Corp


04/22/05

What to send When to send Portion of Facility AffectedApplication for Permit Reissuance due 180 days before expiration of Existing

PermitTotal Facility

B-2

TABLE B: RECURRENT SUBMITTALSFacility Name: Spectro Alloys Corp


04/22/05

What to send When to send Portion of Facility AffectedReport due 60 days after end of each calendar

half-year starting 03/24/2003. Each reportmust contain the information specified in 40CFR Section 63.10(c). When no deviations ofparameters have occurred, the owner oroperator must submit a report stating that noexcess emissions occurred during thereporting period.

Total Facility

Compliance Certification due 30 days after end of each calendar yearfollowing Permit Issuance. Certify continuingcompliance based upon, but not limited to, thefollowing:

1. Any period of excess emissions, thatoccurred during the year were reported asrequired, and2. All monitoring, recordkeeping, and reportingrequirements were met this year.

Total Facility

B-3

APPENDIX MATERIAL Facility Name: Spectro Alloys Corp Permit Number: 03700066-001 Insignificant Activities Required to be Listed: Citation: Minn. R. 7007.1300, subp. 3

Description Applicable Regulations

A. One kerosene space heater Minn. R. 7011.0610 A. Four propane heaters Minn. R. 7011.0610 E.1. Storage tanks, gasoline storage tanks with a

combined tank capacity of 10,000 gallons: two, one gasoline with a capacity of 265 gallons, one #2 oil tank with a capacity of 1000 gallons

H.1. Sources that use less than 200 gallons of VOC for any 12 month period. Spectro operates a 15 gallon parts washer

H. 1 Other VOC containing chemicals used: Penetrating oil: annual use; 7 gallons Brake Cleaner: annual use; 1.8 gallons Anti-seize: annual use; 1.8 gallons Carburetor Cleaner: use; 1.9 qts. Battery Cleaner: annual use; 3.8 gallons Anti-splatter: annual use; 3.4 gallons Muratic Acid: annual use 1.5 gallons Brake Fluid: annual use; 5 gallons Paint Thinner: annual use; 4 gallons

H.4. Miscellaneous brazing, soldering or welding equipment.

Technical Support Document, Permit Action Number: 03700066-001 Page 1 of 11 Date: 5/19/2005

TECHNICAL SUPPORT DOCUMENT For

AIR EMISSION PERMIT NO. 03700066-001 This Technical Support Document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal regulations and Minn. R. (40 CFR, § 70.7(a)(5) and Minn. R. 7007.0850, subp.1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the permit. 1. General Information

Applicant/Address Stationary Source/Address (SIC Code: 3341)

Spectro Alloys Corporation 13220 Doyle Path

Rosemount, MN 55068

13220 Doyle Path Rosemount

Dakota County

Contact: Tom Sherry (651) 480-6121

1.2. Description of the Permit Action Spectro Alloys is a secondary aluminum processing plant. Emission sources include the hammermill, a scrap dryer, and two furnaces. Also included as emission sources are natural gas heaters for heating molds. The facility is a major source for hazardous air pollutants, and as such, this permit is a Part 70 total facility operating permit. Emissions from the hammermill are controlled by baghouse, from the scrap dryer by a thermal oxidizer and lime injected baghouse, and from the furnaces by a lime injected fabric filter. 1.3 Description of any Changes Allowed with this Permit Issuance

This permit authorizes the rebuilding of refractory of Furnace #1, modification of the hood of Furnace #1 such that it will become an enclosed process and the installation of a second scrap dryer. The modifications qualified as a minor amendment, and the company has completed the modifications. The emissions from the second scrap dryer are controlled with a thermal oxidizer and lime injected baghouse, as are the emissions from the existing scrap dryer. Previously, Spectro was permitted as a synthetic minor source for federal new source review purposes. The emissions were controlled, in part, by limits on process throughput. This permit contains limits on throughput. However, Spectro plans to enclose the feed system to Furnace 3.


With the emission limits set by the now promulgated regulation under 40 CFR pt. 63, National Emission Standards for Hazardous Air Pollutants (NESHAP), and the enclosure of the feed system, potential emissions at maximum physical capacity will not exceed major source thresholds as defined under new source review. Therefore, the annual limits on production expire after Spectro has enclosed the Furnace 3 feed system. 1.5. Facility Emissions:

Table 1. Total Facility Potential to Emit Summary:

PM tpy

PM10 tpy

SO2 tpy

NOx tpy

CO tpy

VOC tpy

Single HAP tpy

Total Facility Limited Potential Emissions Prior to Furnace 3 Enclosure

94.99 49.77 2.56 31.96 12.13 13.09 119

Total Facility Limited Potential Emissions After Furnace 3 Enclosure

89.9 41.5 4.12 49.3 17.6 20.9 193

Total Facility Actual* Emissions (tpy)

79.5 61.5 49.6 66.9 7.47 49.9 HAPs not reported in inventory

*Spectro Alloys is subject to a new NESHAP regulation that required additional control. As such, its emissions have been reduced.

Table 2. Facility Classification

Classification Major/Affected Source

Synthetic Minor Minor

PSD PM, PM10 NOx, VOC, CO Part 70 Permit Program HAPs PM10 NOx, VOC, CO 2. Regulatory and/or Statutory Basis

New Source Review

The facility is an existing synthetic minor source under New Source Review regulations. Emission limits set by 40 CFR pt. 63 regulations restrict potential emissions for all criteria pollutants, and proposed modifications to the Furnace 3 scrap feed system will restrict potential emissions to less than major source levels.


This permit contains limits on throughput that restrict potential emissions to less than major source levels. Those limits expire after the modifications to the Furnace 3 scrap feed system are complete.

Part 70 Permit Program

The facility is an existing major source under Part 70 regulations for hazardous air pollutants.

New Source Performance Standards (NSPS)

There are no New Source Performance Standards applicable to the operations at this facility.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

The facility is a major HAP source, and is subject to 40 CFR pt. 63, subp. RRR, National Emissions Standards for Hazardous Air Pollutants for Secondary Aluminum Production.

Minnesota State Rules

The total facility is subject to the following Minnesota Standards of Performance:

• Minn. R. 7011.0150 Control of Particulate Matter

• Minn. R. 7011.0610 Standards of Performance for Direct Heating Equipment

Table 3. Regulatory Overview of Facility

EU, GP, or SV

Applicable Regulations Comments:

FC

Minn. R. 7011.0150 40 CFR § 52.21

Preventing particulate matter from becoming airborne. Prevention of Significant Deterioration: limits are set to restrict potential emissions to less than major source levels under this program.

GP001 Furnaces

40 CFR pt. 63, subp. RRR

National Emission Standards for Secondary Aluminum Processing. For the furnaces sets PM, Dioxin/Furan and HCl limits

GP007 Heaters

Minn. R. 7011.0610 Performance Standards for Direct Heating Equipment

EU011 EU015 Scrap Dryers

40 CFR pt. 63, subp. RRR

National Emission Standards for Secondary Aluminum Processing. For the dryers sets PM, Dioxin/Furan, THC and HCl limits

EU012 40 CFR 63, Subp. RRR National Emission Standards for Secondary Aluminum Processing. For the hammermill (shredder) the standard sets PM limits.


3. Technical Information

3.2 Calculations of Potential to Emit Calculations of potential emissions are attached.

3.2 Periodic Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements.

In evaluating the monitoring included in the permit, the MPCA considers the following:

• The likelihood of violating the applicable requirements;

• Whether add-on controls are necessary to meet the emission limits;

• The variability of emissions over time;

• The type of monitoring, process, maintenance, or control equipment data already available for the emission unit;

• The technical and economic feasibility of possible periodic monitoring methods; and

• The kind of monitoring found on similar units elsewhere:

Table 4 summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate. Since the facility is regulated by a recently promulgated MACT standard, most of the periodic monitoring is adequate as provided by the regulation.

Table 4. Periodic Monitoring

Emission Unit or Group

Requirement (basis)

Additional Monitoring

Discussion

Furnaces, Hammer-mill, and Scrap Dryers

Emission limits for PM, HCl, Dioxins, THC

Repeat stack emission testing as per MPCA guidance. The guidance sets the frequency based on the results of initial stack testing.

The stack test frequency guidance requires annual testing if the initial test yields results greater than 90% of the emission limit, testing every three years if the initial test yields results between 60 and 90% of the limit, and testing every five years if the results are less than 60% of the emission limit.


3.2 Insignificant Activities Insignificant Activities are listed in the Appendix to the permit.

3.3 Dispersion Modeling

Greg Pratt performed screening modeling for the source to determine whether or not the potential existed for Spectro Alloys to cause exceedances of ambient standards for PM10, SO2, and NOx. That dispersion modeling predicted that none of the standards would be exceeded. The RASS results are attached to this technical support document.

4. Comments Received during Public Notice: 4.1 Comment: Totals from the new permit aren’t listed in comparison to the current permit.

If we are looking at the total emissions without taking into account the increased volume being allowed, this is an item to review.

Response:

Table 1. Total Facility Potential to Emit Summary:

PM tpy

PM10 tpy

SO2 tpy

NOx tpy

CO tpy

VOC tpy

Single HAP tpy

Total Facility Potential Emissions Under Current Permit

99.9 59.2 98.7 95.0 24.5 76.7 Uncontrolled Haps not assessed

Total Facility Limited Potential Emissions After Furnace 3 Enclosure

89.9 41.5 4.12 49.3 17.6 20.9 193

Permit totals for most pollutants are higher under the existing permit. This permit requires the facility to meet more stringent emission limits that are required by the promulgation of a new performance standard under 40 CFR pt. 63.

4.2 Comment: When the control equipment breaks down, can the permit require suspension of operations?


Response: The permit requires the following: Under 40 CFR § 63.6(e)(1)(i) that: “At all times, including periods of startup, shutdown, and malfunction, the owner or operator must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. During a period of startup, shutdown, or malfunction, this general duty to minimize emissions requires that the owner or operator reduce emissions from the affected source to the greatest extent which is consistent with safety and good air pollution control practices.” And: “No emission units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate.” This is consistent with 40 CFR § 63.6(e)(1)(ii) and Minn. R. 7019.1000, subp. 4. Minn. R. 7019.1000, subp. 4 reads: “Subp. 4. Operation changes. In any shutdown, breakdown, or deviation covered by subpart 1, 2, or 3, the owner or operator 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.” The MPCA interprets this to mean that if a breakdown/malfunction of control equipment would likely cause exceedances of emission limits, and that the breakdown/malfunction will continue for longer than the equipment shutdown procedures. The following steps are part of the Operation Maintenance, and Monitoring-Startup, Shutdown, and Malfunction Plan that Spectro Alloys was required to submit under federal law, 40 CFR pt. 63, subp. RRR. The steps that Spectro Alloys would take in the event of a breakdown/malfunction of the hammermill baghouse that is likely to cause an exceedance of emission limits, is to immediately shutdown the shredder. The steps that Spectro Alloys would take in the event of a breakdown of the dryer(s) control equipment that is likely to cause an exceedance of emission limits, would be to process the material within the dryer at the time of the breakdown/shutdown, and then discontinue operation of the unit(s).


The steps that Spectro Alloys would take in the event of a breakdown/malfunction of the furnace control equipment that is likely to cause an exceedance of emission limits, and the duration of which would be greater than the time to shut down the unit, Spectro immediately stop feed of new material to the furnaces.

4.3 Comment: If some operation is allowed during breakdowns, the permit should specify allowable timeframes for such, prior to required shutdown of operations.

Response: Operation as long as is necessary for equipment to be safely shutdown is all that is allowed.

4.4 Comment: We need to do a “what if” analysis for times when the control equipment is not operating properly.

Response: Minn. R. 7019.1000, subp. 1 requires: “Subpart 1. Notification of deviations which endanger human health or the environment. The owner or operator of an emission facility, in the event of any deviation, as defined in part 7007.0100, subpart 8a, which could endanger human health or the environment, shall notify, orally or by facsimile, the commissioner or the state duty officer immediately after discovery of the deviation or immediately after when the deviation reasonably should have been discovered by the owner or operator. Within two working days of the discovery, the owner or operator shall submit to the commissioner a written description of the deviation stating:

A. the cause of the deviation;

B. the exact dates of the period of the deviation, if the deviation has been corrected;

C. whether or not the deviation has been corrected;

D. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and

E. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation.” The permit does not allow for continued operation in the event of malfunctions or breakdown of the control equipment. Since this type of operation will not be allowed, the MPCA believes that the emissions need not be assessed. As a practical matter, it would be very difficult to measure emissions during a breakdown. Measurements of pollutants would require stack emissions testing, a process that would take time to set up and complete. It is not something that could be set up and completed within the timeframe of a malfunction.

4.5 Comment: The facility should be required to measure and report emissions during a breakdown to understand the effects on the environment if they are allowed to operate when they are having problems. This information should be publicly noticed.


Response: This is partially answered above. Additionally, Paul Curtis, President of Spectro Alloys, has committed to attending quarterly meetings of the Flint Hills Advisory Group whenever asked. Paul Curtis would also like to be contacted with any questions whenever neighbors have concerns or questions. Mr. Curtis may be reached at (651) 480-6121.

4.6 Comment: Request for an independent consultant to operate monitoring stations for the pollutants emitted in the area.

Response: The monitors in the area measure the following pollutants: Carbon Monoxide (CO), Nitric oxide (NO), Nitrogen Dioxide (NO2), Sulfur Dioxide (SO2), Total Reduced Sulfur (TRS), Total Suspended Particulates (TSP) and selected Hazardous Air Pollutants (HAPs). The TSP samples were analyzed for many metals, with detectable quantities found for Antimony, Arsenic, Beryllium, Cadmium, Chromium, Cobalt, Manganese, Nickel and Zinc. HAP samples were analyzed for Formaldehyde, Carbon Tetrachloride, Benzene and Ethylbenzene. Those monitors will continue to be operated. The agency does not currently have the resources to begin an HCl monitoring program. Instead, the Agency will work to ensure that Spectro Alloys operates in compliance with the most stringent applicable standards.

4.7 Comment: Request for an after hours person available to answer calls from the neighbors to address emissions/breakdowns and report back to the MPCA and the neighborhood. Also suggests a web site section that posts breakdowns with a description , and estimation of when the problem will be fixed.

Response: The MPCA has proposed that Spectro Alloys establish a complaint line that will be answered at any hour by the plant manager. Spectro has agreed to establishing a line that will be checked several times per shift for messages regarding a breakdown, or questions in general. Spectro will continue to report all shutdowns and breakdowns to the MPCA. That information is public. Scott Parr may be contacted at (651) 296-7636 for information pertaining to breakdowns. Regarding the web site, Spectro Alloys’ staff maintains that the site is merely a sales tool, and not appropriate for community involvement. MPCA staff agrees and would propose that concerned citizens contact Paul Curtis at (651) 480-6121 or Scott Parr at (651) 296-7636.

4.8 Comment: Collective effect of the area (all facilities including Endres, Flint Hills, and the dump) needs to be taken into consideration when issuing the permit.

Response: Currently the agency does not perform cumulative risk studies when issuing operating permits to facilities. The purpose of the operating permit is to incorporate the most up to date regulations and compliance demonstration into one legally enforceable document for the facility. As stated above, the MPCA will work to ensure that those regulations are adhered to by the company.

4.9 Comment: Need to have an advisory committee to address concerns with the neighborhood/environment.


Response: As is stated above in item 5, Paul Curtis, President of Spectro Alloys has committed to attending quarterly meetings of the Flint Hills Advisory Group whenever asked. Paul Curtis would also like to be contacted with any questions whenever neighbors have concerns or questions. Mr. Curtis may be reached at (651) 480-6121.

5. Conclusion

Based on the information provided by Spectro Alloys, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 03700066-001, and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Jenny Reinertsen (permit writer/engineer) Scott Parr (enforcement) Marshall Cole (peer reviewer) Attachments: 1. Dispersion Modeling Summary from Greg Pratt 2. PTE Summary and Calculation Spreadsheets 3. Process Flow Diagram


-----Original Message----- From: Pratt, Gregory Sent: Monday, April 12, 2004 4:45 PM To: Reinertsen, Jenny Cc: Schutt, Carolina; Pratt, Gregory Subject: Spectro Alloys Jenny, I used the information you sent to do a more refined analysis of emissions from Spectro Alloys. I ran the DISPERSE procedure for stacks SV001 and SV025 and used the look-up tables from the RASS spreadsheet to evaluate the dispersion from SV007 and SV008. I put the results together in a spreadsheet that compares the total concentration from all stacks with the NAAQS. The DISPERSE summaries can be found on my public drive (Mid-flex subdirectory), and are named "SUMMARYR-Spectro Alloys_*.txt." The spreadsheet is called "MFRASS-Spectro Alloys.XLS." These results document that the NAAQS are not exceeded due to the emissions from this facility. Therefore, we can cross this one off the list. Greg


No Inputs Allowed on this Page RASS version number = 20040302 Screening Date: 4/12/2004 AQ Facility ID No.: AQ File No.: Facility Name: Spectro Alloys Facility Location: Rosemount User Title: Type of emissions Per Jenny Reinertsen (e.g., PTE/Future Actual)

Criteria Pollutant Screen

Chemical Fraction of 1-hr std Fraction

of 3-hr std Fraction of 24-hr std

Fraction of qtrly std

Fraction of annual

std

SO2 0.066 0.066 0.074 0.071

PM10 0.761 0.358

PM2.5

NOx 0.398

CO

Pb


TSD

Air Emission Permit No. 03700066-001 Is Issued to Spectro ...TABLE A: LIMITS AND OTHER REQUIREMENTS...

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