OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY · Initial metal melting is done in the three, 23-ton...

DRAFT

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM July 12, 2017

TO: Phillip Fielder, P.E., Permits and Engineering Group Manager

THROUGH: Rick Groshong, Sr. Environmental Manager, Compliance and Enforcement

THROUGH: Phillip Martin, P.E., Existing Source Permits Section Manager

THROUGH: Jian Yue, P.E., New Source Permits Section

FROM: David Pollard, ROAT

SUBJECT: Evaluation of Permit Application Number 2014-2107-TVR2

American Castings, LLC

Pryor Foundry (Facility ID 802)

Pryor, Mayes County, Oklahoma

Located at Mid-America Industrial Park (Lat. 36.230/Long. -95.275)

Directions: From US Highway 412 in Mayes County, travel east from the

Chouteau exit on Highway 69 to Highway 412B, travel north

for approximately 4 miles into the Mid-America Industrial

Park. Facility is on the east side of the highway.

SECTION I. INTRODUCTION

American Castings, LLC (AMC or applicant) submitted an application received on October 27,

2014 to renew their Title V permit. American Castings is a steel foundry that manufactures

ductile iron and gray iron castings (SIC 3321). The facility is a major source of criteria

pollutants emitting at PSD (Prevention of Significant Deterioration) levels. It is also a major

source of hazardous air pollutants (HAPs).

AMC requested changes to their existing permit, Permit No. 2006-166-TVR (M-2). The list of

changes was revised as a result of discussion with AMC and their reviews of the working

document for this renewal TV Permit, No. 2014-2107-TVR2. The revised list of changes is

itemized below. These changes were deemed to be a significant modification and are being

tracked as a separate permit application, Permit No. 2006-166-TVR (M-3) but have been

included in this Title V renewal permit.

Remove limit of nine (9) molds per hour on M-9 and replace with limit on sand usage in

tons per hour and tons per day. Based on the calculation methodology for emissions from

pouring, cooling and shakeout, the number of molds for M-9 is irrelevant to the

calculation. Thus eliminating the limit on number of molds will not result in any changes

to emissions.

PERMIT MEMORANDUM 2014-2107-TVR2 DRAFT 2

Combine and reorder various emissions points within the EUGs in order to better group

the like-kind equipment in each EUG. This change was made as a convenience in the

way the facility accounts for emissions and did not involve changing any individual

limits or combining limits into a cap limit.

Recombine EUG M – Pouring and Cooling with EUG N – Shakeout to be one EUG as in

the original Title V permit, to be called EUG M - Molding, Pouring, Cooling and

Shakeout and reestablish the associate text concerning derivation of emissions limits.

This change is to return to the original grouping as presented in the original Title V

permit and did not result in any changes to emissions limits.

Correct the emissions limits for Emissions Points S-1, S-2 through S-5 and S-6 to reflect

what has been permitted since the original permit and also to retain the additional limit of

1.5 TPY-PM10 established for S-7, a new shot blast unit permitted under by Permit No.

2006-166-TVR (M-1). This was a correction to re-incorporate what was permitted under

Permit No. 2006-166-TVR (M-1). The justification for this project and PSD analysis

were presented in the application for that permit as well as in that permit.

Revise specific conditions to not reference emissions sources that have been historically

removed. No limits were changed or affected by this revision.

Include changes approved in Permit No. 2006-166-TVR (M-2). This is only to

incorporate what was permitted under Permit No. 2006-166-TVR (M-2). The

justification for this project and PSD analysis were presented in the application for that

permit as well as in that permit.

Revise CAM Plan for the M-8 Carrier Barrelhorse to reflect a baghouse control instead of

a wet scrubber. The baghouse was installed with notification from AMC. This is

allowed under Specific Condition No. 6 of the current operating permit, which states

“Alternative control equipment may be used provided the control efficiency is equivalent

or higher than those listed.” The baghouse has a higher control efficiency than the

scrubber and therefore results in a slight reduction of emissions.

SECTION II. FACILITY DESCRIPTION

The facility currently includes three 23-ton coreless induction furnaces for melting ductile iron.

The facility-wide pouring rate is limited to 26 tons per hour and 187,200 tons per year from the

previous permit and the limits are PSD (Prevention of Significant Deterioration) limits.

Operating all three furnaces simultaneously provides for a maximum melting rate of 26 TPH

allowing for slagging and charging. Also included are facilities for receiving, forming,

recovering, and disposing of sand used to make molds for the melted metals. A painting

operation places weatherproofing coating on some products. A detailed description of each area

in the foundry follows.

Scrap Handling/Preheating/Metal Melting/Refining

Low-manganese steel, foundry returns, and pig iron are loaded into storage bins from railroad

cars and other sources. Approximately 25 percent of this operation occurs outdoors and 75

percent occurs inside the foundry building. A typical charge weighs approximately 10 tons and

consists of 53 percent foundry returns, 5 percent pig iron, and 42 percent low manganese steel.


The charge composition can change with material price consideration and/or availability. The

charge is weighed in scaled hoppers and transferred to a preheat conveyor. The Venetta Furnace,

a natural gas fired preheater with a maximum heat input of 23.52 MMBTU/hr, heats the scrap to

approximately 800 degrees Fahrenheit to remove oil and moisture from the scrap. The preheat

charge is then loaded into a charge bucket which is lifted by crane, and the charge is put into a

melt furnace.

Initial metal melting is done in the three, 23-ton coreless electric induction furnaces. The

melting operations are divided between the melt furnaces and the holding furnaces. The melt

furnaces melt solid metals into a molten stage so that alloys may be added. The composition of

the charge depends upon the specific metal characteristics required. Addition of alloys is done to

improve properties of the castings. Alloying generally consists of 500 to 600 pounds of graphite,

50 pounds of silicon carbide, 15 to 20 pounds of ferrosilicon, and 10-15 pounds of

ferromanganese. Molten metal is tapped by tilting the furnace and pouring through a spout to

one of three, 42-ton or one 45-ton holding furnaces. The holding furnaces maintain the

temperature of the melt at the desired pouring temperature of 2,750oF. Slag removal is done as

part of normal operations of both the melt furnaces and the holding furnaces. Slag removal

reduces the amount of melted metal that reaches the rest of the sources in the foundry by 6%.

However, to be conservative emissions are based on 26 tons/hour.

When a holding furnace is full and the charge attains the desired temperature the metal is tapped

into a ladle containing magnesium ferrosilicon. The introduction of magnesium into the iron

improves its crystalline properties and facilitates the transition from gray to ductile iron. Ductile

iron is formed as a steel matrix containing spheroidal particles (or nodules) of graphite. Ordinary

cast iron contains flakes of graphite. Each flake acts as a crack, which makes cast iron brittle.

Ductile irons have high tensile strength and are silvery in appearance. The metal is then

transferred to pouring ladles and ferrosilicon is added for further refining. Such refining further

improves the properties of the ductile iron. Both the transfer and pouring ladles are heated by

natural gas-fired heaters.

Mold Making

Green Sand Mold Making

The green sand molding process is used to make forms used to shape the exterior of the castings.

The green sand molding process uses sand from the green sand shake-out. Sand separated by

shake-out is passed through the rotary screens and a sand cooler before it is recycled to the core

or mold lines.

The Simpson Multi-cooler Sand Cooler was authorized by Permit No. 97-125-TV (M-2) for the

Line 6 Green Sand Molding line. The sand cooler is used to condition the sand prior to reuse.

The sand cooler system is installed in-line with the existing sand mold handling system, at a

point after mold shake-out has occurred. From shakeout, hot sand travels down a conveyor belt

underneath a cross-belt magnetic separator, dumps onto another conveyor belt, which is covered,

where the sand is then transported outside the main building to a sand tower which houses the

sand cooler. Inside the sand tower, the sand drops into a bucket elevator and is conveyed

upwards to a rotary screen. The sand passes through the rotary screen to a storage silo. Sand

exits the storage silo via a vibratory feeder and enters into the sand cooler. The sand cooler is an


enclosed tank with paddles to lift and drop the sand to allow cooling by heat transfer to the air,

which is being drawn through the cooler by a fan. Air discharging from the sand cooler is

directed into a baghouse, along with other pick-up air points within the sand tower. Particulate

fines collected in the baghouse are returned to the process stream by a new conveyor, installed to

eliminate the trucking and disposal of this material. Cooled sand exits the cooler onto another

conveyor belt which transports the sand back into the sand handling system inside the main

building and dumps the sand onto another conveyor belt. This transfer point is covered, under

vacuum, and pulls any particulate to a baghouse. The emissions associated with such are

minimal.

Reclaimed sand, new silica sand, bentonite clay, sea coal, and water are used to make forms used

to shape the exterior of the castings. Additional conditioning occurs in sand mullers and mixers

which prepare the sand and binders for the cores and molds. Bentonite clay and water are used

as the binding agents. Particulate matter emissions from the rotary screens, sand mullers, and

shake-out are controlled by baghouse at 99% efficiency. After mixing, the sand mixture is

transferred to the molding machines, where it is simultaneously packed mechanically over the

top and bottom portions of the pattern. Once the sand mixture has been properly molded, the

patterns are withdrawn from the forms, using a release agent to facilitate release. Removal of the

pattern leaves a cavity inside the mold that forms the outside of the casting. Cores (described

below) are then set to produce the internal voids in the castings. After the finished mold

(exterior form and core) is prepared, a conveyor transports the mold to pouring where molten

metal from the melt shop is poured into molds.

PUNB Mold Making

Phenolic urethane no-bake (PUNB) molding utilizes a three-part, phenolic urethane binding

system where chemical reactions take place at ambient temperatures. The first part of the PUNB

process uses a phenolic resin, the second part contains an isocyanate component, and part three is

a liquid catalyst. PUNB parts 1, 2, and 3 are mixed with silica sand in a mixer. Silica sand

consists of reclaimed sand from the shake-out process and fresh silica from the sand bin. From

the sand bin, the sand is sent through a preheater and into the mixer. A typical charge consists of

80 percent reclaimed sand and 20 percent fresh silica sand. Resins (PUNB parts 1 and 2), PUNB

catalyst, and iron oxide are also added to the mixer. After mixing, the sand mixture is conveyed

to the mold line where the molds are formed manually. The cope (top half) is assembled first,

followed by the drag (bottom). After assembly, the molds are rotated to allow separation from

the pattern using a release agent. Some of the molds are then washed with a water-based

graphite refractory slurry, cured, and dried with an electric infrared heater. After drying, cores

from the core room are set into place, and the cope is rotated and set in place on top of the drag.

A weight is then added to the mold to prevent cope lift due to metal pressure during pouring.

The weighted molds are then routed to the pouring lines for casting.

Core Making Operations

Cores are molded sand shapes used to make the internal voids in castings. The Core Room uses

three different processes to make cores: a) shell, b) phenolic urethane cold box (PUCB), and c)

phenolic urethane no-bake (PUNB). Sand is recycled from the mold lines shakeouts and reused

in the core room in the PUCB and PUNB processes. Part of the cores from the PUCB and the


PUNB core processes are given a protective wash. This is accomplished by dipping the cores

into a graphite refractory water-based slurry. The washed cores are then dried in two natural

gas-fired drying ovens. Core mud may be used to repair damaged portions of a core. The cores

from all three processes, each described following, are transferred to molding lines for insertion

into the mold.

Phenolic Urethane Cold Box (PUCB) Process

The PUCB process utilizes a phenolic cold box binding system. With this system, sand is mixed

with the three different parts of the organic binder chemicals. The first part is the phenolic resin,

the second part is an isocyanate, and the third is the catalyst (gaseous dimethylethylamine or

DMEA). The sand is mixed with the phenolic and isocyanate resins in a mixer. There are eleven

core machines. The mixed sand with resin is then put into core boxes which are gassed with the

catalyst, causing the resin to bind to the sand and to make the core. DMEA emissions are

controlled by an acid/caustic scrubber with a 95% control efficiency which uses caustic soda and

sulfuric acid to neutralize the DMEA emissions. A release agent is applied to the core boxes to

allow removal of the core from the core box after the core is made. Some of the cores are then

sent to the core wash process. Core mud is utilized, as needed, to finish out the cores. The cores

are then baked by a 2.5 MMBTUH natural gas fired oven and then sent to the mold lines for

insertion. Particulate matter emissions from the mixers and the sand storage are captured by a

99% efficient baghouse. The current chemical binders are stored in two 6,000 gallon bulk

storage tanks.

Phenolic Urethane No-Bake (PUNB) Process

The PUNB process is a three-part, phenolic urethane no-bake binding system where chemical

reactions take place at ambient temperatures. The first part of the PUNB process uses a phenolic

resin, the second part contains an isocyanate component, and part three is a liquid catalyst.

PUNB parts 1, 2, and 3 are mixed with silica sand in a mixer. After mixing, the sand is sent to

the core box to be molded into the proper core shapes. A release agent is used to facilitate

removal of the finished cores. Some of the cores are then sent to the core wash process. Core

mud is applied as needed to finish the cores. The cores are then dried by a 2.5 MMBTUH

natural gas oven and sent to the mold lines for insertion. Under EUG C - Core and Mold

Operations, the facility currently operates one PUNB core sand mixer, designated as C-20. The

new mixer is designated as CB-20. Particulate matter emissions from the new mixer will be

controlled by the same baghouse serving the existing equipment, having 95% efficiency.

Chemical binders used in this process are stored in two 6,000 gallon bulk storage tanks.

Shell Process

The old shell core machines, C-1 through C-6, have been removed from the site and machines C-

26 and C-27 were added by Permit No. 97-125-TV (M-4). The shell process utilizes sand coated

with phenolic resin and hexamethylenetetramine. The sand is charged into the shell machines

and heat is applied from combustion of natural gas. The resin coating is a thermosetting type,

which bonds together when the heat is applied. The pattern or core box temperature usually

varies between 350o and 450

oF. A release agent is used to allow separation of the core from the

pattern. The shell cores are then sent to the mold lines for insertion into the molds.

Pouring, Cooling, and Shakeout


After the molten metal has solidified in the molds, the hot castings are routed through cooling

tunnels. When cooling is finished, the castings are separated from the form/core mold sand via a

shake-out process. Castings are then routed to the finishing and cleaning area. Any remaining

sand is cleaned off the castings by a shot-blast machine in the finishing area. A screening

conveyor reclaims the sand and recycles it through a rotoclaim bin into the sand bin. Particulate

matter emissions from the shake-out and sand handling are controlled by a dry dust collection

system at 98% efficiency.

Finishing

Metal finishing removes sand and unwanted appendages, prepares the castings surface, and

includes a quality assurance step. Castings from the Green Sand lines and the PUNB line are

sent to the finishing area. De-spurring, blasting, and grinding are all performed in this area. De-

spurring removes unwanted appendages such as spurs, gates, and risers by hitting with a sledge

hammer. Remaining sand is cleaned off the castings by a shot-blast machine. The abrasive blast

cleans the castings by removing any remaining mold sand and scale. Additional touch-up

including grinding and surface repair is performed, and castings are then sent for final inspection.

Particulate matter is controlled with a dry collection system at 98% efficiency.

Painting

Some finished castings are painted based on product requirements. The castings undergo rinsing

in a multistage bath consisting of detergent wash, tap water rinse, phosphoric acid rinse, tap

water rinse, and a final deionized water rinse. Two natural gas-fired burners, 2.5 MMBTUH, are

used to warm the soap and first water baths. Thoroughly rinsed castings are sent to a 5,000

gallon water-based, electrodeposition paint dip system. The paint consists of a paste that

provides the color, an epoxy paint resin that provides the medium, and the solvents.

Formaldehyde has been discussed in previous permit memorandums for use as a biocide. The

facility has discontinued the use of formaldehyde. Components and deionized water are pumped

into the tank and mixed. Paint is added from a replenishing tank to maintain a constant level.

The painted castings undergo a post rinsing and are sent to a 4.0 MMBTUH natural gas-fired

oven to cure at 450oF. Following the oven, the castings are cooled by the chiller’s water sprays.

SECTION III. EQUIPMENT

EUG A - Sand Handling System includes all emissions units downstream of the shakeout

process and upstream of the core/mold making process, having emissions (mostly particulate

matter) as a result of conditioning and transferring sand.

EUG A - Sand Handling System

EU Point Description Size/Rating Construct

Date

A-2 131A Simpson 23G Sand Muller 1, GSML #406 200 TPH 42,000 dscfh 1974

A-3 131C Simpson Multi-cooler MC-200, GSML #406 200 TPH/26,200 dscfh July 2005


EUG C – Core and Mold Operations, formerly known as “Core Operations” has been

modified to include emissions from core and mold making due to the similarities in processes

and emissions and now includes all emissions units involved in these operations.

EUG C - Core and Mold Operations

EU EP Description Size/ Rating Construct

Date

C-7 111 Dependable Speed Twin MK1, PUCB Core

Sand Mixer

15 TPH 1979

C-8 112 Shalco U-321, PUCB Core Machine NA 1994

C-12, C-13 112 2 - Shalco U-180, PUCB Core Machines O.O.S. 1978

C-14, C-15 112 2 - Shalco U-180, PUCB Core Machines NA 1979

C-16 112 Beardsley/Piper CB-30, Core Machine NA 1977

C-17 112 Beardsley/Piper CB-40, Core Machine NA 1980

C-18 112 Shalco U-360, Core Machine NA 1990

C-19 113A PUCB, Core Wash NA 1974

C-20 121 Dependable Pacemaster 250, PUNB Core Sand

Mixer

NA 1991

C-20B 121 Dependable Pacemaster 250, PUNB Core Sand

Mixer

250 TPH 2014

C-21 122 PUNB, Core Box Area NA 1974

C-22 113B PUNB, Core Wash NA 1974

C-23 112 CB-22, PUCB Core Machine NA 1999

C-24 114 Laempe – 120, Core Machine 4.2 TPH 2003

C-25 112 Laempe – 40, Core Machine 4.2 TPH 2005

C-26 101 Beardsley/Piper SF6, Shell Core Machine NA 2006

C-27 101 1 - Shalco U-180, Shell Core Machine NA 2006

M-5 132C Molding – Herman Moldmaster, GSML #406 NA 1974

M-9 152 Molding – Vulcan Vibrating Table, NBML 60 molds/8 hr 1985

M-14 151 PUNB Sand Mixer – Dependable Pacemaster 2,000 lbs/min 1998

M-15 155 Vulcan Sand Reclamation NA 1985 O.O.S. - Out-Of-Service EU - Emissions Unit

EP - Emissions Point NA - Not Available

PUCB - Phenolic Urethane Cold Box PUNB - Phenolic Urethane No-bake Box

EUG F – Melting, Holding and Refining, previously known as “Melting/Holding Furnaces and

Ladles,” includes only the melting furnaces, holding furnaces, and ladles.

EUG F – Melting, Holding and Refining

EU Point Description Size Construct Date

F-1 144 Brown-Bovari Electric Induction Melt Furnace 23-ton 1974



F-4 144 Brown-Bovari Electric Induction Holding Furnace 42-ton 1974





F-7 144 Whiting Electric Induction Holding Furnace 45-ton 1984

F-8 145 Tapping/Transfer Ladles NA 1974

F-9 146 Refining/Pouring Ladles NA 1974

EUG H - Material Handling/Preheating, includes equipment related to the handling and

preheating of metal scrap to be used in the melting furnaces.

EUG H - Material Handling/Preheating

EU Point Description Construction Date

H-1 143 Pre-heating 1985

H-2 142 Charge Make-up 1974

H-3 141 Material Handling 1974

EUG I – Combustion Equipment, includes equipment that combusts natural gas. Note that I-1,

the Venetta Furnace, is the source of heat for H-1, Pre-heating.

EUG I - Combustion Equipment

EU/Point Description Size/Rating Construction Date

I-1 (H-1) Venetta Furnace 23.52 MMBTU/HR 1985

I-2 – I-11 Ladle Heaters 1.0 MMBTU/HR 1974

I-12 – I-13 Tank Heaters 5.0 MMBTU/HR 1974

I-14 Paint Oven 4.0 MMBTU/HR 1974

I-15 – I-20 Shell Core Heaters 0.5 MMBTU/HR 1974

I-21 – I-22 Core Ovens 2.5 MMBTU/HR 1974

EUG M - Pouring, Cooling, and Shakeout.

EUG M – Pouring, Cooling and Shakeout

EU Point Description Size/Rating Construct

Date

M-6 133C Pouring – Schneible Side Draft Hood, GSML

#406

NA 1974

M-10 153 Pouring – Schneible Side Draft Hood, NBML NA 1974

M-7 134C Cooling – Kirk and Blum Tunnel NA 1974

M-11 153B Cooling – Vulcan Cooling Room, NBML NA 1974

M-8 135C Shakeout – Carrier Barrelhorse, GSML #406 NA 1993

M-12 154 Shakeout – General Kinematic Table, NBML NA 1985 GSML - Green Sand Molding Line; NBML - No Bake Molding Line

EUG P – Paint System, includes various sources of painting that emit primarily VOC and also

PM emissions.


EUG P - Paint System


P-1 171B Water-based Electrodeposition Dip System 1974

EUG S - Cleaning and Finishing.

EUG S – Cleaning and Finishing

EU Point Description Size/Rating Construct Date

S-1 156 PUNB 4-Wheel Shotblast NA 1974

S-2 161 Wheelabrator/tumblast Shotblast 200 ton/day 1989



S-5 161 Pangborn/Rotoblast Shotblast 200 ton/day 1990

S-6 161 Grinding - 1974

S-7 E61 A Wheelabrator Shotblast 586 ton/day 2013

EUG W - Facility Wide


All All Points Fugitives Various

Emergency Engines

The facility has one 760-hp Cummins emergency diesel generator. Emissions are based on 500

operating hours per year. The unit is an insignificant activity.

SECTION IV. EMISSIONS

Emissions of criteria pollutants are directly proportional to the melt rates and the associated raw

material handling. In general, these emissions can be calculated using available throughput-

based emissions factors, in units of lbs/ton-metal poured or lbs/ton-sand used. Individual

throughput rates for most emissions units are listed in the equipment section. Actual throughput

rates may be less, depending on demand. Steel throughput is generally reduced by about 6% past

the melting area due to slagging and charging. Material usages are based on facility

requirements for processing 26 ton/hr of metal melt. Combustion emissions from natural gas-

fueled equipment are based on AP-42 (7/98), Tables 1.4-2 and 1.4-3. The pouring process also

generates combustion-like emissions, for which emissions factors are taken from a variety of

technical sources detailed in later discussion.



Particulate Emissions from Sand Handling

Emissions calculation methods and limits are carried forward from previous permits. The results

are summarized in the following tables.

EUG A - Sand Handling

EU Point Description Control

Device

Control

Efficiency

Exhaust/Stack(s)

A-2 131 A Sand Muller 1, GSML #406 Baghouse 99% S31 B/C/E

A-3 131C Simpson Multi-cooler MC-200, GSML

#406

Baghouse 95% SC1

Stack/Exhaust Flow (acfm) Height (feet) Diameter (feet) Temperature

(oF)

S31 B/C/E 42,000 68 4 80

S53 A/B 66,500 12 2.3 75

SC1 26,200 40 4 x 3 100

The source for the derivation of the original PM emissions factor for sand handling system is

referenced in the memorandum of Permit No. 97-125-TV, page 12 as 3.6 lb/ton sand handled

from AP-42 (10/86), Table 7.10-4 [now Table 12.10-7 (1/95)]. This emission factor was

normalized to units of lbs-PM/ton-metal using a 6.78:1 sand-to-metal ratio. PM10 was then based

10% of PM from “An Inventory of Iron Foundry Emissions,” Modern Castings, 1972.

3.6 lbs-PM/ton-sand x 6.78 sand/metal ratio = 24.41 lbs-PM/ton-metal

PM10 = 24.41 tons/year x 0.10 PM10/PM = 2.41 lbs-PM/ton-metal (2.44 rounded)

Annual Limit = 2.44 lbs-PM10/ton-metal x 151,840 tons metal x 1-ton/2,000-lbs x 0.05

controlled = 9.27 TPY

This annual limit was assigned to A-2 and A-3, the Sand Muller 1, GSML #406 and the Simpson

Multi-cooler MC-200, GSML #406.

EU Point Description Metal Poured PM10

Emissions

TPH TPY Lbs/hr TPY

A-2 131 A Sand Muller 1, GSML #406 200.0 151,840 2.12 9.27

A-3 131C Simpson Multi-cooler MC-200, GSML #406 200.0

EUG C - Core and Mold Operations

VOC Emissions from Core and Mold Operations

The method for calculating emissions of VOCs generated from the mixing and curing of cores

and molds in the Title V permit was a mass balance based on 50% evaporation of the VOC

content of the core binders. Permit No. 97-125-TV (M-3) changed the 50% evaporation factor to

that determined from a test procedure developed and conducted by the Ohio Cast Metals


Association (OCMA) as part of a Memorandum of Understanding between OCMA and the Ohio

Environmental Protection Agency. This test procedure is a simple mass balance method which

involves weighing the pre-mix ingredients, mixing them and then recording incremental weight

loss measurements until cure time has been achieved. The specifics of the method are in the

permit conditions. The tests will be conducted by the vendor(s) of the binder material(s). The

permit also allows for EPA Method 24 or EPA Method 24A.

Limits on material usage rates were eliminated from previous permits because compliance with

the VOC limit now depends on the emission factor specific to the product, which can change

from one product to the next. Emission factors are not specified in this permit because they will

be specific to each product. Therefore material usage can change with changes in the product

emission factor.

Limits on hourly VOC emission rates were removed in Permit No. 97-125-TV (M-5) to

accommodate elimination of certain requirements to comply with OAC 252:100-41, Part 5, that

appeared to no longer be needed. However, these limits were restored in Permit No. 2006-166-

TVR because it is believed that they were utilized in the PSD and Title V permits in the air

dispersion modeling that was used to check compliance with the NAAQS. From permit No. 95-

527-C (PSD), ‘VOC is not limited directly by NAAQS. Rather, it is regulated as an ozone

precursor. EPA developed a method for predicting ozone concentrations based on VOC and

NOX concentrations in an area. The ambient impacts analysis utilized these tables from

"VOC/NOX Point Source Screening Tables" (Richard Scheffe, OAQPS, September, 1988). The

Scheffe tables utilize increases in NOX and VOC emissions to predict increases in ozone

concentrations. Based on this method, incremental ozone impacts for added emissions were

conservatively estimated at 29.95 µg/m3. Therefore, VOC limits, in pounds per hour and tons

per year, were restored from the Title V permit, but as modified in permit No. 97-125-TV (M-1).

EUG C – Core and Mold Operations

EU VOC Emissions

lb/hr TPY

PUNB Part 1 69.35 249.65

PUNB Part 2 31.66 113.99

PUNB Catalyst 6.04 21.73

PUCB Part 1 16.12 58.05

PUCB Part 2 1.70 6.10

PUCB Catalyst 0.78 * 2.82

Release Agent 29.35 105.60

TOTALS 155.00 557.94 * 95% scrubber efficiency

NA - Not Applicable

Particulate Emissions from Core and Mold Operations

Emissions calculation methods and limits are carried forward from previous permits. The

applicant uses an emissions factor of 1.1 lbs-PM/ton-metal poured from AP-42, Table 12.10-7

for core making and baking, and as noted above from Permit No. 97-125-TV, an assumption that


PM10 and PM2.5 are 10% of PM. An existing baghouse already controlling emissions from the

existing process provides a control efficiency of 95%.

From the memorandum of Permit No. 97-125-TV, emission factors in units of lbs-PM/ton-sand

were normalized to units of lbs-PM/ton-metal using a 6.78:1 sand-to-metal ratio. PM10 was then

based 10% of PM from “An Inventory of Iron Foundry Emissions,” Modern Castings, 1972. The

above emissions factor is already expressed in lbs-PM/ton-metal poured. For C-20B, having a

maximum capacity of 250 TPH sand throughput, this would be 36.87 TPH metal pour except

that AMC has a facility-wide pour limit of 26.0 tons per hour or 187,200 tons per year.

EUG C – Core and Mold Operations


Device

Control

Efficiency

Exhaust/Stack(s)

M-5 132C Molding – Herman Moldmaster, GSML #406 Baghouse 95% E31 A-D, F, G

M-9 152 Molding – Vulcan Vibrating Table, NBML None 95% * E51 A-F

M-14 151 PUNB Sand Mixer Baghouse 95% S53 A/B

C-7 111 Dependable Speed Twin MK1, PUCB Core

Sand Mixer

Baghouse 99% S31A

C-8 112 Shalco U-321, PUCB Core Machine Acid

Scrubber 95% S11

C-12,

C-13

112 2 - Shalco U-180, PUCB Core Machines Acid

Scrubber

95% S11

C-14,

C-15

112 2 - Shalco U-180, PUCB Core Machines Acid

Scrubber

95% S11

C-16 112 Beardsley/Piper CB-30, Core Machine Acid

Scrubber

95% S11

C-17 112 Beardsley/Piper CB-40, Core Machine Acid

Scrubber

95% S11

C-18 112 Shalco U-360, Core Machine Acid

Scrubber

95% S11

C-19 113A PUCB, Core Wash None No

Emissions

S1, S11, E1, E11

A/B, E21 A-C C-20 121 Dependable Pacemaster 250, PUNB Core

Sand Mixer

Baghouse 95% S31A

C-

20B

121b Dependable Pacemaster 250, PUNB Core

Sand Mixer

Baghouse 95% S31A

C-21 122 PUNB, Core Box Area Baghouse 95% S1, S11, E1, E11

A/B, E21 A-C C-22 113B PUNB, Core Wash None No

Emissions

S1, S11, E1, E11

A/B, E21 A-C C-23 112 CB-22, PUCB Core Machine Acid

Scrubber

95% S11

C-24 114 Laempe – 120, Core Machine Acid

Scrubber

95% S11

C-25 112 Laempe – 40, Core Machine Acid

Scrubber

95% S11

C-26 101 Beardsley/Piper SF6, Shell Core Machine None 95% * S1, S11, E1, E11

A/B, E21 A-C

C-27 101 1 - Shalco U-180, Shell Core Machine None 95% * S1, S11, E1, E11

A/B, E21 A-C

* Shell core machines C-26 and C-27 are not routed through controls. Control efficiency was estimated to be

95% because of the effect of the binders. The same assumption is made for the Vulcan Vibrating Table, M-9.



(oF)

S31 B/C/E 42,000 68 4 80

E51 A-F 40,000 61.5 4 75

S31 A/B 42,000 68 4 80

S11 11,000 45 3 75

S1 42,000 65 4 75

S31A 42,000 68 4 80

E1 30,000 43.5 4 75

E11 A/B 30,000 43.5 4 75

E21 A-C 30,000 43.5 4 75

E31 A/B* 30,000 61.5 4 75

E31 C-G* 30,000 43.5 4 75

E32 A-C* 40,000 61.5 4 75 * S31A/B, E31 C-G, and E32 A-C previously served Lines 5 and 6, which included M-1 Molding – EMI Osborn,

GSML #405.

EU EP Description Metal

Throughput

(TPY)

PM10

Emissions

(TPY) C-7 111 Dependable Speed Twin MK1, PUCB Core Sand Mixer

175,968

0.45

C-8 112 Shalco U-321, PUCB Core Machine

C-12, C-13 112 2 - Shalco U-180, PUCB Core Machines

C-14, C-15 112 2 - Shalco U-180, PUCB Core Machines

C-16 112 Beardsley/Piper CB-30, Core Machine

C-17 112 Beardsley/Piper CB-40, Core Machine

C-18 112 Shalco U-360, Core Machine

C-19 113A PUCB, Core Wash

C-20 121 Dependable Pacemaster 250, PUNB Core Sand Mixer

C-21 122 PUNB, Core Box Area

C-22 113B PUNB, Core Wash

C-23 112 CB-22, PUCB Core Machine

C-24 114 Laempe – 120, Core Machine

C-25 112 Laempe – 40, Core Machine

C-26 101 Beardsley/Piper SF6, Shell Core Machine

C-27 101 1 - Shalco U-180, Shell Core Machine

M-5/M-9 132C

/152

Molding – Herman Moldmaster, GSML #406 3.60

C-20B 121 Dependable Pacemaster 250, PUNB Core Sand Mixer 187,200 0.52

M-14, M-15 151 PUNB Sand Mixer – Dependable Pacemaster/

Vulcan Sand Reclamation 75,920 4.63

EUG F – Melting, Holding, Refining

Particulate Emissions from Melting, Holding, and Refining


Melting is accomplished using electric induction. No fuel combustion is involved and grease

and oils imported with the scrap are removed in the preheating process (discussed below).

Therefore, emissions associated with melting, holding, and refining primarily include particulate

matter (PM). Calculations for these emissions are carried forward from the Title V

memorandum, with revisions for clarification. PM10 emissions for melting and holding were

calculated using the total PM emission factor from AP-42 (1/95), Table 12.10-3, Electric

Induction Furnaces, with an assumption that 95.6% is PM10, based on Table AP-42 12.10-9,

(1/95) “Particle Size Distribution Data”, Shakeout. PM10 emissions for tapping/refining were

calculated at 80% of the total PM emission obtained from the FIRE emission factors Version 5.0

(8/95). All sources are uncontrolled.


EU

Point

Operation

PM10

Emission

Factor

Source of

Emission

Factor

Metal

Throughput

(TPY)

Annual

Emissions

(TPY)

Exhaust/

Stack(s)

F-1 144 Induction Melt Furnace

0.8604 lbs/ton

AP-42

12.10-3

187,200

80.53

E42A

F-2 144 Induction Melt Furnace E42B

F-3 144 Induction Melt Furnace E42C

F-4 144 Induction Holding Furnace E42A

F-5 144 Induction Holding Furnace E42B

F-6 144 Induction Holding Furnace E42C

F-7 144 Induction Holding Furnace E42A

F-8 145 Tapping Ladles

0.80 lb/ton

FIRE

emission

factors

Version 5.0

(8/95)

70.18 E41A-D

F-9 146 Refining Ladles E41A-D


(oF)

E42A-C 35,720 111.7 3.25 100

E41A-D 35,720 111.7 3.25 100

The following hourly emission rates are estimated using a PM10 emissions factor of 0.8604 lbs-

PM10/ton-metal to assist in comparing the PTE to the standards of 40 CFR Part 63, Subpart

EEEEE for potential future use in determining compliance or the need for stack testing.

However, it should be noted that as discussed in the “Federal Regulations”, the melt furnaces are

not subject to Subpart EEEEE at this time.

EU Point Description Metal

Throughput

(TPH)

PM10

Emissions

(lbs/hr)

F-1 144 Brown-Bovari Electric Induction Melt Furnace 23 19.79



F-4 144 Brown-Bovari Electric Induction Holding Furnace 42 36.14




EU Point Description Metal

Throughput

(TPH)

PM10

Emissions

(lbs/hr)

F-7 144 Whiting Electric Induction Holding Furnace 45 38.72

F-8 145 Tapping/Transfer Ladles NA NA

F-9 146 Refining/Pouring Ladles NA NA


Particulate Emissions from Material Handling/Preheating

Calculations for emissions of particulate matter from material handling and preheating are taken

from the Title V permit memorandum which states: “Associated emissions include PM10 from

material handling, 25% outdoor and 75% indoor, and pre-heating which also results in

combustion gases. Emission factors are based on “An Inventory of Iron Foundry Emissions,”

Modern Castings, 1972. An emission factor for PM30 was given and an engineering estimate that

15% was PM10 from handling and make-up and 45% from charge pre-heating was used. All

sources are uncontrolled.” Based on the factors given in the table shown below, apparently the

75% factor was applied to “Charge Make-up” emissions.


EU Point Operation PM10 Factor

(lbs/ton-metal)

Metal Throughput

(TPY)

Emissions

(TPY)

H-1 143 Charge Pre-heating 0.090 187,200 8.42

H-2 142 Charge Make-up 0.023 187,200 2.15

H-3 141 Material Handling 0.030 187,200 2.81

Stack/Exhaust Point Flow

(acfm)

Height

(feet)

Diameter

(feet)

Temperature

(°F)

S41 143 1,700 70 3.5 90

E51F 142 30,000 61.5 4.0 75

E41A 141 35,720 111.7 3.25 100


Criteria Pollutants (NOX, CO, VOC, and SO2) Emissions from Combustion Equipment

Criteria pollutants are generated as a result of combustion of natural gas fuel in process heaters.

Emissions were calculated using AP-42 1.4-1 for boilers/heaters less than 100 MMBTU/hr and

the total combined heat input rating. Individual equipment items and their heat input ratings are

detailed in the “Equipment” section above. The total combined rating of combustion equipment

is 55.52 MMBTUH. This combined calculation is applicable because all heaters are rated less

than 100 MMBTUH and therefore have the same emissions factors. The results of the

calculation for each pollutant are tabulated below.



EU NOX CO SO2 VOC

lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY

I-1 – I-23 5.44 23.83 4.57 20.02 0.03 0.13 0.30 1.31


Emissions calculations and limits were carried forward from the original Title V permit.

EUG M – Pouring, Cooling, and Shakeout

EU Point Operation PM10 Emission

Factor

(lbs/ton-metal)

Metal

Poured

(TPY)

Emissions

(TPY)

M-6

M-10

133C

153A

Pouring – GSML #406

Pouring – NBML 0.1469 175,968 12.92

M-7 134C Cooling - NBML

Cooling – GSML #406 0.2938 175,968 25.85

M-11 153B

M-8 135C Shakeout – Carrier

Barrelhorse, GSML #406 2.24

105,580 6.57

M-12 154 Shakeout – General

Kinematic Table, NBML 70,387 1.32

Total PM10 Emissions 46.66

CO Emission

Factor

(lbs/ton-metal)

M-6

M-10

M-7

M-11

133C

153A

134C

153B


Pouring – NBML

Cooling - GSML #406

Cooling - NBML

2.76 175,968 242.91

Total CO Emissions 242.91

NOX Emission

Factor

(lbs/ton-metal)

M-6

M-10

M-7

M-11

133C

153A

134C

153B


Pouring – NBML

Cooling - GSML #406

Cooling - NBML

0.01 175,968 0.88

Total NOX Emissions 0.88

EU Point Operation SO2 Emission

Factor

(lbs/ton-metal)

Metal

Poured

(TPY)

Emissions

(TPY)

M-6

M-10

M-7

M-11

133C

153A

134C

153B


Pouring – NBML

Cooling – GSML #406

Cooling - NBML

0.02 175,968 1.76

Total SO2 Emissions 1.76


EUG M – Pouring, Cooling, and Shakeout

EU Point Operation VOC Emission Factor

(lbs/ton-metal) Emissions

(TPY)

M-6 133C Pouring/Cooling/Shakeout 3.42 12.32

M-10 153A Pouring/Cooling/Shakeout

M-8 135C Pouring/Cooling/Shakeout

29.33 105.59 M-12 154 Pouring/Cooling/Shakeout

M-7 134C Pouring/Cooling/Shakeout

M-11 153 Pouring/Cooling/Shakeout

Total VOC Emissions 117.91


Device

Control

Efficiency

Exhaust/

Stack(s)

M-6 133C Pouring – GSML #406 None 0% S32 A-C, S34 A-B*

M-10 153A Pouring – NBML None 0% S51 A-D

M-7 134C Cooling – GSML #406 None 0% S33 A-G

M-11 153B Cooling – NBML None 0% S52 A/B

M-8 135C Shakeout – Carrier

Barrelhorse, GSML

#406

Baghouse 99% S31 A/B

M-12 154 Shakeout – General

Kinematic Table,

NBML

Baghouse 98% S53 A/B

Stack/Exhaust Flow

(acfm)

Height

(feet)

Diameter

(feet)

Temperature

(oF)

S34 A/B* 26,000 62 4 80

S32 A-C 39,000 62 4 80

S51 A-D 29,000 81 4 80

S35 A-G** 8,600 57 2 80

S33 A-G 5,000 57 1.5 80

S52 A/B 32,000 81 4 80

Stack/Exhaust Flow

(acfm)

Height

(feet)

Diameter

(feet)

Temperature

(oF)

S31 A/B 42,000 68 4 80

S53 A/B 66,500 12 2.3 75

S31 D* 42,000 68 4 80


VOC Emissions from Dip Coating

Emissions of VOC generated from coating (painting) operations are based on the VOC content

of the coating and 100% evaporation. Because coatings are applied by a dip method, emissions


of particulate matter do not occur from this process. However, an insignificant amount of PM

and VOC emissions are generated from spray coating using water-based (low VOC) coatings.

Coating DENSITY

(lbs/gal)

WEIGHT

PERCENT

VOC

Annual

Usage

(gallons)

Annual

Emissions

(Tons)

Powercron

Additive AA201 8.35 100 2,315 9.66

Powercron

Additive NA101 7.51 100 3,120 11.72

Powercron Resin

AR150 8.85 57.5 2,187 5.56

Powercron Yellow

Paste 11.10 48.8 2,187 5.92

Total VOC

32.87

EUG S - Cleaning and Finishing

Particulate Emissions from Shotblasting and Grinding

PM10 emissions from shotblasting and grinding for Permit No. 2006-166-TVR (M-1) were based

on a total PM emission factor of 17 lb/ton-metal handled from AP-42 (5/03), Table 12.10-7,

“Cleaning, Finishing”, and an assumption that PM10 can be calculated as 10% of PM. This

method replaces the one from the previous permit where emissions from shotblasting were taken

from “An Inventory of Iron Foundry Emissions,” Modern Castings, 1972, and from EPA-600/2-

80-021, U.S. EPA, 1987.

An analysis to demonstrate that a significant increase has not occurred from the new blast unit

was presented by the applicant, based on the potential to emit. Using an uncontrolled PM

emissions factor (from AP-42, Table 12-10.7) of 17 lbs-PM/ton of iron and a control efficiency

of 98% results in controlled emissions of 15 TPY. Assuming 10% is PM10 and PM2.5 resulted in

1.5 TPY PM10 and 1.5 TPY PM2.5. The applicant also stated that the new blast unit will not

create any associated emissions or debottlenecking from other processes.

Additionally, the new shot blast unit will not increase the amount of total particulate matter

generated from finishing operations. Therefore, total PM emissions are not increased from

current operations and are represented in the table below as in previous permit memorandums.

EU Point Operation Control

Device

Control

Efficiency

Exhaust/

Stack(s)

S-1 156 PUNB 4-Wheel Shotblast Baghouse 98% S53 A/B

S-2 161 Wheelabrator/tumblast Shotblast

Baghouse 98% E61 A-E,

E62 A-E



S-5 161 Pangborn/Rotoblast Shotblast


EU Point Operation Control

Device

Control

Efficiency

Exhaust/

Stack(s)

S-6 161 Grinding Baghouse 98% S61 A-D

S-7 161 Wheelabrator Shotblast Baghouse 98% S61A-D

EU Point Operation PM10 Factor

(lbs/ton-

metal)

Metal

Pour

(TPY)

Emissions

(TPY)

S-1 156 PUNB 4-Wheel Shotblast

1.7

175,968

1.82

3.64




S-5 161 Pangborn/Rotoblast Shotblast

S-6 161 Grinding 0.14

S-7 161 Wheelabrator Shotblast 1.50


(°F)

S53 A/B 66,500 12 2.3 75

E61 A-E 40,000 61.5 4.0 75

E62 A-E 40,000 61.5 4.0 75

S61 A-D 86,000 68 5.2 75



EU Point Description Construction

Date


Emergency Engines

The facility has one 760-hp Cummins emergency diesel generator. There are no requirements

for this engine either under NSPS IIII or NESHAP ZZZZ. AMC claims this as an insignificant

activity.

Hazardous Air Pollutant Emissions

Emissions of hazardous air pollutant (HAP) were calculated for melting; pouring, cooling, and

shakeout; PUNB core and mold making; and PUCB core making using emissions factors from

various documents published by the Casting Emissions Reduction Program (CERP) data for


similar mold and core mixtures. Lead emissions are included in the “melting” category due to

the possibility of lead in scrap. Emissions and the specific CERP document from which the

emission factors were taken are summarized in the following table.

Process Pollutant Metal

Pour

(TPY)

Emissions Factor Control

Efficiency

Emissions

(TPY)

Melting

Melting

CERP Test Report

#1256-12 GSA.3

CO

Antimony

187,200

0.000048 lbs/ton-metal 0% 0.004493

Arsenic 0.000053 lbs/ton-metal 0% 0.004961

Beryllium 0.0000014 lbs/ton-metal 0% 0.000131

Cadmium 0.000056 lbs/ton-metal 0% 0.005242

Chromium 0.00038 lbs/ton-metal 0% 0.035568

Cobalt 0.0000072 lbs/ton-metal 0% 0.000674

Lead 0.00077 lbs/ton-metal 0% 0.072072

Manganese 0.0213 lbs/ton-metal 0% 1.993680

Mercury 0.0 lbs/ton-metal 0% 0.000000

Nickel 0.0015 lbs/ton-metal 0% 0.140400

Selenium 0.0000041 lbs/ton-metal 0% 0.000384

Pouring, Cooling, Shakeout

Green Sand

Molds

CERP Test Report

#1411-318

Acetaldehyde

112,320

0.0080 lbs/ton-metal 0.449

Aniline 0.0213 lbs/ton-metal 0% 1.196

Benzene 0.1821 lbs/ton-metal 0% 10.227

o, m, p-Cresol 0.0377 lbs/ton-metal 0% 2.117

Dimethylnaphthalenes 0.0105 lbs/ton-metal 0% 0.590

Ethylbenzene 0.0096 lbs/ton-metal 0% 0.539

Formaldehyde 0.0020 lbs/ton-metal 0% 0.112

Hexane 0.0167 lbs/ton-metal 0% 0.938

Methylnaphthalenes 0.0256 lbs/ton-metal 0% 1.438

Naphthalene 0.0203 lbs/ton-metal 0% 1.140

Phenol 0.0773 lbs/ton-metal 0% 4.341

Toluene 0.0773 lbs/ton-metal 0% 4.341

o, m, p-Xylene 0.0555 lbs/ton-metal 0% 3.117

PUNB Molds

and Cores

CERP Test Report

#1256-119 EG and

RV100127 EG

Benzene

74,880

0.2900 lbs/ton-metal 0% 10.858

o,m,p-Cresol 0.0260 lbs/ton-metal 0% 0.973

Dimethylnapthalenes 0.0030 lbs/ton-metal 0% 0.112

Formaldehyde 0.0240 lbs/ton-metal 0% 0.899




o,m,p-Xylene 0.0330 lbs/ton-metal 0% 1.236

PUCB Cores

CERP Test Report

#1409-125 FB

Aniline

147,982

0.0273 lbs/ton-metal 0% 2.020

Benzene 0.1417 lbs/ton-metal 0% 10.485

o, m, p-Cresol 0.0223 lbs/ton-metal 0% 1.650

Hexane 0.0040 lbs/ton-metal 0% 0.296



POMs 0.0653 lbs/ton-metal 0% 4.832


o, m, p-Xylene 0.0210 lbs/ton-metal 0% 1.554

Process Pollutant Binder

Used


Efficiency

Emissions

(TPY)


Process Pollutant Metal

Pour

(TPY)


Efficiency

Emissions

(TPY)

(lb/yr)

Core and Mold Making

PUNB Molds

CERP Test Report

#1409-124 EY

Formaldehyde

4,847,649

0.0001 lbs/lb-binder 0% 0.242

1-Methylnaphthalene 0.0018 lbs/lb-binder 0% 4.363

Naphthalene 0.0005 lbs/lb-binder 0% 1.212

Phenol 0.0005 lbs/lb-binder 0% 1.212

PUCB Core making

PUCB Cores

CERP Test Report

#1409-123 EQ

Formaldehyde

4,003,056

0.0002 lbs/lb-binder 0% 0.400





PUNB Core making

PUNB Cores

CERP #1409-124

EY

Formaldehyde

307,647

0.0001 lbs/lb-binder 0% 0.015




HAP TOTALS

Metal HAP

Antimony 0.004493

Arsenic 0.004961

Beryllium 0.000131

Cadmium 0.005242

Chromium 0.035568

Cobalt 0.000674

Lead 0.072072

Manganese 1.993680

Mercury 0.000000

Nickel 0.140400

Selenium 0.000384

VOC HAP

Acetaldehyde 0.449

Aniline 3.216

Benzene 31.570

o, m, p-Cresol 4.740

Dimethylnaphthalenes 0.702

Ethylbenzene 0.539

Formaldehyde 1.668

Hexane 1.234

Methylnaphthalenes 1.438

1-Methylnaphthalene 5.641

2-Methylnaphthalene 1.401

Naphthalene 15.164

Phenol 36.545

POMs 4.832

Toluene 6.427

o, m, p-Xylene 5.907


Emissions Summary

EU NOX

(TPY)

CO

(TPY)

SO2

(TPY)

VOC

(TPY)

PM10

(TPY)

EUG A – Sand Handling 0.00 0.00 0.00 0.00 10.70

EUG C – Core and Mold Operations 0.00 0.00 0.00 557.94 9.20

EUG F – Melting, Holding and Refining 0.00 0.00 0.00 0.00 155.44

EUG H - Material Handling/Preheating 0.00 0.00 0.00 0.00 13.38

EUG I - Combustion Equipment 23.83 20.02 0.13 1.31 0.00

EUG M – Pouring, Cooling and Shakeout 0.88 242.91 1.76 117.91 46.66

EUG P - Paint System 0.00 0.00 0.00 32.87 0.00

EUG S - Cleaning and Finishing 0.00 0.00 0.00 0.00 4.49

Totals 24.71 262.93 1.89 710.03 240.07

Greenhouse Gas Emissions

Applicant submitted the following estimates for Greenhouse Gas Emissions in a previous permit

based on natural gas consumption and using emissions factors and global warming potential

conversion factors from 40 CFR 98, Subpart A, Table A-1. Total emissions were estimated to be

11,913.5 TPY of CO2e.

PM2.5 Emissions

AMC submitted an estimated total PM2.5 emissions of 111.7 TPY.

SECTION V. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified in the application are duplicated below.

Appropriate recordkeeping of activities indicated below with “*” is specified in the Specific

Conditions.

1. * Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel

which are either used exclusively for emergency power or for peaking power service not

exceeding 500 hours/year. One 760-hp Cummins emergency diesel generator is located on-

site.

2. Space heaters, boilers, process heaters (not subject to a NSPS or NESHAP), and emergency

flares less than or equal to 5 MMBTU/hr heat input (commercial natural gas). The Venetta

Furnace and the Core Ovens are subject to NESHAP EEEEE and are no longer insignificant

activities.

EU/Point Description Size/Rating Construct

Date

Applicability

I-1 (H-1) Venetta Furnace 23.52 MMBTU/HR 1985 Subpart EEEEE



Date

Applicability

I-2 – I-11 Ladle Heaters 1.0 MMBTU/HR 1974 Insignificant

I-12 – I-13 Tank Heaters 5.0 MMBTU/HR 1974 Insignificant

I-14 Paint Oven 4.0 MMBTU/HR 1974 Insignificant

I-15 – I-20 Shell Core

Heaters

0.5 MMBTU/HR 1974 Insignificant

I-21 – I-22 Core Ovens 2.5 MMBTU/HR 1974 Subpart EEEEE

2. * Emissions from fuel storage/dispensing equipment operated solely for facility owned

vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day

period. One 300 gallon unleaded gasoline tank is on-site. Throughput is much less than the

limit specified here.

3. * Storage tanks with less than or equal to 39,894 gallons capacity that store volatile organic

liquids with a true vapor pressure less than or equal to 1.5 psia at maximum storage

temperature. Several small tanks are located on-site that are less than 39,894 gallons and

store liquids with a vapor pressure below 1.0 psia.

4. Alkaline/phosphate washers and associated burners. None identified but they may be used in

the future.

5. * Non-commercial water washing operations (less than 2,250 barrels/year) and drum

crushing operations of empty barrels less than or equal to 55 gallons with less than three

percent by volume of residual material. None identified but they may be used in the future.

6. Hazardous waste and hazardous materials drum staging areas. None identified but they may

be used in the future.

7. * Surface coating operations which do not exceed a combined total usage of more than 60

gallons/month of coatings, thinners, clean-up solvents, and degreasing solvents at any one

emission unit. None identified but they may be used in the future.

8. Hand wiping and spraying of solvents from containers with less than 1 liter capacity used for

spot cleaning and/or degreasing in ozone attainment areas. None identified but they may be

used in the future.

9. * Activities that have the potential to emit no more than 5 TPY (actual) of any criteria

pollutant. Several sources including grinding, material handling, and pattern shop operations

are included in this category, as well as spray-applied surface coating using water-based (low

VOC) and emitting less than 5 tons of VOC or PM.


SECTION VI. OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Provisions) [Applicable]

Subchapter 1 includes definitions but there are no regulatory requirements.

OAC 252:100-2 (Incorporation by Reference) [Applicable]

This subchapter incorporates by reference applicable provisions of Title 40 of the Code of

Federal Regulations listed in OAC 252:100, Appendix Q. These requirements are addressed in

the “Federal Regulations” section. NESHAP EEEEE is applicable to this facility.

OAC 252:100-3 (Air Quality Standards and Increments) [Applicable]

Subchapter 3 enumerates the primary and secondary ambient air quality standards and the

significant deterioration increments. At this time, all of Oklahoma is in “attainment” of these

standards. In addition, modeled emissions from the proposed facility, conducted for PSD and Title

V permitting, demonstrated that the facility would not have a significant impact on air quality.

OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees) [Applicable]

Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission

inventories annually, and pay annual operating fees based upon total annual emissions of regulated

pollutants. Emission inventories were submitted and fees paid for previous years as required.

OAC 252:100-8 (Permits for Part 70 Sources) [Applicable]

Part 5 includes the general administrative requirements for Part 70 permits. Any planned

changes in the operation of the facility that result in emissions not authorized in the permit and

that exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior

notification to AQD and may require a permit modification. Insignificant activities refer to those

individual emission units either listed in Appendix I or whose actual calendar year emissions do

not exceed the following limits.

5 TPY of any one criteria pollutant

2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAP or 20%

of any threshold less than 10 TPY for a HAP that the EPA may establish by rule

Emission limitations and operational requirements necessary to assure compliance with all

applicable requirements for all sources are taken from the permit application, or are developed

from the applicable requirement.

OAC 252:100-9 (Excess Emissions Reporting Requirements) [Applicable]

Except as provided in OAC 252:100-9-7(a)(1), the owner or operator of a source of excess

emissions shall notify the Director as soon as possible, but no later than 4:30 p.m. the following

working day of the first occurrence of excess emissions in each excess emissions event. No later

than thirty (30) calendar days after the start of any excess emission event, the owner or operator

of an air contaminant source from which excess emissions have occurred shall submit a report

for each excess event describing the extent of the event and the actions taken by the owner or

operator in response to this event. Request for mitigation, as described in OAC 252:100-9-8,

shall be included in the excess emissions event report. Additional reporting may be required in


the case of ongoing emission events and in the case of excess emissions reporting required by 40

CFR Parts 60, 61, or 63.

OAC 252:100-13 (Open Burning) [Applicable]

Open burning of refuse and other combustible material is prohibited except as authorized in the

specific examples and under the conditions listed in this subchapter.

OAC 252:100-19 (Particulate Matter (PM)) [Applicable]

Section 19-4 regulates emissions of PM from the combustion of fuel in any new and existing fuel-

burning unit, with emission limits based on maximum design heat input rating. Fuel-burning unit

is defined in OAC 252:100-19 as any internal combustion engine or gas turbine, or other

combustion device used to convert the combustion of fuel into usable energy. Thus, the gas-fired

equipment listed in the following EUG tables is subject to the requirements of this subchapter.

Appendix C specifies a PM emission limitation of 0.60 lb/MMBTU for all equipment at this

facility with a heat input rating of 10 MMBTUH or less, and a limit of 0.49 lb/MMBTU for the

23.52 MMBTUH Venetta Furnace.


EU Point Description Size/Rating Appendix C Limit

I-1/H-1 I-1 Venetta Furnace 23.52 MMBTU/HR 0.49

I-2 – I-11 I-2 – I-11 Ladle Heaters 1.0 MMBTU/HR 0.60

I-12 – I-

13

I-12 – I-13 Tank Heaters 5.0 MMBTU/HR 0.60

I-14 I-14 Paint Oven 4.0 MMBTU/HR 0.60

I-15 – I-

20

I-15 – I-20 Shell Core Heaters 0.5 MMBTU/HR 0.60

I-21 – I-

22

I-21 – I-22 Core Ovens 2.5 MMBTU/HR 0.60

All these emission units are fired on natural gas. AP-42 (7/98) Table 1.4-2 lists natural gas total

PM emissions to be 7.6 lbs/million scf or about 0.0076 lbs/MMBTU, which is in compliance. The

permit will require the furnaces and heaters to be fired only with commercial grade natural gas.

Section 19-12 limits particulate emissions from emission points in an industrial process based on

process weight rate, as specified in Appendix G. As shown in the following table, all emission

points are in compliance with Subchapter 19.

Process Process Rate

TPH

Appendix G Emission

Limit

(lbs/hr)

Potential Emission

Rate

(lbs/hr)

Scrap Yard 26 36.4 14.30

Melting/Holding 26 36.4 23.40

Refining 24.44 34.9 24.44

Molding 24.44 34.9 12.22

Pouring 24.44 34.9 7.33


Process Process Rate

TPH

Appendix G Emission

Limit

(lbs/hr)

Potential Emission

Rate

(lbs/hr)

Cooling 24.44 34.9 14.66

Shakeout 24.44 34.9 3.13

Shotblasting 24.44 34.9 7.58

Grinding 12.22 21.9 0.39

Sand Handling 176.28 57.2 31.73

Core Departments 250 61.0 0.26

The permit will require some of the listed operations to use dry controls. These controls will be

monitored for compliance with this subchapter.

OAC 252:100-25 (Visible Emissions and Particulates) [Applicable]

No discharge of greater than 20% opacity is allowed except for short-term occurrences that consist

of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such

periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed

60% opacity. Monitoring of pollution control equipment is a requirement of the permit to assure

compliance with this standard.

OAC 252:100-29 (Fugitive Dust) [Applicable]

No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the

property line on which the emissions originated in such a manner as to damage or to interfere with

the use of adjacent properties, or cause air quality standards to be exceeded, or to interfere with the

maintenance of air quality standards. Fugitive sources are contained within the facility, therefore,

fugitive emissions will not interfere with the use of adjacent properties.

OAC 252:100-31 (Sulfur Compounds) [Part 5 Applicable]

Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1,

1972). For gaseous fuels the limit is 0.2 lb/MMBTU heat input averaged over 3 hours. The

permit requires the use of pipeline natural gas as defined in Part 72 having 0.5 grains TRS/100

scf to ensure compliance with Subchapter 31.

OAC 252:100-33 (Nitrogen Oxides) [Not Applicable]

This subchapter limits new gas-fired fuel-burning equipment with rated heat input greater than or

equal to 50 MMBTUH to emissions of 0.20 lbs of NOX per MMBTU, three-hour average. There

are no equipment items that exceed the 50 MMBTUH threshold. The largest of the units is the

Venetta Furnace, rated at 23.5 MMBTUH, which is less than the 50 MMBTUH applicability

threshold.

OAC 252:100-35 (Carbon Monoxide) [Not Applicable]

This subchapter affects gray iron cupolas, blast furnaces, basic oxygen furnaces, petroleum

catalytic cracking units, and petroleum catalytic reforming units. It requires removal of 93% or

more of CO by “complete secondary combustion” from new sources and also from existing

sources located in or significantly impacting a non-attainment area for CO. “Gray iron cupola”

means shaft-type furnace used for the melting of metals usually consisting of, but not limited to,


the furnace proper, tuyeres, fans or blowers, tapping spout, charging equipment, gas-cleaning

devices and other auxiliaries. Shaft furnaces used for processing non-metallic materials are not

included under this definition but are included in the definition of process equipment. This

facility, among other processes, manufactures gray iron castings but has no gray iron cupolas or

any other of the listed processes subject to this rule. There are no affected sources.

OAC 252:100-37 (Volatile Organic Compounds) [Part 5 and Part 7 Applicable]

Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a

vapor pressure greater than 1.5 psia to be equipped with a permanent submerged fill pipe or with

an organic vapor recovery system. The only fuel tank on-site stores diesel having a vapor

pressure less than 1.5 psia and has a capacity less than 400 gallons.

Part 5 limits the VOC content of coatings used in coating lines and operations. Based on mixture

requirements the coating will have a maximum content of 3.52 lbs/gallon. This content accounts

for all solvent and is in compliance with the 4.8 lb/gal limit for maintenance finishes.

Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize VOC

emissions. Temperature and available air must be sufficient to provide essentially complete

combustion. The combustion equipment, as listed above in the applicability section for

Subchapter 19, is designed to provide essentially complete combustion of organic materials.

OAC 252:100-42 (Toxic Air Contaminants (TAC)) [Applicable]

This subchapter regulates toxic air contaminants (TAC) that are emitted into the ambient air in

areas of concern (AOC). Any work practice, material substitution, or control equipment required

by the Department prior to June 11, 2004, to control a TAC, shall be retained, unless a

modification is approved by the Director. Since no AOC has been designated there are no

specific requirements for this facility at this time.

OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable]

This subchapter provides general requirements for testing, monitoring and recordkeeping and

applies to any testing, monitoring or recordkeeping activity conducted at any stationary source.

To determine compliance with emissions limitations or standards, the Air Quality Director may

require the owner or operator of any source in the state of Oklahoma to install, maintain and

operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant

source. All required testing must be conducted by methods approved by the Air Quality Director

and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol

shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests.

Emissions and other data required to demonstrate compliance with any federal or state emission

limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained,

and submitted as required by this subchapter, an applicable rule, or permit requirement. Data

from any required testing or monitoring not conducted in accordance with the provisions of this

subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive

use, of any credible evidence or information relevant to whether a source would have been in

compliance with applicable requirements if the appropriate performance or compliance test or

procedure had been performed.


The following Oklahoma Air Pollution Control Rules are not applicable to this facility:

OAC 252:100-11 Alternative Reduction not requested

OAC 252:100-15 Mobile Sources not in source category

OAC 252:100-17 Incinerators not type of emission unit

OAC 252:100-23 Cotton Gins not type of emission unit

OAC 252:100-24 Feed & Grain Facility not in source category

OAC 252:100-39 Nonattainment Areas not in a subject area

OAC 252:100-47 Landfills not type of source category

SECTION VII. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Not Applicable to This Project]

Final total facility emissions are greater than the threshold of 250 TPY of any single regulated

pollutant. However, emission increases from this project are less than the significance levels (40

TPY NOX, 100 TPY CO, 40 TPY VOC, 40 TPY SO2, 25 TPY PM10, and 75K TPY CO2e). Any

future increases of emissions must be evaluated for PSD if they exceed those levels.

NSPS, 40 CFR Part 60 [Not Applicable]

Subpart Z, Standards of Performance for Ferroalloy Production Facilities.

Subparts AA, Standards of Performance Steel Plants: Electric Arc Furnace.

Subparts AAa, Standards of Performance Steel Plants: Electric Arc Furnaces and Argon-Oxygen

Decarburization.

Subpart IIII, Stationary Compression Ignition Internal Combustion Engines, affects stationary

compression ignition (CI) internal combustion engines (ICE) based on power and displacement

ratings, depending on date of construction, beginning with those constructed after July 11, 2005.

Stationary CI ICE that commence construction after July 11, 2005 where the stationary CI ICE

are manufactured after April 1, 2006 and are not fire pump engines, or are manufactured as a

certified National Fire Protection Association (NFPA) fire pump engine after July 1, 2006 and

stationary CI ICE that modify or reconstruct their stationary CI ICE after July 11, 2005 are

subject to this subpart. §60.4205 specifies the standards for owners and operators of emergency

stationary CI internal combustion engines.

The 760-horsepower Cummins emergency engine was manufactured and constructed prior to the

threshold dates and is therefore not affected under this subpart.

None of the listed subparts affect induction furnaces.

NESHAP, 40 CFR Part 61 [Not Applicable]

There are no emissions of any of the regulated pollutants: arsenic, asbestos, benzene, beryllium,

coke oven emissions, mercury, radionuclides, or vinyl chloride.

NESHAP, 40 CFR Part 63 [Subpart EEEEE Applicable]

Subpart MMMM, National Emission Standards for Hazardous Air Pollutants for Surface Coating

of Miscellaneous Metal Parts and Products, establishes national emission standards for hazardous

air pollutants (NESHAP) for miscellaneous metal parts and products surface coating facilities.


This subpart does not apply to a coating operation conducted at a facility where the facility uses

only coatings, thinners and other additives, and cleaning materials that contain no organic HAP,

as determined according to §63.3941(a). Therefore, this facility is not subject to the rule.

Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart affects

existing, new, or reconstructed stationary RICE located at a major or area source of HAP

emissions.

Existing compression ignition emergency stationary RICE with a site rating of more than 500

brake HP located at a major source of HAP emissions do not have to meet the requirements of

this subpart and of subpart A of this part. Therefore the Cummins emergency engine has no

requirements to meet under either of the aforementioned subparts.

Subpart EEEEE, National Emission Standards for Hazardous Air Pollutants (NESHAP) for Iron

and Steel Foundries, establishes national emission standards for hazardous air pollutants (HAPs)

for iron and steel foundries that are, or are part of, a major source of HAP emissions. This

subpart also establishes requirements to demonstrate initial and continuous compliance with the

emission limitations, work practice standards, and operation and maintenance requirements in

this subpart. Based on information in the existing Title V permit, this facility is a major source

of HAPs for purposes of this subpart and is therefore an affected source. The date of compliance

for existing facilities was April 23, 2007, and April 22, 2005, for the work practice standards.

§63.7690 - Emissions limitations. The facility is subject to the PM standards of §63.7690(a)(5).

For each pouring station at an existing iron and steel foundry, emissions discharged through a

conveyance to the atmosphere must not exceed either 0.010 gr/dscf of PM, or (ii) 0.0008 gr/dscf

of total metal HAP. Based on the definitions of conveyance, metal melting furnace (which does

not include the holding furnaces and ladles), only the pouring lines appear to be subject to an

emissions rate standard. Testing performed in August and October 2006 demonstrated

compliance with the standard of 0.01 gr/dscf for both pouring lines. The results of the testing are

summarized later in this memorandum.

The facility is also subject to the opacity standard of §63.7690(a)(7). For each building or

structure housing any iron and steel foundry emissions source at the iron and steel foundry,

fugitive emissions discharged to the atmosphere from foundry operations must not exhibit

opacity greater than 20 percent (6-minute average), except for one 6-minute average per hour

that does not exceed 27 percent opacity. The EHS Manager for the facility submitted by letter

dated April 30, 2007, certification that the initial opacity testing had been performed on that day

and that no opacity was observed.

The facility does not conduct triethylamine (TEA) cold box mold or core making TEA and is

therefore not subject to requirements associated with this pollutant.

§63.7700 - Work practice standards. The facility is subject to the requirements of this section

except for §63.7700(d) which pertains to furan core and mold making. See the following

discussion in §63.7744 for documenting compliance.

§63.7730 - Performance tests or other initial compliance demonstrations. As required by

§63.7(a)(2), an initial compliance performance test must be conducted no later than 180 calendar

days after the compliance date that is specified in §63.7683 (April 23, 2007). Initial compliance

with the work practice standards in §63.7700 must be demonstrated no later than 30 calendar

days after April 22, 2005.

§63.7731 - The facility is required to conduct subsequent performance tests to demonstrate

compliance with the opacity limit in §63.7690(a)(7) no less frequently than once every 6 months.


§63.7744 - Demonstrating continuous compliance with the work practice standards. The facility

must maintain records that document continuous compliance with the certification requirements

in §63.7700(b) or with the procedures in the scrap selection and inspection plan required in

§63.7700(c). Records documenting compliance with the scrap selection and inspection plan

must include a copy (kept onsite) of the procedures used by the scrap supplier for either

removing accessible mercury switches or for purchasing automobile bodies that have had

mercury switches removed, as applicable. For a scrap preheater at an existing iron and steel

foundry, the facility must operate and maintain each gas-fired preheater such that the flame

directly contacts the scrap charged to demonstrate continuous compliance with the requirement

§63.7700(e)(1). If the facility chooses to meet the work practice standard in §63.7700(e)(2), the

facility must keep records to document that the scrap preheater charges only material that is

subject to and in compliance with the scrap certification requirements in §63.7700(b). The

facility complies with this rule under §63.7700(b) and §63.7700(e)(1). A report dated August

13, 2008, for an FCE performed on June 17, 2008, states “An existing affected source must

comply with the work practice standards in § 63.7700 (b) or (c), as applicable, no later than April

22, 2005. Initial demonstration of compliance with these work practice standards is

accomplished by providing a certification with the initial notification of compliance status.

Semiannual compliance reports are then due January 31 and July 31 of each year or the required

information may be submitted with the TV Annual Compliance Certifications and Semiannual

Reports. The facility submitted the initial notification of compliance status on September 24,

2004, and the facility has submitted the semiannual compliance reports with the ACCs and

SARs.”

§63.7751 - Reports. The facility is subject to the requirements of this section.

§63.7752 - Records. The facility is subject to the requirements of this section.

§63.7753 – Records maintenance. The facility is subject to the requirements of this section.

Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Industrial,

Commercial and Institutional Boilers and Process Heaters, establishes national emission

limitations and work practice standards for hazardous air pollutants (HAP) emitted from at major

sources of HAP. This subpart also establishes requirements to demonstrate initial and

continuous compliance with the emission limitations and work practice standards. The following

table lists the process combustion sources at the facility.

EUG I - Combustion Equipment NESHAP DDDD Gas 1 Process Heaters


Date

Subpart DDDDD

Category

I-1 (H-1) Venetta Furnace 23.52 MMBTU/HR 1985 Metal Process Furnace

I-2 – I-11 Ladle Heaters 1.0 MMBTU/HR 1974 Metal Process Furnace

I-12 – I-13 Tank Heaters 5.0 MMBTU/HR 1974 Metal Process Furnace

I-14 Paint Oven 4.0 MMBTU/HR 1974 Process Heater

I-15 – I-20 Shell Core Heaters 0.5 MMBTU/HR 1974 Process Heater

I-21 – I-22 Core Ovens 2.5 MMBTU/HR 1974 Process Heater

The following exclusions and definitions apply to this discussion.

Pursuant to §63.7491, the types of boilers and process heaters listed in paragraphs (a) through (n)

of this section are not subject to this subpart.


(d) A hot water heater as defined in this subpart.

(h) Any boiler or process heater that is part of the affected source subject to another subpart of

this part, such as boilers and process heaters used as control devices to comply with subparts JJJ,

OOO, PPP, and U of this part.

“Process heater means an enclosed device using controlled flame, and the unit's primary

purpose is to transfer heat indirectly to a process material. Process heaters are devices in which

the combustion gases do not come into direct contact with process materials.”

“Hot water heater means a closed vessel with a capacity of no more than 120 U.S. gallons in

which water is heated by combustion of gaseous, liquid, or biomass/bio-based solid fuel and is

withdrawn for use external to the vessel.”

The Venetta Furnace is covered by NESHAP EEEEE and is therefore not subject to this rule.

The Ladle Heaters are open flame into the ladles to dry them, which does not meet the definition

of a process heater and are therefore not affected sources under this rule.

The Tank Heaters meet the definition of hot water heater and are therefore not subject.

The Paint Oven does not meet the definition of process heater and is therefore not an affected

source under this rule.

The Shell Core Heaters do not meet the definition of process heater and are therefore not affected

sources under this rule.

The Core Ovens are covered by NESHAP EEEEE and are therefore not subject to this rule.

CAM, 40 CFR Part 64 [Applicable]

This part applies to any pollutant-specific emissions unit at a major source that is required to obtain

an operating permit, for any application for an initial operating permit submitted after April 18,

1998, that addresses “large emissions units,” or any application that addresses “large emissions

units” as a significant modification to an operating permit, or for any application for renewal of an

operating permit, if it meets all of the following criteria.

It is subject to an emission limit or standard for an applicable regulated air pollutant

It uses a control device to achieve compliance with the applicable emission limit or standard

It has potential emissions, prior to the control device, of the applicable regulated air

pollutant of 100 TPY or 10/25 TPY of a HAP

There are some emissions units for which the capacity rating is not known. Note that from Part

70, “Potential to emit” (PTE) means the maximum capacity of a stationary source to emit any air

pollutant under its physical and operational design. Any physical or operational limitation on the

capacity of a source to emit an air pollutant, including air pollution control equipment and

restrictions on hours of operation or on the type or amount of material combusted, stored, or

processed, shall be treated as part of its design if the limitation is enforceable by the

Administrator. Therefore, since the existing Title V permit has an enforceable limit on

throughput that is considered an operational limitation that is enforceable, the uncontrolled PTE


must take that into consideration and the maximum capacity rating is not a factor in determining

the PTE. Based on this criteria, the following emissions units have potential pre-control

emissions of 100 TPY or more.

EU Process PM10

Factor

Throughput Emissions

Sand Handling (lbs/ton-

sand)

Sand

(TPY)

(TPY)

A-3 Simpson Multi-cooler MC-200, GSML #406 2.52 1,193,063 1,503

M-15 Vulcan Sand Reclamation

Shakeout (lbs/ton-

metal)

Metal

(TPY)

(TPY)

M-8 Shakeout – Carrier Barrelhorse, GSML #406 2.24 105,580 118

Potential pre-control emissions from A-3, the Simpson Multi-cooler, and M-15, the Vulcan Sand

Reclamation, exceed major source levels and each utilizes a baghouse to maintain compliance

with OAC 252:100-19, OAC 252:100-25, and the permit emissions limits. The definition of

control device excludes inherent process equipment. From 40 CFR Part 64, “Inherent process

equipment means equipment that is necessary for the proper or safe functioning of the process, or

material recovery equipment that the owner or operator documents is installed and operated

primarily for purposes other than compliance with air pollution regulations. Equipment that

must be operated at an efficiency higher than that achieved during normal process operations in

order to comply with the applicable emission limitation or standard is not inherent process

equipment. For the purposes of this part, inherent process equipment is not considered a control

device.” The applicant has realized the need to reuse the particulate fines collected in the

baghouse and has installed a return conveyor to re-circulate these fines to the process. Permit

No. 97-125-TV (M-2) determined that the baghouse for the Simpson Multi-cooler is inherent to

the process and CAM will not be required for the A-3. M-15 has an enforceable permit limit of

4.4 tons per year, controlled. Uncontrolled emissions at 95% control efficiency are 88 tons per

year. Therefore, CAM is required only for M-8. Following is an outline of applicant’s proposed

Compliance Assurance Monitoring.

EUG N – Shakeout

EU Description Control Device Control Efficiency

M-8 Shakeout – Carrier Barrelhorse, GSML #406 Baghouse 99%

M-8: Monitor pressure differential across the baghouse as an indication of proper operation and

fouling using a magnahelic gauge located in a position amenable to visible observation of

pressure readings. The baghouse is considered to be operating properly when the

pressure differential measures between 1 and 8.0 inches of water, with a threshold of five

excursions per month as recommended in the facility’s Quality Improvement Plan (OIP).

Data is to be recorded on a daily log.


Baghouse:

M-8, Carrier Barrelhorse Indicator No. 1 Indicator No. 2

Indicator Opacity baghouse pressure differential

Measurement

Approach

Opacity shall be monitored using a certified

Visible Emissions Evaluator

Differential pressure transducer

Indicator Range An excursion is defined as an opacity

greater than 20% except for one six-minute

period per hour not to exceed 60% opacity

An excursion is defined as a daily

pressure differential below 1 inches

water column. Excursions trigger an

inspection, corrective actions, and a

reporting requirement

Data

Representativeness

Performance

Criteria

The Visible Emissions Evaluator shall be

positioned in compliance with EPA Method

9 of 40 CFR Part 60, Appendix A

The differential pressure

manometer(s) shall monitor the

static pressures upstream and

downstream of the baghouse QA/QC Practices

and Criteria


certified every six months in Method 9

Monthly comparison to U-tube

manometer. Acceptability criterion

is 1 inch pressure differential

baghouse

Monitoring

Frequency

One six-minute average shall be conducted

per week

Measured daily

Data Collection

Procedure

Data are recorded manually Data are recorded manually

Averaging Period Six-minute averages Daily

Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable]

This facility will not process or store more than the threshold quantity of any regulated substance

(Section 112r of the Clean Air Act 1990 Amendments). The facility uses commercial natural gas

fuel which is comprised of mainly methane, a regulated substance per CAAA 90 Section 112(r).

However, this substance is not stored on-site. The small quantity which is in the pipelines on the

facility is much less than the 10,000 pound threshold and therefore is excluded from all

requirements including the Risk Management Plan.

Stratospheric Ozone Protection, 40 CFR Part 82 [Subparts A and F Applicable]

These standards require phase out of Class I & II substances, reductions of emissions of Class I

& II substances to the lowest achievable level in all use sectors, and banning use of nonessential

products containing ozone-depleting substances (Subparts A & C); control servicing of motor

vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations

which meet phase out requirements and which maximize the substitution of safe alternatives to

Class I and Class II substances (Subpart D); require warning labels on products made with or

containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon

disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds

under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons

(Subpart H).

Subpart A identifies ozone-depleting substances and divides them into two classes. Class I

controlled substances are divided into seven groups; the chemicals typically used by the

manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform

(Class I, Group V). A complete phase-out of production of Class I substances is required by


January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are

hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs.

Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances,

scheduled in phases starting by 2002, is required by January 1, 2030.

Subpart F applies to any person servicing, maintaining, or repairing appliances. This subpart

also applies to persons disposing of appliances, including small appliances and motor vehicle air

conditioners. In addition, this subpart applies to refrigerant reclaimers, technician certifying

programs, appliance owners and operators, manufacturers of appliances, manufacturers of

recycling and recovery equipment, approved recycling and recovery equipment testing

organizations, persons selling class I or class II refrigerants or offering class I or class II

refrigerants for sale, and persons purchasing class I or class II refrigerants. The purpose of this

subpart is to reduce emissions of class I and class II refrigerants and their substitutes to the

lowest achievable level by maximizing the recapture and recycling of such refrigerants during

the service, maintenance, repair, and disposal of appliances and restricting the sale of refrigerants

consisting in whole or in part of a class I and class II ODS in accordance with Title VI of the

Clean Air Act.

Standard Conditions included in the permit address required work practices to be used during the

maintenance, service, repair, or disposal of appliances, leak repair requirements, standards for

recycling and recovery equipment, technician certification, and recordkeeping requirements.

Additional applicable requirements are found in the rule.

SECTION VIII. COMPLIANCE

Inspection

A full compliance evaluation was conducted by Drake Hanna of AQD on June 9, 2016.

Violations related to requirements of NESHAP DDDDD including the applicability notification,

burner tune-up, and one-time energy assessment have been corrected. An area of concern related

to emissions reporting is pending the results of the next EI report.

Testing

Testing to confirm compliance with the standards for particulate matter (PM) set in NESHAP

Subpart EEEEE for pouring emissions was performed for the Green Sand Molding Line on

August 8 and 9, 2006, and for the No-Bake Molding Line on October 4, 2006. The facility was

in compliance. The standards and results of the tests are illustrated in the following table.

Emissions Source NESHAP EEEEE Standard

(gr-PM/dscf)

Test Result

(gr-PM/dscf)

Schneible Side Draft Hood, GSML 0.01 0.003

Schneible Side Draft Hood, NBML 0.01 0.002

The Green Sand Molding Line and the No-Bake Molding Line were tested again on September

13, and 14, 2011. The DEQ observer was not able to observe the test but noted in his report that

the results were in compliance with the standard.


Fee Paid

Payment of $7,500 was submitted to satisfy the fee for a Title V permit renewal.

Tier Classification And Public Review

This application has been determined to be a Tier II based on the request to renew a Title V

permit. The applicant has submitted an affidavit that they are not seeking a permit for land use or

for any operation upon land owned by others without their knowledge. The affidavit certifies that

the applicant owns the real property.

The applicant will publish a “DEQ Notice Of Tier II Permit Application Filing” and a “DEQ

Notice Of Tier II Draft Permit” in a local newspaper for 30 day public review. In addition, a

copy of the draft permit will be available at the AQD office in Oklahoma City, and on the Air

Quality section of the DEQ web page at www.deq.state.ok.us.

Information on all permit actions is available for review by the public in the Air Quality section of

the DEQ Web page: www.deq.state.ok.us/.

SECTION IX. SUMMARY

Based on the information submitted by the applicant and the estimated potential emissions

associated with this project, this modification does not result in a significant emission increase or

a significant net emission increase and the facility is not required to get a construction permit for

this modification.

Ambient air quality standards are not threatened at this site. There are no active Air Quality

compliance or enforcement issues that would affect the issuance of this permit. Issuance of the

operating permit is recommended contingent on Public and EPA reviews.

http://www.deq.state.ok.us/

DRAFT

PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

American Castings, LLC Permit No. 2014-2107-TVR2

Pryor - Ductile Iron Foundry

The permittee is authorized to operate in conformity with the specifications submitted to Air

Quality on May 11, 2006, with supplemental information received on October 17, 2006, August 7,

2007, April 21 and November 25, 2008, and April 8, 2009; the application to add the new blast

unit received on October 19, 2012; the application to add the new mixer received on February 4,

2014 with supplemental information received on September 16, 2015 and by e-mail on February

15, March 29, and May 5, 2016; and on December 30, 2016; and the application for the Title V

renewal permit received on October 27, 2014, with supplemental information received by e-mail

on March 13, 2017, April 12, 2017, and May 11 and 18, 2017 and June 8, 2017. The Evaluation

Memorandum dated July 12, 2017, explains the derivation of applicable permit requirements and

estimates of emissions; however, it does not contain operating limitations or permit requirements.

Continuing operations under this permit constitutes acceptance of, and consent to, the conditions

contained herein:

1. Points of emission and emissions limitations. Permittee shall maintain and operate the facility

in a manner to prevent the exceedance of ambient air quality standards contained in OAC

252:100-3 and the limitations established by this permit.

All annual pollutant and throughput limits: Monthly and 12-month rolling cumulative, unless

specified more frequently.

[OAC 252:100-8-6(a)(1)]

A. EUG A - Sand Handling System.


EU Stack Make/Model Size/Rating Construct Date

A-2 131A Simpson 23G Sand Muller 1,

GSML #406

200 TPH

42,000 dscfh

1974

A-3 SC1 Simpson Multi-cooler MC-200,

GSML #406

200 TPH/

26,200 dscfh

July 2005

i. Emissions of particulate matter having an aerodynamic diameter of 10 microns or less

(PM10) shall not exceed those specified in the following table.

EU Make/Model Control

Efficiency

PM10

Emissions

lb/hr TPY

A-2 Simpson 23G Sand Muller 1, GSML #406 95% 2.12 9.27

A-3 Simpson Multi-cooler MC-200, GSML #406

B. EUG C - Core and Mold Operations

SPECIFIC CONDITIONS 2014-2107-TVR2 DRAFT 2

EUG C - Core and Mold Operations EU Stack Description Size/ Rating Construct

Date

C-7 S31A Dependable Speed Twin MK1, PUCB Core

Sand Mixer

15 TPH 1979

C-8 S11 Shalco U-321, PUCB Core Machine NA 1994

C-12, C-13 S11 2 - Shalco U-180, PUCB Core Machines O.O.S. 1978

C-14, C-15 S11 2 - Shalco U-180, PUCB Core Machines NA 1979

C-16 S11 Beardsley/Piper CB-30, Core Machine NA 1977

C-17 S11 Beardsley/Piper CB-40, Core Machine NA 1980

C-18 S11 Shalco U-360, Core Machine NA 1990

C-19 S1, S11, E1,

E11 A/B, E21

A-C

PUCB, Core Wash NA 1974

C-20 S31A Dependable Pacemaster 250, PUNB Core

Sand Mixer

NA 1991

C-20B 121 Dependable Pacemaster 250, PUNB Core

Sand Mixer

250 TPH 2014

C-21 S1, S11, E1,

E11 A/B, E21

A-C

PUNB, Core Box Area NA 1974

C-22 S1, S11, E1,

E11 A/B, E21

A-C

PUNB, Core Wash NA 1974

C-23 S11 CB-22, PUCB Core Machine NA 1999

C-24 S11 Laempe – 120, Core Machine 4.2 TPH 2003

C-25 S11 Laempe – 40, Core Machine 4.2 TPH 2005

C-26 S1, S11, E1,

E11 A/B, E21

A-C

Beardsley/Piper SF6, Shell Core Machine NA 2006

C-27 S1, S11, E1,

E11 A/B, E21

A-C

1 - Shalco U-180, Shell Core Machine NA 2006

M-5 E31 A-D, F,

G

Molding – Herman Moldmaster, GSML

#406

NA 1974

M-9 E51 A-F Molding – Vulcan Vibrating Table, NBML NA 1985

M-14 S53 A/B PUNB Sand Mixer – Dependable Pacemaster 2,000

lbs/min

1998

M-15 S53 A/B Vulcan Sand Reclamation NA 1985

O.O.S. - Out-Of-Service NA - Not Available

PUCB - Phenolic Urethane Cold Box PUNB - Phenolic Urethane No-bake Box

i. Emissions of volatile organic compounds (VOC) shall not exceed 557.94 TPY. The

following products shall be used at the facility. The usage rates and VOC contents

shall not exceed those listed below.

Product Density

(lbs/gal)

Hourly

Usage

(gallons)

Yearly

Usage

(gallons)

Maximum

VOC Content,

(lbs/gal)

PUNB Part 1 7.5 29.2 210,230 4.75

PUNB Part 2 7.5 20.69 149,000 3.06


PUNB Catalyst 7.92 1.53 11,000 7.90

PUCB Part 1 9.10 8.33 60,000 3.87

PUCB Part 2 7.28 5.56 40,000 0.61

PUCB Catalyst 5.64 2.78 20,000 5.64

Release Agent 7.29 4.11 29,580 7.14

Release Agent* 7.29 0.01 20 7.14

* limits are specific to the release agent containing Polydimethylsiloxane

ii. Emissions of particulate matter having an aerodynamic diameter of 10 microns or less

(PM10) shall not exceed the combined limits for each group of emissions units

specified in the following table.

a. Shell core machines C-26 and C-27 and the Vulcan Vibrating Table M-9 are not

routed through controls. Permittee may apply a control efficiency of 95%

because of the effect of the binders.

b. PUCB and PUNB core machines shall be controlled by a baghouse with a control

efficiency of at least 95%. The Vulcan Sand Reclamation unit has a baghouse

having 98% control efficiency

EU Stack Control

Efficiency

PM10 Emissions

lb/hr TPY

C-7, C-8 through C-20, C-21,

C-22, C-23, C-24, C-25

S1, S11, S31A, E1,

E11 A/B, E21 A-C

95%

0.13

0.45

C-26 & C-27 S1, S11, E1, E11 A/B,

E21 A-C

M-5, M-9 E31 A-D, F, G/E51 A-F 95% 1.22 3.60

M-14/M-15 S53 A/B 95% 1.06 4.63

C-20B S31A 95% 0.14 0.52

C. EUG F – Melting, Holding and Refining


EU Stack Description Size Construct

Date

F-1 E42A Brown-Bovari Electric Induction Melt Furnace 23-ton 1974

F-2 E42B Brown-Bovari Electric Induction Melt Furnace 23-ton 1974

F-3 E42C Brown-Bovari Electric Induction Melt Furnace 23-ton 1974

F-4 E42A Brown-Bovari Electric Induction Holding

Furnace

42-ton 1974

F-5 E42B Brown-Bovari Electric Induction Holding

Furnace

42-ton 1974

F-6 E42C Brown-Bovari Electric Induction Holding

Furnace

42-ton 1974

F-7 E42A Whiting Electric Induction Holding Furnace 45-ton 1984

F-8 E41A-D Tapping/Transfer Ladles NA 1974

F-9 E41A-D Refining/Pouring Ladles NA 1974




EU Stack Control

Efficiency

PM10 Emissions

lb/hr TPY

F-1, F-2, F-3, F-4, F-5, F-6, and F-7 E42A None 22.37 80.53

F-8 and F-9 E41A-D None 19.55 70.18

ii. Emissions of lead (Pb) shall not exceed 1.11 lbs/hr or 3.98 TPY.

D. EUG H - Material Handling/Preheating


EU Stack Description Construction Date

H-1 S41 Pre-heating 1985

H-2 E51F Charge Make-up 1974

H-3 E41A Material Handling 1974



EU Stack Control

Efficiency

PM10 Emissions

lb/hr TPY

H-1 S41 0% 2.34 8.42

H-2 E51F 0% 0.59 2.11

H-3 E41A 0% 0.78 2.81

E. EUG I - Combustion Equipment.


EU/Point Description Size/Rating Construction Date

I-1 (H-1) Venetta Furnace 23.52 MMBTU/HR 1985

I-2 – I-11 Ladle Heaters 1.0 MMBTU/HR 1974

I-12 – I-13 Tank Heaters 5.0 MMBTU/HR 1974

I-14 Paint Oven 4.0 MMBTU/HR 1974

I-15 – I-20 Shell Core Heaters 0.5 MMBTU/HR 1974

I-21 – I-22 Core Ovens 2.5 MMBTU/HR 1974


EU NOX CO SO2 VOC

lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY

I-1 – I-23

Total Combined

5.44 23.83 4.57 20.02 0.03 0.13 0.30 1.31


F. EUG M – Pouring, Cooling and Shakeout


EU Stack Description Size/

Rating

Construct

Date

M-6 S32 A-C Pouring – Schneible Side Draft Hood,

GSML #406

NA 1974

M-10 S51 A-D Pouring – Schneible Side Draft Hood,

NBML

NA 1974

M-7 S33 A-G Cooling – Kirk and Blum Tunnel NA 1974

M-11 S52 A/B Cooling – Vulcan Cooling Room, NBML NA 1985

M-8 S31 A/B Shakeout – Carrier Barrelhorse, GSML

#406

NA 1993

M-12 S53 A/B Shakeout – General Kinematic Table,

NBML

NA 1985

GSML - Green Sand Molding Line; NBML - No Bake Molding Line

i. Emissions of particulate matter from pouring, cooling and shakeout having an

aerodynamic diameter of 10 microns or less (PM10) shall not exceed those specified

in the following table.

EU Stack Control

Efficiency

PM10 Emissions

lb/hr TPY

M-6 Pouring – GSML #406 S32 A-C 0% 3.59 12.94

M-10 Pouring – NBML S51 A-D 0%

M-7 Cooling - NBML &

M-11 Cooling – GSML #406

S33 A-G and

S52 A/B

0% 7.18 25.86

M-8 S31 A/B 95% 1.83 6.57

M-12 S53 A/B 98% 0.36 1.32

ii. Emissions of volatile organic compounds (VOC) from pouring, cooling, and shakeout

shall not exceed those specified in the following table.

EU Stack Control

Efficiency

VOC Emissions

(lbs/ton-metal) TPY

M-6 S32 A-C 0% 3.42 12.32

M-10 S51 A-D 0%

M-8 S31 A/B 0%

29.33 105.59 M-12 S53 A/B 0%

M-7 S33 A-G 0%

M-11 S52 A/B 0%

iii. Emissions of criteria pollutants shall not exceed those specified in the following table.

EU Stack NOX CO SO2


lb/hr TPY lb/hr TPY lb/hr TPY

M-6

and M-10

S32 A-C

and S51 A-D

0.24 0.88 13.49 48.58 0.49 1.76

M- 7

and M-11

S33 A-G and

S52 A/B

53.98 194.33

G. EUG S - Cleaning and Finishing.

EUG S - Shotblast and Grinding

EU Stack Description Size/Rating Construct Date

S-1 S53 A/B PUNB 4-Wheel Shotblast - 1974

S-2 E61 A Wheelabrator/tumblast Shotblast 200 ton/day 1989



S-5 E61 A Pangborn/Rotoblast Shotblast 200 ton/day 1990

S-6 S61 A-D Grinding - 1974

S-7 E61 A Wheelabrator Shotblast 586 ton/day 2013

EU Stack Control

Efficiency

PM10 Emissions

lb/hr TPY

S-1 S53 A/B 98% 0.51 1.82

S-2 through S-5 E61 A-E, E62 A-E 98% 1.01 3.64

S-6 S61 A-D 98% 0.04 0.14

S-7 S61-A 99% 0.41 1.50

H. EUG P - Paint System



P-1 171B Water-based Electrodeposition Dip System 1974

i. Emissions of volatile organic compounds (VOC) shall not exceed those specified in

the following table.

a. Calculations for emissions of VOC generated from coating (painting) operations

shall be based on the VOC content of the coating and 100% evaporation.

EU Control

Efficiency

VOC Emissions

lb/hr TPY

P-1 VOC None. 100 % Evaporated and emitted. 39.08 146.18

I. EUG W - Facility Wide


EU Point Description Construction

Date



2. The facility is subject to Subpart EEEEE, National Emission Standards for Hazardous Air

Pollutants (NESHAP) for Iron and Steel Foundries, and shall comply with all applicable

requirements including but not limited to the following. [NESHAP, 40 CFR Part 63]

What this Subpart Covers

§63.7680 What is the purpose of this subpart?

§63.7681 Am I subject to this subpart?

§63.7682 What parts of my foundry does this subpart cover?

§63.7683 When do I have to comply with this subpart?

§63.7690 What emissions limitations must I meet?

§63.7700 What work practice standards must I meet?

§63.7710 What are my operation and maintenance requirements?

§63.7720 What are my general requirements for complying with this subpart?

§63.7730 By what date must I conduct performance tests or other initial compliance

demonstrations?

§63.7731 When must I conduct subsequent performance tests?

§63.7732 What test methods and other procedures must I use to demonstrate initial

compliance with the emissions limitations?

§63.7733 What procedures must I use to establish operating limits?

§63.7734 How do I demonstrate initial compliance with the emissions limitations that apply

to me?

§63.7735 How do I demonstrate initial compliance with the work practice standards that

apply to me?

§63.7736 How do I demonstrate initial compliance with the operation and maintenance

requirements that apply to me?

§63.7740 What are my monitoring requirements?

§63.7741 What are the installation, operation, and maintenance requirements for my

monitors?

§63.7742 How do I monitor and collect data to demonstrate continuous compliance?

§63.7743 How do I demonstrate continuous compliance with the emissions limitations that

apply to me?

§63.7744 How do I demonstrate continuous compliance with the work practice standards

that apply to me?

§63.7745 How do I demonstrate continuous compliance with the operation and maintenance

requirements that apply to me?

§63.7746 What other requirements must I meet to demonstrate continuous compliance?

§63.7747 How do I apply for alternative monitoring requirements for a continuous

emissions monitoring system?

§63.7750 What notifications must I submit and when?

§63.7751 What reports must I submit and when?

§63.7752 What records must I keep?

§63.7753 In what form and for how long must I keep my records?

§63.7760 What parts of the General Provisions apply to me?

§63.7761 Who implements and enforces this subpart?

http://www.ecfr.gov/cgi-bin/text-idx?SID=00fa71f7b08bf47874045d7ca2682052&mc=true&node=sp40.14.63.eeeee&rgn=div6#sg40.14.63.eeeee.sg34

http://www.ecfr.gov/cgi-bin/text-idx?SID=00fa71f7b08bf47874045d7ca2682052&mc=true&node=sp40.14.63.eeeee&rgn=div6#se40.14.63_17680








































§63.7765 What definitions apply to this subpart?

Table 1 to Subpart EEEEE of Part 63 - Applicability of General Provisions to Subpart

EEEEE

3. The total facility-wide metal pour rate shall not exceed 26.0 tons per hour or 187,200 tons

annually, 12-month rolling total.

4. The permittee shall be permitted to operate the 3-coreless electric induction furnaces 24

hours per day, 365 days per year up to 8,760 hours per year, using the following raw

materials: steel, foundry returns, and pig iron. [OAC 252:100-8-6(a)]

A. The permittee shall be permitted to operate the sand cooler with appurtenances and

ancillary equipment no more than 8,760 hours per year.

5. Fuel Limitations. The fuel-burning equipment shall be fired with pipeline natural gas as

defined in Part 72 having 0.5 grains/100 scf or less total sulfur. Compliance can be shown by

the following methods: a current gas company bill, lab analysis, stain-tube analysis, gas

contract, tariff sheet, or other approved methods. Compliance shall be demonstrated at least

once per calendar year. [OAC 252:100-31]

6. Controls. Emissions from the listed equipment shall be exhausted through the following

control equipment and limited to the pressure drops listed. Alternative control equipment

may be used provided the control efficiency is equivalent or higher than those listed.

[OAC 252:100-25-3(b)(1) & (c) & OAC 252:100-8-6(a)(1)]

EU Exhaust/

Stack(s)

Description Control

Device

Control

Efficiency

ΔP

(H2O)

A-2 S31

B/C/E

Sand Muller 1, GSML #406 Baghouse 95% 0.80 – 1.4

A-3 SC1 Sand Cooler, Simpson Multi-cooler

MC-200, GSML #406

Baghouse 95.0% 1.0 – 8.0

M-5 E31 A-D,

F, G Molding – Herman Moldmaster,

GSML #406

Baghouse 95.0% 0.80 – 1.4

M-8 S31 A/B Shakeout – GSML #406 Baghouse 95.0% 0.80 – 1.4

M-9 E51 A-F Molding – Vulcan Vibrating Table,

NBML

None 95% Not

Applicable

M-12 S53 A/B Shakeout – NBML Baghouse 98.0% 1.0 – 8.0

M-14 S53 A/B PUNB Sand Mixer Baghouse 95% 1.0 – 8.0

M-15 S53 A/B Vulcan Sand Reclamation Baghouse 95% 1.0 – 8.0

C-7 S31A Dependable Speed Twin MK1,

PUCB Core Sand Mixer

Baghouse 95% 1.0 – 8.0

C-8 S11 Shalco U-321, PUCB Core Machine Acid Scrubber 95% 5.0 – 11.0

C-12,

C-13

S11 2 - Shalco U-180, PUCB Core

Machines

Acid Scrubber 95% 5.0 – 11.0

C-14,

C-15

S11 2 - Shalco U-180, PUCB Core

Machines


C-16 S11 Beardsley/Piper CB-30, Core

Machine




EU Exhaust/

Stack(s)

Description Control

Device

Control

Efficiency

ΔP

(H2O)

C-17 S11 Beardsley/Piper CB-40, Core

Machine


C-18 S11 Shalco U-360, Core Machine Acid Scrubber 95% 5.0 – 11.0

C-19 S1, S11,

E1, E11

A/B, E21

A-C

PUCB, Core Wash None No

Emissions

Not

Applicable

C-20 S31A Dependable Pacemaster 250, PUNB

Core Sand Mixer

Baghouse 95% 1.0 – 8.0

C-20B S31A Dependable Pacemaster 250, PUNB

Core Sand Mixer

Baghouse 95%

C-21 S1, S11,

E1, E11

A/B, E21

A-C

PUNB, Core Box Area Baghouse 99% 0.80 – 1.4

C-22 S1, S11,

E1, E11

A/B, E21

A-C

PUNB, Core Wash None No

Emissions

Not

Applicable

C-23 S11 CB-22, PUCB Core Machine Acid Scrubber 95% 5.0 – 11.0

C-24 S11 Laempe – 120, Core Machine Acid Scrubber 95% 5.0 – 11.0

C-25 S11 Laempe – 40, Core Machine Acid Scrubber 95% 5.0 – 11.0

C-26 S1, S11,

E1, E11

A/B, E21

A-C

Beardsley/Piper SF6, Shell Core

Machine

None 95% Not

Applicable

C-27 S1, S11,

E1, E11

A/B, E21

A-C

1 - Shalco U-180, Shell Core

Machine

None 95% Not

Applicable

S-1 S53 A/B PUNB 4-Wheel Shotblast Baghouse 98.0% 1.0 – 8.0

S-2

E61 A-E,

E62 A-E Wheelabrator/tumblast Shotblast Baghouse 98.0% 1.0 – 8.0

S-3

E61 A-E,


S-4

E61 A-E,


S-5

E61 A-E,

E62 A-E Pangborn/Rotoblast Shotblast Baghouse 98.0% 1.0 – 8.0

S-6 S61 A-D Grinding Baghouse 98.0% 1.0 – 8.0

i. Shell core machines C-26 and C-27 and the Vulcan Vibrating Table M-9 are not routed

through controls. Permittee may apply a control efficiency of 95% because of the effect

of the binders.

7. Maintenance and Monitoring. [OAC 252:100-8-6(a)],

[OAC 252:100-43]

A. Pressure drop shall be recorded at least once daily for each of the control devices listed in

Specific Condition No. 6.


B. The method for calculating emissions of VOCs generated from the mixing and curing of

cores shall be based on the emission factor determined using one of the following

methods: EPA Method 24, EPA Method 24A, or the mass balance test procedure

developed and conducted by the Ohio Cast Metals Association (OCMA) as part of a

Memorandum of Understanding between OCMA and the Ohio Environmental Protection

Agency. The test may be performed either at the facility or by the vendor of the binder

material and the results provided to the facility. Results of the test for each binder

product shall be maintained at the facility. For EPA Method 24 or EPA Method 24A, the

one hour bake option is required. For the OCMA Method:

i. The tests shall be conducted in accordance with the protocol for VOC testing for

foundry binder systems.

ii. The test shall be conducted for a period lasting no less than 12 hours, or for the

estimated average holding time of the cores prior to consumption in the pouring and

molding process, whichever time period is greatest.

iii. The test shall be conducted to account for emissions generated during the mixing

process.

Tests may also be required upon request from Air Quality Division. Upon a written request

from Air Quality, compliance with the emission limitations shall be determined at the

permittee's expense using Reference Method 24 or 24A as specified in 40 CFR Part 60,

Appendix A. Note: the one hour bake option is required.

8. Compliance Assurance Monitoring (CAM). [OAC 252:100-8-6(a)(1)], [OAC 252:100-43]

A. The permittee shall implement compliance assurance monitoring (CAM) in accordance

with 40 CFR Part 64 and shall install perform monitoring operations as specified in the

following tables at the specified frequencies.

Baghouse:


Indicator Opacity baghouse pressure differential

Measurement

Approach

Opacity shall be monitored using a certified

Visible Emissions Evaluator

Differential pressure transducer

Indicator Range An excursion is defined as an opacity

greater than 20% except for one six-minute

period per hour not to exceed 60% opacity

An excursion is defined as a daily

pressure differential below 1 inches

water column. Excursions trigger an

inspection, corrective actions, and a

reporting requirement

Data

Representativeness

Performance

Criteria


positioned in compliance with EPA Method

9 of 40 CFR Part 60, Appendix A

The differential pressure

manometer(s) shall monitor the

static pressures upstream and

downstream of the baghouse QA/QC Practices

and Criteria


certified every six months in Method 9

Monthly comparison to U-tube

manometer. Acceptability criterion

is 1 inch pressure differential

baghouse


Baghouse:


Monitoring

Frequency

One six-minute average shall be conducted

per week

Measured daily

Data Collection

Procedure

Data are recorded manually Data are recorded manually

Averaging Period Six-minute averages Daily

B. The permittee shall comply with all applicable requirements of CAM including the

following. [40 CFR 64.1 to 64.9]

i. §64.7 Operation of approved monitoring;

ii. §64.8 Quality improvement plan (QIP) requirements; and

iii. §64.9 Reporting and recordkeeping requirements.

9. The permittee shall maintain records of operations as listed below. These records shall be

maintained on-site or at a local field office for at least five years after the date of recording

and shall be provided to regulatory personnel upon request. [OAC 252:100-8-6 (a)(3)(B)],

[OAC 252:100-43]

a. Hourly and 12-month rolling total of the amount of material melted. The hourly limit

shall be based on the amount of material melted monthly divided by the number of hours

operated between the first day of the month beginning at 12:00 AM and ending at 12:00

AM on the last day of the month.

b. Hourly and 12-month rolling totals of the amount of products used to demonstrate

compliance with Specific Condition 1.B.i. The hourly limit shall be based on the amount

of products used monthly divided by the number of hours operated between the first day

of the month beginning at 12:00 AM and ending at 12:00 AM on the last day of the

month.

c. MSDS information which documents the volatile organic compound content expressed in

pounds of VOC per gallon of coating less water and exempt solvents, percentage of water

by weight, solids percent by weight, solvent density, and percentage of exempt solvents by

weight (if any), of each coating, binder, solvent, and paint.

d. For the fuel(s) burned, the appropriate document(s) as described in Specific Condition

No. 5, updated whenever the supplier changes.

e. All records required by 40 CFR, Part 63, Subpart EEEEE. f. Records of monitoring and inspection of all air pollution control equipment required by

Specific Condition Nos. 6, 7, and 8 of this permit.

g. Records required for CAM.

10. The following records shall be maintained on-site or at a local field office to verify insignificant

activities. No recordkeeping is required for those operations which qualify as Trivial Activities.

[OAC 252:100-8-6(a)(3)(B)]


a. Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel

fuel which are either used exclusively for emergency power or for peaking power

service not exceeding 500 hours/year: Hours of operation.

b. For fuel storage/dispensing equipment operated solely for facility owned vehicles if fuel

throughput is not more than 2,175 gallons/day, averaged over a 30-day period: 30-day

average of fuel throughput.

c. For storage tanks constructed with a capacity less than 39,894 gallons which store VOC

with a vapor pressure less than 1.5 psia at maximum storage temperature: Records of

capacity of the tanks, and contents.

d. For non-commercial water washing operations (less than 2,250 barrels/year) and drum

crushing operations of empty barrels less than or equal to 55 gallons with less than three

percent by volume of residual material: Size and number of barrels washed per year.

e. Surface coating and degreasing operations which do not exceed a combined total usage

of more than 60 gallons/month of coatings, thinners, clean-up solvents, and degreasing

solvents at any one emissions unit: Amount of solvent/coatings used (annual total).

f. For activities that have the potential to emit less than 5 TPY (actual) of any criteria

pollutant: Type of activity and the amount of emissions from that activity (annual).

11. The Permit Shield (Standard Conditions, Section VI) is extended to the following requirements

that have been determined to be inapplicable to this facility. [OAC 252:100-8-6(d)(2)]

OAC 252:100-11 Alternative Reduction - not requested

OAC 252:100-15 Mobile Sources - not in source category

OAC 252:100-17 Incinerators - not type of emission unit

OAC 252:100-23 Cotton Gins - not type of emission unit

OAC 252:100-24 Feed & Grain Facility - not in source category

OAC 252:100-33 Nitrogen Oxides - not in source category

OAC 252:100-35 Carbon Monoxide - not in source category

OAC 252:100-39 Nonattainment Areas - not in a subject area

OAC 252:100-47 Landfills - not type of source category

12. No later than 30 days after each anniversary date of the issuance of the original Title V permit

(November 8, 2001), the permittee shall submit to Air Quality Division of DEQ, with a copy to the

US EPA, Region 6, certification of compliance with the terms and conditions of this permit.

[OAC 252:100-8-6(c)(5)(A), (C), & (D)]

13. This permit supersedes all existing Air Quality operating permits for this facility, which are now

cancelled.

MAJOR SOURCE AIR QUALITY PERMIT

STANDARD CONDITIONS

(June 21, 2016)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with the federal

Clean Air Act (42 U.S.C. 7401, et al.) and under the authority of the Oklahoma Clean Air Act

and the rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma

Department of Environmental Quality (DEQ). The permit does not relieve the holder of the

obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or

ordinances. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

C. The permittee shall comply with all conditions of this permit. Any permit noncompliance

shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement

action, permit termination, revocation and reissuance, or modification, or for denial of a permit

renewal application. All terms and conditions are enforceable by the DEQ, by the

Environmental Protection Agency (EPA), and by citizens under section 304 of the Federal Clean

Air Act (excluding state-only requirements). This permit is valid for operations only at the

specific location listed.

[40 C.F.R. §70.6(b), OAC 252:100-8-1.3 and OAC 252:100-8-6(a)(7)(A) and (b)(1)]

D. It shall not be a defense for a permittee in an enforcement action that it would have been

necessary to halt or reduce the permitted activity in order to maintain compliance with the

conditions of the permit. However, nothing in this paragraph shall be construed as precluding

consideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for

noncompliance if the health, safety, or environmental impacts of halting or reducing operations

would be more serious than the impacts of continuing operations. [OAC 252:100-8-6(a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any exceedance resulting from an emergency and/or posing an imminent and substantial

danger to public health, safety, or the environment shall be reported in accordance with Section

XIV (Emergencies). [OAC 252:100-8-6(a)(3)(C)(iii)(I) & (II)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported

consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.

[OAC 252:100-8-6(a)(3)(C)(iv)]

C. Every written report submitted under this section shall be certified as required by Section III

(Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]

MAJOR SOURCE STANDARD CONDITIONS June 21, 2016 2

SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTING

A. The permittee shall keep records as specified in this permit. These records, including

monitoring data and necessary support information, shall be retained on-site or at a nearby field

office for a period of at least five years from the date of the monitoring sample, measurement,

report, or application, and shall be made available for inspection by regulatory personnel upon

request. Support information includes all original strip-chart recordings for continuous

monitoring instrumentation, and copies of all reports required by this permit. Where appropriate,

the permit may specify that records may be maintained in computerized form.

[OAC 252:100-8-6 (a)(3)(B)(ii), OAC 252:100-8-6(c)(1), and OAC 252:100-8-6(c)(2)(B)]

B. Records of required monitoring shall include:

(1) the date, place and time of sampling or measurement;

(2) the date or dates analyses were performed;

(3) the company or entity which performed the analyses;

(4) the analytical techniques or methods used;

(5) the results of such analyses; and

(6) the operating conditions existing at the time of sampling or measurement.

[OAC 252:100-8-6(a)(3)(B)(i)]

C. No later than 30 days after each six (6) month period, after the date of the issuance of the

original Part 70 operating permit or alternative date as specifically identified in a subsequent Part

70 operating permit, the permittee shall submit to AQD a report of the results of any required

monitoring. All instances of deviations from permit requirements since the previous report shall

be clearly identified in the report. Submission of these periodic reports will satisfy any reporting

requirement of Paragraph E below that is duplicative of the periodic reports, if so noted on the

submitted report. [OAC 252:100-8-6(a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or

operator shall comply with the provisions of Section II (Reporting Of Deviations From Permit

Terms) of these standard conditions. [OAC 252:100-8-6(a)(3)(C)(iii)]

E. In addition to any monitoring, recordkeeping or reporting requirement specified in this

permit, monitoring and reporting may be required under the provisions of OAC 252:100-43,

Testing, Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean

Air Act or Oklahoma Clean Air Act. [OAC 252:100-43]

F. Any Annual Certification of Compliance, Semi Annual Monitoring and Deviation Report,

Excess Emission Report, and Annual Emission Inventory submitted in accordance with this

permit shall be certified by a responsible official. This certification shall be signed by a

responsible official, and shall contain the following language: “I certify, based on information

and belief formed after reasonable inquiry, the statements and information in the document are

true, accurate, and complete.”

[OAC 252:100-8-5(f), OAC 252:100-8-6(a)(3)(C)(iv), OAC 252:100-8-6(c)(1), OAC

252:100-9-7(e), and OAC 252:100-5-2.1(f)]


G. Any owner or operator subject to the provisions of New Source Performance Standards

(“NSPS”) under 40 CFR Part 60 or National Emission Standards for Hazardous Air Pollutants

(“NESHAPs”) under 40 CFR Parts 61 and 63 shall maintain a file of all measurements and other

information required by the applicable general provisions and subpart(s). These records shall be

maintained in a permanent file suitable for inspection, shall be retained for a period of at least

five years as required by Paragraph A of this Section, and shall include records of the occurrence

and duration of any start-up, shutdown, or malfunction in the operation of an affected facility,

any malfunction of the air pollution control equipment; and any periods during which a

continuous monitoring system or monitoring device is inoperative.

[40 C.F.R. §§60.7 and 63.10, 40 CFR Parts 61, Subpart A, and OAC 252:100, Appendix Q]

H. The permittee of a facility that is operating subject to a schedule of compliance shall submit

to the DEQ a progress report at least semi-annually. The progress reports shall contain dates for

achieving the activities, milestones or compliance required in the schedule of compliance and the

dates when such activities, milestones or compliance was achieved. The progress reports shall

also contain an explanation of why any dates in the schedule of compliance were not or will not

be met, and any preventive or corrective measures adopted. [OAC 252:100-8-6(c)(4)]

I. All testing must be conducted under the direction of qualified personnel by methods

approved by the Division Director. All tests shall be made and the results calculated in

accordance with standard test procedures. The use of alternative test procedures must be

approved by EPA. When a portable analyzer is used to measure emissions it shall be setup,

calibrated, and operated in accordance with the manufacturer’s instructions and in accordance

with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document

or an equivalent method approved by Air Quality.

[OAC 252:100-8-6(a)(3)(A)(iv), and OAC 252:100-43]

J. The reporting of total particulate matter emissions as required in Part 7 of OAC 252:100-8

(Permits for Part 70 Sources), OAC 252:100-19 (Control of Emission of Particulate Matter), and

OAC 252:100-5 (Emission Inventory), shall be conducted in accordance with applicable testing

or calculation procedures, modified to include back-half condensables, for the concentration of

particulate matter less than 10 microns in diameter (PM10). NSPS may allow reporting of only

particulate matter emissions caught in the filter (obtained using Reference Method 5).

K. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required

by 40 C.F.R. Part 60, 61, and 63, for all equipment constructed or operated under this permit

subject to such standards. [OAC 252:100-8-6(c)(1) and OAC 252:100, Appendix Q]

SECTION IV. COMPLIANCE CERTIFICATIONS

A. No later than 30 days after each anniversary date of the issuance of the original Part 70

operating permit or alternative date as specifically identified in a subsequent Part 70 operating

permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a

certification of compliance with the terms and conditions of this permit and of any other

applicable requirements which have become effective since the issuance of this permit.

[OAC 252:100-8-6(c)(5)(A), and (D)]


B. The compliance certification shall describe the operating permit term or condition that is the

basis of the certification; the current compliance status; whether compliance was continuous or

intermittent; the methods used for determining compliance, currently and over the reporting

period. The compliance certification shall also include such other facts as the permitting

authority may require to determine the compliance status of the source.

[OAC 252:100-8-6(c)(5)(C)(i)-(v)]

C. The compliance certification shall contain a certification by a responsible official as to the

results of the required monitoring. This certification shall be signed by a responsible official,

and shall contain the following language: “I certify, based on information and belief formed

after reasonable inquiry, the statements and information in the document are true, accurate, and

complete.” [OAC 252:100-8-5(f) and OAC 252:100-8-6(c)(1)]

D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions

units or stationary sources that are not in compliance with all applicable requirements. This

schedule shall include a schedule of remedial measures, including an enforceable sequence of

actions with milestones, leading to compliance with any applicable requirements for which the

emissions unit or stationary source is in noncompliance. This compliance schedule shall

resemble and be at least as stringent as that contained in any judicial consent decree or

administrative order to which the emissions unit or stationary source is subject. Any such

schedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the

applicable requirements on which it is based, except that a compliance plan shall not be required

for any noncompliance condition which is corrected within 24 hours of discovery.

[OAC 252:100-8-5(e)(8)(B) and OAC 252:100-8-6(c)(3)]

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE

PERMIT TERM

The permittee shall comply with any additional requirements that become effective during the

permit term and that are applicable to the facility. Compliance with all new requirements shall

be certified in the next annual certification. [OAC 252:100-8-6(c)(6)]

SECTION VI. PERMIT SHIELD

A. Compliance with the terms and conditions of this permit (including terms and conditions

established for alternate operating scenarios, emissions trading, and emissions averaging, but

excluding terms and conditions for which the permit shield is expressly prohibited under OAC

252:100-8) shall be deemed compliance with the applicable requirements identified and included

in this permit. [OAC 252:100-8-6(d)(1)]

B. Those requirements that are applicable are listed in the Standard Conditions and the Specific

Conditions of this permit. Those requirements that the applicant requested be determined as not

applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6(d)(2)]


SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees

based on emissions inventories. The methods used to calculate emissions for inventory purposes

shall be based on the best available information accepted by AQD.

[OAC 252:100-5-2.1, OAC 252:100-5-2.2, and OAC 252:100-8-6(a)(8)]

SECTION VIII. TERM OF PERMIT

A. Unless specified otherwise, the term of an operating permit shall be five years from the date

of issuance. [OAC 252:100-8-6(a)(2)(A)]

B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely

and complete renewal application has been submitted at least 180 days before the date of

expiration. [OAC 252:100-8-7.1(d)(1)]

C. A duly issued construction permit or authorization to construct or modify will terminate and

become null and void (unless extended as provided in OAC 252:100-8-1.4(b)) if the construction

is not commenced within 18 months after the date the permit or authorization was issued, or if

work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]

D. The recipient of a construction permit shall apply for a permit to operate (or modified

operating permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]

SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this permit, or the application

of any provision of this permit to any circumstance, is held invalid, the application of such

provision to other circumstances, and the remainder of this permit, shall not be affected thereby.

[OAC 252:100-8-6 (a)(6)]

SECTION X. PROPERTY RIGHTS

A. This permit does not convey any property rights of any sort, or any exclusive privilege.

[OAC 252:100-8-6(a)(7)(D)]

B. This permit shall not be considered in any manner affecting the title of the premises upon

which the equipment is located and does not release the permittee from any liability for damage

to persons or property caused by or resulting from the maintenance or operation of the equipment

for which the permit is issued. [OAC 252:100-8-6(c)(6)]

SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty

(60) days of the request unless the DEQ specifies another time period, any information that the

DEQ may request to determine whether cause exists for modifying, reopening, revoking,


reissuing, terminating the permit or to determine compliance with the permit. Upon request, the

permittee shall also furnish to the DEQ copies of records required to be kept by the permit.

[OAC 252:100-8-6(a)(7)(E)]

B. The permittee may make a claim of confidentiality for any information or records submitted

pursuant to 27A O.S. § 2-5-105(18). Confidential information shall be clearly labeled as such

and shall be separable from the main body of the document such as in an attachment.

[OAC 252:100-8-6(a)(7)(E)]

C. Notification to the AQD of the sale or transfer of ownership of this facility is required and

shall be made in writing within thirty (30) days after such sale or transfer.

[Oklahoma Clean Air Act, 27A O.S. § 2-5-112(G)]

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopened and reissued, or terminated for cause.

Except as provided for minor permit modifications, the filing of a request by the permittee for a

permit modification, revocation and reissuance, termination, notification of planned changes, or

anticipated noncompliance does not stay any permit condition.

[OAC 252:100-8-6(a)(7)(C) and OAC 252:100-8-7.2(b)]

B. The DEQ will reopen and revise or revoke this permit prior to the expiration date in the

following circumstances: [OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)]

(1) Additional requirements under the Clean Air Act become applicable to a major source

category three or more years prior to the expiration date of this permit. No such

reopening is required if the effective date of the requirement is later than the expiration

date of this permit.

(2) The DEQ or the EPA determines that this permit contains a material mistake or that the

permit must be revised or revoked to assure compliance with the applicable requirements.

(3) The DEQ or the EPA determines that inaccurate information was used in establishing the

emission standards, limitations, or other conditions of this permit. The DEQ may revoke

and not reissue this permit if it determines that the permittee has submitted false or

misleading information to the DEQ.

(4) DEQ determines that the permit should be amended under the discretionary reopening

provisions of OAC 252:100-8-7.3(b).

C. The permit may be reopened for cause by EPA, pursuant to the provisions of OAC 100-8-

7.3(d). [OAC 100-8-7.3(d)]

D. The permittee shall notify AQD before making changes other than those described in Section

XVIII (Operational Flexibility), those qualifying for administrative permit amendments, or those

defined as an Insignificant Activity (Section XVI) or Trivial Activity (Section XVII). The

notification should include any changes which may alter the status of a “grandfathered source,”

as defined under AQD rules. Such changes may require a permit modification.

[OAC 252:100-8-7.2(b) and OAC 252:100-5-1.1]


E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that

are not specifically approved by this permit are prohibited. [OAC 252:100-8-6(c)(6)]

SECTION XIII. INSPECTION & ENTRY

A. Upon presentation of credentials and other documents as may be required by law, the

permittee shall allow authorized regulatory officials to perform the following (subject to the

permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(17)

for confidential information submitted to or obtained by the DEQ under this section):

(1) enter upon the permittee's premises during reasonable/normal working hours where a

source is located or emissions-related activity is conducted, or where records must be

kept under the conditions of the permit;

(2) have access to and copy, at reasonable times, any records that must be kept under the

conditions of the permit;

(3) inspect, at reasonable times and using reasonable safety practices, any facilities,

equipment (including monitoring and air pollution control equipment), practices, or

operations regulated or required under the permit; and

(4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times

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

[OAC 252:100-8-6(c)(2)]

SECTION XIV. EMERGENCIES

A. Any exceedance resulting from an emergency shall be reported to AQD promptly but no later

than 4:30 p.m. on the next working day after the permittee first becomes aware of the

exceedance. This notice shall contain a description of the emergency, the probable cause of the

exceedance, any steps taken to mitigate emissions, and corrective actions taken.

[OAC 252:100-8-6 (a)(3)(C)(iii)(I) and (IV)]

B. Any exceedance that poses an imminent and substantial danger to public health, safety, or the

environment shall be reported to AQD as soon as is practicable; but under no circumstance shall

notification be more than 24 hours after the exceedance. [OAC 252:100-8-6(a)(3)(C)(iii)(II)]

C. An "emergency" means any situation arising from sudden and reasonably unforeseeable

events beyond the control of the source, including acts of God, which situation requires

immediate corrective action to restore normal operation, and that causes the source to exceed a

technology-based emission limitation under this permit, due to unavoidable increases in

emissions attributable to the emergency. An emergency shall not include noncompliance to the

extent caused by improperly designed equipment, lack of preventive maintenance, careless or

improper operation, or operator error. [OAC 252:100-8-2]

D. The affirmative defense of emergency shall be demonstrated through properly signed,

contemporaneous operating logs or other relevant evidence that: [OAC 252:100-8-6 (e)(2)]


(1) an emergency occurred and the permittee can identify the cause or causes of the

emergency;

(2) the permitted facility was at the time being properly operated;

(3) during the period of the emergency the permittee took all reasonable steps to minimize

levels of emissions that exceeded the emission standards or other requirements in this

permit.

E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an

emergency shall have the burden of proof. [OAC 252:100-8-6(e)(3)]

F. Every written report or document submitted under this section shall be certified as required

by Section III (Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop

and register with the appropriate agency a risk management plan by June 20, 1999, or the

applicable effective date. [OAC 252:100-8-6(a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate individual emissions units that are either on the list in Appendix I to OAC Title 252,

Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below.

Any activity to which a State or Federal applicable requirement applies is not insignificant even

if it meets the criteria below or is included on the insignificant activities list.

(1) 5 tons per year of any one criteria pollutant.

(2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an

aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year

for single HAP that the EPA may establish by rule.

[OAC 252:100-8-2 and OAC 252:100, Appendix I]

SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate any individual or combination of air emissions units that are considered inconsequential

and are on the list in Appendix J. Any activity to which a State or Federal applicable

requirement applies is not trivial even if included on the trivial activities list.

[OAC 252:100-8-2 and OAC 252:100, Appendix J]

SECTION XVIII. OPERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the

need for any permit revision or any notification to the DEQ (unless specified otherwise in the


permit). When an operating scenario is changed, the permittee shall record in a log at the facility

the scenario under which it is operating. [OAC 252:100-8-6(a)(10) and (f)(1)]

B. The permittee may make changes within the facility that:

(1) result in no net emissions increases,

(2) are not modifications under any provision of Title I of the federal Clean Air Act, and

(3) do not cause any hourly or annual permitted emission rate of any existing emissions unit

to be exceeded;

provided that the facility provides the EPA and the DEQ with written notification as required

below in advance of the proposed changes, which shall be a minimum of seven (7) days, or

twenty four (24) hours for emergencies as defined in OAC 252:100-8-6 (e). The permittee, the

DEQ, and the EPA shall attach each such notice to their copy of the permit. For each such

change, the written notification required above shall include a brief description of the change

within the permitted facility, the date on which the change will occur, any change in emissions,

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

permit shield provided by this permit does not apply to any change made pursuant to this

paragraph. [OAC 252:100-8-6(f)(2)]

SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

A. The following applicable requirements and state-only requirements apply to the facility

unless elsewhere covered by a more restrictive requirement:

(1) Open burning of refuse and other combustible material is prohibited except as authorized

in the specific examples and under the conditions listed in the Open Burning Subchapter.

[OAC 252:100-13]

(2) No particulate emissions from any fuel-burning equipment with a rated heat input of 10

MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19]

(3) For all emissions units not subject to an opacity limit promulgated under 40 C.F.R., Part

60, NSPS, no discharge of greater than 20% opacity is allowed except for:

[OAC 252:100-25]

(a) Short-term occurrences which consist of not more than one six-minute period in any

consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours.

In no case shall the average of any six-minute period exceed 60% opacity;

(b) Smoke resulting from fires covered by the exceptions outlined in OAC 252:100-13-7;

(c) An emission, where the presence of uncombined water is the only reason for failure

to meet the requirements of OAC 252:100-25-3(a); or

(d) Smoke generated due to a malfunction in a facility, when the source of the fuel

producing the smoke is not under the direct and immediate control of the facility and

the immediate constriction of the fuel flow at the facility would produce a hazard to

life and/or property.


(4) No visible fugitive dust emissions shall be discharged beyond the property line on which

the emissions originate in such a manner as to damage or to interfere with the use of

adjacent properties, or cause air quality standards to be exceeded, or interfere with the

maintenance of air quality standards. [OAC 252:100-29]

(5) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2

lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur

dioxide. [OAC 252:100-31]

(6) Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and

with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia

or greater under actual conditions shall be equipped with a permanent submerged fill pipe

or with a vapor-recovery system. [OAC 252:100-37-15(b)]

(7) All fuel-burning equipment shall at all times be properly operated and maintained in a

manner that will minimize emissions of VOCs. [OAC 252:100-37-36]

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A. The permittee shall comply with the following standards for production and consumption of

ozone-depleting substances: [40 CFR 82, Subpart A]

(1) Persons producing, importing, or placing an order for production or importation of certain

class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the

requirements of §82.4;

(2) Producers, importers, exporters, purchasers, and persons who transform or destroy certain

class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping

requirements at §82.13; and

(3) Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons,

HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane

(Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include

HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves an

ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air

conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term

“motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the

vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the

air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger

buses using HCFC-22 refrigerant. [40 CFR 82, Subpart B]

C. The permittee shall comply with the following standards for recycling and emissions

reduction except as provided for MVACs in Subpart B: [40 CFR 82, Subpart F]

(1) Persons opening appliances for maintenance, service, repair, or disposal must comply

with the required practices pursuant to § 82.156;

(2) Equipment used during the maintenance, service, repair, or disposal of appliances must


comply with the standards for recycling and recovery equipment pursuant to § 82.158;

(3) Persons performing maintenance, service, repair, or disposal of appliances must be

certified by an approved technician certification program pursuant to § 82.161;

(4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply

with record-keeping requirements pursuant to § 82.166;

(5) Persons owning commercial or industrial process refrigeration equipment must comply

with leak repair requirements pursuant to § 82.158; and

(6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant

must keep records of refrigerant purchased and added to such appliances pursuant to §

82.166.

SECTION XXI. TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work associated with permit review and, wherever it is

not inconsistent with Federal requirements, to provide for incorporation of requirements

established through construction permitting into the Source’s Title V permit without causing

redundant review. Requirements from construction permits may be incorporated into the Title V

permit through the administrative amendment process set forth in OAC 252:100-8-7.2(a) only if

the following procedures are followed:

(1) The construction permit goes out for a 30-day public notice and comment using the

procedures set forth in 40 C.F.R. § 70.7(h)(1). This public notice shall include notice to

the public that this permit is subject to EPA review, EPA objection, and petition to

EPA, as provided by 40 C.F.R. § 70.8; that the requirements of the construction permit

will be incorporated into the Title V permit through the administrative amendment

process; that the public will not receive another opportunity to provide comments when

the requirements are incorporated into the Title V permit; and that EPA review, EPA

objection, and petitions to EPA will not be available to the public when requirements

from the construction permit are incorporated into the Title V permit.

(2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR §

70.8(a)(1).

(3) A copy of the draft construction permit is sent to any affected State, as provided by 40

C.F.R. § 70.8(b).

(4) A copy of the proposed construction permit is sent to EPA for a 45-day review period

as provided by 40 C.F.R.§ 70.8(a) and (c).

(5) The DEQ complies with 40 C.F.R. § 70.8(c) upon the written receipt within the 45-day

comment period of any EPA objection to the construction permit. The DEQ shall not

issue the permit until EPA’s objections are resolved to the satisfaction of EPA.

(6) The DEQ complies with 40 C.F.R. § 70.8(d).

(7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8(a).

(8) The DEQ shall not issue the proposed construction permit until any affected State and

EPA have had an opportunity to review the proposed permit, as provided by these

permit conditions.

(9) Any requirements of the construction permit may be reopened for cause after

incorporation into the Title V permit by the administrative amendment process, by


DEQ as provided in OAC 252:100-8-7.3(a), (b), and (c), and by EPA as provided in 40

C.F.R. § 70.7(f) and (g).

(10) The DEQ shall not issue the administrative permit amendment if performance tests fail

to demonstrate that the source is operating in substantial compliance with all permit

requirements.

B. To the extent that these conditions are not followed, the Title V permit must go through the

Title V review process.

SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifications or establishing whether or not a person

has violated or is in violation of any provision of the Oklahoma implementation plan, nothing

shall preclude the use, including the exclusive use, of any credible evidence or information,

relevant to whether a source would have been in compliance with applicable requirements if the

appropriate performance or compliance test or procedure had been performed.

[OAC 252:100-43-6]

Mike Fuller, General Manager


5265 Hunt Street

Pryor, OK 74361

Re: Permit No. 2014-2107-TVR2

Application to Add New Core Mixer


Dear Mr. Fuller:

Enclosed is the permit authorizing operation of the referenced facility. Please note that this permit

is issued subject to standard and specific conditions, which are attached. These conditions must be

carefully followed since they define the limits of the permit and will be confirmed by periodic

inspections.

Also note that you are required to annually submit an emission inventory for this facility. An

emission inventory must be completed on approved AQD forms and submitted (hardcopy or

electronically) every year by April 1st. Any questions concerning the form or submittal process

should be referred to the Emission Inventory Staff at (405) 702-4100.

Thank you for your cooperation in this matter. If we may be of further service, please contact

me at (405) 702-4100.

Sincerely,

Phillip Fielder, P.E.

Permits and Engineering Group Manager


Enclosures

Mike Fuller, General Manager


5265 Hunt Street

Pryor, OK 74361

Re: Permit No. 2014-2107-TVR2

Application to Add New Core Mixer


Dear Mr. Fuller:

Air Quality has received the permit application for the referenced facility and completed initial

review. This application has been determined to be a Tier II. In accordance with 27A O.S. 2-14-

301 and 302 and OAC 252:4-7-13(c), the enclosed draft permit is now ready for public review.

The requirements for public review of the draft permit include the following steps, which you

must accomplish.

1. Publish at least one legal notice (one day) in at least one newspaper of general circulation

within the county where the facility is located. (Instructions enclosed)

2. Provide for public review, for a period of 30 days following the date of the newspaper

announcement, a copy of the application and draft permit at a convenient location

(preferentially at a public location) within the county of the facility.

3. Send AQD a signed affidavit of publication for the notice(s) from Item #1 above within 20

days of publication of the draft permit. Any additional comments or requested changes you

have for the draft permit or the application should be submitted within 30 days of

publication.

Thank you for your cooperation in this matter. If we may be of further service, please contact

David Pollard at (918) 293-1617 or by mail at 3105 E. Skelly Drive, Suite 200, Tulsa, OK

74105.

Sincerely,

Phillip Fielder, P.E.



Enclosures

PART 70 PERMIT


STATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY

707 N. ROBINSON, SUITE 4100

P.O. BOX 1677

OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit No. 2014-2107-TVR2


having complied with the requirements of the law, is hereby granted permission to operate

all the sources within the boundaries of their Pryor Foundry located in Mid-America

Industrial Park, near Pryor, Mayes County, Oklahoma,

subject to standard conditions dated June 21, 2016, and specific conditions, both attached.

This permit shall expire five (5) years from the issuance date below, except as authorized

under Section VIII of the Standard Conditions.

_________________________________

Phillip Fielder, P.E. Date


OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY · Initial metal melting is done in the three, 23-ton...

Documents

Transcript of OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY · Initial metal melting is done in the three, 23-ton...