oregon department of environmental quality …

Issued Permit Number: 26-1869-ST-01

Expiration Date: 02/01/2026

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OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY

STANDARD

AIR CONTAMINANT DISCHARGE PERMIT

Northwest Region

700 NE Multnomah St., Suite 600

Portland, OR 97232

This permit is being issued in accordance with the provisions of ORS 468A.040 and based on the

land use compatibility findings included in the permit record.

ISSUED TO:

Columbia Steel Casting Co., Inc.

P.O. Box 83095

Portland, OR 97283

INFORMATION RELIED UPON:

Application No.: 021205

Date Received: 10/25/2004

PLANT SITE LOCATION:

10425 N. Bloss Avenue

Portland, OR 97283

LAND USE COMPATIBILITY FINDING:

Approving Authority: City of Portland

Approval Date: 12/01/1994

ISSUED BY THE DEPARTMENT OF ENVIRONMENTAL QUALITY

_________________________________________________ _______________________

Steven A. Dietrich, Northwest Region Air Quality Manager Date

Source(s) Permitted to Discharge Air Contaminants (OAR 340-216-8010):

Table 1 Code Source Description SIC/NAICS

Part B, 39 Gray iron and steel foundries, malleable iron foundries, steel

investment foundries, steel foundries 100 or more tons/year

metal charged, not elsewhere identified

3325/331513

Steven A. Dietrich (Feb 18, 2021 15:36 PST)Steven A. Dietrich

02/18/2021

https://oregondeq.na2.documents.adobe.com/verifier?tx=CBJCHBCAABAAPfsuTVAi-0mQOYPl8FR-GPDYtI5_5B8P



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TABLE OF CONTENTS

1.0 DEVICE, PROCESS AND POLLUTION CONTROL DEVICE (PCD)

IDENTIFICATION..........................................................................................................................3

2.0 GENERAL EMISSION STANDARDS AND LIMITS .......................................................5 3.0 SPECIFIC PERFORMANCE AND EMISSION STANDARDS ........................................7 4.0 OPERATION AND MAINTENANCE REQUIREMENTS ..............................................15 5.0 PLANT SITE EMISSION LIMITS ....................................................................................17 6.0 COMPLIANCE DEMONSTRATION ...............................................................................17

7.0 SOURCE TESTING ...........................................................................................................20 8.0 RECORDKEEPING REQUIREMENTS ...........................................................................24

9.0 REPORTING REQUIREMENTS ......................................................................................29 10.0 ADMINISTRATIVE REQUIREMENTS ..........................................................................32 11.0 DEQ CONTACTS / ADDRESSES ....................................................................................33 12.0 GENERAL CONDITIONS AND DISCLAIMERS ...........................................................33

13.0 40 CFR 63, SUBPART ZZZZZ, TABLE 3 (LARGE FOUNDRIES) ...............................35 14.0 EMISSION FACTORS .......................................................................................................37 15.0 ABBREVIATIONS, ACRONYMS, AND DEFINITIONS ...............................................41



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1.0 DEVICE, PROCESS AND POLLUTION CONTROL DEVICE

(PCD) IDENTIFICATION

The devices, processes, and pollution control devices regulated by this permit are the following:

Devices and Processes

Description Device ID

Pollution Control Device

Description

PCD

ID

#1 6MT Steel Electric Arc

Furnace #1

41,000 cfm Pangborn Shaker

Baghouse CD #1

#2 10TT Steel Electric Arc

Furnace #1

#3 10TT Manganese Electric Arc

Furnace #2

35,000 cfm National Shaker

Baghouse CD #2

Scrap Prep & Charge Makeup –

Torch Cutting TC

Inductotherm Steel Induction

Furnace, Bldg. #8 (two crucibles

w/one power supply)

None -

Inductotherm Induction Furnace,

Bldg. 11 (two crucibles w/one

power supply)

None -

Main Foundry Sand System

(Mills 1 & 3) #5 20,000 cfm Fuller Reverse Pulse

Baghouse CD #5

Group 8 Sand System (Mill 2) #6 27,000 cfm Wheelabrator Shaker

Baghouse CD #6

Core Room Sand System #9 5,000 cfm Fabric Filters NW Pulse

Jet CD #9

South Foundry Sand System

(Mills 1 & 3) #17 18,000 cfm Fabric Filters NW

Reverse Pulse

CD

#17

Main Foundry Shakeout #3 45,000 cfm Fuller Reverse Pulse

Baghouse CD #3

Group 3 & 6 Sand System (Mill

4) #8 45, 000 cfm Fabric Filters NW

Shaker Baghouse CD #8

National Sand Reclaimer #4 10,000 cfm Fuller Reverse Pulse

Baghouse CD #4

Group 9 Sand Reclaim System #20 20,000 cfm LMC Pulse Jet

Baghouse

CD

#20

SMS Sand Reclaimer #22 4,800 cfm LMC Pulse Jet

Baghouse

CD

#22



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Description

PCD

ID

Sand Dryer at Landfill #23 6,000 cfm Torit Reverse Pulse

Baghouse

CD

#23

Joslyn Burn/Arc #1 #10 15,000 cfm Wheelabrator Shaker

Baghouse

CD

#10

South Foundry Burn/Arc #15 55,000 cfm Wheelabrator Shaker

Baghouse

CD

#15

Joslyn Rotoblast #1 #7 16,000 cfm Pangborn Shaker

Baghouse CD #7

Joslyn Rotoblast #2 #24 6,000 cfm Wheelabrator Shaker

Baghouse

CD

#24

Main Foundry Table Blast and

Blast Room #26 Torit Pulse Jet Baghouse 15,000

cfm

CD

#26

Joslyn Turnblast #16 6,500 cfm US Air Pulse Jet

Baghouse

CD

#16

Joslyn Spinblast #19 5,300 cfm Wheelabrator Shaker

Baghouse

CD

#19

Main Foundry Burn/Weld

#11

#12

#13

American Sheet Metal Baffle

Chambers:

CD #11: 23,000 cfm

CD #12: 15,300 cfm

CD #13: 33,000 cfm

CDs #

11, 12,

13

Pattern Shop PS 15,000 cfm Rotoclone CD

#18

Heat Treat Ovens (13 misc.),

0.35-12 MMBtu/hr

HT1,

HT2A,

HT3,

HT4,

HT5,

HT6,

HT10,

HT12,

HT13,

HT14-1/2,

HT18,

HT20,

HT21

None -

Heat treat Oven #102; 18

MMBtu/hr HT102 None -



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Description

PCD

ID

Core Ovens (3); 0.5-0.75

MMBtu/hr CO1-3 None -

Ladle Heaters (3); 0.6 MMBtu/hr LH1-3 None -

Floor Pouring and Cooling FP&C None -

Casting Painting CP None -

Mold Wash MW flaming off the coatings that

contain alcohol solvent FO

2.0 GENERAL EMISSION STANDARDS AND LIMITS

2.1. Visible Emissions

The permittee must comply with the following visible emission limits from air contaminant

sources other than fugitive emission sources, as applicable. Opacity must be measured as a six-

minute block average using EPA Method 9.

a. Emissions from #5, #11, #12, #13, #15, HT1, TC, #1, #2, #3, #4, #6, #7, #8, #9, #10, #16,

#17, #19, #20, #22, #23, # 24, HT3, HT4, HT5, HT6, HT10, HT12, HT13, HT14-1/2,

HT18, HT21, HT102, PS, #26, HT2A, and HT20 must not equal or exceed 20% opacity.

[OAR 340-208-0110(3)(b), (4) and (7)]

b. Any devices or processes installed, constructed, or modified on or after April 16, 2015

must not equal or exceed 20% opacity. [OAR 340-208-0110(4) and (7)]

2.2. Fugitive Emissions

a. The permittee must take reasonable precautions to prevent fugitive dust emissions from

leaving the property of a source. Reasonable precautions include, but are not limited to:

[OAR 340-208-0210]

i. Using, where possible, water or chemicals for control of dust in the demolition of

existing buildings or structures, construction operations, the grading of roads or

the clearing of land;

ii. Applying water or other suitable chemicals on unpaved roads, materials

stockpiles, and other surfaces which can create airborne dusts;

iii. Enclosing (full or partial) materials stockpiles in cases where application of water

or other suitable chemicals are not sufficient to prevent particulate matter,

including dust, from becoming airborne;

iv. Installing and using hoods, fans, and fabric filters to enclose and vent the handling

of dusty materials;

v. Installing adequate containment during sandblasting or other similar operations;



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vi. Covering, at all times when in motion, open bodied trucks transporting materials

likely to become airborne; and

vii. Promptly removing earth or other material that does or may become airborne from

paved streets.

b. If requested by DEQ, the permittee must:

i. Prepare and submit a fugitive emission control plan within 60 days of the request;

ii. Implement the DEQ approved plan whenever fugitive emissions leave the

property for more than 18 seconds in a six-minute period; and

iii. Keep the plan on site and make the plan available upon request. [OAR 340-208-

0210]

c. In no case may fugitive dust emissions leave the property of a source for a period or

periods totaling more than 18 seconds in a six-minute period. Fugitive emissions must be

measured by EPA method 22 with the minimum observation time of six minutes.

2.3. Particulate Matter Emissions

The permittee must comply with the following particulate matter emission limits. For fuel

burning equipment that burns wood fuel by itself or in combination with any other fuel, emission

results are corrected to 12% CO2. For fuel burning equipment that burns fuels other than wood,

emission results are corrected to 50% excess air.

a. Particulate matter emissions from #1, #26, HT2A, and HT20 must not exceed 0.10 grains

per standard cubic foot. [OAR 340-226-0210(2)(a)(A), (b)(A) and (c)]

b. Particulate matter emissions from #5, #11, #12, #13, #15, HT1, and TC must not exceed

0.15 grains per dry standard cubic foot. [OAR 340-226-0210(2)(a)(A), (b)(A) and (c)]

c. Particulate matter emissions from #2, #3, #4, #6, #7, #8, #9, #10, #16, #17, #19, #20, #22,

#23, # 24, HT3, HT4, HT5, HT6, HT10, HT12, HT13, HT14-1/2, HT18, HT21, HT102,

and PS must not exceed 0.14 grains per dry standard cubic foot. [OAR 340-226-

0210(2)(b)(B)]

d. Non-fugitive particulate matter emissions from processes listed in OAR 340-226-0300

must not exceed the process weight emission standards shown in Table 1 of OAR 340-

226-0310.

e. Particulate matter emissions from any fuel burning equipment (except solid fuel burning

devices that have been certified under OAR 340-262-0500) that is installed, constructed

or modified on or after April 16, 2015 must not exceed 0.10 grains per dry standard cubic

foot, corrected to 12% CO2 or 50% excess air. [OAR 340-228-0210(2)(c)]

f. Particulate matter emissions from any device or process (other than fugitive emissions

sources, fuel burning equipment, refuse burning equipment, or solid fuel burning devices

certified under OAR 340-262-0500) that is installed, constructed or modified after April

16, 2015 must not exceed 0.10 grains per dry standard cubic foot. [OAR 340-226-

0210(2)(c)]



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2.4. Particulate Matter Fallout

The permittee must not cause or permit the deposition of any particulate matter larger than 250

microns in size at sufficient duration or quantity, as to create an observable deposition upon the

real property of another person. [OAR 340-208-0450]

2.5. Nuisance and Odors

The permittee must not cause or allow the emission of odorous or other fugitive emissions so as

to create nuisance conditions off the permittee’s property. Nuisance conditions will be verified

by DEQ personnel. [OAR 340-208-0300]

2.6. Complaint Log

The permittee must maintain a log of all complaints received by the permittee in person, in

writing, by telephone or through other means that specifically refer to air pollution, odor, or

nuisance concerns associated with the permitted facility. Documentation must include: [OAR

340-214-0114]

a. The date the complaint was received;

b. The date and time the complaint states the condition was present;

c. A description of the pollution or odor condition;

d. The location of the complainant/receptor relative to the plant site;

e. The status of plant operation or activities during the complaint’s stated time of pollution

or odor condition; and

f. A record of the permittee’s actions to investigate the validity of each complaint and a

record of actions taken for complaint resolution.

2.7. Fuels and Fuel Sulfur Content

a. The permittee must not use any fuels other than natural gas, propane, butane or No. 2

distillate oil (diesel).

b. The permittee must not use No. 2 distillate oil with more than 0.5% sulfur by weight.

3.0 SPECIFIC PERFORMANCE AND EMISSION STANDARDS

3.1. Baghouse Operation

The permittee must observe the following baghouse operation and maintenance requirements:

a. The permittee must maintain the differential pressure of each fabric/cartridge filter

baghouse within the range observed during the most recent approved performance test or

either the manufacturer’s design specification or equivalent documentation detailing

proper operation and maintenance of the unit if performance testing has not been

conducted.



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b. The permittee must post the differential pressure observed during the most recent valid

performance test or either the manufacturer’s design specification or equivalent

documentation detailing proper operation and maintenance of the unit on each respective

fabric/cartridge filter baghouse at the facility.

c. The permittee must monitor and record the differential pressure of each fabric/cartridge

filter baghouse at least once per day during operation of associated emissions units.

d. The permittee must investigate and commence corrective action measures within 24

hours of an observed excursion of the designed differential pressure range of any

fabric/cartridge filter baghouse.

e. The permittee must correct the problem as soon as practicable, but no later than 10

calendar days from the date of discovery.

f. When replacing fabric/cartridge filters in any baghouse the permittee may not substitute a

filter with lower control efficiency specifications than the bag design relied upon to

establish a related emission factor used in this permit.

3.2. NESHAP Subpart ZZZZZ – Small Foundries

The permittee must comply with all applicable provisions of 40 CFR 63 Subpart ZZZZZ. The

affected source under Subpart ZZZZZ is each iron and steel foundry (refer to 40 CFR 63

Subparts ZZZZZ and/or Subpart A for definitions of terminology stated in these associated

conditions). The following conditions summarize the applicable requirements of Subpart ZZZZZ

for Small Foundries, but are not intended to supersede the Subpart:

a. The permittee must comply with the following requirements of the General Provisions

(40 CFR part 63, subpart A): §63.1 through 63.5; §63.6(a), (b), (c), and (e)(1); §63.9;

§63.10(a), (b)(1), (b)(2)(xiv), (b)(3), (d)(1), (d)(4), and (f); and §63.13 through 63.16.

Requirements of the General Provisions not cited in the preceding sentence do not apply

to the owner or operator of a new or existing affected source that is classified as a small

foundry. [40 CFR 63.10890(i)]

b. Metallic scrap management program. For each segregated metallic scrap storage area,

bin or pile, the permittee must comply with the materials acquisition requirements in this

condition. A copy of the material specifications must be kept onsite and readily available

to all personnel with material acquisition duties, and a copy must be provided to each

scrap provider. [40 CFR 63.10885(a)]

i. Restricted metallic scrap. The permittee must prepare and operate at all times

according to written material specifications for the purchase and use of only metal

ingots, pig iron, slitter, or other materials that do not include post-consumer

automotive body scrap, post-consumer engine blocks, post-consumer oil filters,

oily turnings, lead components, chlorinated plastics, or free liquids. For the

purpose of this condition, “free liquids” is defined as material that fails the paint

filter test by EPA Method 9095B, “Paint Filter Liquids Test” (revision 2),

November 2004 (incorporated by reference—see §63.14). The requirements for

no free liquids do not apply if the owner or operator can demonstrate that the free

liquid is water that resulted from scrap exposure to rain.

ii. General iron and steel scrap. The permittee must prepare and operate at all times

according to written material specifications for the purchase and use of only iron

and steel scrap that has been depleted (to the extent practicable) of organics and

HAP metals in the charge materials used by the iron and steel foundry.



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The materials specifications must include specifications for metallic scrap

materials charged to a scrap preheater or metal melting furnace to be depleted (to

the extent practicable) of the presence of used oil filters, chlorinated plastic parts,

accessible lead-containing components (such as batteries and wheel weights), and

a program to ensure the scrap materials are drained of free liquids.

c. Mercury requirements. [40 CFR 63.10885(b)]

i. The permittee must maintain records that document its procured scrap does not

contain motor vehicle scrap and is not subject to Subpart ZZZZZ mercury

management requirements or that the only materials from motor vehicles in the

scrap are materials recovered for their specialty alloy content (including, but not

limited to, chromium, nickel, molybdenum, or other alloys) and, based on the

nature of the scrap and purchase specifications, the scrap is not reasonably

expected to contain mercury switches.

ii. The permittee is prohibited from accepting and using other motor vehicle scrap

that does not meet the description in Condition 3.2.c.i above.

d. The permittee must use a binder chemical formulation that does not use methanol as a

specific ingredient of the catalyst formulation for each furfuryl alcohol warm box mold or

core making line. This requirement does not apply to the resin portion of the binder

system. [40 CFR 63.10886]

3.3. NESHAP Subpart ZZZZZ – Large Foundries

The affected source under Subpart ZZZZZ is each iron and steel foundry (refer to 40 CFR 63

Subparts ZZZZZ and/or Subpart A for definitions of terminology stated in these associated

conditions). The following conditions summarize the applicable requirements of Subpart ZZZZZ

for Large Foundries, but are not intended to supersede the Subpart:

a. If the annual metal melt production exceeds 20,000 tons during the preceding year, the

permittee must comply with the following requirements for large foundries by the

applicable dates in Condition 9.2.c. [40 CFR 63.10890(h)]

b. See Condition 13.0. for reference/guidance to the applicability of the General Provisions

to Subpart ZZZZZ for large foundries.

c. The permittee must not discharge to the atmosphere emissions from any metal melting

furnace or group of all metal melting furnaces that exceed 0.8 pounds of particulate

matter (PM) per ton of metal charged or 0.06 pounds of total metal HAP per ton of metal

charged. [40 CFR 63.10895(c)]

d. The permittee must not discharge to the atmosphere fugitive emissions from foundry

operations that exhibit opacity greater than 20 percent (6-minute average), except for one

6-minute average per hour that does not exceed 30 percent. [40 CFR 63.10895(e)]

e. The permittee must comply with the requirements for a large foundry for at least 3 years

before reclassifying as a small foundry, even if annual metal melt production falls below

20,000 tons. After 3 years, the permittee may reclassify your facility as a small foundry

provided the annual metal melt production for the preceding calendar year was 20,000

tons or less. If the permittee reclassifies a large foundry as a small foundry, the permittee

must submit a notification of reclassification to the Administrator within 30 days and

comply with the requirements for a small foundry no later than the date of notifying the

Administrator of the reclassification. If the annual metal melt production exceeds 20,000

tons during a subsequent year,



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the permittee must submit a notification of reclassification to the Administrator within 30

days and comply with the requirements for a large foundry no later than the date of

notifying the Administrator of the reclassification. [40 CFR 63.10881(d)(2)]

f. Metallic scrap management program. For each segregated metallic scrap storage area,

bin or pile, the permittee must comply with the materials acquisition requirements in this

condition. A copy of the material specifications must be kept onsite and readily available

to all personnel with material acquisition duties, and a copy must be provided to each

scrap provider. [40 CFR 63.10885(a)]

i. Restricted metallic scrap. The permittee must prepare and operate at all times

according to written material specifications for the purchase and use of only metal

ingots, pig iron, slitter, or other materials that do not include post-consumer

automotive body scrap, post-consumer engine blocks, post-consumer oil filters,

oily turnings, lead components, chlorinated plastics, or free liquids. For the

purpose of this condition, “free liquids” is defined as material that fails the paint

filter test by EPA Method 9095B, “Paint Filter Liquids Test” (revision 2),

November 2004 (incorporated by reference—see §63.14). The requirements for

no free liquids do not apply if the owner or operator can demonstrate that the free

liquid is water that resulted from scrap exposure to rain.

ii. General iron and steel scrap. The permittee must prepare and operate at all times

according to written material specifications for the purchase and use of only iron

and steel scrap that has been depleted (to the extent practicable) of organics and

HAP metals in the charge materials used by the iron and steel foundry. The

materials specifications must include specifications for metallic scrap materials

charged to a scrap preheater or metal melting furnace to be depleted (to the extent

practicable) of the presence of used oil filters, chlorinated plastic parts, accessible

lead-containing components (such as batteries and wheel weights), and a program

to ensure the scrap materials are drained of free liquids.

g. Mercury requirements. [40 CFR 63.10885(b)]

i. The permittee must maintain records that document its procured scrap does not

contain motor vehicle scrap and is not subject to Subpart ZZZZZ mercury

management requirements or that the only materials from motor vehicles in the

scrap are materials recovered for their specialty alloy content (including, but not

limited to, chromium, nickel, molybdenum, or other alloys) and, based on the

nature of the scrap and purchase specifications, the scrap is not reasonably

expected to contain mercury switches.

ii. The permittee is prohibited from accepting and using other motor vehicle scrap

that does not meet the description in Condition 3.3.g.i above.

h. The permittee must use a binder chemical formulation that does not use methanol as a

specific ingredient of the catalyst formulation for each furfuryl alcohol warm box mold or

core making line. This requirement does not apply to the resin portion of the binder

system. [40 CFR 63.10886]

i. The permittee must operate a capture and collection system for each metal melting

furnace unless that furnace is specifically uncontrolled as part of an emissions averaging

group. Each capture and collection system must meet accepted engineering standards,

such as those published by the American Conference of Governmental Industrial

Hygienists. [40 CFR 63.10895(b)]



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j. The permittee must prepare and operate at all times according to a written operation and

maintenance (O&M) plan for each control device for an emissions source subject to a

PM, metal HAP, or opacity emissions limit in Conditions 3.3.c and 3.3.d. The permittee

must maintain a copy of the O&M plan at the facility and make it available for review

upon request. At a minimum, each plan must contain the following information: [40 CFR

63.10896(a)]

i. General facility and contact information;

ii. Positions responsible for inspecting, maintaining, and repairing emissions control

devices which are used to comply with this subpart;

iii. Description of items, equipment, and conditions that will be inspected, including

an inspection schedule for the items, equipment, and conditions. For baghouses

that are equipped with bag leak detection systems, the O&M plan must include

the site-specific monitoring plan required in Condition 3.3.m.ii.

iv. Identity and estimated quantity of the replacement parts that will be maintained in

inventory; and

k. The permittee may use any other O&M, preventative maintenance, or similar plan which

addresses the requirements in Condition 3.3.j of this section to demonstrate compliance

with the requirements for an O&M plan. [40 CFR 63.10896(b)]

l. The permittee must conduct an initial inspection of each PM control device for a metal

melting furnace at an existing affected source. The permittee must conduct each initial

inspection no later than 60 days after the applicable compliance date for each installed

control device which has been operated within 60 days of the compliance date. For an

installed control device which has not operated within 60 days of the compliance date,

the permittee must conduct an initial inspection prior to startup of the control device.

Following the initial inspections, the permittee must perform periodic inspections and

maintenance of each PM control device for a metal melting furnace at an existing

affected source. Initial and periodic inspections must be performed according to the

requirements in this condition. The permittee must record the results of each initial and

periodic inspection and any maintenance action in the logbook required in Condition

8.6.b.xi. [40 CFR 63.10897(a)]

i. For the initial inspection of each baghouse, the permittee must visually inspect the

system ductwork and baghouse units for leaks and must also inspect the inside of

each baghouse for structural integrity and fabric filter condition. Following the

initial inspections, each baghouse must be inspected and maintained according to

the following requirements:

A. Conduct monthly visual inspections of the system ductwork for leaks.

B. Conduct inspections of the interior of the baghouse for structural integrity

and to determine the condition of the fabric filter every 6 months.

ii. For the initial inspection of each dry electrostatic precipitator, the permittee must

verify the proper functioning of the electronic controls for corona power and

rapper operation, that the corona wires are energized, and that adequate air

pressure is present on the rapper manifold. The permittee must also visually

inspect the system ductwork and electrostatic housing unit and hopper for leaks

and inspect the interior of the electrostatic precipitator to determine the condition

and integrity of corona wires, collection plates, hopper, and air diffuser plates.



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Following the initial inspection, the permittee must inspect and maintain each dry

electrostatic precipitator according to the following requirements:

A. Conduct a daily inspection to verify the proper functioning of the

electronic controls for corona power and rapper operation, that the corona

wires are energized, and that adequate air pressure is present on the rapper

manifold.

B. Conduct monthly visual inspections of the system ductwork, housing unit,

and hopper for leaks.

C. Conduct inspections of the interior of the electrostatic precipitator to

determine the condition and integrity of corona wires, collection plates,

plate rappers, hopper, and air diffuser plates every 24 months.

iii. For the initial inspection of each wet electrostatic precipitator, the permittee must

verify the proper functioning of the electronic controls for corona power, that the

corona wires are energized, and that water flow is present. The permittee must

also visually inspect the system ductwork and electrostatic precipitator housing

unit and hopper for leaks and inspect the interior of the electrostatic precipitator to

determine the condition and integrity of corona wires, collection plates, plate

wash spray heads, hopper, and air diffuser plates. Following the initial inspection,

the permittee must inspect and maintain each wet electrostatic precipitator

according to the following requirements:

A. Conduct a daily inspection to verify the proper functioning of the

electronic controls for corona power, that the corona wires are energized,

and that water flow is present.

B. Conduct monthly visual inspections of the system ductwork, electrostatic

precipitator housing unit, and hopper for leaks.

C. Conduct inspections of the interior of the electrostatic precipitator to

determine the condition and integrity of corona wires, collection plates,

plate wash spray heads, hopper, and air diffuser plates every 24 months.

iv. For the initial inspection of each wet scrubber, the permittee must verify the

presence of water flow to the scrubber. The permittee must also visually inspect

the system ductwork and scrubber unit for leaks and inspect the interior of the

scrubber for structural integrity and the condition of the demister and spray

nozzle. Following the initial inspection, the permittee must inspect and maintain

each wet scrubber according to the following requirements:

A. Conduct a daily inspection to verify the presence of water flow to the

scrubber.

B. Conduct monthly visual inspections of the system ductwork and scrubber

unit for leaks.

C. Conduct inspections of the interior of the scrubber to determine the

structural integrity and condition of the demister and spray nozzle every

12 months.



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m. The permittee may install, operate, and maintain a bag leak detection system for each

negative pressure baghouse or positive pressure baghouse as an alternative to the

baghouse inspection requirements in Condition 3.3.l.i. Each bag leak detection system

must be installed, operated, and maintained according to the following requirements: [40

CFR 63.10897(d)]

i. Each bag leak detection system must meet the following requirements:

A. The system must be certified by the manufacturer to be capable of

detecting emissions of particulate matter at concentrations of 10

milligrams per actual cubic meter (0.00044 grains per actual cubic foot) or

less.

B. The bag leak detection system sensor must provide output of relative

particulate matter loadings and the owner or operator shall continuously

record the output from the bag leak detection system using a strip chart

recorder, data logger, or other means.

C. The system must be equipped with an alarm that will sound when an

increase in relative particulate loadings is detected over the alarm set point

established in the operation and maintenance plan, and the alarm must be

located such that it can be heard by the appropriate plant personnel.

D. The initial adjustment of the system must, at minimum, consist of

establishing the baseline output by adjusting the sensitivity (range) and the

averaging period of the device, and establishing the alarm set points. If the

system is equipped with an alarm delay time feature, you also must adjust

the alarm delay time.

E. Following the initial adjustment, do not adjust the sensitivity or range,

averaging period, alarm set point, or alarm delay time. Except, once per

quarter, the permittee may adjust the sensitivity of the bag leak detection

system to account for seasonable effects including temperature and

humidity according to the procedures in the monitoring plan required by

Condition 3.3.m.ii.

F. For negative pressure baghouses, induced air baghouses, and positive

pressure baghouses that are discharged to the atmosphere through a stack,

the bag leak detector sensor must be installed downstream of the baghouse

and upstream of any wet scrubber.

G. Where multiple detectors are required, the system's instrumentation and

alarm may be shared among detectors.

ii. The permittee must prepare a site-specific monitoring plan for each bag leak

detection system to be incorporated in the permittee’s O&M plan. The permittee

must operate and maintain each bag leak detection system according to the plan at

all times. Each plan must address all of the following items:

A. Installation of the bag leak detection system.



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B. Initial and periodic adjustment of the bag leak detection system including

how the alarm set-point will be established.

C. Operation of the bag leak detection system including quality assurance

procedures.

D. Maintenance of the bag leak detection system including a routine

maintenance schedule and spare parts inventory list.

E. How the bag leak detection system output will be recorded and stored.

F. Procedures for determining what corrective actions are necessary in the

event of a bag leak detection alarm as required in Condition 3.3.m.iii.

iii. In the event that a bag leak detection system alarm is triggered, the permittee must

initiate corrective action to determine the cause of the alarm within 1 hour of the

alarm, initiate corrective action to correct the cause of the problem within 24

hours of the alarm, and complete corrective action as soon as practicable, but no

later than 10 calendar days from the date of the alarm. Record the date and time of

each valid alarm, the time corrective action was initiated, the correction action

taken, and the date on which corrective action was completed. Corrective actions

may include, but are not limited to:

A. Inspecting the bag house for air leaks, torn or broken bags or filter media,

or any other condition that may cause an increase in emissions.

B. Sealing off defective bags or filter media.

C. Replacing defective bags or filter media or otherwise repairing the control

device.

D. Sealing off a defective baghouse department.

E. Cleaning the bag leak detection system probe, or otherwise repairing the

bag leak detection system.

F. Shutting down the process producing the particulate emissions.

n. The permittee must make monthly inspections of the equipment that is important to the

performance of the total capture system (i.e., pressure sensors, dampers, and damper

switches). This inspection must include observations of the physical appearance of the

equipment (e.g., presence of holes in the ductwork or hoods, flow constrictions caused by

dents or accumulated dust in the ductwork, and fan erosion). The permittee must repair

any defect or deficiency in the capture system as soon as practicable, but no later than 90

days and must record the date and results of each inspection and the date of repair of any

defect or deficiency. [40 CFR 63.10897(e)]

o. The permittee must install, operate, and maintain each CPMS or other measurement

device according to the permittee’s O&M plan. The permittee must record all information

needed to document conformance with these requirements. [40 CFR 63.10897(f)]

p. In the event of an exceedance of an established emissions limitation (including an

operating limit), the permittee must restore operation of the emissions source (including

the control device and associated capture system) to its normal or usual manner or



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operation as expeditiously as practicable in accordance with good air pollution control

practices for minimizing emissions. The response shall include minimizing the period of

any startup, shutdown or malfunction and taking any necessary corrective actions to

restore normal operation and prevent the likely recurrence of the exceedance. The

permittee must record the date and time correction action was initiated, the correction

action taken, and the date corrective action was completed. [40 CFR 63.10897(g)]

q. If the permittee chooses to comply with an emissions limit in Condition 3.3.c. using

emissions averaging, the permittee must calculate and record for each calendar month the

pounds of PM or total metal HAP per ton of metal melted from the group of all metal

melting furnaces at the foundry. The permittee must calculate and record the weighted

average pounds per ton emissions rate for the group of all metal melting furnaces at the

foundry determined from the performance test procedures in Conditions 7.2.d and 7.2.e.

[40 CFR 63.10897(h)]

r. The permittee may change the operating limits for a wet scrubber, electrostatic

precipitator, or baghouse if the permittee meet the following requirements. [40 CFR

63.10898(l)]

i. Submit a written notification to the Administrator of a plan to conduct a new

performance test to revise the operating limit.

ii. Conduct a performance test to demonstrate compliance with the applicable

emissions limitation in Condition 3.3.c.

iii. Establish revised operating limits according to the applicable procedures in Table

2 to 40 CFR 63 Subpart ZZZZZ.

3.4. NESHAP Subpart CCCCCC – Gasoline Dispensing Facilities

The permittee may be subject to the federal regulations in 40 CFR Part 63 Subpart CCCCCC for

gasoline dispensing activities. The Environmental Quality Commission has not adopted or

incorporated these requirements in Oregon Administrative Rules, and are therefore, only

enforceable by the United States Environmental Protection Agency.

4.0 OPERATION AND MAINTENANCE REQUIREMENTS

4.1. Operation of Pollution Control Devices and Processes

The permittee must operate and ensure proper functioning of all air pollution control devices and

components at all times when the associated emission source is operating. [OAR 340-226-0120]

4.2. Surface Coating Restriction

The permittee is prohibited from using surface coatings that contain compounds of chromium,

lead, manganese, nickel, and/or cadmium.



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4.3. Gasoline Dispensing Facilities

a. The permittee must not allow gasoline to be handled in a manner that would result in

vapor releases to the atmosphere for extended periods of time. Measures to be taken

include, but are not limited to the following: [40 CFR 63.11116(a), (b), (d) and OAR

340-244-0240]

i. Minimize gasoline spills;

ii. Clean up spills as expeditiously as practicable;

iii. Cover all open gasoline containers and all gasoline storage tank fill-pipes with a

gasketed seal when not in use;

iv. Do not top off or overfill vehicle tanks;

v. Post a sign at the gasoline dispensing facility instructing a person filling up a

motor vehicle to not top off the vehicle tank;

vi. Minimize gasoline sent to open waste collection systems that collect and transport

gasoline to reclamation and recycling devices, such as oil/water separators.

vii. Ensure cargo tanks unloading at the gasoline dispensing facility comply with the

requirements of Condition 4.3.a; and

viii. Portable gasoline containers that meet the requirements of 40 CFR Part 59,

subpart F, are considered acceptable for compliance with Condition 4.3.a.iii.

b. Except for gasoline storage tanks with a capacity of less than 250 gallons, the permittee

must only load gasoline into storage tanks at the facility utilizing submerged filling as

follows:

i. Submerged fill pipes installed on or before Nov. 9, 2006, must be no more than 12

inches from the bottom of the storage tank.

ii. Submerged fill pipes installed after Nov. 9, 2006, must be no more than 6 inches

from the bottom of the storage tank.

c. The applicable distances above must be measured from the point in the opening of the

submerged fill pipe that is the greatest distance from the bottom of the storage tank.

4.4. Highest and Best Practicable Treatment and Control

The permittee must provide the highest and best practicable treatment and control of air

contaminant emissions in every case so as to maintain overall air quality at the highest possible

levels, and to maintain contaminant concentrations, visibility reduction, odors, soiling, and other

deleterious factors at the lowest possible levels as provided below. [OAR 340-226-0100]

a. The permittee must not conduct any oxygen lancing on the #3 10TT Manganese Electric

Arc Furnace except when utilizing additional control equipment with prior written

approval of the Department.

b. The permittee must not backcharge in any electric arc furnace.

c. The permittee must, during tapping of either #1 6MT or #2 10TT Electric Arc Furnaces

shut the melting power off on both furnaces and divert all collection capacity (41,000

cfm) to the furnace collection hood.



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5.0 PLANT SITE EMISSION LIMITS

5.1. Plant Site Emission Limits (PSEL)

The permittee must not cause or allow plant site emissions to exceed the following: [OAR 340-

222-0040 and/or OAR 340-222-0041, OAR 340-222-0060]

Pollutant Limit Units

PM 42

tons per year

PM10 28

PM2.5 19

NOX 39

CO 99

VOC 72

GHGs (CO2e) 87,000

5.2. Annual Period

The annual plant site emissions limits apply to any 12-consecutive calendar month period. [OAR

340-222-0035]

6.0 COMPLIANCE DEMONSTRATION

6.1. Monitoring Requirements

The permittee must monitor the operation and maintenance of the facility and associated air

contaminant control devices as follows: [OAR 340-226-0120]

a. Quantity (tons) of metal melted in the #1 6MT and #2 10TT steel EAFs.

b. Quantity (tons) of metal melted in the #3 10TT manganese EAF.

c. Quantity (tons) of metal melted in the induction furnaces (Building #8 and 11).

d. Quantity (tons) of sand throughput for the Main Foundry Sand System (Mills 1 & 3).

e. Quantity (tons) of sand throughput for the Group 8 Sand System (Mill 2).

f. Quantity (tons) of sand throughput for the Core Room Sand system.

g. Quantity (tons) of sand throughput for the South Foundry Sand System (Mills 1 & 3).

h. Quantity (tons) of sand throughput for the Main Foundry Shakeout.

i. Quantity (tons) of sand throughput for the Group 3 & 6 Sand System (Mill 4).

j. Quantity (tons) of sand throughput for the National Sand Reclaimer.



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k. Quantity (tons) of sand throughput for the Group 9 Sand Reclaim system.

l. Quantity (tons) of sand throughput for the SMS Sand Reclaimer.

m. Quantity (tons) of sand processed through the Sand Dryer at Landfill.

n. Quantity (tons) of steel processed through the Joslyn Burn Arc #1.

o. Quantity (tons) of steel processed through the South Foundry Burn/Arc.

p. Quantity (tons) of steel processed through the Joslyn Rotoblast #1.

q. Quantity (tons) of steel processed through the Joslyn Rotoblast #2.

r. Quantity (tons) of steel processed through the Main Foundry Rotoblast.

s. Quantity (tons) of steel processed through the Joslyn Turnblast.

t. Quantity (tons) of steel processed through the Joslyn Spinblast.

u. Quantity (tons) of steel processed through the Main Foundry Rotoblast Room.

v. Quantity (tons) of steel processed through the Main Foundry Burn/Weld.

w. Number of patterns produced by the Pattern Shop.

x. Quantity of fuel combusted (MMft3 for gaseous fuels and gal for liquid fuels).

y. Name and quantity (pounds or gallons) of each coating/solvent used.

z. Name and quantity (pounds or gallons) of each mold/core wash used.

aa. Name and quantity of each coating, solvent, and mold/core wash shipped off site.

bb. If the permittee uses the Alternative PM PSEL Compliance methodology of Condition

6.3.; Quantity of PM captured by the respective control device (in lbs). If, based on

source operations, monthly PM capture monitoring is not feasible, monitoring may be

performed on an alternate schedule and the determined emission rate extrapolated to a

monthly value.

6.2. PSEL Compliance Monitoring using Emission Factors

The permittee must calculate the emissions for each 12-consecutive calendar month period based

on the following calculation for each pollutant except GHGs: [OAR 340-222-0080]

E = (EF * P) / 2000 pounds

where:

E = pollutant emissions (tons/year);

= symbol representing “summation of”;

EF = pollutant emission factor (see Condition 14.0);

P = process throughput (e.g., metal melted, natural gas combusted)

6.3. Alternative PM PSEL Compliance Monitoring

For any process controlled by a PM control device (e.g., baghouse, filter, rotoclone), the

permittee may demonstrate compliance with the PSEL for each 12-consecutive calendar month

period based on the following calculation for PM, PM10, and PM2.5:

E = (MC * 0.01) / 2000 pounds



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where:

E = pollutant emissions (tons/year);

MC = Mass captured by PM control device (lbs/yr);

0.01 = 1 – Control efficiency (99%)

6.4. PSEL Compliance Monitoring: VOC Emissions

The permittee must demonstrate compliance with the annual VOC PSEL for each 12 consecutive

calendar month period based on the following formula:

EVOC-A= (EVOC-M)

EVOC-M= EVOC-CB + EVOC-CS

EVOC-CS= [(CX * DX * KX) – W] / 2,000

EVOC-CB= [(EFX * TX)] / 2,000 where:

EVOC-A = Annual VOC emissions in tons

EVOC-M = Monthly VOC emissions in tons

EVOC-CS= Monthly VOC emissions from coatings, cleaners, solvents, and other

liquids in tons

EVOC-CB= Monthly VOC emissions from combustion and furnaces in tons

C = Material usage for the period in gallons

D = Material density in pounds per gallon

K = VOC concentration expressed as a decimal

X = Subscript X represents a specific material

W = Weight of VOC shipped offsite in pounds

EF = Emission factor (see Condition 14.0)

T = Throughput (e.g., metal melted, natural gas combusted)

6.5. Emission Factors

The permittee must use the default emission factors provided in Condition 14.0 for calculating

pollutant emissions, unless alternative emission factors are approved in writing by DEQ. The

permittee may request or DEQ may require using alternative emission factors provided they are

based on actual test data or other documentation (e.g., AP-42 compilation of emission factors)

that has been reviewed and approved by DEQ. [OAR 340-222-0080]

6.6. Greenhouse Gas Emissions

The permittee must calculate greenhouse gas emissions in metric tons and short tons for each 12-

consecutive calendar month period to determine compliance with the GHG PSEL by using the

following: [OAR 340-215-0040]

a. DEQ Fuel Combustion Greenhouse Gas Calculator

https://www.oregon.gov/deq/FilterDocs/ghgCalculatorFuelCombust.xlsx;

b. EPA emission quantification methodologies as prescribed in 40 CFR Part 98 subparts E

through UU; and

https://www.oregon.gov/deq/FilterDocs/ghgCalculatorFuelCombust.xlsx



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c. https://ccdsupport.com/confluence/display/help/Optional+Calculation+Spreadsheet+Instr

uctions.

6.7. PSEL Compliance Monitoring

The permittee must demonstrate compliance with the PSEL by totaling the emissions from all

point sources calculated under Conditions 6.2, 6.3, 6.4, and 6.6. [OAR 340-222-0080]

7.0 SOURCE TESTING

7.1. Source Testing Requirements

The permittee must perform the following source tests within 18 months of permit issuance

unless an extension is approved by DEQ: [OAR 340-212-0120]

a. the permittee must conduct a source test of the three Electric Arc Furnaces (#1 6MT Steel

Electric Arc Furnace, #2 10TT Steel Electric Arc Furnace, and #3 10TT Manganese

Electric Arc Furnace) to verify emission factors used to determine compliance with the

PSELs of Condition 5.1 for Particulate Matter, PM10, PM2.5, NOx, and CO and must test

these units for As, Cr, Pb, Ni, and Mn emissions using the following test methods and

procedures:

b. DEQ approved testing conducted after July 1, 2020, may satisfy the testing requirements

of this permit.

c. The permittee must perform oxygen lancing on the #1 6MT and #2 10TT Electric Arc

Furnaces during the performance test.

d. During the source test, the following parameters must be monitored and recorded:

i. Visible emissions as measured by EPA Method 9 for a period of at least six

minutes during or within 30 minutes before or after each test run;

ii. Quantity of metal melted;

iii. Baghouse pressure differential

iv. Times that oxygen lancing occurs in the #1 6MT and #2 10TT Electric Arc

Furnaces; and

v. Oxygen flow for each oxygen lancing event in the #1 6MT and #2 10TT Electric

Arc Furnaces.

e. All tests must be conducted in accordance with DEQ’s Source Sampling Manual and the

approved source test plan. The source test plan must be submitted at least 30 days in

advance and approved by the Regional Source Test Coordinator. The source test report

must be submitted to the Regional Source Test Coordinator within 60 days of the test

unless otherwise approved in the source test plan.

Tested Pollutant Reference Test Method*

PM See Condition 7.1.f

NOx EPA Method 7E

https://ccdsupport.com/confluence/display/help/Optional+Calculation+Spreadsheet+Instructions

https://ccdsupport.com/confluence/display/help/Optional+Calculation+Spreadsheet+Instructions



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Tested Pollutant Reference Test Method*

CO EPA Method 10 but the test must include quality

assurance from EPA Method 7E

As, Cr, Pb, Ni,

and Mn EPA Method 29

Opacity EPA Method 9

*Substitution of alternative test methods must be pre-approved by the DEQ.

f. For particulate matter, PM10, and PM2.5, the permittee must use:

i. Oregon Method 5 or

ii. EPA 201 or 201A for front-half, filterable particulate matter and EPA Method

202 for back-half, condensable particulate matter. The sample-volume

requirements of the Department’s Source Sampling Manual for Method 5 apply to

Methods 201 and 201A as well.

iii. The minimum sample-mass requirements in Method 5I apply separately to the

front and back half samples instead of the Manual’s sample-volume requirements.

If performing Oregon Method 5, adopt all procedures and quality assurance in

Method 5I, applying the requirements for acetone to the other solvents, water and

methylene chloride. For emission-factor verification, the minimum sample mass

requirement applies at the level of the permit’s current, applicable emission factor

for reporting emissions instead of half the emission limit.

g. Only regular operating staff may adjust the combustion system or production processes

and emission control parameters during the source test and within two hours prior to the

source test. Any operating adjustments made during the source test, which are a result of

consultation with source testing personnel, equipment vendors or consultants, may render

the source test invalid.

7.2. NESHAP Subpart ZZZZZ – Large Foundries

If the annual metal melt production exceeds 20,000 tons during the preceding year, the permittee

must comply with the following requirements for large foundries by the applicable dates in

Condition 9.2.c. [40 CFR 63.10890(h)] The following conditions summarize the applicable

compliance demonstration requirements of 40 CFR Subpart ZZZZZ for Large Foundries, but are

not intended to supersede the Subpart:

a. The permittee must conduct a performance test to demonstrate initial compliance with the

applicable emissions limits for each metal melting furnace or group of all metal melting

furnaces that is subject to an emissions limit in Condition 3.3.c and for each building or

structure housing foundry operations that is subject to the opacity limit for fugitive

emissions in Condition 3.3.d. The test must be conducted within 180 days of the

compliance date and results must be reported in the notification of compliance status. [40

CFR 63.10898(a)]

i. The permittee may choose to submit the results of a prior performance test for PM

or total metal HAP that demonstrates compliance with the applicable emissions

limit for a metal melting furnace or group of all metal melting furnaces provided

the test was conducted within the last 5 years using the methods and procedures

specified in this condition and either no process changes have been made since



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the test, or it can be demonstrated that the results of the performance test, with or

without adjustments, reliably demonstrate compliance with the applicable

emissions limit despite such process changes.

ii. If the permittee chooses to submit the results of a prior performance test

according to Condition 7.2.a.i of this section, the permittee must submit a written

notification to the Administrator of intent to use the previous test data no later

than 60 days after the compliance date. The notification must contain a full copy

of the performance test and contain information to demonstrate, if applicable, that

either no process changes have been made since the test, or that the results of the

performance test, with or without adjustments, reliably demonstrate compliance

despite such process changes.

iii. If the permittee has an electric induction furnace equipped with an emissions

control device at an existing foundry, the permittee may use the test results from

another electric induction furnace to demonstrate compliance with the applicable

PM or total metal HAP emissions limit in Condition3.3.c provided the furnaces

are similar with respect to the type of emission control device that is used, the

composition of the scrap charged, furnace size, and furnace melting temperature.

iv. If the permittee has an uncontrolled electric induction furnace at an existing

foundry, the permittee may use the test results from another electric induction

furnace to demonstrate compliance with the applicable PM or total metal HAP

emissions limit in Condition 3.3.c provided the test results are prior to any control

device and the electric induction furnaces are similar with respect to the

composition of the scrap charged, furnace size, and furnace melting temperature.

v. For electric induction furnaces that do not have emission capture systems, the

permittee may install a temporary enclosure for the purpose of representative

sampling of emissions. A permanent enclosure and capture system is not required

for the purpose of the performance test.

b. The permittee must conduct subsequent performance tests to demonstrate compliance

with all applicable PM or total metal HAP emissions limits in Condition 3.3.c for a metal

melting furnace or group of all metal melting furnaces no less frequently than every 5

years and each time the permittee elects to change an operating limit or make a process

change likely to increase HAP emissions. [40 CFR 63.10898(b)]

c. The permittee must conduct each performance test according to the requirements in 40

CFR 63.7(e)(1), Table 1, and Conditions 7.2.d through 7.2.g. [40 CFR 63.10898(c)]

d. To determine compliance with the applicable PM or total metal HAP emissions limit in

3.3.c for a metal melting furnace in a lb/ton of metal charged format, compute the

process-weighted mass emissions (Ep) for each test run using the following equation: [40

CFR 63.10898(d)]

Where:

Ep = Process-weighted mass emissions rate of PM or total metal HAP, pounds of PM or total metal HAP per ton

(lb/ton) of metal charged;

C = Concentration of PM or total metal HAP measured during performance test run, grains per dry standard cubic foot

(gr/dscf);

Q = Volumetric flow rate of exhaust gas, dry standard cubic feet per hour (dscf/hr);

T = Total time during a test run that a sample is withdrawn from the stack during melt production cycle, hr;

P = Total amount of metal charged during the test run, tons; and



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K = Conversion factor, 7,000 grains per pound.

e. To determine compliance with the applicable emissions limit in Condition 3.3.c for a

group of all metal melting furnaces using emissions averaging: [40 CFR 63.10898(e)]

i. Determine and record the monthly average charge rate for each metal melting

furnace at your iron and steel foundry for the previous calendar month; and

ii. Compute the mass-weighted PM or total metal HAP using the following equation

Where:

EC = The mass-weighted PM or total metal HAP emissions for the group of all metal melting furnaces at the

foundry, pounds of PM or total metal HAP per ton of metal charged;

Epi = Process-weighted mass emissions of PM or total metal HAP for individual emission unit i as determined

from the performance test and calculated using Equation 1 of this section, pounds of PM or total metal HAP

per ton of metal charged;

Tti = Total tons of metal charged for individual emission unit i for the calendar month prior to the

performance test, tons; and

n = The total number of metal melting furnaces at the iron and steel foundry.

iii. For an uncontrolled electric induction furnace that is not equipped with a capture

system and has not been previously tested for PM or total metal HAP, the

permittee may assume an emissions factor of 2 pounds per ton of PM or 0.13

pounds of total metal HAP per ton of metal melted in Equation 2 of this section

instead of a measured test value. If the uncontrolled electric induction furnace is

equipped with a capture system, the permittee must use a measured test value.

f. To determine compliance with the applicable PM or total metal HAP emissions limit for

a metal melting furnace in Condition 3.3.c when emissions from one or more regulated

furnaces are combined with other non-regulated emissions sources, the permittee may

demonstrate compliance using the procedures below: [40 CFR 63.10898(f)]

i. Determine the PM or total metal HAP process-weighted mass emissions for each

of the regulated streams prior to the combination with other exhaust streams or

control device.

ii. Measure the flow rate and PM or total metal HAP concentration of the combined

exhaust stream both before and after the control device and calculate the mass

removal efficiency of the control device using the following equation.

Where:

Ei = Mass emissions rate of PM or total metal HAP at the control device inlet, lb/hr;

Eo = Mass emissions rate of PM or total metal HAP at the control device outlet, lb/hr.

iii. Meet the applicable emissions limit based on the calculated PM or total metal

HAP process-weighted mass emissions for the regulated emissions source using

the following equation:



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Where:

Ep1released = Calculated process-weighted mass emissions of PM (or total metal HAP) predicted to be released to

the atmosphere from the regulated emissions source, pounds of PM or total metal HAP per ton of metal

charged; and

Ep1i = Process-weighted mass emissions of PM (or total metal HAP) in the uncontrolled regulated exhaust

stream, pounds of PM or total metal HAP per ton of metal charged.

g. To determine compliance with an emissions limit for situations when multiple sources are

controlled by a single control device, but only one source operates at a time or other

situations that are not expressly considered in Conditions 7.2.d through 7.2.f, submit a

site-specific test plan to the Administrator for approval according to the requirements in

40 CFR 63.7(c)(2) and (3). [40 CFR 63.10898(g)]

h. Conduct each opacity test for fugitive emissions according to the requirements in 40 CFR

63.6(h)(5) and Table 1 of 40 CFR 63 Subpart ZZZZZ. [40 CFR 63.10898(h)]

i. Conduct subsequent performance tests to demonstrate compliance with the opacity limit

in Condition 3.3.d. no less frequently than every 6 months and each time you make a

process change likely to increase fugitive emissions. [40 CFR 63.10898(i)]

j. In the performance test report, the permittee must certify that the capture system operated

normally during the performance test. [40 CFR 63.10898(j)]

8.0 RECORDKEEPING REQUIREMENTS

8.1. Operation and Maintenance

The permittee must maintain the following records related to the operation and maintenance of

the facility and associated air contaminant control devices: [OAR 340-214-0114]

a. Baghouse operational parameters:

i. Records documenting the date, time, and differential pressure reading for each

fabric/cartridge filter baghouse.

ii. Records of baghouse inspections and bag replacement.

iii. Records documenting the engineering design specifications or equivalent

documentation detailing proper operation and maintenance for all fabric/cartridge

filter baghouses at the facility.

iv. Date and time corrective action commenced and completion date of corrective

action for noted excursions of a baghouse/fabric filter operational design range.

b. Quantity (tons) of metal melted in the #1 6MT and #2 10TT steel EAFs.

c. Quantity (tons) of metal melted in the #3 10TT manganese EAF.

d. Quantity (tons) of metal melted in the induction furnaces (Building #8 and 11).

e. Quantity (tons) of sand throughput for the Main Foundry Sand System (Mills 1 & 3).

f. Quantity (tons) of sand throughput for the Group 8 Sand System (Mill 2).

g. Quantity (tons) of sand throughput for the Core Room Sand system.

h. Quantity (tons) of sand throughput for the South Foundry Sand System (Mills 1 & 3).

i. Quantity (tons) of sand throughput for the Main Foundry Shakeout.

j. Quantity (tons) of sand throughput for the Group 3 & 6 Sand System (Mill 4).



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k. Quantity (tons) of sand throughput for the National Sand Reclaimer.

l. Quantity (tons) of sand throughput for the Group 9 Sand Reclaim system.

m. Quantity (tons) of sand throughput for the SMS Sand Reclaimer.

n. Quantity (tons) of sand processed through the Sand Dryer at Landfill.

o. Quantity (tons) of steel processed through the Joslyn Burn Arc #1.

p. Quantity (tons) of steel processed through the South Foundry Burn/Arc.

q. Quantity (tons) of steel processed through the Joslyn Rotoblast #1.

r. Quantity (tons) of steel processed through the Joslyn Rotoblast #2.

s. Quantity (tons) of steel processed through the Main Foundry Rotoblast.

t. Quantity (tons) of steel processed through the Joslyn Turnblast.

u. Quantity (tons) of steel processed through the Joslyn Spinblast.

v. Quantity (tons) of steel processed through the Main Foundry Rotoblast Room.

w. Quantity (tons) of steel processed through the Main Foundry Burn/Weld.

x. Number of patterns produced by the Pattern Shop.

y. Quantity of fuel combusted (MMft3 for gaseous fuels and gal for liquid fuels).

z. Name and quantity (pounds or gallons) of each coating/solvent used.

aa. Name and quantity (pounds or gallons) of each mold/core wash used.

bb. Name and quantity of each coating, solvent, and mold/core wash shipped off site.

cc. For each VOC containing, solvent, and mold/core wash used, records identifying the

product name and VOC content in lbs/gal. Records must be updated upon change of

product or change of product formulation.

dd. If the permittee uses the Alternative PM PSEL Compliance methodology of Condition

6.3; Quantity of PM captured by the respective control device (in lbs). If, based on source

operations, monthly PM capture monitoring is not feasible, monitoring may be performed

on an alternate schedule and the determined emission rate extrapolated to a monthly

value.

ee. Monthly, and 12-month emission rate calculations in accordance with Conditions 6.2,

6.3, 6.4, and 6.6 to demonstrate compliance with each of the PSELs of Condition 5.1

8.2. Excess Emissions

a. The permittee must maintain the records of excess emissions listed below and as defined

in OAR 340-214-0300 through 340-214-0340, recorded on occurrence. Typically, excess

emissions are caused by process upsets, startups, shutdowns, or scheduled maintenance.

In many cases, excess emissions are evident when visible emissions are greater than 20%

opacity as a six-minute block average.

i. The date and time of the beginning of the excess emissions event and the duration

or best estimate of the time until return to normal operation;

ii. The date and time the permittee notified DEQ of the event;

iii. The equipment involved;

iv. Whether the event occurred during planned startup, planned shutdown, scheduled

maintenance, or as a result of a breakdown, malfunction, or emergency;



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v. Steps taken to mitigate emissions and corrective action taken, including whether

the approved procedures for a planned startup, shutdown, or maintenance activity

were followed;

vi. The magnitude and duration of each occurrence of excess emissions during the

course of an event and the increase over normal rates or concentrations as

determined by continuous monitoring or best estimate (supported by operating

data and calculations); and

vii. The final resolution of the cause of the excess emissions;

b. If there is an ongoing excess emission caused by an upset or breakdown, the permittee

must immediately take action to minimize emissions by reducing or ceasing operation of

the equipment or facility, unless doing so could result in physical damage to the

equipment or facility, or cause injury to employees. In no case may the permittee operate

more than 48 hours after the beginning of the excess emissions, unless continued

operation is approved by DEQ in accordance with OAR 340-214-0330(4).

c. In the event of any excess emissions which are of a nature that could endanger public

health and occur during non-business hours, weekends, or holidays, the permittee must

immediately notify DEQ by calling the Oregon Emergency Response System (OERS).

The current number is 1-800-452-0311.

d. If startups or shutdowns may result in excess emissions, the permittee must submit

startup/shutdown procedures used to minimize excess emissions to DEQ for prior

authorization, as required in OAR 340-214-0310. New or modified procedures must be

received by DEQ in writing at least 72 hours prior to the first occurrence of the excess

emission event. The permittee must abide by the approved procedures and have a copy

available at all times.

e. If permittee anticipates that scheduled maintenance may result in excess emissions, the

permittee must submit scheduled maintenance procedures used to minimize excess

emissions to DEQ for prior authorization, as required in OAR 340-214-0320. New or

modified procedures must be received by DEQ in writing at least 72 hours prior to the

first occurrence of the excess emission event. The permittee must abide by the approved

procedures and have a copy available at all times.

f. The permittee must maintain a log of all excess emissions in accordance with OAR 340-

214-0340(3).

8.3. Complaints

The permittee must maintain a log of all complaints received by the permittee in person, in

writing, by telephone or through other means according to Condition 2.6. Documentation must

include all information identified in Condition 2.6. [OAR 340-214-0114]

8.4. Retention of Records

Unless otherwise specified, the permittee must retain all records for a period of at least five (5)

years from the date of the monitoring sample, measurement, report, or application and make

them available to DEQ upon request. The permittee must maintain the two (2) most recent years

of records onsite. [OAR 340-214-0114]



of 41

8.5. NESHAP Subpart ZZZZZ – Small Foundry

The following conditions summarize the applicable recordkeeping requirements of 40 CFR

Subpart ZZZZZ for Small Foundries, but are not intended to supersede the Subpart:

a. The permittee must maintain files of all information (including all reports and

notifications) for at least 5 years following the date of each occurrence, measurement,

maintenance, corrective action, report, or record. At a minimum, the most recent 2 years

of data shall be retained on site. The remaining 3 years of data may be retained off site.

[40 CFR 63.10890(d)]

b. The permittee must maintain the following records: [40 CFR 63.10890(e)]

i. Records supporting initial notification of applicability and notification of

compliance status.

ii. Records of written materials specifications according to 3.2.b and records that

demonstrate compliance with the requirements for restricted metallic scrap in

3.2.b.i and/or for the use of general scrap in 3.2.b.ii and for mercury in 3.2.c, as

applicable. The permittee must keep records documenting compliance with 3.2.c.i

for scrap that does not contain motor vehicle scrap.

iii. Records to document use of binder chemical formulation that does not contain

methanol as a specific ingredient of the catalyst formulation for each furfuryl

alcohol warm box mold or core making line. These records must be the Material

Safety Data Sheet (provided that it contains appropriate information), a certified

product data sheet, or a manufacturer's hazardous air pollutant data sheet.

iv. Records of the annual quantity and composition of each HAP-containing chemical

binder or coating material used to make molds and cores. These records must be

copies of purchasing records, Material Safety Data Sheets, or other documentation

that provides information on the binder or coating materials used.

v. Records of metal melt production for each calendar year.

8.6. NESHAP Subpart ZZZZZ – Large Foundry




recordkeeping requirements of 40 CFR Subpart ZZZZZ for Large Foundries, but are not

intended to supersede the Subpart:

a. The permittee must maintain files of all information (including all reports and

notifications) for at least 5 years following the date of each occurrence, measurement,

maintenance, corrective action, report, or record. At a minimum, the most recent 2 years

of data shall be retained on site. The remaining 3 years of data may be retained off site.

Such files may be maintained on microfilm, on a computer, on computer floppy disks, on

magnetic tape disks, or on microfiche. [40 CFR 63.10899(a)]

b. In addition to the records required by 40 CFR 63.10, the permittee must keep records of

the information specified below: [40 CFR 63.10899(b)]

i. Records of written materials specifications according to Condition 3.3.f and

records that demonstrate compliance with the requirements for restricted metallic

scrap in Condition 3.3.f.i and/or for the use of general scrap in Condition 3.3.f.ii



of 41

and for mercury in Condition 3.3.g.i. Records documenting compliance with

Condition 3.3.g.i for scrap that does not contain motor vehicle scrap.

ii. The permittee must keep records to document use of any binder chemical

formulation that does not contain methanol as a specific ingredient of the catalyst

formulation for each furfuryl alcohol warm box mold or core making line as

required by Condition 3.3.h. These records must be the Material Safety Data

Sheet (provided that it contains appropriate information), a certified product data

sheet, or a manufacturer's hazardous air pollutant data sheet.

iii. The permittee must keep records of the annual quantity and composition of each

HAP-containing chemical binder or coating material used to make molds and

cores. These records must be copies of purchasing records, Material Safety Data

Sheets, or other documentation that provide information on the binder or coating

materials used.

iv. The permittee must keep records of monthly metal melt production for each

calendar year.

v. The permittee must keep a copy of the operation and maintenance plan as

required by Condition 3.3.j. and records that demonstrate compliance with plan

requirements.

vi. If the permittee uses emissions averaging, records of the monthly metal melting

rate for each furnace at the iron and steel foundry, and records of the calculated

pounds of PM or total metal HAP per ton of metal melted for the group of all

metal melting furnaces required by Condition 3.3.q.

vii. If applicable, records for bag leak detection systems as follows:

A. Records of the bag leak detection system output;

B. Records of bag leak detection system adjustments, including the date and

time of the adjustment, the initial bag leak detection system settings, and

the final bag leak detection system settings; and

C. The date and time of all bag leak detection system alarms, and for each

valid alarm, the time you initiated corrective action, the corrective action

taken, and the date on which corrective action was completed.

viii. Records of capture system inspections and repairs as required by Condition 3.3.n.

ix. Records demonstrating conformance with your specifications for the operation of

CPMS as required by Condition 3.3.o.

x. Records of corrective action(s) for exceedances and excursions as required by

Condition 3.3.p.

xi. Record the results of each inspection and maintenance required by Condition 3.3.l

for PM control devices in a logbook (written or electronic format).

The logbook must be kept onsite and made available to the Administrator upon

request. The permittee must keep records of the information as follows:

A. The date and time of each recorded action for a fabric filter, the results of

each inspection, and the results of any maintenance performed on the bag

filters.



of 41

B. The date and time of each recorded action for a wet or dry electrostatic

precipitator (including ductwork), the results of each inspection, and the

results of any maintenance performed for the electrostatic precipitator.

C. The date and time of each recorded action for a wet scrubber (including

ductwork), the results of each inspection, and the results of any

maintenance performed on the wet scrubber.

9.0 REPORTING REQUIREMENTS

9.1. Excess Emissions

a. The permittee must notify DEQ of excess emissions events if the excess emission is of a

nature that could endanger public health.

b. The permittee must also submit follow-up reports summarizing records of excess

emissions as required in Condition 8.2 when required by DEQ. Such notice must be

provided as soon as possible, but never more than one hour after becoming aware of the

problem. Notice must be made to the regional office identified in Condition 11.0 by

email, telephone, facsimile, or in person.

9.2. NESHAP Subpart ZZZZZ – Small Foundry Reporting

The following conditions summarize the applicable reporting requirements of 40 CFR 63

Subpart ZZZZZ for Small Foundries, but are not intended to supersede the Subpart:

a. The permittee must submit semiannual compliance reports to the Administrator according

to the requirements in §63.10(e). The report must clearly identify any deviation from the

pollution prevention management practices in Conditions 3.2.b, 3.2.c, and 3.2.d and the

corrective action taken. [40 CFR 63.10890(f)]

b. The permittee must submit a written notification to the Administrator of the initial

classification of your facility as a small foundry as required in 40 CFR 63.10880(f) and

(g), as applicable, and for any subsequent reclassification as required in Condition 9.2.c.

[40 CFR 63.10890(g)]

c. If the annual metal melt production of the small foundry exceeds 20,000 tons during the

preceding calendar year, the permittee must submit a notification of foundry

reclassification to the Administrator within 30 days and comply with the following

requirements. [40 CFR 63.10881(d)(1)]

i. If the permittee’s small foundry has never been classified as a large foundry, the

permittee must comply with the requirements for a large foundry no later than 2

years after the date of the foundry's notification that the annual metal melt

production exceeded 20,000 tons.

ii. If the permittee’s small foundry had previously been classified as a large foundry,

the permittee must comply with the requirements for a large foundry no later than



of 41

the date of the foundry's most recent notification that the annual metal melt

production exceeded 20,000 tons.

9.3. NESHAP Subpart ZZZZZ – Large Foundry Reporting




reporting requirements of 40 CFR 63 Subpart ZZZZZ for Large Foundries, but are not intended

to supersede the Subpart:

a. The permittee must submit semiannual compliance reports to the Administrator according

to the requirements in 40 CFR 63.10(e). The reports must include, at a minimum, the

following information as applicable: [40 CFR 63.10899(c)]

i. Summary information on the number, duration, and cause (including unknown

cause, if applicable) of excursions or exceedances, as applicable, and the

corrective action taken;

ii. Summary information on the number, duration, and cause (including unknown

cause, if applicable) for monitor downtime incidents (other than downtime

associated with zero and span or other calibration checks, if applicable); and

iii. Summary information on any deviation from the pollution prevention

management practices in Conditions 3.3.f through 3.3.h and the operation and

maintenance requirements in Conditions 3.3.j. and 3.3.k. and the corrective action

taken.

b. The permittee must submit written notification to the Administrator of the initial

classification of the existing affected source as a large iron and steel facility as required

in 40 CFR 63.10880(f) and (g), as applicable, and for any subsequent reclassification as

required in Condition 3.3.e. [40 CFR 63.10899(d)]

9.4. Annual Report

For each year this permit is in effect, the permittee must submit to DEQ by March 1 two (2)

paper copies and one (1) electronic copy of the following information for the previous calendar

year. If March 1 falls on a weekend or Monday holiday, the permittee must submit their annual

report on the next business day.

a. Operating parameters as listed in Condition 6.1:

i. Quantity of steel melted annually in each Electric Arc and Induction furnace, in

tons.

ii. Quantity of sand used annually in each mold and coremaking line, and each sand

reclamation line.

iii. Pattern production, in 1000’s of patterns.

iv. Throughput on each burn arc station, in tons steel of castings.

v. Usage of coatings, solvents, and mold & core washes, in gallons.

vi. Fuel consumption for stationary sources, in millions of cubic feet (MMft3) for

gaseous fuels and gallons for liquid fuels.



of 41

b. Calculations of annual pollutant emissions determined each month in accordance with

Condition 6.2, 6.3, 6.4, and 6.6.

c. A brief summary listing the date, time, and the affected device/process for each excess

emission that occurred during the reporting period.

d. Summary of complaints relating to air quality received by permittee during the year in

accordance with Condition 2.6.

e. List permanent changes made in facility process, production levels, and pollution control

equipment which affected air contaminant emissions.

f. List major maintenance performed on pollution control equipment.

9.5. Greenhouse Gas Registration and Reporting

a. If the calendar year greenhouse gas emissions (CO2e) are ever greater than or equal to

2,756 tons (2,500 metric tons), the permittee must annually register and report its

greenhouse gas emissions with DEQ in accordance with OAR 340 division 215.

b. If the calendar year greenhouse gas emissions (CO2e) are less than 2,756 tons (2,500

metric tons) for three consecutive years, the permittee may stop reporting greenhouse gas

emissions but must retain all records used to calculate greenhouse gas emissions for the

five years following the last year that they were required to report. The permittee must

resume reporting its greenhouse gas emissions if the calendar year greenhouse gas

emissions (CO2e) are greater than or equal to 2,756 tons (2,500 metric tons) in any

subsequent calendar year.

9.6. Notice of Change of Ownership or Company Name

The permittee must notify DEQ in writing using a DEQ “Transfer Application Form” within 60

days after the following:

a. Legal change of the name of the company as registered with the Corporations Division of

the State of Oregon; or

b. Sale or exchange of the activity or facility.

9.7. Construction or Modification Notices

The permittee must notify DEQ in writing using a DEQ “Notice of Intent to Construct Form,” or

other permit application form and obtain approval in accordance with OAR 340-210-0205

through 340-210-0250 and OAR 340-245-0060(4)(c) before:

a. Constructing, installing, or establishing a new stationary source that will cause an

increase in any regulated pollutant emissions;

b. Making any physical change or change in operation of an existing stationary source that

will cause an increase, on an hourly basis at full production, in any regulated pollutant

emissions; or

c. Constructing or modifying any air pollution control equipment.



of 41

10.0 ADMINISTRATIVE REQUIREMENTS

10.1. Permit Renewal Application

The permittee must submit the completed application package for renewal of this permit 180

days prior to the expiration date. Two (2) paper copies and one (1) electronic copy of the

application must be submitted to the DEQ Permit Coordinator listed in Condition 11.2. [OAR

340-216-0040]

10.2. Permit Modifications

Application for a modification of this permit must be submitted at least 60 days prior to the

source modification. When preparing an application, the applicant should also consider

submitting the application 180 days prior to allow DEQ adequate time to process the application

and issue a permit before it is needed. A special activity fee must be submitted with an

application for the permit modification. The fees and two (2) copies of the application must be

submitted to the DEQ Business Office.

10.3. Annual Compliance Fee

The permittee must pay the annual fees specified in OAR 340-216-8020, Table 2, Part 2 and 3

for a Standard ACDP by December 1 of each year this permit is in effect. An invoice indicating

the amount, as determined by DEQ regulations will be mailed prior to the above date. Late fees

in accordance with Part 5 of the table will be assessed as appropriate.

10.4. Change of Ownership or Company Name Fee

The permittee must pay the non-technical permit modification fee specified in OAR 340-216-

8020, Table 2, Part 4 with an application for changing the ownership or the name of the

company.

10.5. Special Activity Fees

The permittee must pay the special activity fees specified in OAR 340-216-8020, Table 2, Part 4

with an application to modify the permit.



of 41

11.0 DEQ CONTACTS / ADDRESSES

11.1. Business Office

The permittee must submit payments for invoices, applications to modify the permit, and any

other payments to DEQ’s Business Office:

Oregon Dept. of Environmental Quality

Financial Services – Revenue Section


Portland, Oregon 97232-4100

11.2. Permit Coordinator

The permittee must submit all notices and applications that do not include payment to the Permit

Coordinator.


Northwest Region AQ Permit Coordinator


Portland, OR 97232-4100

[email protected]

11.3. Report Submittals

Unless otherwise notified, the permittee must submit all reports (annual reports, source test plans

and reports, etc.) to DEQ’s Region. If you know the name of the Air Quality staff member

responsible for your permit, please include it:


Northwest Region Air Quality


Portland, OR 97232-4100

11.4. Web Site

Information about air quality permits and DEQ’s regulations may be obtained from the DEQ web

page at www.oregon.gov/deq/.

12.0 GENERAL CONDITIONS AND DISCLAIMERS

12.1. Permitted Activities

a. Until this permit expires or is modified or revoked, the permittee is allowed to discharge

air contaminants from the following:

mailto:[email protected]

http://www.oregon.gov/deq/



of 41

i. Processes and activities directly related to or associated with the

devices/processes listed in Condition 1.0 of this permit;

i. Any categorically insignificant activities, as defined in OAR 340-200-0020, at the

source; and

ii. Construction or modification changes that are Type 1 or Type 2 changes under

OAR 340-210-0225 that are approved by DEQ in accordance with OAR 340-210-

0215 through 0250, if the permittee complies with all of the conditions of DEQ’s

approval to construct and all of the conditions of this permit.

b. Discharge of air contaminants from any other equipment or activity not identified herein

is not authorized by this permit.

12.2. Other Regulations

In addition to the specific requirements listed in this permit, the permittee must comply with all

other applicable legal requirements enforceable by DEQ.

12.3. Conflicting Conditions

In any instance in which there is an apparent conflict relative to conditions in this permit, the

most stringent conditions apply. [OAR 340-200-0010]

12.4. Masking of Emissions

The permittee must not cause or permit the installation of any device or use any means designed

to mask the emissions of an air contaminant that causes or is likely to cause detriment to health,

safety, or welfare of any person or otherwise violate any other regulation or requirement. [OAR

340-208-0400]

12.5. DEQ Access

The permittee must allow DEQ’s representatives access to the plant site and pertinent records at

all reasonable times for the purposes of performing inspections, surveys, collecting samples,

obtaining data, reviewing and copying air contaminant emissions discharge records and

conducting all necessary functions related to this permit in accordance with ORS 468.095.

12.6. Permit Availability

The permittee must have a copy of the permit available at the facility at all times. [OAR 340-

216-0020(3)]

12.7. Open Burning

The permittee may not conduct any open burning except as allowed by OAR 340, division 264.



of 41

12.8. Asbestos

The permittee must comply with the asbestos abatement requirements in OAR 340, division 248

for all activities involving asbestos-containing materials, including, but not limited to,

demolition, renovation, repair, construction, and maintenance.

12.9. Property Rights

The issuance of this permit does not convey any property rights in either real or personal

property, or any exclusive privileges, nor does it authorize any injury to private property or any

invasion of personal rights, nor any infringement of federal, state, or local laws or regulations.

12.10. Permit Expiration

a. A source may not be operated after the expiration date of the permit, unless any of the

following occur prior to the expiration date of the permit: [OAR 340-216-0082]

i. A timely and complete application for renewal of this permit or for a different

ACDP has been submitted; or

ii. A timely and complete application for renewal or for an Oregon Title V

Operating Permit has been submitted, or

iii. Another type of permit (ACDP or Oregon Title V Operating Permit) has been

issued authorizing operation of the source.

b. For a source operating under an ACDP or Oregon Title V Operating Permit, a

requirement established in an earlier ACDP remains in effect notwithstanding expiration

of the ACDP, unless the provision expires by its terms or unless the provision is modified

or terminated according to the procedures used to establish the requirement initially.

12.11. Permit Termination, Revocation, or Modification

DEQ may terminate, revoke, or modify this permit pursuant to OAR chapter 340 division 216.

[OAR 340-216-0082].

13.0 40 CFR 63, SUBPART ZZZZZ, TABLE 3 (LARGE

FOUNDRIES)



Condition 9.2.c. [40 CFR 63.10890(h)]

Citation Subject Applies to

large foundry? Explanation

63.1 Applicability Yes.

63.2 Definitions Yes.

63.3 Units and abbreviations Yes.

63.4 Prohibited activities Yes.



of 41



63.5 Construction/reconstruction Yes.

63.6(a)-(g) Compliance with standards and

maintenance requirements Yes.

63.6(h) Opacity and visible emissions

standards Yes.

63.6(i)(i)-(j)

Compliance extension and

Presidential compliance

exemption

Yes.

63.7(a)(3), (b)-(h) Performance testing

requirements Yes.

63.7(a)(1)-(a)(2) Applicability and performance

test dates No

Subpart ZZZZZ

specifies

applicability and

performance test

dates.

63.8(a)(1)-(a)(3),

(b), (c)(1)-(c)(3),

(c)(6)-(c)(8), (d),

(e), (f)(1)-(f)(6),

(g)(1)-(g)(4)

Monitoring requirements Yes.

63.8(a)(4)

Additional monitoring

requirements for control

devices in §63.11

No.

63.8(c)(4) Continuous monitoring system

(CMS) requirements No.

63.8(c)(5)

Continuous opacity monitoring

system (COMS) minimum

procedures

No.

63.8(g)(5) Data reduction No.

63.9 Notification requirements Yes.

63.10(a), (b)(1)-

(b)(2)(xii) -

(b)(2)(xiv), (b)(3),

(d)(1)-(2), (e)(1)-

(2), (f)

Recordkeeping and reporting

requirements Yes.

63.10(c)(1)-(6),

(c)(9)-(15)

Additional records for

continuous monitoring systems No.

63.10(c)(7)-(8)

Records of excess emissions

and parameter monitoring

exceedances for CMS

Yes.

63.10(d)(3) Reporting opacity or visible

emissions observations Yes.

63.10(e)(3) Excess emissions reports Yes.

63.10(e)(4) Reporting COMS data No.

63.11 Control device requirements No.

63.12 State authority and delegations Yes.



of 41



63.13-63.16

Addresses of State air

pollution control agencies and

EPA regional offices.

Incorporation by reference.

Availability of information and

confidentiality. Performance

track provisions

Yes.

14.0 EMISSION FACTORS

PM, PM10 and PM2.5

Control

Device

ID

Emission

Point

EF for

PM

EF for

PM10

EF

for

PM2.5

Monitored

Parameter

(P)

Units EF Reference

CD #1

#1 6MT

Steel and #2

10TT Steel

Electric Arc

Furnace

0.0152 0.0152 .0152 steel

melted

lb/ton

steel

melted

December 2005

Stack Test,

DEQ AQ-EF08

CD #2

#3 10TT

Manganese

Electric Arc

Furnace

0.31 0.31 0.31 steel

melted

lb/ton

steel

melted

April 1982

Stack Test,

DEQ AQ-EF08

Melting – 2

Induction

Furnaces

Accounted for in Roof

Vent Fugitive emissions

steel

melted

lb/ton

metal

melted

PM/PM10 by

MiniVol

Testing

CD #5

Main

Foundry

Sand System

(Mills 1 & 3)

0.038 0.038 0.038 sand

throughput

lb/ton

sand

April 1981

Stack Test,

DEQ AQ-EF08

CD #6

Group 8

Sand System

(Mill 2)

0.021 0.021 0.021 sand

throughput

lb/ton

sand

April 1996

Stack Test,

DEQ AQ-EF08

CD #9 Core Room

Sand System 0.027 0.027 0.027

sand

throughput

lb/ton

sand

Baghouse Dust

Study, DEQ

AQ-EF08

CD

#17

South

Foundry

Sand System

(Mills 1 & 3)

0.01 0.01 0.01 sand

throughput

lb/ton

sand

Baghouse Dust

Study, DEQ

AQ-EF08

CD #3

Main

Foundry

Shakeout

0.037 0.037 0.037 sand

throughput

lb/ton

sand

Baghouse Dust

Study, DEQ

AQ-EF08



of 41

Control

Device

ID

Emission

Point

EF for

PM

EF for

PM10

EF

for

PM2.5

Monitored

Parameter

(P)

Units EF Reference

CD #8

Group 3 & 6

Sand System

(Mill 4)

0.038 0.038 0.038 sand

throughput

lb/ton

sand

Baghouse Dust

Study, DEQ

AQ-EF08

CD #4

National

Sand

Reclaimer

0.061 0.061 0.061 sand

throughput

lb/ton

sand

Baghouse Dust

Study, DEQ

AQ-EF08

CD

#20

Group 9

Sand

Reclaim

System

0.029 0.029 0.029 Sand

throughput

lb/ton

sand

Baghouse Dust

Study, DEQ

AQ-EF08

CD

#22

SMS Sand

Reclaimer 0.06 0.06 0.06

Sand

throughput

lb/ton

sand

Baghouse Dust

Study, DEQ

AQ-EF08

CD

#23

Sand Dryer

at Landfill 0.01 0.01 0.01

Sand

throughput

lb/ton

sand

Baghouse Dust

Study, DEQ

AQ-EF08

CD

#10

Joslyn

Burn/Arc #1 0.027 0.027 0.027

metal

processed

lb/ton

metal

Baghouse Dust

Study, DEQ

AQ-EF08

CD

#15

South

Foundry

Burn/Arc

0.001 0.001 0.001 metal

processed

lb/ton

metal

October 1980

Stack Test,

DEQ AQ-EF08

CD #7 Joslyn

Rotoblast #1 0.08 0.08 0.08

metal

processed

lb/ton

metal

Baghouse Dust

Study, DEQ

AQ-EF08

CD

#24

Joslyn

Rotoblast #2 0.08 0.08 0.08

metal

processed

lb/ton

metal

Baghouse Dust

Study, DEQ

AQ-EF08

CD

#26

Main

Foundry

Table Blast

and Blast

Room

0.014 0.014 0.014 metal

processed

lb/ton

metal

Baghouse Dust

Study, DEQ

AQ-EF08

CD

#16

Joslyn

Tumblast 0.02 0.02 0.02

metal

processed

lb/ton

metal

Baghouse Dust

Study, DEQ

AQ-EF08

CD

#19

Joslyn

Spinblast 0.14 0.14 0.14

metal

processed

lb/ton

metal

Baghouse Dust

Study, DEQ

AQ-EF08

CDs

#11,

12, 13

Main

Foundry

Burn/Weld

0.014 0.014 .014 metal

processed

lb/ton

metal

November 1980

Stack Test,

DEQ AQ-EF08



of 41

Control

Device

ID

Emission

Point

EF for

PM

EF for

PM10

EF

for

PM2.5

Monitored

Parameter

(P)

Units EF Reference

CD

#18 Pattern Shop 0.05 0.05 0.05 patterns

lb/1000

patterns

Assume 99%

control with

baghouse, DEQ

AQ-EF08

Natural Gas

Combustion 2.5 2.5 2.5

MMft3 nat.

gas

lb/

MMft3

ODEQ Form

AQ-EF05

Bldg. 8 Roof

Vent

Fugitives

1.24 0.67 0.33 metal

melted

lb/ton

metal

melted

PM/PM10 by

MiniVol

Testing, AP-42

Table 12.10-8

(Pouring,

cooling)

Bldg. 11

Roof Vent

Fugitives

1.3 0.8 0.39 metal

melted

lb/ton

metal

melted

PM/PM10 by

MiniVol

Testing, AP-42

Table 12.10-8

(Pouring,

cooling)

Alternate

Method for

PM

See Condition 6.3 Assume 99%

control

Nitrogen Oxides -NOX

Emission Point EF for NOx Monitored Parameter

(P) Units EF Reference

#1 6MT Steel

and #2 10TT

Steel Electric

Arc Furnace

0.32 Metal melted lb/ton metal AP-42 Table

12.10-5

#3 10TT

Manganese

Electric Arc

Furnace

0.32 Metal melted lb/ton metal AP-42 Table

12.10-5

Melting – 2

Induction

Furnaces

0.01 Metal melted lb/ton metal

Fire v6.25

Factor ID

#16110

Natural Gas

Combustion 100 MMft3 nat. gas lb/MMft3

AP-42 Table

1.4-1



of 41

Carbon Monoxide – CO

Emission Point EF for CO

Monitored

Parameter

(P)

Units EF Reference

#1 6MT Steel

and #2 10TT

Steel Electric

Arc Furnace

4.05 Metal melted lb/ton metal December 2005

Stack Test

#3 10TT

Manganese

Electric Arc

Furnace

0.30 Metal melted lb/ton metal

Columbia Steel

Engineering

Tests

Melting – 2

Induction

Furnaces

0 Metal melted lb/ton metal AP 42 Table

12.10-5

Pouring, Cooling

& Shakeout

Material

Thermal

Decomposition

EF

Material Used

(e.g., cereal, oil,

binder, resin)

lb/lb material Material SDS

Natural Gas

Combustion 84 MMft3 nat. gas lb/MMft3

AP-42 Table

1.4-1

Volatile Organic Compounds - VOC

Emission Point EF for VOC Monitored Parameter

(P) Units EF Reference

#1 6MT Steel

and #2 10TT

Steel Electric

Arc Furnace

0.18 Metal melted lb/ton steel AP 42-Table

12.10-5

#3 10TT

Manganese

Electric Arc

Furnace


12.10-5

Melting – 2

Induction

Furnaces


12.10-5 for EAF

Pouring, Cooling

& Shakeout Mass Balance Mass Balance lb/ton steel MSDS

Mold & Core

Alcohol Wash Mass Balance Mass Balance lb/gal

DEQ, 50%

destruction eff.

Mold &

Core Making Mass Balance Mass Balance lb/ton steel MSDS

Casting

Painting Mass Balance Mass Balance lb/gal MSDS

Pattern

Painting Mass Balance Mass Balance lb/gal MSDS

Natural Gas

Combustion 5.5 MMft3 nat. gas lb/ MMft3

AP-42 Table

1.4-2



of 41

15.0 ABBREVIATIONS, ACRONYMS, AND DEFINITIONS

ACDP Air Contaminant Discharge

Permit

ASTM American Society for Testing

and Materials

AQMA Air Quality Maintenance Area

calendar

year

The 12-month period

beginning January 1st and

ending December 31st

CAO Cleaner Air Oregon

CFR Code of Federal Regulations

CO

CO2e

carbon monoxide

carbon dioxide equivalent

DEQ Oregon Department of

Environmental Quality

dscf dry standard cubic foot

EPA US Environmental Protection

Agency

FCAA Federal Clean Air Act

Gal

GHG

gallon(s)

greenhouse gas

gr/dscf grains per dry standard cubic

foot

HAP Hazardous Air Pollutant as

defined by OAR 340-244-

0040

I&M inspection and maintenance

lb pound(s)

MMBtu million British thermal units

NA not applicable

NESHAP National Emissions Standards

for Hazardous Air Pollutants

NOX nitrogen oxides

NSPS New Source Performance

Standard

NSR New Source Review

O2 oxygen

OAR Oregon Administrative Rules

ORS Oregon Revised Statutes

O&M operation and maintenance

Pb lead

PCD pollution control device

PEMS Predictive emission

monitoring system

PM particulate matter

PM10

PM2.5

particulate matter less than 10

microns in size

particulate matter less than 2.5

microns in size

ppm part per million

PSD Prevention of Significant

Deterioration

PSEL Plant Site Emission Limit

PTE Potential to Emit

RACT Reasonably Available Control

Technology

scf standard cubic foot

SER Significant Emission Rate

SIC Standard Industrial Code

SIP State Implementation Plan

SO2 sulfur dioxide

Special

Control

Area

as defined in OAR 340-204-

0070

TACT Typically Achievable Control

Technology

VE visible emissions

VOC volatile organic compound

year A period consisting of any 12-

consecutive calendar months

oregon department of environmental quality …

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