DAQ-2025-001328

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DAQC-207-25
Site ID 10794 (B1)

MEMORANDUM

TO: FILE – MCWANE DUCTILE

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Jeremiah Marsigli, Environmental Scientist

DATE: February 21, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Utah County,
FRS ID# 0000004904900017
INSPECTION DATE: January 30, 2025

SOURCE ADDRESS: P.O. Box 1219, Provo, UT 84601

SOURCE LOCATION: 2550 South Industrial Parkway, Provo, UT 84601

SOURCE CONTACT(S): Christy Seiger-Webster, Environmental Engineer 801-623-4224
Oran Croft, Environmental Engineer 801-623-4223

OPERATING STATUS: Plant operating except zinc coating

PROCESS DESCRIPTION: Manufacturer of ductile iron pipe. McWane produces various sizes of iron
products in Utah County. The iron product production process includes
melting, core preparation, casting, annealing, lining, coating, and special
lining operation. McWane is a major source of CO and VOC and an Area
Source for HAPS.

APPLICABLE
REGULATIONS: Title V Operating Permit # 4900017004, Date of Last Revision:
November 8, 2022

SOURCE INSPECTION
EVALUATION:

Title V Operating Permit # 4900017004
SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990
(CAA) except those terms and conditions that are specifically designated as "State
Requirements". (R307-415-6b)

Status: This is not an inspection item.

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I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)

Status: In compliance. The source appeared to be operating in compliance with the conditions of this
permit. See each condition below for more specific details.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of
the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that
the Director may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating this permit or to determine compliance with this
permit. Upon request, the permittee shall also furnish to the Director copies of records
required to be kept by this permit or, for information claimed to be confidential, the
permittee may furnish such records directly to the EPA along with a claim of
confidentiality. (R307-415-6a(6)(e))

I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The
filing of a request by the permittee for a permit modification, revocation and reissuance, or
termination, or of a notification of planned changes or anticipated noncompliance shall not
stay any permit condition, except as provided under R307-415-7f(1) for minor permit
modifications. (R307-415-6a(6)(c))

Status: In compliance. The source appeared to be operating in compliance with the conditions of this
permit. See each condition below for more specific details.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this permit is due on or before the date shown under
"Enforceable Dates and Timelines" at the front of this permit. An application may be
submitted early for any reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be
accepted for processing, but shall not be considered a timely application and shall not
relieve the permittee of any enforcement actions resulting from submitting a late
application. (R307-415-5a(5))

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I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: The permit has not expired.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's
failure to have an operating permit will not be a violation of R307-415, until the Director
takes final action on the permit renewal application. In such case, the terms and conditions
of this permit shall remain in force until permit renewal or denial. This protection shall
cease to apply if, subsequent to the completeness determination required pursuant to R307-
415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the deadline
specified in writing by the Director any additional information identified as being needed to
process the application. (R307-415-7b(2))

Status: This permit expires May 5, 2026. Application for renewal is due by November 5, 2025.

I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

Status: This is not an inspection item.

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: In compliance. Permit fees have been paid as invoiced.

I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: This is not an inspection item.

I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are
provided for in this permit. (R307-415-6a(8))

Status: This is not an inspection item.

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I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the Director or an authorized representative to perform any of the
following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related
activity is conducted, or where records are kept under the conditions of this permit.
(R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practice, or operation regulated or required under this
permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of
assuring compliance with this permit or applicable requirements. (R307-415-
6c(2)(d))

I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall
be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: In compliance. Entry was allowed during this inspection. Records were provided as requested.

I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit
shall contain certification as to its truth, accuracy, and completeness, by a responsible
official as defined in R307-415-3. This certification shall state that, based on information
and belief formed after reasonable inquiry, the statements and information in the document
are true, accurate, and complete. (R307-415-5d)

Status: In compliance. All application forms, reports, or compliance certifications submitted pursuant
to this permit in the past year appeared to have contained certification as to its truth,
accuracy, and completeness by a responsible individual as defined in R307-415-3.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later than
the date shown under "Enforceable Dates and Timelines" at the front of this permit, and that
date each year following until this permit expires. The certification shall include all the
following (permittee may cross-reference this permit or previous reports): (R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the
certification;

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I.L.1.b The identification of the methods or other means used by the permittee for
determining the compliance status with each term and condition during the
certification period. Such methods and other means shall include, at a minimum, the
monitoring and related recordkeeping and reporting requirements in this permit. If
necessary, the permittee also shall identify any other material information that must
be included in the certification to comply with section 113(c)(2) of the Act, which
prohibits knowingly making a false certification or omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period
covered by the certification, including whether compliance during the period was
continuous or intermittent. The certification shall be based on the method or means
designated in Provision I.L.1.b. The certification shall identify each deviation and
take it into account in the compliance certification. The certification shall also
identify as possible exceptions to compliance any periods during which compliance
is required and in which an excursion or exceedance as defined under 40 CFR Part
64 occurred; and

I.L.1.d Such other facts as the Director may require to determine the compliance status.

I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director:
(R307-415-6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: In compliance. The last certification was received by DAQ on August 5, 2024. This report was
reviewed under separate cover and found to meet the requirements of this condition.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this
permit, or (R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed
in this permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-
112, and the provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of the source for any violation of applicable
requirements under Utah Code Ann. Section 19-2-107(2)(a)(xiii) and Section 19-2-
110 prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)

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I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA
Section 408(a). (R307-415-6f(3)(c))

I.M.2.d The ability of the Director to obtain information from the source under Utah Code
Ann. Section 19-2-120, and the ability of the EPA to obtain information from the
source under the CAA Section 114. (R307-415-6f(3)(d))

Status: This is not an inspection item.

I.N Emergency Provision.

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to
the extent caused by improperly designed equipment, lack of preventive maintenance,
careless or improper operation, or operator error. (R307-415-6g(1))

I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance
with such technology-based emission limitations if the affirmative defense is demonstrated
through properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency.
(R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to
minimize levels of emissions that exceeded the emission standards, or other
requirements in this permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergency to the Director within two
working days of the time when emission limitations were exceeded due to the
emergency. This notice must contain a description of the emergency, any steps
taken to mitigate emissions, and corrective actions taken. This notice fulfills the
requirement of Provision I.S.2.c below. (R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. (R307-415-6g(4))

I.N.4 This emergency provision is in addition to any emergency or upset provision contained in
any other section of this permit. (R307-415-6g(5))

Status: In compliance. No emergency events were reported or recorded during the 12-month period
preceding this inspection.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

Status: This is not an inspection item.
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I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

Status: This is not an inspection item.

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

Status: This is not an inspection item.

I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.

Status: This is not an inspection item.

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be
retained by the permittee for a period of at least five years from the date of the
monitoring sample, measurement, report, or application. Support information
includes all calibration and maintenance records, all original strip-charts or
appropriate recordings for continuous monitoring instrumentation, and copies of all
reports required by this permit. (R307-415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the
source shall record the following information, where applicable:
(R307-415-6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or
measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or
measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

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I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more
frequently if specified in Section II. All instances of deviation from permit
requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a
responsible official in accordance with Provision I.K of this permit. (R307-415-
6a(3)(c)(i)

I.S.2.c The Director shall be notified promptly of any deviations from permit requirements
including those attributable to upset conditions as defined in this permit, the
probable cause of such deviations, and any corrective actions or preventative
measures taken. Prompt, as used in this condition, shall be defined as written
notification within the number of days shown under "Enforceable Dates and
Timelines" at the front of this permit. Deviations from permit requirements due to
breakdowns shall be reported in accordance with the provisions of R307-107.
(R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be
submitted to the Director are to be sent to the following address or to such other
address as may be required by the Director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

I.S.3.b All reports, notifications or other submissions required by this permit to be
submitted to the EPA should be sent to one of the following addresses or to such
other address as may be required by the Director:

For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

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For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:

Environmental Protection Agency, Region VIII
Office of Partnerships and Regulatory Assistance Air and Radiation Program (mail
code 8P-AR)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: In compliance. Records are kept as required. Monitoring reports have been submitted every
six months. Deviation reports have been submitted.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a
remaining permit term of three or more years. No such reopening is required if the
effective date of the requirement is later than the date on which this permit is due to
expire, unless the terms and conditions of this permit have been extended pursuant
to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The Director or EPA determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other
terms or conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to
assure compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date
of this permit and are in conflict with existing permit conditions.
(R307-415-7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a
Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess
emissions offset plans shall be deemed to be incorporated into this permit.
(R307-415-7g(1)(b))

I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen
exists. (R307-415-7g(2))

Status: This is not an inspection item.

I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307-150)

Status: In compliance. Emission inventories have been submitted as required.

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I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, Acid Deposition Control, both
provisions shall be incorporated into this permit. (R307-415-6a(1)(b))

Status: This is not an inspection item.

SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-Wide

II.A.2 Cupola
Cupola with emissions controlled by a baghouse (with a reagent silo and a bin vent) and CO oxidizer
burner system.

II.A.3 Desulfurization and Ductile System
Desulfurization and ductile treatment system with emissions controlled by a fume hood with a baghouse
(no stack).

II.A.4 Annealing Oven
Natural gas and oil burners heat the ductile iron pipe.

II.A.5 Core Sand Silo
Core sand silo with emissions controlled by a bin vent.

II.A.6 Core Sand Handling and Core Making
Core sand handling with emissions controlled by a baghouse.

II.A.7 Sand Coating Process
Sand is heated and mixed with resin and Hexa with emissions controlled by a wet scrubber and a
baghouse (share the same baghouse with Emission Unit Core Sand Handling).

II.A.8 Three Natural Gas-fired Heaters
Two 3.0 MMBtu/hr heaters - one each in the pipe drying and pipe curing areas, and one 2.0 MMBtu/hr
heater also in the pipe curing area. No unit specific applicable requirements.

II.A.9 Cement Lining Cement Silo
Cement lining cement silo with emissions controlled by a bin vent.

II.A.10 Cement Lining Sand Silo
Cement lining sand silo with emissions controlled by a bin vent.

II.A.11 Pipe Coating
Pipe coating with emissions controlled by dry filter pads.

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II.A.12 Special Lining Operation
Including special lining shot blast with emissions controlled by a baghouse, special lining painter, and
special lining grinding.

II.A.13 Portable Limespar Silos
Portable limespar silos with emissions controlled by a bin vent.

II.A.14 VOC and HAP Emission Units
Including Cupola, Pipe coating, the operations associated with pipe coating, and special lining operation.

II.A.15 Miscellaneous
Storage piles, grinding, hot metal transfer, charge handling and casting operations, and casting operations
baghouse (share the same baghouse with Emission Unit Desulfurization and Ductile System).

II.A.16 Cooling Towers
Associated with compressors 10, 11, 12, and casting machines #7, 1, 2, C, D. No unit specific applicable
requirements.

II.A.17 NESHAP Emergency CI Internal Combustion Engine
550 hp Diesel-fired emergency recouperater generator manufactured in 2002. NESHAP ZZZZ

II.A.18 NESHAP Emergency SI Internal Combustion Engines
Two natural gas-fired generators (27 bhp and 10.06 bhp) are manufactured prior 2005 and are subject to
NESHAP ZZZZ.

II.A.19 NSPS JJJJ Emergency Internal Combustion Engine
One natural gas fired generator (34 hp) located at Works Office is manufactured in 2015 and is subject to
NSPS JJJJ.

II.A.20 Zinc Thermal Spray Process
The process uses an electrical arc and compressed air to apply a zinc coating to ductile iron products.
Emissions are controlled by a high-efficiency baghouse

II.A.21 Diesel-fired Emergency Generator (2018)
Cummins 646 hp emergency generator, installed in 2018, NSPS IIII

II.A.22 Pipe Cleaning Oven Blow Out
Cyclone/baghouse on pipe cleaning system

II.A.23 Pipe Cutting Grinding and Welding
Pipe cutting, grinding and welding (saw rail and welding area baghouse)

II.A.24 Poles Building
Includes painting controlled by paint arrestor filters, wet cutting and drilling, and welding

II.A.25 Poles Flange Saw Building
Includes pole flange saw and a baghouse

Status: In compliance. No unapproved equipment was observed. The sand coating process has been
removed. See the Approval Order below for additional equipment installed.

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II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted facility
as indicated:

II.B.1 Conditions on permitted source (Source-wide).

II.B.1.a Condition:

At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent
practicable, maintain and operate any affected emission units, including associated air pollution control
equipment, in a manner consistent with good air pollution control practice for minimizing emissions.
Determination of whether acceptable operating and maintenance procedures are being used will be based
on information available to the Director which may include, but is not limited to, monitoring results,
opacity observations, review of operating and maintenance procedures, and inspection of the source.
[DAQE-AN107940037-22]. [R307-401-8(2)]

II.B.1.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.a.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. At the time of this inspection, the emission units and associated control devices
appeared to be operating in a manner that minimizes emissions. Activities are documented using a
database that includes a preventative maintenance schedule and tracking.

II.B.1.b Condition:

The permittee shall comply with the applicable requirements for recycling and emission reduction for
class I and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and Emissions Reduction.
[40 CFR 82.150(b)]. [40 CFR 82150(b)]

II.B.1.b.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82, Subpart F.

II.B.1.b.2 Recordkeeping:

All records required in 40 CFR 82, Subpart F shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

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II.B.1.b.3 Reporting:

All reports required in 40 CFR 82, Subpart F shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance. The source certified compliance with this condition in the latest annual compliance
certification.

II.B.1.c Condition:

(1) Opacity caused by fugitive dust shall not exceed 10% at the property boundary, and 20% on site.
[R307-309-5(1)].

(2) The permittee shall comply with the most current fugitive dust control plan approved by the Director.
[R307-309-6].

(3) Opacity requirements shall not apply when the wind speed exceeds 25 miles per hour if the owner or
operator has implemented, and continues to implement, the accepted fugitive dust control plan and
administers one or more of the following contingency measures:

(a) Pre-event watering;

(b) Hourly watering;

(c) Additional chemical stabilization;

(d) Cease or reduce fugitive dust producing operations to the extent practicable. [R307-309-5(3)]

(4) The permittee shall prevent, to the maximum extent possible, and in accordance with R307-309-6,
material from being deposited onto any paved road other a designated deposit site. If materials are
deposited that may create fugitive dust on a public or private pave road, the permittee shall clean the road
promptly. [R307-309-7]

(5) (a) If the permittee is responsible for construction or maintenance of any existing road or has right-of
way easement or possesses the right to use the same whose activities result in fugitive dust from the road,
the permittee shall minimize fugitive dust to the maximum extent possible and in accordance with R307-
309-6. If materials are deposited that may create fugitive dust on a public or private paved road, the
permittee shall clean the road promptly.

(b) Unpaved Roads. If the permittee is responsible for construction or maintenance of any new or existing
unpaved road, the permittee shall prevent, to the maximum extent possible, the deposit of material from
the unpaved road onto any intersecting paved road during construction or maintenance. If materials are
deposited that may create fugitive dust on a public or private paved road, the permittee shall clean the
road promptly.

[AO DAQE-AN107940037-22]. [R307-309, R307-401-8]

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II.B.1.c.1 Monitoring:

(a) For paragraph (1) of the above Condition: In lieu of monitoring via visible emissions
observations, adherence to the most recently approved fugitive dust control plan shall be
monitored to demonstrate that appropriate measures are being implemented to control fugitive
dust.

(b) Recordkeeping shall serve as monitoring for paragraph (2) of the above Condition.

(c) For paragraph (3) of the above Condition: wind speed shall be measured by an anemometer to
identify periods when velocity exceeds 25 mph. [R307-309-5(4)].

(d) Recordkeeping shall serve as monitoring for paragraph (4) of the above Condition.

(e) Recordkeeping shall serve as monitoring for paragraph (5) of the above Condition.

II.B.1.c.2 Recordkeeping:

(a) Records of measures taken to control fugitive dust shall be maintained to demonstrate
compliance with opacity limits.

(b) A copy of the fugitive dust control plan shall be maintained on-site.

(c) Records of measures taken to control fugitive dust shall be maintained to demonstrate
adherence to the most recently approved fugitive dust control plan. Records shall be maintained
in accordance with the plan.

(d) If wind speeds are measured to establish an exception from the visible emissions limits,
records of the administered contingency measures and the wind speed measurements shall be
maintained.

(e) Records shall be maintained as described in Provision I.S.1 of this permit.

II.B.1.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The company has a fugitive dust control plan dated December 20, 2021. The
company has a sweeper for paved surfaces, a watering truck for unpaved areas, and applies slag on
dirt roads where necessary. Records of dust control measures are kept and were provided.

II.B.1.d Condition:

Except in the emergency generators, the permittee shall use only natural gas as a primary fuel. The
emergency generators listed in Emission Units II.A.18 and 19 shall use only pipeline quality natural gas
as fuel for all periods of operation. The emergency generators listed in Emission Units II.A.17 and 21
shall only use diesel fuel (e.g. fuel oil #1, #2 or diesel fuel oil additives) as fuel for all periods of
operation. [DAQE-AN107940037-22]. [R307-401-8]

15
II.B.1.d.1 Monitoring:

The permittee shall monitor both primary and backup fuel usage on a monthly basis. The
permittee may use meter reading, inventory records, purchase records or other appropriate
records. The records shall indicate the reason for using backup fuel (natural gas curtailment,
maintenance, etc.). The ratio of backup fuel usage for maintenance firings to total fuel usage shall
be calculated every year no later January 31.

II.B.1.d.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The main fuel oil tanks have been removed from this site and natural gas is the only
fuel available for the majority of equipment. The only exceptions are the Emergency Recuperator
Generator and the Emergency Generator listed in II.A.21 (for hot metal cranes) which run on
ultra-low sulfur diesel.

II.B.1.e Condition:

Visible emissions shall be no greater than 15 percent opacity and shall be no greater than 10 percent
opacity at the property boundary, unless otherwise specified. [DAQE-AN107940037-22]. [R307-401-8]

II.B.1.e.1 Monitoring:

Unless otherwise specified, a visual opacity survey of each affected emission unit shall be
performed once each day when the unit is operating. The visual opacity survey shall be performed
by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If
visible emissions other than condensed water vapor are observed from an emission unit, an
opacity determination of that emission unit shall be performed by a certified observer within 24
hours of the initial survey. The opacity determination shall be performed in accordance with 40
CFR 60, Appendix A, Method 9 for point sources, and in accordance 40 CFR 51, Appendix M,
Method 203A for fugitive sources.

II.B.1.e.2 Recordkeeping:

The permittee shall record the date of each visual survey. The permittee shall also keep a log of
the following information for each observed visual emission: date and time visual emissions
observed, emission point location and description, time and date of opacity determination, and
percent opacity. The records required by this provision and all data required by 40 CFR 60,
Appendix A, Method 9 or by 40 CFR 51, Appendix M, Method 203A shall be maintained in
accordance with Provision I.S.1 of this permit.

16
II.B.1.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Records of daily visual opacity surveys were checked during inspection with no
deviations discovered.

II.B.1.f Condition:

The permittee shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD),
which has a sulfur content of 15 ppm or less. [DAQE-AN107940037-22]. [R307-401-8]

II.B.1.f.1 Monitoring:

Sulfur content shall be determined either by testing each fuel delivery of fuel oil or by inspection
of the fuel sulfur-content specifications provided by the vendor in purchase records or vendor
provided MSDS sheets. Sulfur content in either instance shall be determined in accordance with
ASTM Method D-4294-89, ASTM Method D-396, or approved equivalent.

II.B.1.f.2 Recordkeeping:

For each fuel load received, the permittee shall maintain either fuel receipt records showing sulfur
content of the delivered fuel or records of all sulfur content testing performed on the delivered
fuel. These records shall be maintained in accordance with Provision I.S.1. of this permit.

II.B.1.f.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Fuel oil deliveries have not contained sulfur content greater than 15 ppm. The latest
delivery was received from Christensen Oil, and a fuel trip ticket indicating sulfur content was
produced.

II.B.1.g Condition:

The permittee shall comply with all applicable requirements in 40 CFR 63, Subpart A and Subpart
ZZZZZ - National Emissions Standards for Hazardous Air Pollutants for Iron and Steel Foundries Area
Sources, but not limited to, the following: the pollution prevention management practices in 40 CFR
63.10885 and 63.10886, standards and management practices in 40 CFR 63.10895(b)-(e), and operation
and maintenance requirements in 40 CFR 63.10896. [40 Subparts A and ZZZZZ]. [40 CFR 63 Subpart A,
40 CFR 63 Subpart ZZZZZ]

II.B.1.g.1 Monitoring:

The permittee shall perform all applicable monitoring and performance test required in 40 CFR
63.10897 and 63.10898. The permittee shall certify, in the annual compliance statement required
in Section I of this permit, its compliance status with the requirements of 40 CFR 63, Subpart
ZZZZZ.

17
II.B.1.g.2 Recordkeeping:

The permittee shall maintain all records required in 40 CFR 63.10899 (a) and 63.10899(b). There
are no additional recordkeeping requirements except as outline in Provision I.S.1 of this permit.

II.B.1.g.3 Reporting:

The permittee shall submit all reports required in 40 CFR 63.10899(b) and 63.10899(d). There are
no additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance. See Subpart ZZZZZ evaluation below. McWane certifies compliance with this
condition in the annual certification. The latest semi-annual fugitive opacity observation report was
received by DAQ on January 16, 2025.

II.B.1.h Condition:

The permittee shall operate a degreasing or solvent cleaning operation in accordance to the state standards
of R307-335-4 with the following requirements:

(1) A cover shall be installed which shall remain closed except during actual loading, unloading or
handling of parts in cleaner. The cover shall be designed so that it can be easily operated with one hand if:
(a) The volatility of the solvent is greater than 2 kPa (15 mm Hg or 0.3 psi) measured at 38 degrees C
(100 degrees F),

(b) The solvent is agitated, or

(c) The solvent is heated.

(2) An internal draining rack for cleaned parts shall be installed on which parts shall be drained until all
dripping ceases. If the volatility of the solvent is greater than 4.3 kPa (32 mm Hg at 38 degrees C (100
degrees F)), the drainage facility must be internal, so that parts are enclosed under the cover while
draining. The drainage facility may be external for applications where an internal type cannot fit into the
cleaning system.

(3) Waste or used solvent shall be stored in covered containers.

(4) Tanks, containers and all associated equipment shall be maintained in good operating condition, and
leaks shall be repaired immediately or the degreaser shall be shutdown.

(5) Written procedures for the operation and maintenance of the degreasing or solvent cleaning equipment
shall be permanently posted in an accessible and conspicuous location near the equipment.

(6) If the solvent volatility is greater than 4.3 kPa (33 mm Hg or 0.6 psi) measured at 38 degrees C (100
degrees F), or if solvent is heated above 50 degrees C (120 degrees F), then one of the following control
devices shall be used:

(a) Freeboard that gives a freeboard ratio greater than 0.7;

(b) Water cover if the solvent is insoluble in and heavier than water); or

(c) Other systems of equivalent control, such as a refrigerated chiller or carbon adsorption.
18
(7) If used, the solvent spray shall be a solid fluid stream at a pressure that does not cause excessive
splashing and may not be a fine, atomized or shower type spray. [R307-335-4]. [R307-335-4]

II.B.1.h.1 Monitoring:

Visual inspections shall be made at least once per semi-annual period to determine compliance
with this condition. Checklists used during each visual inspection shall contain the requirements
for the operation and maintenance of degreasing or solvent cleaning equipment.

II.B.1.h.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.h.3 Recordkeeping:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Semi-annual visual inspections have been performed and recorded. No
discrepancies were noticed in the record.

II.B.1.i Condition:

For all miscellaneous metal parts and products coatings:

(1) The permittee shall not apply coatings with a VOC content greater than the amounts specified in Table
1, unless the permittee uses an add-on control device as specified in R307-350-8.

TABLE 1
METAL PARTS AND PRODUCTS VOC CONTENT LIMITS (values in pounds of VOC per gallon of
coating, minus water and exempt solvents (compounds not classified as VOC as defined in R307-101-2),
as applied)

Coating Category VOC Content Limits (lb/gal)
Air Dried Baked
General One Component 2.8 2.3
General Multi Component 2.8 2.3
Camouflage 3.5 3.5
Electric-Insulating 3.5 3.5
varnish Etching Filler 3.5 3.5
Extreme High-Gloss 3.5 3.0
Extreme Performance 3.5 3.0
Heat-Resistant 3.5 3.0
High-Performance 6.2 6.2
architectural High-Temperature 3.5 3.5
Metallic 3.5 3.5
Military Specification 2.8 2.3
Mold-Seal 3.5 3.5
Pan Backing 3.5 3.5
Prefabricated Architectural 3.5 2.3
Multi-Component Prefabricated Architectural 3.5 2.3
One-Component Pretreatment Coatings 3.5 3.5
19
Repair and Touch Up 3.5 3.0
Silicone Release 3.5 3.5
Solar-Absorbent 3.5 3.0
Vacuum-Metalizing 3.5 3.5
Drum Coating, New, Exterior 2.8 2.8
Drum Coating, New, Interior 3.5 3.5
Drum Coating, Reconditioned, 3.5 3.5
Exterior Drum Coating, Reconditioned, 4.2 4.2
Interior

(2) If more than one content limit indicated in this section applies to a specific coating, then the most
stringent content limit shall apply.

(3) The permittee shall apply VOC containing coatings to metal parts and products unless the coating is
applied with equipment operated according to the equipment manufacturer specifications, and by the use
of one of the following methods:

(a) Electrostatic application;

(b) Flow coat;

(c) Dip/electrodeposition coat;

(d) Roll coat;

(e) Hand Application Methods;

(f) High-volume, low-pressure (HVLP) spray; or

(g) Another application method capable of achieving 65% or greater transfer efficiency equivalent or
better to HVLP spray, as certified by the manufacturer.

(4) The permittee shall implement control techniques and work practices at all times to reduce VOC
emissions. Control techniques and work practices shall include:

(a) Storing all VOC-containing coatings, thinners, and coating-related waste materials in closed
containers, containers with activated carbon or other control method approved by the EPA Administrator;

(b) Ensuring that mixing and storage containers used for VOC-containing coatings, thinners, and coating-
related waste material are kept closed at all times except when depositing or removing these materials,
unless a container has activated carbon or other control method approved by the EPA Administrator;

(c) Minimizing spills of VOC-containing coatings, thinners, and coating-related waste materials;

(d) Conveying VOC-containing coatings, thinners, and coating-related waste materials from one location
to another in closed containers, containers with activated carbon or other control method approved by the
EPA Administrator, or pipes; and

(e) Minimizing VOC emission from cleaning of application, storage, mixing, and conveying equipment
by ensuring that equipment cleaning is performed without atomizing the cleaning solvent and all spent
solvent is captured in closed containers.

20
(5) Solvent cleaning operations shall be performed using cleaning materials having a VOC composite
vapor pressure no greater than 1 mm Hg at 20 degrees Celsius.
[R307-350-2, R307-350-4, R307-350-6, R307-350-7]. [R307-350]

II.B.1.i.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.i.2 Recordkeeping:

Records shall include, but are not limited to, inventory and product data sheets of all coatings and
solvents subject to this condition. Records demonstrating compliance with this condition shall be
maintained in accordance with provisions of Section I.S.1 of this permit and shall be available to
the Director upon request.

II.B.1.i.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. No processes currently fall under this provision. Only non-VOC coatings are used
except for special linings. A water based Winkleman product is the main coating used and does not
contain VOCs. A two stage PermaSafe product is applied to the end of poles and contains a small
amount of VOC when mixed.

II.B.2 Conditions on Cupola.

II.B.2.a Condition:

Emissions of CO shall be no greater than 0.80 lbs/ton of iron melted. [DAQE-AN107940037-22].
[R307-401-8]

II.B.2.a.1 Monitoring:

(a) Stack testing shall be performed as specified here:

(1) Frequency. Emissions shall be tested once every two years. Tests may also be required at the
direction of the Director at any time.

(2) Notification. At least 30 days before the test, the permittee shall submit a source test protocol
to the Director. The source shall attend a pretest conference if determined necessary by the
Director. The source test protocol shall include:

(A) The date, time and place of the proposed test;
(B) The proposed test methodologies;
(C) The stack to be tested;
(D) The procedures to be used;
(E) Any deviation from an EPA-approved test method;
(F) Explanation of any deviation from an EPA-approved test method.

21
(3) Testing. The permittee shall conduct testing according to the approved source test protocol.
The Director may reject emission test data if the test did not follow the approved source test
protocol or if Director was not provided an opportunity to have an observer present at the test.

(4) Standard Conditions and Emission Limit Parameters

(A) Temperature - 68 degrees Fahrenheit (293 K)
(B) Pressure - 29.92 in Hg (101.3 kPa)
(C) Concentration (ppmdv) - 3% oxygen, dry basis
(D) Averaging Time - As specified in the applicable test method

(5) Methods.

(A) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, and Occupational Safety and Health Administration (OSHA) approved
access shall be provided to the test location.
(B) 40 CFR 60, Appendix A, Method 10 shall be used to determine CO emissions;
(C) 40 CFR 60, Appendix A, Method 2 shall be used to determine stack gas velocity and
volumetric flow rate.

(6) Calculations. To determine hourly emission rates (lb/hr, etc.), the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate and
any necessary conversion factors determined by the Director to give the results in the specified
units of the hourly emission limitation. The mass emission rate (lb/ton) shall be calculated by
dividing the hourly emission rate (lb/hr) by the hourly production rate (ton/hr) determined by this
permit.

(7) Test Condition The production rate during all compliance testing shall be no less than 90% of
the maximum production achieved in the previous three (3) years, unless otherwise specified in
the approved source test protocol. If the desired production rate is not achieved at the time of the
test, the maximum production rate shall be 110% of the tested achieved rate, but not more than
the maximum allowable production rate. This new allowable maximum production rate shall
remain in effect until successfully tested at a higher rate. The permittee shall request a higher
production rate when necessary. Testing shall be conducted at no less than 90% of the higher rate.
A new maximum production rate (110% of the new rate) will then be allowed if the test is
successful. This process may be repeated until the maximum allowable production rate is
achieved. During the tests, the permittee shall burn fuels or combinations of fuels, use raw
materials, and maintain process conditions representative of normal operations. In addition, the
permittee shall operate under any other relevant conditions that the Director specifies.

(8) Possible Rejection of Test Results. The Director may reject emissions test data if they are
determined to be incomplete, inadequate, not representative of operating conditions specified for
the test, or if the Director was not provided an opportunity to have an observer present at the test.

(b) Temperature in CO thermal oxidizer shall be used as an indicator to provide a reasonable assurance of
compliance with the CO emission limitation as specified below:

(1) Measurement Approach: CO oxidizer temperature shall be determined by using a thermocouple sensor
located in the oxidizer chamber.

22
(2) Indicator Range: An excursion is defined as a three-hour average of less than 1,500o F as measured by a
thermocouple sensor. Excursions trigger an inspection and review of the CO oxidizer performance as indicated
by other parameters (to confirm if the temperature reading is valid and to determine the CO oxidizer operating
deficiencies), corrective action, and a reporting requirement.

(3) Performance Criteria:

(A) Data Representativeness: Temperature measurements made by a thermocouple sensor shall provide a direct
indicator of CO oxidizer performance. A sensor shall be located in the oxidizer chamber as integral part of
design. The minimum tolerance of the thermocouple is +/- 2%.
(B) QA/QC Practices and Criteria: The accuracy of the thermocouple shall be verified by a second thermocouple
probe. The acceptance criterion is +/- 10%. When the difference between the two thermocouples is greater than
10% of the average of the two thermocouples, both thermocouples shall be changed. This criterion is only valid
during the monitoring periods.
(C) Monitoring Frequency: Temperature shall be monitored continuously when the cupola is in operation.
(D) Data Collection Procedure: Data shall be recorded and stored electronically or may be maintained on strip
charts.
(E) Averaging Period: The data shall be averaged over a three-hour period.

II.B.2.a.2 Recordkeeping:

In addition to the recordkeeping requirement described in Provision I.S.1 of this permit,

(a) The permittee shall maintain a file of all stack testing and all other information required by
permit provision I.S.1.

(b) The permittee shall maintain a file of continuous monitor measurements, including
performance testing measurements, all performance evaluations, all calibration checks, all
adjustments, and maintenance.

(c) The permittee shall maintain a file of the occurrence and duration of any excursion, corrective
actions taken, and any other supporting information required to be maintained under 40 CFR 64
(such as data used to document the adequacy of monitoring, or records of monitoring
maintenance or corrective actions). Instead of paper records, the permittee may maintain records
on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche,
provided that the use of such alternative media allows for expeditious inspection and review, and
does not conflict with other applicable recordkeeping requirements. (40 CFR 64.9(b)).

II.B.2.a.3 Reporting:

In addition to the reporting requirement described in Provision I.S.2 of this permit,

(a) The monitoring report required in Provision I.S.2 of this permit shall include, at a minimum,
the following information, as applicable:

(1) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions taken;(40 CFR
64.9(a)(2)(i))

(2) 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 daily calibration checks, if applicable). (40 CFR 64.9(a)(2)(ii))
23
(b) The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status.

Status: In compliance. Thermal oxidizer temperature is continuously recorded by a data logger. One
excursion was recorded in January, 2024. The CAM summary reports were submitted with each six
month report.

Stack testing was last conducted June 20-21, 2023. Test results were submitted to DAQ and audited
in DAQC-963-23. DAQ calculated results for CO were 0.067 lb/ton of iron melted.

II.B.2.b Condition:

Emissions of NOx shall be no greater than 33 lbs/hr. [DAQE-AN107940037-22]. [R307-401-8]

II.B.2.b.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested once every two years. The source may also be tested at
any time if directed by the Director.

(b) Notification. At least 30 days before the test, the permittee shall submit a source test protocol
to the Director. The source shall attend a pretest conference if determined necessary by the
Director. The source test protocol shall include:

(1) The proposed test methodologies;

(2) The stack to be tested;

(3) The procedures to be used;

(4) Any deviation from an EPA-approved test method;

(5) Explanation of any deviation from an EPA-approved test method.

(c) Testing. The permittee shall conduct testing according to the approved source test protocol.
The Director may reject emission test data if the test did not follow the approved source test
protocol or if Director was not provided an opportunity to have an observer present at the test.

(d) Standard Conditions and Emission Limit Parameters

(1) Temperature - 68 degrees Fahrenheit (293 K)

(2) Pressure - 29.92 in Hg (101.3 kPa)

(3) Concentration (ppmdv) - 3% oxygen, dry basis

(4) Averaging Time - As specified in the applicable test method

(e) Methods.

24
(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, and Occupational Safety and Health Administration (OSHA) approved
access shall be provided to the test location.

(2) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, or 7E shall be used to determine the
pollutant emission rate.

(3) 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow rate.

(f) Calculations. To determine hourly emission rates (lb/hr, etc.), the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate and
any necessary conversion factors determined by the Director to give the results in the specified
units of the hourly emission limitation.

(g) Testing Condition: The production rate during all compliance testing shall be no less than
90% of the maximum production achieved in the previous three (3) years, unless otherwise
specified in the approved source test protocol. If the desired production rate is not achieved at the
time of the test, the maximum production rate shall be 110% of the tested achieved rate, but not
more than the maximum allowable production rate. This new allowable maximum production rate
shall remain in effect until successfully tested at a higher rate. The permittee shall request a
higher production rate when necessary. Testing should be conducted at no less than 90% of the
higher rate. A new maximum production rate (110% of the new rate) will then be allowed if the
test is successful. This process may be repeated until the maximum allowable production rate is
achieved. During the tests, the permittee shall burn fuels or combinations of fuels, use raw
materials, and maintain process conditions representative of normal operations. In addition, the
permittee shall operate under any other relevant conditions that the Director specifies.

(h) Possible Rejection of Test Results. The Director may reject emissions test data if they are
determined to be incomplete, inadequate, not representative of operating conditions specified for
the test, or if the Director was not provided an opportunity to have an observer present at the test.

II.B.2.b.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.2.b.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: In compliance. Stack testing was last conducted on June 20-21, 2023. Test results were submitted to
DAQ and audited in DAQC-963-23. DAQ calculated results for NOX were 16.2 lbs/hr.

II.B.2.c Condition:

Emissions of NOx to the atmosphere from the cupola baghouse shall not exceed 52 tons per rolling 12
months. [DAQE-AN107940037-22]. [R307-401-8]

25
II.B.2.c.1 Monitoring:

(a) By the twentieth day of each month, a new 12-month total shall be calculated using data from
the previous 12 months based on the following equation:

Total NOx = (SUHR * SUEF) + (SSHR * SSEF) + (SDHR * SDEF)

Where:
SUHR = hours of startup operation during the most recent 12 months
SUEF = emission factor for startup operating phase (2.2 lb/hr)
SSHR = hours of steady-state operation during the most recent 12 months
SSEF = emission factor for steady-state operating phase.
SDHR = hours of shutdown operation during the most recent 12 months
SDEF = emission factor for shutdown operating phase (21.2 lbs/hr)

The emission factor for steady-state operation shall be set using the most recent stack test on a
going forward basis.

(b) For purposes of this condition startup, steady-state and shutdown operating phases shall be
monitored and recorded to the nearest tenth of an hour and shall have the following meanings:

Startup operating phase means the time period commencing when blast air (that is, high
temperature air applied to initiate burning) is first put to the coke bed and ending with first iron
(that is, the time that molten iron is first seen through the tuyeres).

Steady-state operating phase means the time period commencing with first iron and ending when
the cupola cap is lowered.

Shutdown operating phase means the time period commencing when the cupola cap is lowered
and ending when the last iron is taken from the cupola.

II.B.2.c.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Records were reviewed during this inspection and indicated 14.07 tons of NOX were
emitted during the 12-month period ending December 31, 2024. The emission factor used in the
calculations appeared correct (taken from most recent stack test).

II.B.2.d Condition:

Emissions of SO2 shall be no greater than 20.7 lb/hr. [DAQE-AN107940037-22]. [R307-401-8]

26
II.B.2.d.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested once every two years. The source may also be tested at
any time if directed by the Director.

(b) Notification. At least 30 days before the test, the permittee shall submit a source test protocol
to the Director. The source shall attend a pretest conference if determined necessary by the
Director. The source test protocol shall include:

(1) The proposed test methodologies;

(2) The stack to be tested;

(3) The procedures to be used;

(4) Any deviation from an EPA-approved test method;

(5) Explanation of any deviation from an EPA-approved test method.

(c) Testing. The permittee shall conduct testing according to the approved source test protocol.
The Director may reject emission test data if the test did not follow the approved source test
protocol or if Director was not provided an opportunity to have an observer present at the test.

(d) Standard Conditions and Emission Limit Parameters

(1) Temperature - 68 degrees Fahrenheit (293 K)

(2) Pressure - 29.92 in Hg (101.3 kPa)

(3) Concentration (ppmdv) - 3% oxygen, dry basis

(4) Averaging Time - As specified in the applicable test method

(e) Methods.

(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, and Occupational Safety and Health Administration (OSHA) approved
access shall be provided to the test location.

(2) 40 CFR 60, Appendix A, Method 6, 6A, 6B, or 6C shall be used to determine the pollutant
emission rate.

(3) 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow rate.

(f) Calculations. To determine hourly emission rates (lb/hr, etc.), the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate and
any necessary conversion factors determined by the Director to give the results in the specified
units of the hourly emission limitation.
(g) Testing Condition. The production rate during all compliance testing shall be no less than
90% of the maximum production achieved in the previous three (3) years, unless otherwise
27
specified in the approved source test protocol. If the desired production rate is not achieved at the
time of the test, the maximum production rate shall be 110% of the tested achieved rate, but not
more than the maximum allowable production rate. This new allowable maximum production rate
shall remain in effect until successfully tested at a higher rate. The permittee shall request a
higher production rate when necessary. Testing shall be conducted at no less than 90% of the
higher rate. A new maximum production rate (110% of the new rate) will then be allowed if the
test is successful. This process may be repeated until the maximum allowable production rate is
achieved. During the tests, the permittee shall burn fuels or combinations of fuels, use raw
materials, and maintain process conditions representative of normal operations. In addition, the
permittee shall operate under any other relevant conditions that the Director specifies.

(h) Possible Rejection of Test Results. The Director may reject emissions test data if they are
determined to be incomplete, inadequate, not representative of operating conditions specified for
the test, or if the Director was not provided an opportunity to have an observer present at the test.

II.B.2.d.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision S.1 in Section I of this permit.

II.B.2.d.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: In compliance. Stack testing was last conducted June 20-21, 2023. Test results were submitted to
DAQ and audited in DAQC-963-23. DAQ calculated results for SO2 were 14.9 lbs/hr.

II.B.2.e Condition:

Emissions of SO2 to the atmosphere from the cupola baghouse shall not exceed 35.58 tons per rolling 12
months. [DAQE-AN107940037-22]. [R307-401-8]

II.B.2.e.1 Monitoring:

(a) By the twentieth day of each month, a new 12-month total shall be calculated using data from
the previous 12 months based on the following equation:

Total SO2 = (SUHR * SUEF) + (SSHR * SSEF) + (SDHR * SDEF)

Where:
SUHR = hours of startup operation during the most recent 12 months
SUEF = emission factor for startup operating phase (2.5 lb/hr)
SSHR = hours of steady-state operation during the most recent 12 months
SSEF = emission factor for steady-state operating phase and shall be set using the most recent
stack test.
SDHR = hours of shutdown operation during the most recent 12 months
SDEF = emission factor for shutdown operating phase (50 lbs/hr)

28
The emission factor for steady-state operation shall be set using the most recent stack test on a
going forward basis.

(b) For purposes of this condition startup, steady-state and shutdown operating phases shall be
monitored and recorded to the nearest tenth of an hour and shall have the following meanings:
Startup operating phase means the time period commencing when blast air (that is, high
temperature air applied to initiate burning) is first put to the coke bed and ending with first iron
(that is, the time that molten iron is first seen through the tuyeres).

Steady-state operating phase means the time period commencing with first iron and ending when
the cupola cap is lowered.

Shutdown operating phase means the time period commencing when the cupola cap is lowered
and ending when the last iron is taken from the cupola.

II.B.2.e.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Records were reviewed during this inspection and indicated 16.16 tons of SO2 were
emitted during the 12-month period ending December 31, 2024. The emission factor used in the
calculations appeared correct (taken from most recent stack test).

II.B.2.f Condition:

Production of melted iron shall be no greater than 85 tons/hour and 205,000 tons per rolling 12-month
period. [DAQE-AN107940037-22]. [R307-401-8]

II.B.2.f.1 Monitoring:

For the annual production limit, within the first 20 days of each month, a 12-month rolling total
shall be determined using records from the previous 12 months. For the hourly limitation, the
recorded daily production value shall be divided by the operating hours of the day and compared
to the limitation. The production and operating hours shall be recorded on a daily basis for all
periods of operation.

II.B.2.f.2 Recordkeeping:

Record of production shall be kept for all periods when the plant is in operation. Results of
monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

29
II.B.2.f.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Records were reviewed during this inspection and showed no production over 85
tons/hr. Maximum hourly production during the prior 12-month period was 48.1 tons. Production
runs roughly 35 to 45 tons per hour. 64,927.43 tons of melted iron were produced during the
12-month period ending December 31, 2024.

II.B.2.g Condition:

Visible emissions shall be no greater than 10 percent opacity from the baghouse.
[DAQE-AN107940037-22]. [R307-401-8]

II.B.2.g.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each day when the
unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions other than steam are observed, an opacity determination of that emission
unit shall be performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method
9 within 24 hours of the initial observation.

II.B.2.g.2 Recordkeeping:

A log of opacity observations shall be maintained in accordance with Provision I.S.1 of this
permit. If an observation indicates visible emissions, a notation of those visible emissions shall be
made in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained
in accordance with Provision I.S.1 of this permit.

II.B.2.g.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Daily observations have been performed and recorded. No excursions were
discovered in the records. No visible emissions were observed coming from the cupola baghouse
during this inspection.

II.B.2.h Condition:

Visible emissions shall be no greater than 10 percent opacity from the reagent silo bin vent.
[Origin: DAQE-AN107940037-22]. [R307-401-8]

30
II.B.2.h.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each week when the
unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions other than steam are observed, an opacity determination of that emission
unit shall be performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method
9 within 24 hours of the initial observation.

II.B.2.h.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60 Appendix A, Method 9 shall also be maintained in
accordance with Provision I.S.1 of this permit.

II.B.2.h.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Weekly observations have been performed and recorded. No excursions were
discovered in the records. No silos were being filled during this inspection.

II.B.3 Conditions on Desulfurization and Ductile System.

II.B.3.a Condition:

Visible emissions shall be no greater than 10 percent opacity from the baghouse.
[DAQE-AN107940037-22]. [R307-401-8]

II.B.3.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each day when the
unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 51, Appendix M, Method 203A within
24 hours of the initial observation.

II.B.3.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 51, Appendix M, Method 203A shall also be maintained
in accordance with Provision I.S.1 of this permit.

31
II.B.3.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Daily observations have been performed and recorded. No excursions were
discovered in the records. No visible emissions were observed during this inspection.

II.B.4 Conditions on Annealing Oven

II.B.4.a Condition:

The amount of seal-coat removed in the annealing oven shall be no greater than 15.9 pounds per day and
shall be no greater than 1,850 pounds per rolling 12-month period. [DAQE-AN107940037-22].
[R307-401-8]

II.B.4.a.1 Monitoring:

When operating, the amount of seal-coat removed in the annealing oven shall be recorded each
day in the operations log. Records shall be kept for all period when the plant is in operation.
Monthly totals shall be determined within the first 20 calendar days of each month, for the
previous month. The total shall then be added to the previous 11 months total for the 12-month
rolling total.

II.B.4.a.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.4.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. This process did not operate in the 12-month period preceding this inspection.

II.B.4.b Condition:

The heat input to the annealing oven shall be no greater than 63.29 MMBtu/hr. [DAQE-AN107940037-22
and SIP.IX.H.13.c.ii]. [R307-110-17, R307-401-8]

II.B.4.b.1 Monitoring:

Total heat input shall be determined by an hourly gas flow meter, natural gas vendor supplier
records, and/or McWane's own testing.

II.B.4.b.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

32
II.B.4.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The company keeps daily records to confirm compliance. No excursions were
recorded or reported. During the 12-month period preceding this inspection, maximum heat input
was 32.0 MMBtu/hr.

II.B.5 Conditions on Core Sand Silo

II.B.5.a Condition:

Visible emissions shall be no greater than 10 percent opacity from the bin vent.
[DAQE-AN107940037-22]. [R307-401-8]

II.B.5.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each week when the
unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24
hours of the initial observation.

II.B.5.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained in
accordance with Provision I.S.1 of this permit.

II.B.5.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Weekly observations have been performed and recorded. No excursions were
discovered in the records.

II.B.6 Conditions on Core Sand Handling and Core Making

II.B.6.a Condition:

Hours of operation shall be no greater than 18 hours per day and shall be no greater than 3,012.5 hours
per rolling 12-month period. [DAQE-AN107940037-22]. [R307-401-8]

33
II.B.6.a.1 Monitoring:

When operating, hours shall be recorded using an hour meter or operations log. Hours shall be
recorded on a daily basis. Monthly totals shall be determined within the first 20 calendar days of
each month, for the previous month. The total shall be than be added to the previous 11 months
total for 12-month rolling total.

II.B.6.a.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.6.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. 1,671.8 hours of operation were recorded during the 12-month rolling period ending
December 31, 2024. The maximum daily limit was not exceeded during this period.

II.B.6.b Condition:

Visible emissions shall be no greater than 10 percent opacity from the baghouse.
[DAQE-AN107940037-22]. [R307-401-8]

II.B.6.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each day when the
unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24
hours of the initial observation.

II.B.6.b.2 Recordkeeping:

A log of opacity observations shall be maintained in accordance with Provision I.S.1 of this
permit. If an observation indicates visible emissions, a notation of those visible emissions shall be
made in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained
in accordance with Provision I.S.1 of this permit.

II.B.6.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Daily observations have been performed and recorded. No excursions were
discovered in the records. No visible emissions were observed during this inspection.

34
II.B.7 Conditions on Sand Coating Process

II.B.7.a Condition:

Sand throughput shall be no greater than 4.6 tons/hour. [DAQE-AN107940037-22]. [R307-401-8]

II.B.7.a.1 Monitoring:

The hourly throughput shall be calculated by dividing daily production throughput by daily
operating hours. The production and operating hours shall be recorded on a daily basis for all
periods of operation.

II.B.7.a.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.7.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Not applicable. This equipment has been removed. McWane Ductile purchases pre-coated sand.

II.B.7.b Condition:

Hours of operation shall be no greater than 18 hours per day and shall be no greater than 1,300 hours per
rolling 12-month period. [DAQE-AN107940037-22]. [R307-401-8]

II.B.7.b.1 Monitoring:

When operating, hours shall be recorded using an hour meter or operations log. Hours shall be
recorded on a daily basis. Monthly total shall be determined within the first 20 calendar days of
each month, for the previous month. The total shall then be added to the previous 11 months' total
to determine the 12-month rolling total.

II.B.7.b.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.7.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Not applicable. This equipment has been removed.

II.B.8 Conditions on Cement Lining Cement Silo

II.B.8.a Condition:

Visible emissions shall be no greater than 10 percent opacity from the bin vent.
[DAQE-AN107940037-22]. [R307-401-8]
35
II.B.8.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each week when the
unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24
hours of the initial observation.

II.B.8.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained in
accordance with Provision I.S.1 of this permit.
II.B.8.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Weekly observations have been performed and recorded. No excursions were
discovered in the records.

II.B.9 Conditions on Cement Lining Sand Silo

II.B.9.a Condition:

Visible emissions shall be no greater than 10 percent opacity from the bin vent.
[DAQE-AN107940037-22]. [R307-401-8]

II.B.9.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each week when the
unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24
hours of the initial observation.

II.B.9.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained in
accordance with Provision I.S.1 of this permit.

36
II.B.9.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Weekly observations have been performed and recorded. No excursions were
discovered in the records.

II.B.10 Conditions on Pipe Coating

II.B.10.a Condition:

State Only Requirement: Emission of VOCs from the finishing paint line shall not exceed 1 ton/day. A
day is defined as a period of 24-hour commencing at midnight and ending at the following night
[SIP.IX.H.13.c.i]. [R307-110-17]

II.B.10.a.1 Monitoring:

Emissions shall be calculated on daily basis when the unit is operating. VOC emissions at the
finishing paint line shall be determined by asphalt paint consumption. Asphalt paint consumption
shall be monitored by liquid level monitoring sensors on the finishing paint line bulk tanks.

II.B.10.a.2 Recordkeeping:

VOC emissions shall be determined by maintaining a record of asphalt paint used each day when
the unit is operating. The records shall include the following data:

(a) Gallons of asphalt paint consumption each day when the unit is operating

(b) Density of asphalt (pounds per gallon).

(c) Percent by weight of VOC in asphalt paint.

(d) The amount of VOC emitted every day, calculated by the following procedure or equivalent
method approved by the Director:

VOC = (% VOC by Weight/100) x (Density lb/gal) x (Gal Consumed) x (1 ton/2,000 lb).

II.B.10.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Only non-VOC paint is used in this process.

II.B.11 Conditions on Special Lining Operation

II.B.11.a Condition:

Hours of operation shall be no greater than 18 hours per day. [DAQE-AN107940037-22]. [R307-401-8]

37
II.B.11.a.1 Monitoring:

When operating, hours shall be recorded using an hour meter or operations log. Hours shall be
recorded on a daily basis.

II.B.11.a.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.11.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Hours of operation have been recorded. No exceedances of the daily limit were
discovered. During the 12-month period preceding this inspection, a maximum of 10 hours of
operation was recorded during one day.

II.B.11.b Condition:

Visible emissions shall be no greater than 10 percent opacity from the baghouse.
[DAQE-AN107940037-22]. [R307-306, R307-401-8]

II.B.11.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each day when the
unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24
hours of the initial observation.

II.B.11.b.2 Recordkeeping:

A log of opacity observations shall be maintained in accordance with Provision I.S.1 of this
permit. If an observation indicates visible emissions, a notation of those visible emissions shall be
made in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained
in accordance with Provision I.S.1 of this permit.

II.B.11.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Daily observations have been performed and recorded. No excursions were
discovered in the records. No visible emissions were observed during this inspection.

II.B.11.c Condition:

Epoxy Linings or other specialty coating shall be applied in accordance with R307-350-6 - Application
Methods. [DAQE-AN107940037-22]. [R307-350, R307-401-8]

38
II.B.11.c.1 Monitoring:

Recordkeeping requirement in this permit condition will serve as monitoring requirements for this
condition.

II.B.11.c.2 Recordkeeping:

Records of paint and epoxy lining application shall be maintained in a supervisor log.

II.B.11.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The exterior of poles lined in the specialty lining operation are coated by hand
application. The interior of the poles are coated with epoxy through a flow coating process. Epoxy is
pressurized through an airless process, not atomized, and a spinning nozzle is robotically pulled
through the poles. The coating is applied from the nozzle very close to the surface, mostly enclosed
by the pole, and with little to no waste.

II.B.12 Conditions on Portable Limespar Silos

II.B.12.a Condition:

Visible emissions shall be no greater than 10 percent opacity from the portable limespar silos.
[DAQE-AN107940037-22]. [R307-401-8]

II.B.12.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each week when the
unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24
hours of the initial observation.

II.B.12.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained in
accordance with Provision I.S.1 of this permit.

II.B.12.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Weekly observations have been performed and recorded during each week the silo
was filled. No excursions were discovered in the records.

39
II.B.13 Conditions on VOC and HAP Emission units.

II.B.13.a Condition:

Plant-wide emissions of VOCs and HAPs shall not exceed:

166.70 tons per rolling 12-month period for VOCs
13.34 tons per rolling 12-month period for HAPs
7.34 tons per rolling 12-month period for Phenol
[DAQE-AN107940037-22]. [R307-401-8]

II.B.13.a.1 Monitoring:

Emissions shall be calculated on a rolling 12-month total. Based on the first day of each month, a
new 12-month total shall be calculated using data from the previous twelve months. Monthly
calculations shall be made no later than 20 days after the end of each calendar month.

II.B.13.a.2 Recordkeeping:

VOC and HAP emissions shall be determined by maintaining a record of VOC and HAP emitting
materials used each month. The records shall include the following data for each material used:

(a) Name of the VOC or HAP emitting material, such as pipe coatings.

(b) Density of each material used (pounds per gallon).

(c) Percent by weight of VOC and HAP in each material used.

(d) Gallons of each VOC and HAP emitting material used each month.

(e) The amount of VOC and individual HAP emitted monthly by each material used, calculated
by the following procedure or equivalent method approved by the Director:
VOC = (% VOC by Weight/100) x (Density lb/gal) x (Gal Consumed) x (1 ton/2,000 lb)

HAP = (% HAP by Weight/100) x (Density lb/gal) x (Gal Consumed) x (1 ton/2,000 lb)

(f) The total amount of VOC and HAP emitted monthly from all materials used.

(g) The amount of VOC and HAP reclaimed for the month shall be similarly quantified and
subtracted from the quantities calculated above, to provide the monthly total VOC and HAP
emissions.

(h) The amount of VOC and HAP emitted monthly from combustion processes shall be estimated
based on production or operations data. The amount of natural gas burned in the cupola CO
oxidizer shall be quantified each month and multiplied by the latest AP-42emission factor to
determine the monthly cupola VOC emissions.

40
II.B.13.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Operator usage is recorded daily and summed monthly, then totals are calculated
based on MSDS values. The 12-month rolling totals through December 31, 2024, were: 30.52 tons of
VOC, 1.77 tons of HAPs, and 0.61 tons of phenol.

II.B.14 Conditions on Miscellaneous.

II.B.14.a Condition:

Visible emissions shall be no greater than 15 percent opacity for the fugitive emission from the casting
building. [DAQE-AN107940037-22]. [R307-401-8]

II.B.14.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each day when the
unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 51, Appendix M, Method 203A within
24 hours of the initial observation.

II.B.14.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 51, Appendix M, Method 203A shall also be maintained
in accordance with Provision I.S.1 of this permit.

II.B.14.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Daily observations have been performed and recorded. No excursions were
discovered in the records. No visible emissions were observed during this inspection.

II.B.15 Conditions on NESHAP Emergency CI Internal Combustion Engine

II.B.15.a Condition:

Visible emissions shall be no greater than 20 percent opacity. [DAQE-AN107940037-22]. [R307-401-8]

41
II.B.15.a.1 Monitoring:

During any period that an emergency generator is operated for longer than 12 hours
consecutively, a visual observation of that generator's exhaust shall be made by an individual
trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The individual is
not required to be a certified visual emissions observer. If any visible emissions other than steam
are observed, then an opacity determination shall be performed in accordance with 40 CFR 60,
Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, by
a certified visible emissions observer. If a generator continues to operate on consecutive days
following the initial observation, an opacity determination shall be performed on a daily basis.

II.B.15.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method
9, or other EPA-approved testing method, as acceptable to the Director, for each determination
shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.15.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Records indicating compliance are kept and were made available. No 12 hour
episodes were recorded in the past year.

II.B.15.b Condition:

At all times the permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. Determination of whether such operation and maintenance procedures are being used
will be based on information available to the Director which may include, but is not limited to, monitoring
results, review of operation and maintenance procedures, review of operation and maintenance records,
and inspection of the source. [40 CFR 63.6595(a), 40 CFR 63.6605(b)]. [40 CFR 63 Subpart ZZZZ]

II.B.15.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.15.b.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

The permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

42
II.B.15.b.3 Reporting:

There are no additional reporting requirements for this provision except those specified in Section
I of this permit.

Status: In compliance. Records indicating compliance are kept and were made available. Maintenance
requirements have been entered into a preventative maintenance database.

II.B.15.c Condition:

The permittee shall comply with the following operating limitations at all times for each emergency
affected emission unit:

(1) The permittee shall operate the affected emission unit according to the requirements in paragraphs
(1)(a) through (1)(c). Any operation other than emergency operation, maintenance and testing, and
operation in non-emergency situations for 50 hours per year, as described in (1)(a) through (1)(c), is
prohibited. If the engine is not operated in accordance with paragraphs (1)(a) through (1)(c), it will not be
considered an emergency engine and shall meet all requirements for non-emergency engines.
(a) There is no time limit on the use of emergency stationary RICE in emergency situations.

(b) Emergency stationary RICE for any combination of the purposes specified in paragraphs (i) through
(iii) of this section for a maximum of 100 hours per calendar year. Any operation for non-emergency
situations as allowed by paragraphs (1)(c) of this section counts as part of the 100 hours per calendar year
allowed by this paragraph (1)(b).

(i) Emergency stationary RICE may be operated for maintenance checks and readiness testing, provided
that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the
regional transmission organization or equivalent balancing authority and transmission operator, or the
insurance company associated with the engine. The permittee may petition the Director for approval of
additional hours to be used for maintenance checks and readiness testing, but a petition is not required if
the permittee maintains records indicating that federal, state, or local standards require maintenance and
testing of emergency RICE beyond 100 hours per calendar year.

(ii) Emergency stationary RICE may be operated for emergency demand response for periods in which
the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability
Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see 40 CFR 63.14),
or other authorized entity as determined by the Reliability Coordinator, has declared an Energy
Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3.

(iii) Emergency stationary RICE may be operated for periods where there is a deviation of voltage or
frequency of 5 percent or greater below standard voltage or frequency.

(c) The permittee may operate up to 50 hours per year in non-emergency situations, but those 50 hours are
counted towards the 100 hours per calendar year provided for maintenance and testing and shall meet the
requirements in 40 CFR 63.6640(f)(4).

(2) The permittee shall meet the following requirements at all times, except during periods of startup:

(a) Change oil and filter every 500 hours of operation or annually, whichever comes first.

(b) Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first;

43
(c) Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.

(3) The permittee have the option to utilize an oil analysis program as described in 40 CFR 63.6625(i) in
order to extend the specified oil change requirement in paragraph (2)(a) of this condition.

(4) During periods of startup the permittee shall minimize the engine's time spent at idle and minimize the
engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30
minutes, after which time the non-startup emission limitations apply.

(5) The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40CFR 63 Subpart ZZZZ.

[40 CFR 63.6595(a)(1), 40 CFR 636603(a), 40 CFR 63.6605(a), 40 CFR63.6625(h), 40 CFR 63.6640(f),
40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2d(4), 40 CFR 63 Subpart ZZZZ Table 2d(footnote 1),
40 CFR 63 Subpart ZZZZ Table 8].

II.B.15.c.1 Monitoring:

The permittee shall install a non-resettable hour meter if one is not already installed.
[40 CFR 63.6625(f)]

If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the management practice requirements on the required schedule or if
performing the management practice on the required schedule would otherwise pose an
unacceptable risk under Federal, State, or local law, the management practice can be delayed until
the emergency is over or the unacceptable risk under Federal, State, or local law has abated. The
management practice shall be performed as soon as practicable after the emergency has ended or
the unacceptable risk under Federal, State, or local law has abated. [40 CFR 63 Subpart ZZZZ
Table 2d Footnote 2]

The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution control practice for minimizing
emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6]

The permittee has the option of utilizing an oil analysis program in order to extend the specified
oil change requirement in accordance with 40 CFR 63.6625(i).

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665].

II.B.15.c.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable.
[40 CFR 63.6655(a)]

44
For each affected emission unit that does not meet the standards applicable to non-emergency
engines, the permittee shall keep records of the hours of operation of the engine that are recorded
through the non-resettable hour meter. The permittee shall document how many hours are spent
for emergency operation; including what classified the operation as emergency and how many
hours are spent for non-emergency operation. If the engines are used for demand response
operation, the permittee shall keep records of the notification of the emergency situation, and the
time the engine was operated as part of demand response. [40 CFR 63.6655(f)]

If additional hours are to be used for maintenance checks and readiness testing, the permittee
shall maintain records indicating that Federal, State, or local standards require maintenance and
testing of emergency RICE beyond 100 hours per year. [40 CFR 63.6640(f)(1)(ii)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]
Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

II.B.15.c.3 Reporting:

The permittee shall report any failure to perform the management practice on the schedule
required and the Federal, State or local law under which the risk was deemed unacceptable. [40
CFR 63 Subpart ZZZZ Table 2d Footnote 2]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665] The permittee shall also
report each instance in which it did not meet the applicable requirements in Table 8. [40 CFR
63.6640(e)]

There are no additional reporting requirements for this provision except those specified in Section
I of this permit.

Status: In compliance. Records indicating compliance are kept and were made available. Maintenance
requirements have been entered into a preventative maintenance database to help ensure
maintenance is performed and recorded as required. The maximum generator run time was 50
hours in calendar year 2024, including maintenance and readiness testing hours.

II.B.16 Conditions on NESHAP Emergency SI Internal Combustion Engines

II.B.16.a Condition:

Visible emissions shall be no greater than 15 percent opacity. [DAQE-AN107940037-22]. [R307-401-8]

45
II.B.16.a.1 Monitoring:

During any period that an emergency generator is operated for longer than 12 hours
consecutively, a visual observation of that generator's exhaust shall be made by an individual
trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The individual is
not required to be a certified visual emissions observer. If any visible emissions other than steam
are observed, then an opacity determination shall be performed in accordance with 40 CFR 60,
Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, by
a certified visible emissions observer. If a generator continues to operate on consecutive days
following the initial observation, an opacity determination shall be performed on a daily basis.

II.B.16.a.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method
9, or other EPA-approved testing method, as acceptable to the Director, for each determination
shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.16.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Records indicating compliance are kept and were made available. No 12 hour
episodes were recorded in the past year.

II.B.16.b Condition:

At all times the permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. Determination of whether such operation and maintenance procedures are being used
will be based on information available to the Director which may include, but is not limited to, monitoring
results, review of operation and maintenance procedures, review of operation and maintenance records,
and inspection of the source. [40 CFR 63.6595(a), 40 CFR 63.6605(b)]. [40 CFR 63 Subpart ZZZZ]

II.B.16.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.16.b.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

The permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

46
II.B.16.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Records indicating compliance are kept and were made available. Maintenance
requirements have been entered into a preventative maintenance database to help ensure
maintenance is performed and recorded as required.

II.B.16.c Condition:

The permittee shall comply with the following operating limitations at all times for each emergency
affected emission unit:

(1) The permittee shall operate the affected emission unit according to the requirements in paragraphs
(1)(a) through (1)(c). Any operation other than emergency operation, maintenance and testing, and
operation in non-emergency situations for 50 hours per year, as described in 1.a through 1.c, is prohibited.
If the engine is not operated in accordance with paragraphs (1)(a) through (1)(c), it will not be considered
an emergency engine and shall meet all requirements for non-emergency engines.

(a) There is no time limit on the use of emergency stationary RICE in emergency situations.

(b) Emergency stationary RICE for any combination of the purposes specified in paragraphs (i) through
(iii) of this section for a maximum of 100 hours per calendar year. Any operation for non-emergency
situations as allowed by paragraphs (1)(c) of this section counts as part of the 100 hours per calendar year
allowed by this paragraph (1)(b).

(i) Emergency stationary RICE may be operated for maintenance checks and readiness testing, provided
that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the
regional transmission organization or equivalent balancing authority and transmission operator, or the
insurance company associated with the engine. The permittee may petition the Director for approval of
additional hours to be used for maintenance checks and readiness testing, but a petition is not required if
the permittee maintains records indicating that federal, state, or local standards require maintenance and
testing of emergency RICE beyond 100 hours per calendar year.

(ii) Emergency stationary RICE may be operated for emergency demand response for periods in which
the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability
Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see 40 CFR 63.14),
or other authorized entity as determined by the Reliability Coordinator, has declared an Energy
Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3.

(iii) Emergency stationary RICE may be operated for periods where there is a deviation of voltage or
frequency of 5 percent or greater below standard voltage or frequency.

(c) The permittee may operate up to 50 hours per year in non-emergency situations, but those 50 hours are
counted towards the 100 hours per calendar year provided for maintenance and testing and shall meet the
requirements in 40 CFR 63.6640(f)(4).

(2) The permittee shall meet the following requirements at all times, except during periods of startup:

(a) Change oil and filter every 500 hours of operation or annually, whichever comes first.

47
(b) Inspect spark plugs every 1,000 hours of operation or annually, whichever comes first, and replace as
necessary;

(c) Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.

(3) The permittee have the option to utilize an oil analysis program as described in 40 CFR 63.6625(j) in
order to extend the specified oil change requirement in paragraph (2)(a) of this condition.

(4) During periods of startup the permittee shall minimize the engine's time spent at idle and minimize the
engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30
minutes, after which time the non-startup emission limitations apply.

(5) The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ.

[40 CFR 63.6595(a)(1), 40 CFR 636603(a), 40 CFR 63.6605(a), 40 CFR 63.6625(h), 40 CFR 63.6640(f),
40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2d(5), 40 CFR 63 Subpart ZZZZ Table 2d(footnote 1),
40 CFR 63 Subpart ZZZZ Table 8]. [40 CFR 63 Subpart ZZZZ]

II.B.16.c.1 Monitoring:

The permittee shall install a non-resettable hour meter if one is not already installed.
[40 CFR 63.6625(f)]

If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the management practice requirements on the required schedule or if
performing the management practice on the required schedule would otherwise pose an
unacceptable risk under Federal, State, or local law, the management practice can be delayed until
the emergency is over or the unacceptable risk under Federal, State, or local law has abated. The
management practice shall be performed as soon as practicable after the emergency has ended or
the unacceptable risk under Federal, State, or local law has abated. [40 CFR 63 Subpart ZZZZ
Table 2d Footnote 2]

The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution control practice for minimizing
emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6]

The permittee has the option of utilizing an oil analysis program in order to extend the specified
oil change requirement in accordance with 40 CFR 63.6625(j).

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665].

II.B.16.c.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

48
For each affected emission unit that does not meet the standards applicable to non-emergency
engines, the permittee shall keep records of the hours of operation of the engine that are recorded
through the non-resettable hour meter. The permittee shall document how many hours are spent
for emergency operation; including what classified the operation as emergency and how many
hours are spent for non-emergency operation. If the engines are used for demand response
operation, the permittee shall keep records of the notification of the emergency situation, and the
time the engine was operated as part of demand response. [40 CFR 63.6655(f)]

If additional hours are to be used for maintenance checks and readiness testing, the permittee
shall maintain records indicating that Federal, State, or local standards require maintenance and
testing of emergency RICE beyond 100 hours per year. [40 CFR 63.6640(f)(1)(ii)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

II.B.16.c.3 Reporting:

The permittee shall report any failure to perform the management practice on the schedule
required and the Federal, State or local law under which the risk was deemed unacceptable. [40
CFR 63 Subpart ZZZZ Table 2d Footnote 2]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665] The permittee shall also
report each instance in which it did not meet the applicable requirements in Table 8. [40 CFR
63.6640(e)]

There are no additional reporting requirements for this provision except those specified in Section
I of this permit.

Status: In compliance. Records confirm compliance with this condition. The company performs
maintenance on a preventative and as needed basis. A computerized work order system is in place
to track all maintenance activities. Maximum generator run time was 50 hours in calendar year
2024, including maintenance and readiness testing hours.

49
II.B.17 Conditions on NSPS SI Emergency Internal Combustion Engine

II.B.17.a Condition:

(1) The permittee shall comply with the emission standards in Table 1 of 40 CFR 60 Subpart JJJJ.

(2) The permittee shall operate and maintain affected emission units that achieve the emission standards
as required in this condition over the entire life of the engine.

(3) For emergency stationary SI ICE, the permittee shall not install engines that do not meet the
applicable requirements of this condition after January 1, 2011. This requirement does not apply to units
that have been modified or reconstructed, and it does not apply to engines that were removed from one
existing location and reinstalled at a new location.

(4) The air-to-fuel ratio (AFR) controller shall be maintained and operated appropriately in order to
ensure proper operation of affected emission units and control device to minimize emissions at all times.
[40 CFR 63 Subpart ZZZZ, 40 CFR 60.4233(d), 40 CFR 60.4234, 40 CFR 60.4236(c), 40 CFR
60.4236(e), 40 CFR 60.4243(g)]. [40 CFR 60 Subpart JJJJ]

II.B.17.a.1 Monitoring:

The permittee shall demonstrate compliance with the emission standards according to one of the
methods specified in (a) and (b) below.

(a) Purchasing an engine certified according to procedures specified in 40 CFR Subpart JJJJ, for
the same model year and demonstrating compliance according to one of the methods specified in
paragraph (1) and (2).

(1) If the permittee operates and maintains the certified stationary SI internal combustion engine
and control device according to the manufacturer's emission-related written instructions, the
permittee shall keep records of conducted maintenance to demonstrate compliance, but no
performance testing is required. The permittee shall also meet the requirements as specified in 40
CFR part 1068, subparts A through D, as they apply. If the permittee adjusts engine settings
according to and consistent with the manufacturer's instructions, the affected emission unit will
not be considered out of compliance.

(2) If the permittee does not operate and maintain the certified stationary SI internal combustion
engine and control device according to the manufacturer's emission-related written instructions,
the engine will be considered a non-certified engine, and the permittee shall demonstrate
compliance according to (2)(i) below.

(i) If the affected emission unit is less than 100 HP, the permittee shall keep a maintenance plan
and records of conducted maintenance to demonstrate compliance and shall, to the extent
practicable, maintain and operate the engine in a manner consistent with good air pollution
control practice for minimizing emissions, but no performance testing is required.
(40 CFR 60.4243(b)(1), 40 CFR 60.4243(a))

50
(b) Purchasing a non-certified engine and demonstrating compliance with the emission standards
according to the testing requirements specified in 40 CFR 60.4244, as applicable. If the affected
emission unit is greater than 25 HP and less than or equal to 500 HP, the permittee shall keep a
maintenance plan and records of conducted maintenance and shall, to the extent practicable,
maintain and operate the engine in a manner consistent with good air pollution control practice
for minimizing emissions. In addition, the permittee shall conduct an initial performance test to
demonstrate compliance.
(40 CFR 60.4243(b)(2)).

II.B.17.a.2 Recordkeeping:

For each affected emission unit, the permittee shall keep records of the information in paragraphs
(a) through (d).

(a) All notifications submitted to comply with this condition and all documentation supporting
any notification.

(b) Maintenance conducted on the engine.

(c) If the stationary SI ICE is a certified engine, documentation from the manufacturer that the
engine is certified to meet the emission standards and information as required in 40 CFR parts 90,
1048, 1054, and 1060, as applicable.

(d) If the stationary SI ICE is not a certified engine or is a certified engine operating in a non-
certified manner and subject to II.B.16.a.1(a)(2), documentation that the engine meets the
emission standards. (Origin: 40 CFR 60.4245(a))
Records and results of monitoring shall be maintained in accordance with Provision I.S.1 of this
permit.

II.B.17.a.3 Reporting:

For stationary SI ICE that are subject to performance testing, the permittee shall submit a copy of
each performance test as conducted in 40 CFR 60.4244 within 60 days after the test has been
completed. (40 CFR 60.4245(d))

There are no additional reporting requirements for this provision except those specified in Section
I of this permit.

Status: In compliance. Only DAQ approved engines have been installed. Engines are operated and
maintained according to manufacturer’s recommendations. Records are kept.

II.B.17.b Condition:

Emergency stationary ICE shall be operated as specified in 40 CFR 60.4243(d).
[40 CFR 63 Subpart ZZZZ, 40 CFR 60.4243(d), 40 CFR 60.4243(e)]. [40 CFR 60 Subpart JJJJ]

II.B.17.b.1 Monitoring:

The permittee shall install a non-resettable hour meter upon startup of the emergency engine.

51
II.B.17.b.2 Recordkeeping:

The permittee shall keep records of the hours of operation of the affected emission unit that is
recorded through the non-resettable hour meter.

The permittee shall document how many hours are spent for emergency operation, including what
classified the operation as emergency and how many hours are spent for non-emergency
operation. (40 CFR 60.4245(b))

Records shall be maintained as described in Provision I.S.1 of this permit.

II.B.17.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Non-resettable hour meters are installed.

II.B.17.c Condition:

Visible emissions shall be no greater than 15 percent opacity. [DAQE-AN107940037-22]. [R307-401-8]

II.B.17.c.1 Monitoring:

During any period that an emergency generator is operated for longer than 12 hours
consecutively, a visual observation of that generator's exhaust shall be made by an individual
trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The individual is
not required to be a certified visual emissions observer. If any visible emissions other than steam
are observed, then an opacity determination shall be performed in accordance with 40 CFR 60,
Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, by
a certified visible emissions observer. If a generator continues to operate on consecutive days
following the initial observation, an opacity determination shall be performed on a daily basis.

II.B.17.c.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method
9, or other EPA-approved testing method, as acceptable to the Director, for each determination
shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.17.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Records indicating compliance are kept and were made available. No 12 hour
episodes were recorded in the past year.

52
II.B.18 Conditions on Zinc Thermal Spray Process

II.B.18.a Condition:

The amount of zinc wire used in the zinc process shall be no greater than 3,241 tons per rolling 12-month
period. [DAQE-AN107940037-22]. [R307-401-8]

II.B.18.a.1 Monitoring:

When operating, the amount of zinc wire used shall be recorded each day in the operations log.
Monthly totals shall be determined within the first 20 calendar days of the month, for the previous
month. The total shall then be added to the previous 11 months' total to determine the 12-month
rolling total.

II.B.18.a.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.18.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Records of zinc wire used are maintained. 80.0 tons of wire were used during the
12-month period ending December 31, 2024.

II.B.18.b Condition:

Visible emissions shall be no greater than 10 percent opacity from the baghouse.
[DAQE-AN107940037-22]. [R307-401-8]

II.B.18.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each day when the
unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24
hours of the initial observation.

II.B.18.b.2 Recordkeeping:

A log of opacity observations shall be maintained in accordance with Provision I.S.1 of this
permit. If an observation indicates visible emissions, a notation of those visible emissions shall be
made in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained
in accordance with Provision I.S.1 of this permit.

53
II.B.18.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Visual observations have been performed and recorded each day of operation.

II.B.19 Conditions on Diesel-fired Emergency Generator (2018)

II.B.19.a Condition:

Emergency generators shall use diesel fuel that meets the requirements of 40 CFR 1090.305 for nonroad
diesel fuel.

[40 CFR 60.4207(b)]. [40 CFR 60 Subpart IIII]

II.B.19.a.1 Monitoring:

The permittee shall either:

(a) Determine the fuel sulfur content expressed as wt% in accordance with the
methods of the American Society for Testing Materials (ASTM);

(b) Inspect the fuel sulfur content expressed as wt% determined by the vendor
using methods of the ASTM; or

(c) Inspect documentation provided by the vendor that directly or indirectly
demonstrates compliance with this provision.

II.B.19.a.2 Recordkeeping:

Fuel receipt records and documentation demonstrating compliance with this provision shall be
maintained. [40 CFR 60 Subpart IIII].

Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.19.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Diesel fuel meeting the standards listed above are used.

II.B.19.b Condition:

The permittee shall operate the emergency affected emission unit according to the requirements in
paragraphs (1) through (3). In order for the engine to be considered an emergency stationary ICE under 40
CFR 60 Subpart IIII, any operation other than emergency operation, maintenance and testing, and
operation in non-emergency situations for 50 hours per year, as described in (1) through (3), is prohibited.
If the engine is not operated in accordance with paragraphs (1) through (3), it will not be considered an
emergency engine and shall meet all requirements for non-emergency engines.

54
(1) There is no time limit on the use of emergency stationary ICE in emergency situations.

(2) Emergency stationary ICE may be operated for any combination of the purposes specified in
paragraph (a) for a maximum of 100 hours per calendar year. Any operation for non-emergency situations
as allowed by paragraph (3) counts as part of the 100 hours per calendar year allowed by this paragraph

(a) Emergency stationary ICE may be operated for maintenance checks and readiness testing, provided
that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the
regional transmission organization or equivalent balancing authority and transmission operator, or the
insurance company associated with the engine. A petition for approval of additional hours to be used for
maintenance checks and readiness testing is not required if the permittee maintains records indicating that
federal, state, or local standards require maintenance and testing of emergency ICE beyond 100 hours per
calendar year.

(3) Emergency engines may operate up to 50 hours per calendar year in non-emergency situations. The 50
hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for
maintenance and testing provided in paragraph (2). Except as provided in paragraph (3)(a), the 50 hours
per calendar year for non-emergency situations cannot be used for peak shaving or non-emergency
demand response, or to generate income for the permittee to an electric grid or otherwise supply power as
part of a financial arrangement with another entity.

(a) The 50 hours per year for non-emergency situations can be used to supply power as part of a financial
arrangement with another entity if all of the following conditions are met:

(i) The engine is dispatched by the local balancing authority or local transmission and distribution system
operator;

(ii) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert
potential voltage collapse or line overloads that could lead to the interruption of power supply in a local
area or region.

(iii) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC,
regional, state, public utility commission or local standards or guidelines.

(iv) The power is provided only to the permittee itself or to support the local transmission and distribution
system.

(v) The permittee identifies and records the entity that dispatches the engine and the specific NERC,
regional, state, public utility commission or local standards or guidelines that are being followed for
dispatching the engine. The local balancing authority or local transmission and distribution system
operator may keep these records on behalf of the permittee. [40 CFR 60.4211(f), 40 CFR 63 Subpart
ZZZZ]. [40 CFR 60 Subpart IIII]

II.B.19.b.1 Monitoring:

The permittee shall install a non-resettable hour meter upon startup of the emergency engine.

55
II.B.19.b.2 Recordkeeping:

Records of monitoring shall be kept on a monthly basis in an operation and maintenance log.
Records shall distinguish between maintenance-related hours and emergency use-related hours. If
maintenance and testing of a generator beyond 100 hours per calendar year are required by
Federal, State, or local standards, records of these standards shall also be kept. The permittee shall
record the time of operation of each engine and the reason the engine was in operation during that
time. [40 CFR 60.4211(e), and 40 CFR 60.4214(b)].
If an affected emission unit does not meet the standards applicable to non-emergency engines, the
permittee shall keep records of the operation of the engine in emergency and non-emergency
service that are recorded through the non-resettable hour meter. The permittee shall record the
time of operation of the engine and the reason the engine was in operation during that time.
Records shall be maintained as described in Provision I.S.1 of this permit. [40 CFR 60.4211(e),
and 40 CFR 60.4214(b)]. [40 CFR 60 Subpart IIII]

II.B.19.b.3 Reporting:

If the permittee operates the engine for the purposes specified in Condition II.B.19.b(3) (40 CFR
60.4211(f)(3)(i)), the permittee shall submit an annual report according to the requirements in
paragraphs (i) through (iii) below.

(a) The report shall contain the following information:

(1) Company name and address where the engine is located.

(2) Date of the report and beginning and ending dates of the reporting period.

(3) Engine site rating and model year.

(4) Latitude and longitude of the engine in decimal degrees reported to the fifth decimal place.

(5) Hours spent for operation for the purposes specified in Condition II.B.19.b(3)(a) (40 CFR
60.4211(f)(3)(i)), including the date, start time, and end time for engine operation for the
purposes specified in Condition II.B.18.b(3)(a) (40 CFR 60.4211(f)(3)(i)). The report shall also
identify the entity that dispatched the engine and the situation that necessitated the dispatch of the
engine.

(b) The first annual report shall cover the calendar year 2021 and shall be submitted no later than
March 31, 2022. Subsequent annual reports for each calendar year shall be submitted no later than
March 31 of the following calendar year.

(c) The annual report shall be submitted electronically using the subpart specific reporting form in
the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's
Central Data Exchange (CDX) (www.epa.gov/cdx). However, if the reporting form specific to
this subpart is not available in CEDRI at the time that the report is due, the written report shall be
submitted to the Administrator at the appropriate address listed in 40 CFR 60.4. (Origin: 40 CFR
60.4214(d)).

Status: In compliance. Records confirm compliance with this condition. Non-resettable hour meters are
installed. Engines are not operated for maintenance and readiness testing, and non-emergency
situations for more than 100 hours per calendar year.

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II.B.19.c Condition:

The permittee shall operate and maintain the engine that achieve the emission standards as required in 40
CFR 60.4205 over the entire life of the engine.

[40 CFR 60.4205]. [40 CFR 60 Subpart IIII]

II.B.19.c.1 Monitoring:

(a) The permittee shall operate and maintain the engine and control device according to the
manufacturer emissions-related written instructions, over the entire life of the associated engine.
The permittee may only change those settings that are permitted by the manufacturer. The
permittee shall also meet the requirements of 40 CFR Part 89, 94 and/or 1068, as they apply.

(b) If the permittee does not install, configure, operate, and maintain the engine and control
device according to the manufacturer's emission-related written instructions, or change emission-
related settings in a way that is not permitted by the manufacturer, The permittee shall keep a
maintenance plan and records of conducted maintenance and shall, to the extent practicable,
maintain and operate the engine in a manner consistent with good air pollution control practice
for minimizing emissions. In addition, the permittee shall conduct an initial performance test to
demonstrate compliance with the applicable emission standards within 1 year of startup, or within
1 year after an engine and control device is no longer installed, configured, operated, and
maintained in accordance with the manufacturer's emission-related written instructions, or within
1 year after the permittee change emission-related settings in a way that is not permitted by the
manufacturer. The permittee shall conduct subsequent performance testing every 8,760 hours of
engine operation or 3 years, whichever comes first, thereafter to demonstrate compliance with the
applicable emission standards. [40 CFR 60.4206, 40 CFR 60.4211(a)(1)-(3), 40 CFR
60.4211(g)(3)]. [40 CFR 60 Subpart IIII]

II.B.19.c.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.
II.B.19.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Engines are operated and maintained according to manufacturer’s
recommendations. Records are kept.

II.B.19.d Condition:

Visible emissions shall be no greater than 20 percent opacity. [DAQE -AN107940037-22]. [R307-401-8]

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II.B.19.d.1 Monitoring:

During any period that an emergency generator is operated for longer than 12 hours
consecutively, a visual observation of that generator's exhaust shall be made by an individual
trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The individual is
not required to be a certified visual emissions observer. If any visible emissions other than steam
are observed, then an opacity determination shall be performed in accordance with 40 CFR 60,
Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the Director, by
a certified visible emissions observer. If a generator continues to operate on consecutive days
following the initial observation, an opacity determination shall be performed on a daily basis.

II.B.19.d.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A, Method
9, or other EPA-approved testing method, as acceptable to the Director, for each determination
shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.19.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Records indicating compliance are kept and were made available. No 12 hour
episodes were recorded in the past year.

II.B.20 Conditions on Pipe Cleaning Blow Out

II.B.20.a Condition:

Visible emissions shall be no greater than 10 percent opacity from the baghouse.
[DAQE-AN107940037-22]. [R307-401-8]

II.B.20.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each day when the
unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24
hours of the initial observation.

II.B.20.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained in
accordance with Provision I.S.1 of this permit.

58
II.B.20.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Daily observations have been performed and recorded. No excursions were
discovered in the records.

II.B.21 Conditions on Pipe Cutting Grinding and Welding

II.B.21.a Condition:

Visible emissions shall be no greater than 10 percent opacity from the baghouse.
[DAQE-AN107940037-22]. [R307-401-8]

II.B.21.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each day when the
unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24
hours of the initial observation.

II.B.21.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained in
accordance with Provision I.S.1 of this permit.

II.B.21.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Daily observations have been performed and recorded. No excursions were
discovered in the records. No visible emissions were observed during this inspection.

II.B.22 Conditions on Poles Building

II.B.22.a Condition:

Visible emissions shall be no greater than 15 percent opacity for the fugitive emission from the Poles
building. [DAQE-AN107940037-22]. [R307-309-4, R307-401-8]

59
II.B.22.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each day when the
unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 51, Appendix M, Method 203A within
24 hours of the initial observation.

II.B.22.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 51, Appendix A, Method 203A shall also be maintained
in accordance with Provision I.S.1 of this permit.

II.B.22.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Daily observations have been performed and recorded. No excursions were
discovered in the records. No visible emissions were observed during this inspection.

II.B.22.b Condition:

The coating shall be applied in accordance with R307-350-5 - VOC Content Limits and R307-350-6 -
Application Methods. [DAQE-AN107940037-22]. [R307-350, R307-401-8]

II.B.22.b.1 Monitoring:

Recordkeeping requirement in this permit condition will serve as monitoring requirements for this
condition.

II.B.22.b.2 Recordkeeping:

Records of coating materials and application methods shall be maintained in a supervisor log.

II.B.22.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. McWane uses a Grayco XP70 airless paint system, which is certified by the
manufacturer to achieve a transfer efficiency greater than 65%.

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II.B.23 Conditions on Poles Flange Saw Building

II.B.23.a Condition:

Visible emissions shall be no greater than 10 percent opacity from the baghouse.
[DAQE-AN107940037-22]. [R307-401-8]

II.B.23.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each day when the
unit is operating by an individual trained on the observation procedures of 40 CFR 60, Appendix
A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24
hours of the initial observation.

II.B.23.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained in
accordance with Provision I.S.1 of this permit.

II.B.23.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Daily observations have been performed and recorded. No excursions were
discovered in the records. No visible emissions were observed during this inspection.

II.C Emissions Trading.

Not applicable to this source.

II.D Alternative Operating Scenarios.

Not applicable to this source.

II.E Source-specific Definitions.

Not applicable to this source.

II.C Emissions Trading

Not applicable to this source.

II.D Alternative Operating Scenarios.

Not applicable to this source.

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II.E Source-specific Definitions.

Not applicable to this source.

40 CFR 63 Subpart ZZZZZ NESHAP for HAP for Iron and Steel Foundries Area Sources

63.10880 – Subpart (b)(1) and (f) applies. McWane is an existing large metal foundry.

63.10881 – What are my compliance dates?

Status: In compliance. McWane complies with the compliance dates listed in this Subpart.

63.10885 – What are my management practices for metallic scrap and mercury switches?

(a) Metallic scrap management program

Status: In compliance. McWane complies with (a)(2)(ii) Metallic scrap management program for
general iron and steel scrap. A written material specifications for purchase is used for compliance
(Revision 2 dated January 2016). For scrap charged to the cupola with an afterburner, McWane
uses a program to ensure materials are drained free of liquids.

(b) Mercury requirements

Status: In compliance. On January 22, 2010, McWane (Pacific States) submitted a NOC for
Management Practices for Mercury. McWane chose option (2)(b) by participating in and
purchasing motor vehicles scrap only from scrap providers who participate in a program for
removal of mercury switches and has prepared a plan for participation in the EPA approve
program. McWane uses a broker that certifies compliance (certification dates are February 4,
2020).

63.10886 – What are my management practices for binder formulations?

Status: Not applicable. McWane does not operate a furfuryl alcohol warm box.

63.10895 – Requirements for New and Existing Affected Sources Classified as Large Iron and Steel
Foundries - What are my standards and management practices?

Status: In compliance. McWane complies with the pollution prevention management practices of
63.10885 (see above). McWane uses a baghouse and oxidizer to control the cupola as required by
Subpart (b). The NOC was sent February 1, 2011. For the PM emission limit, McWane complies
with (c)(1) by not exceeding 0.8 lbs of PM per ton of metal charged. The last test was completed
June 20-21, 2023. DAQ calculated result of the test were 0.01 lb/ton. See DAQC-963-23. McWane
complies with the 20% opacity limit for fugitive emissions. Method 9 and 22 observations are
performed daily and every six months to confirm compliance.

63.10896 – What are my operations and maintenance requirements?

Status: In compliance. McWane uses an O&M plan for each control device (dated December 17,
2010, and revised February 2017).

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63.19897- What are my monitoring requirements?

Status: In compliance. McWane complies with (a)(1)(i) and (ii) by inspecting ductwork monthly
and baghouses either weekly or monthly. Records confirm compliance with the monthly visual
inspections. McWane does not use bag leak detection. McWane does not use emissions averaging.

63.10898 – What are my performance test requirements?

Status: In compliance. The initial performance test occurred in 2015. McWane completes
subsequent performance tests at least every 5 years. See 63.10895 above. Semi-annual fugitive
opacity observations have been performed, recorded, and reported to DAQ.

63.10899 – What are my recordkeeping and reporting requirements?

Status: In compliance with recordkeeping requirements. No determination made for reporting
requirements. Records are maintained on-site for at least 5 years. Monthly ductwork inspections
have been performed and recorded. Baghouse inspections have been performed either weekly or
monthly instead of semi-annually. McWane does not have monitors so (c)(1) and (2) do not apply.
After March 9, 2021, semiannual compliance reports are no longer required to be submitted to the
administrator, but to the USEPA through CEDRI.

Approval Order DAQE-AN107940040-0040-25

Only conditions not listed in the Title V Operating Permit above are listed below.

I.8 The owner/operator shall submit documentation of the status of construction of the new equipment in Section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]
Status: McWane has 18-months from the date of this AO to submit this notification.

II.A.7 Charge Handling and Casting Operations (NEW)
Includes casting operations baghouse & five casting machines
II.A.27 Cold-Cure Core Making
Controls: bin vent and packed-bed scrubber
Status: II.A.27 was added through a 2023 AO and has been installed. The Charge Handling and
Casting Operations have not been installed.

63
II.B.1.b Visible emissions from the following emission points shall not exceed the following values:
A. All baghouses - 10% opacity
B. Casting area hoods fugitive emissions - 15% opacity
C. 10% opacity at the property boundary
D. 20% for all diesel-fired emergency generators
E. All other points - 15% opacity.
[40 CFR 60]
II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. Opacity observations of emissions from fugitive sources shall be conducted according to 58 FR 61640 Method 203A. [40 CFR 60]
Status: In compliance. Unless otherwise noted, source wide opacity surveys are performed and
recorded daily. Opacity observations on diesel generators are performed per Title V Operating
Permit requirements when generators operate for longer than 12-hours at one time. Semi-annual
Subpart ZZZZZ observations have been performed and reported to DAQ. No opacity was observed
during this inspection.

EMISSION INVENTORY: Taken from DAQ’s 2023 emission inventory database:

Pollutant Emissions (t/yr controlled)
PM10 16.51
PM2.5 13.39
SOX 3.45
NOX 40.95
CO 24.85
VOC 19.24
NH3 1.07

PREVIOUS ENFORCEMENT
ACTIONS: Warning – January 31, 2022, for a II.B.14.a opacity exceedance

COMPLIANCE
ASSISTANCE: None requested.

COMPLIANCE STATUS &
RECOMMENDATIONS: McWane Ductile should be considered in compliance with the evaluated
Conditions of the Title V permit, Approval Order, and 40 CFR 63
Subpart ZZZZZ.

HPV STATUS: Not applicable

RECOMMENDATION FOR
NEXT INSPECTION: None

ATTACHMENT: VEO form