                                  ENCLOSURE 1
        Facility Questionnaire for Electric Arc Furnace Steelmaking[,]

Part A.  Facility Information

1. 	Name and address of the PARENT COMPANY that owns the facility:
North American Stainless	
6870 Highway 42 East	
Ghent, KY 41045	

2. 	Name and address of legal OPERATOR of the facility, if different than the legal OWNER
	
	
	
	

3. 	Complete street address of facility (physical location) and latitude/longitude (in decimal degrees to 6 decimal places):
a. 	Address:  6870 Highway 42 East		
b. 	City: Ghent	
c. 	State: KY	
d. 	Zip: 41045	
e. 	County: Carroll	
f.	Latitude:  38.728209	
g.   Longitude:  -85.07555	
      
4. 	Provide mailing address of the facility if different than physical location: 
a. 	Address: 	
b. 	City: 	
c. 	State: 	
d. 	Zip: 	

5. 	Facility contact able to answer technical questions about the completed survey:
a. 	Name (First Name, Last Name): Maria Eichelberger	
b. 	Title: Environmental Manager	
c. 	Telephone number:  _____502-347-6534______________________   ext. 	
d. 	Fax number: 502-347-6607	
e. 	E-mail: meichelberger@northamericanstainless.com	
6. 	Is the facility a major source of hazardous air pollutant (HAP) emissions? (CHECK one)  (A definition of size classification for HAP emissions is located at the following link: http://www.epa.gov/ttn/atw/pollsour.html).  See Appendix B for a list of HAP. 
	 
                Yes
         x     No
      
      If yes, please list the specific HAPs that result in major source status and the major source categories or subcategories that apply under Section 112:  
      
      Specific HAPs:  __________________________________________________________
      Section 112 standard (s) or subpart (s):_______________________________________
      
7. 	Facility NAICS codes (FILL in)
Note: The primary NAICS code represents the line of business that generates the most income for the facility.  The list of NAICS codes is located at the following link:  http://www.census.gov/eos/www/naics/ 
a.	Primary NAICS code      331111	 
b.	Other facility NAICS codes: ______________, ______________,	

8. 	Company Size (CHECK one)
Note:  Approximate number of employees (worldwide) of the business enterprise that owns this facility, including where applicable, the parent company and all subsidiaries, branches, and unrelated establishments owned by the parent company.  
            ___ <50
            ___ 50-99
            ___ 100-499
            ___500-749
            ___ 750-999
            _x_ >1000

9. 	Facility Size (CHECK one)
Note:  Approximate number of employees at facility in location identified in question #3 above.
            ___ <50
            ___ 50-99
            ___ 100-499
            ___ 500-749
            ___ 750-999
            _x_ >1000




10. 	Is the legal owner a small entity as defined by the Regulatory Flexibility Act (if known)?  
(CHECK one)
Note:  For private businesses, small entity is defined for each NAICS of the owning entity based on number of employees and/or company revenue.  The parent company number of employees is used for the iron and steel mills industry subsector (331).  The small business size standards for NAICS subsectors is located at the following link: https://epic.od.nih.gov/naics/Naicscodelist.asp#Manufacturing
            ___ Yes
            _x_ No
      
11. 	a)	Does this facility have a Title V permit?
            _x_ Yes
            ___ No
            
	b)	If yes, please provide a copy of the most current Title V permit.

	c)	Is the facility subject to Part 63, Subpart YYYYY (EAF Area Source Rule)?
		_x_ Yes
		___ No

	d)	If yes, please indicate the selected compliance option(s):
		___ Site specific plan for mercury switches
		_x_ Option for EPA-approved mercury programs
		_x_ Option for specialty metal scrap
		___ Scrap that does not contain motor vehicle scrap

	e)	Is the facility subject to the NSPS for EAF (Subparts AA or AAa)?
		_x_ Yes
		___ No

	f)	If yes, please indicate which NSPS limits apply:
		___ Subpart AA
		_x_ Subpart AAa

	g)	Is the facility subject to a state mercury emission limit?
		___ Yes
		_x_ No
		If yes, please identify the limit and the regulation:
		______________________________________________

12. 	Normal Facility Production Hours:
	Most recent year of normal operation for your facility: __2006______
	Hours/day: _____24______________
	Shifts/day: _____2______________
	Days/week:____7_______________
	Weeks/year: ____52______________
	
	2009 Facility Production Hours (if different from above):
	Hours/day: ________24___________
	Shifts/day: ________2___________
	Days/week:________7___________
	Weeks/year: _______51___________

13. 	Amount of steel produced in 2009 and the most recent year of normal operation since 2003 (if different).  Please SPECIFY the alternate year below, if used:
	0		tons of carbon steel produced 2009
752,022		tons of stainless steel produced 2009
0		tons of high alloy steel produced 2009

0		tons of carbon steel produced in last normal operating year
Not applicable		Year OTHER THAN 2009

936,591		tons of stainless steel produced in last normal operating year
2006		Year OTHER THAN 2009

0		tons of high alloy produced in last normal operating year
Not applicable		Year OTHER THAN 2009


14. 	Amount of scrap charge in 2009 OR the most recent year of normal operation since 2003 (if different).   Please SPECIFY the alternate year below, if used:
               _705,269_______	tons of scrap charged in 2009
885,585		tons of scrap charged in last normal operating year
2006		Year OTHER THAN 2009
 

15. 	Please provide a copy of a schematic of the plant layout for equipment in service under subpart YYYYY.  Please include unit IDs in the schematic that correspond to the unit IDs used in Table 1.  
	(CHECK one) 
	
            _x_ Yes, I have provided a schematic.
            ___ No, I have not provided a schematic because (state reason):
            	_____________________________________________

16. 	Types of charging system and burners used at a facility's EAF.

	a)	What type of charging system does your EAF employ?  
		_x_ Top Charge
		___ Side Charge
		___ Continuous charging system

	Please describe the charging system (e.g., Consteel, shaft furnace, twin shell, etc.): 
 -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  -  - 	_Basket charge_________________________________________________________

	b)	Does the EAF employ a sidewall burner system?
		___ Yes
		_x_ No
		
		If yes, please describe the burner system: ____________________________Part B.  Previously Performed Testing and Test Reports for Mercury, PM, Opacity, and CO Emissions at Electric Arc Furnace Steelmaking Facilities 

For Part B 1., 2., 3. and Table 1 below, EAF1, EAF2, AOD1 & AOD2 emission compliance test reports and details have been previously submitted and testing exemptions and/or similarity determinations have been granted.  Please refer to the attached NAS Testing Exemption Chart and EAF/AOD Similarity Tables. 


 Please provide copies of all previous emission test reports for the emission units and pollutants listed in the table below performed using any EPA reference test methods within the last five (5) years.  Please provide either the full test reports or summary pages that contain the information listed below:  

   If only test summaries are submitted, please ensure that the following information is included (at a minimum):  
   (a) Pollutants and emission rates measured (e.g., lb/hr, gr/dscf, lb/ton) for the pollutants of interest for this survey, including mercury, CO, and any of the forms of PM plus melt shop opacity observations, 
   (b) Stack parameters (volumetric flow rates, temperature, % oxygen, % moisture, etc.), 
   (c) Names of the test methods or procedures used, 
   (d) For PM, identify whether it is filterable (front half) PM, total PM (filterable plus condensable), PM10, or PM2.5 (indicating whether it is filterable, condensable, or both), 
   (e) Information on actual production or processing rates during the test, and 
   (f) Identify any runs where the process or control device was not operating normally and any runs that were invalidated (including the reason).  
   
   Please include test reports for tests conducted for engineering purposes if the tests were performed according to EPA reference test methods and are representative of normal operation.  
   
   We expect all facilities to have recent PM and opacity compliance test results for the GACT PM and opacity limits in Subpart YYYYY.  Please submit opacity data for the meltshop collected during PM performance or compliance tests conducted over the past 5 years, plus up to 50 sets of daily opacity observations (if available) representative of normal operations, conducted at other times over the past 5 years.   
     
                                 Emission unit
                              Pollutants/Opacity
EAF primary control device[1] 
PM (including any tests for filterable and condensable PM, PM10, PM2.5), mercury (including any tests for particulate divalent mercury, gaseous divalent mercury, and elemental gaseous mercury), carbon monoxide (CO)
EAF meltshop
Opacity by EPA Method 9
EAF control device for fugitive emissions from charging and tapping (if different from the primary control device)
Mercury, PM (including any tests for filterable and condensable PM, PM10, PM2.5)
Argon-oxygen decarburization (AOD) vessel control device
PM (including any tests for filterable and condensable PM, PM10, PM2.5)
Ladle metallurgy facility (LMF) control device
PM (including any tests for filterable and condensable PM, PM10, PM2.5)
[1] The primary control device for an EAF with multiple baghouses is the baghouse serving the direct-shell evacuation control (DEC) of the EAF.  If there is no DEC, the baghouse primarily responsible for controlling emissions from melting and refining operations is the primary control device.  
      
For the previous tests that you enclose, please fill in the summary of operation information during source testing in Table 1 for each test report submitted.  You may make duplicates of Table 1 for each test, facility, or emission unit tested.  Note that the production rate of raw steel during each of the emission tests is part of the requested information.  You are not required to enter previously-conducted emission test results into the ERT database.  

Note that facilities with previously performed PM, PM2.5, mercury, opacity, or CO tests are only exempt from the testing request in Enclosure 2 if the testing was performed in the last five years, the testing was done with EPA methods or approved alternative methods, and certain criteria specified in Section 1.0 of Enclosure 2 are met.  If you intend to submit past test data, you must do so by 30 days from receipt of this letter because if EPA determines that such data are not representative, you will need to conduct the testing and submit the test data required by this survey by 120 days from the receipt of this letter.   














2. 	If you are providing test reports, please fill in the following information: 	

 I have included previous test reports from the last five years (2005 to present): 

	_________	No
		
      ___X _____	Yes, from 2005 or later (for SOME of the pollutants requested*) AND 
			_X______	I am asking for a testing waiver for this pollutant
			_X______	Pollutant name (CO, PM filterable, Opacity)

	_________	Yes, from 2005 or later (for ALL of the pollutants requested *) AND 
			________	I am asking for a full waiver for this testing

	* Test requests include stack emissions of mercury, speciated forms of mercury, PM, PM10, PM2.5 (filterable and condensable), and CO and EPA Method 9 observations of opacity of melt shop fugitive emissions.

 If you have enclosed test reports, please indicate the pollutants measured, the EPA methods used, the production rate during the tests, and the year the data was taken.  The pollutants of primary concern are Hg, PM, PM2.5 (filterable and condensable), CO, and opacity.
      
SEE ATTACHED TABLES OF APPENDIX C FOR TESTING EXEMPTIONS AND SIMILARITY DETERMINATIONS  -  STACK TEST REPORTS PREVIOUSLY SUBMITTED FOR CO AND PM FILTERABLE.  ADDITIONAL OPACITY READINGS ARE ENCLOSED.
                                       
	Pollutant: 		______________ 	Pollutant:		______________
	Test(s) Used:		______________	Test(s) Used:		______________
	Production Rate:	______________	Production Rate:	______________
	Year(s) of Data:	______________	Year(s) of Data:	______________

	
3.   	What percent of your scrap charge is shredded automobile scrap (e.g., ISRI Code 210)?   Please provide your best estimate (average and a range) if you do not have actual records:  Please differentiate between what is typical and what was used during the source tests 
      
      Typical		__________% (average) and ____0____% to ______% (range)
      During tests		__0 (for previous tests)_% (average) and _0__% to __0_% (range)
      
NAS DID NOT HISTORICALLY USE AUTO SHRED.  NAS RECENTLY RECEIVED REVISED PERMIT TO USE AUTO SHRED.


4.   	Please provide any available information on the mercury content of the carbon electrodes:

      ______0____ppm (average) and ________ppm to ______ppm (range)
      
5. 	Use the table below to report the generation rate of your EAF dust (PM) and its HAP metal content.  Fill in the average and range in the table below for HAP metals listed below, or provide the results of at least five of the most recent analyses of the EAF dust for metals.

      Dust (PM) generation rate: __2009:  0.0127 ton eaf dust/ton steel  
                                                  2006 :  0.0148 ton eaf dust/ton steel 
      
                                       
                                   HAP Metal
                                    Content

                                 ppm (average)
                                   ppm (low)
                                  ppm (high)
Mercury
13.2
1
26
Antimony
82
65
100
Arsenic
31
25
100
Beryllium
0.17
0.07
0.3
Cadmium
220
100
500
Total Chromium
15,000
13,000
88,000
Hexavalent Chromium
0.26
0.08
0.44
Cobalt
270
200
350
Lead
4,900
4,200
50,000
Manganese
21,000
15,000
26,000
Nickel
9,400
5,700
14,000
Selenium
22
5
200
      
6. 	Indicate below the fate of your EAF dust in 2009 and last year of normal/full operation, if different.   (Indicate the year if not 2009: _____2006_____.)

                               Fate of EAF dust
                    Tons per year at 2009 production rates
                   Tons per year at normal production rates
Landfilled 
775
5,142
Shipped to a zinc recovery facility
0
0
Shipped for use as fertilizer
0
0
Recycled to EAF
0
0
Other (describe):
Shipped to recovery facility  -  Inmetco (for Stainless  -  recover Ni and Cr )

8,795
8,736
          Table 1:  Previously Performed Source Tests (2005 to 2010)
      Summary of Operational Information for Each Test Report Submitted*
Facility name

Emission unit(s) ID - use same ID as in schematic

Latitude of stack (decimal degrees, 6 decimal places)

Longitude of stack (decimal degrees, 6 decimal places)

Date of test

Indicate if before or after MACT or GACT controls in place

                                       
                                     Item
                                       
Run 1
                                       
Run 2
                                       
Run 3
Units of Measure
Steel production (EAF, AOD vessel, LMF)




Type of scrap charged (for EAF test reports only):
                                       
 No. 2 heavy melting steel (ISRI Codes 204-206)
                                       
                                       


 Shredded scrap (ISRI Code 210)
                                       
                                       


 Other type of scrap 1 (describe)
 
                                       
                                       


 Other type of scrap 2 (describe)
 
                                       
                                       


 Other type of scrap 3 (describe)
 
                                       
                                       


 Other type of scrap 4 (describe)
 
                                       
                                       


 Other type of scrap 5 (describe)
 
                                       
                                       


Direct reduced iron charged
                                       
                                       


Other ferrous materials charged (describe):
                                       
                                       


Metallurgical coke charged
                                       
                                       


Petroleum coke charged
                                       
                                       


Coal charged
                                       
                                       


Lime charged
                                       
                                       


Alloy 1 charged (describe):

                                       
                                       


Alloy 2 charged (describe):

                                       
                                       


Alloy 3 charged (describe):

                                       
                                       


Tires charged
                                       
                                       


Other materials charged (list):




                                       
                                       


* Please make copies of this page for each previous test report submitted.  We prefer receiving the completed tables electronically in the MS Word file included with this package.

                                  Appendix C
                                       
    Documentation of Rationale for Reduced Mercury Testing for Similar EAFs
                                       
Please fill out the following table and include a description of the required parameters used to establish the similarity between your EAFs.  All parameters noted with * are required to be the same for EAFs to be considered "similar" with respect to mercury emissions potential.

                                   Parameter
                               EAF Being Tested
                                  Similar EAF
                                  Similar EAF
                                  Similar EAF
EAF ID No.
EAF1
EAF2


Latitude and longitude of stack(s) decimal degrees, 6 decimal places
38.721253,
-85.081894
38.721584,
-85.082256


*Type and proportion of scrap charged (please list scrap grades and percent or tons of each)
Stainless Steel(~75%) Carbon Steel (~25%)
201 (4.3%)
301 (3.6%)
304 (53.6)
316 (11.97)
409 (3.7)
430 (1.6%)
Ferrous (21.2%)

Stainless Steel(~75%) Carbon Steel (~25%)
201 (4.3%)
301 (3.6%)
304 (53.6)
316 (11.97)
409 (3.7)
430 (1.6%)
Ferrous (21.2%)



*Scrap supplier(s)
ELG, ISA, Allied Alloys,
Simms Metals,
Cronimet,
Omnisource
ELG, ISA, Allied Alloys,
Simms Metals,
Cronimet,
Omnisource


*Materials charged other than scrap (please list each material)
FeCr, FeSi, 
Lime Oxide,
MO Oxide
Dolomitic Lime
FeCr, FeSi, 
Lime Oxide,
MO Oxide
Dolomitic Lime


*Type of steel produced

Stainless Steel
Stainless Steel


Amount of steel produced (tpy)
410,223.73 tpy
Sep `09  -  Aug `10
486,137.27 tpy
Sep `09  -  Aug `10



EAF1 and EAF2 have identical process rates of 154 tons per batch and both have independent direct evacuation control systems consisting of ductwork which draws the emissions from the furnace to their own baghouse. Scrap baskets are loaded indiscriminate of which furnace is used to charge/melt the material.  Scrap percentages listed above taken from total consumptions for year end of 2009. 

                                       
        Documentation of Rationale for Reduced Testing for Similar AODs
                                       
Please fill out the following table and include a description of the required parameters used to establish the similarity between your argon-oxygen decarburization vessels (AODs).  All parameters noted with * are required to be the same or reasonably close for AODs to be considered "similar" with respect to particulate matter emissions potential.

                                   Parameter
                                     AOD 1
                                     AOD 2
AOD ID No.
AOD 1
AOD 2
Latitude and longitude of stack(s) decimal degrees, 6 decimal places
38.720910
-85.081588
38.720435
-85.081344
*Type and proportion of steel processed
100% Stainless Steel; processes molten steel delivered by either EAF
 
100% Stainless Steel; processes molten steel delivered by either EAF
*Type of steel product produced
100% Stainless Steel
100% Stainless Steel
*Vessel size
165 tons/batch
165 tons/batch
Control Device ID No.
AOD 1 Baghouse
AOD 2 Baghouse
*Type of baghouse fabric
16 oz. Polyester Felt
16 oz. Polyester Felt
*Baghouse design/cleaning mechanism (e.g., pulse jet, reverse air, etc.)
Pulse Jet
Pulse Jet
*Air-to-cloth ratio of baghouse (acfm/ft2)
4.5
4.1


  

                                       
        Documentation of Rationale for Reduced Testing for Similar EAFs
                                       
Please fill out the following table and include a description of the required parameters used to establish the similarity between your Electric Arc Furnace Baghouses.  All parameters noted with * are required to be the same or reasonably close for EAF baghouses to be considered "similar" with respect to particulate matter emissions potential.

                                   Parameter
                                EAF  1 Baghouse
                                EAF 2 Baghouse 
Control Device ID No.
                                EAF 1 Baghouse
                                EAF 2 Baghouse
*Type of baghouse fabric
                             16 oz. Polyester Felt
                             16 oz. Polyester Felt
*Baghouse design/cleaning mechanism (e.g., pulse jet, reverse air, etc.)
                                   Pulse Jet
                                   Pulse Jet
*Air-to-cloth ratio of baghouse (acfm/ft2)
                                      4.5
                                      5.0
                                       


  
EAF#1 4.5  A/C	
EAF#2 5.0  A/C
AOD#1 4.5 A/C
AOD#2 4.1 A/C







                     North American Stainless  -  11/10/10
                            Contact:  Brian Carson
                      Bcarson@northamericanstainless.com
                                       
 North American Stainless:  Ghent, KY  -  Request for New Testing Exemptions 
                                       
                                   Facility
                                    Source
                                   Pollutant
                                 EPA Response
                               Test Method Used
                                    Comment
Ghent, KY
EAF #1 Baghouse
CO
                                      Yes
                                       
EPA Method 10

Ghent, KY
EAF #2 Baghouse
CO
                                      Yes
                                       
EPA Method 10

Ghent, KY
AOD2
CO
                                 Not required

ICR does not require CO testing of the AOD control device
Ghent, KY
EAF #1 Baghouse
PM Filterable
                                      Yes
                                       
EPA Method 5

Ghent, KY
AOD-1
PM Filterable
                                      Yes
                                       
EPA Method 5

Ghent, KY
EAF #2 Baghouse
PM Filterable
                                      Yes
                                       
EPA Method 5

Ghent, KY
AOD2 
PM filterable
                                      Yes
EPA Method 5 
Compliance demonstration 
4/13-14/2010.
Ghent, KY
Melt Shop
Opacity

                                     Maybe
Need individual field reports for 180 minutes of observation concurrent with EAF Jan 2010 PM testing.
EPA Method 9
Provided daily summaries of melt shop opacity readings.

                                       
 North American Stainless:  Ghent, KY  -  Requests for Similar EAFs and AODs 
                                       
                                       
                                       
                                   Facility
                                       
                                    Source 
                                       
                                   Pollutant
                                       
                                 EPA Response
                                       
                                   Comment 
Ghent, KY
EAF 2 
Mercury
                                      Yes
Based on information provided below, these two EAFs are similar.
Ghent, KY
EAF 2 
PM2.5 filterable 
and condensable 
                                      Yes
PM2.5 filterable & condensable testing has already been completed at EAF1 per the request and is believed to be representative of EAF2.
Ghent, KY
AOD2
PM2.5 filterable and condensable performed on AOD1
                                      Yes
PM2.5 filterable & condensable testing has already been completed at AOD1 as per the request and is believed to be representative of both processes. 
                                       

