Certified Mail

No
TOXIC REVIEW
Yes
PSD
No
SYNTHETIC MINOR TO AVOID MAJOR NSR
No
CEMS
Yes
MACT/GACT
Yes
NSPS
No
NESHAPS
No
NETTING
Yes
MAJOR NON-ATTAINMENT
Yes
MODELING SUBMITTED
No
MAJOR GHG
No
SYNTHETIC MINOR TO AVOID MAJOR GHG



Certified Mail

No
TOXIC REVIEW
Yes
PSD
No
SYNTHETIC MINOR TO AVOID MAJOR NSR
No
CEMS
Yes
MACT/GACT
Yes
NSPS
No
NESHAPS
No
NETTING
Yes
MAJOR NON-ATTAINMENT
Yes
MODELING SUBMITTED
No
MAJOR GHG
No
SYNTHETIC MINOR TO AVOID MAJOR GHG



6/12/2017

	
Jay Lawniczak
Charter Steel - Cleveland Inc
4300 East 49th Street
Cuyahoga Heights, OH 44125

  RE:	DRAFT AIR POLLUTION PERMIT-TO-INSTALL
      Facility ID: 			1318171623
      Permit Number: 	P0120585
      Permit Type:		OAC Chapter 3745-31 Modification
      County: 			Cuyahoga

Dear Permit Holder:

A draft of the Ohio Administrative Code (OAC) Chapter 3745-31 Air Pollution Permit-to-Install for the referenced facility has been issued for the emissions unit(s) listed in the Authorization section of the enclosed draft permit.  This draft action is not an authorization to begin construction or modification of your emissions unit(s).  The purpose of this draft is to solicit public comments on the permit.  A public notice will appear in the Ohio Environmental Protection Agency (EPA) Weekly Review and the local newspaper, The Plain Dealer.  A copy of the public notice and the draft permit are enclosed.  This permit can be accessed electronically on the Division of Air Pollution Control (DAPC) Web page, www.epa.ohio.gov/dapc by clicking the "Search for Permits" link under the Permitting topic on the Programs tab.  Comments will be accepted as a marked-up copy of the draft permit or in narrative format.  Any comments must be sent to the following:

Andrew Hall
Permit Review/Development Section
Ohio EPA, DAPC
50 West Town Street, Suite 700
P.O. Box 1049
Columbus, Ohio  43216-1049
and
Cleveland Division of Air Quality
2nd Floor
75 Erieview Plaza
Cleveland, OH 44114

Comments and/or a request for a public hearing will be accepted within 30 days of the date the notice is published in the news - paper.  You will be notified in writing if a public hearing is scheduled.  A decision on issuing a final permit-to-install will be made after consideration of comments received and oral testimony if a public hearing is conducted.  Any permit fee that will be due upon issuance of a final Permit-to-Install is indicated in the Authorization section.  Please do not submit any payment now.  If you have any questions, please contact Cleveland Division of Air Quality at (216)664-2297.
 Sincerely,
 
 Michael E. Hopkins, P.E.
 Assistant Chief, Permitting Section, DAPC
Cc:		U.S. EPA Region 5  - Via E-Mail Notification
		CDAQ;   Pennsylvania;   Canada
   
      
      
                           Permit Strategy Write-Up

 Check all that apply:
      
      	       Synthetic Minor Determination   
      
             Netting Determination   

 Source Description:
      
      Charter Steel - Cleveland Inc. submitted a Chapter 31 permit modification application for the emissions units involved in making steel billets using an electric arc furnace.  This modification will allow Charter Steel to increase production from the current limit of 710,600 tons of steel per year up to 842,100 tons of steel per year.  The Melt Shop consists of the electric arc furnace (EAF), a ladle metallurgy furnace (LMF), vacuum oxygen degasser (VOD), a continuous caster, and multiple natural gas fired preheaters.
      
      The Melt Shop production levels are largely constrained by the size of the charging ladle.  Additionally, the equipment and configuration of the scrap yard constrains the ability to move more scrap even quicker to the charging bins.  Consequently, Charter Steel will be undertaking several projects over the next one to five years, including purchasing an additional crane for the scrap yard, bin modifications, replacing the lining of the charging ladles in a manner that will increase the ladle size, modifying the turret to accommodate heavier ladles, purchasing an additional crane for the billet yard, and modifying the billet rack system.
      
      In addition, in order to increase flexibility to make different types of steel, Charter Steel has proposed a new approach relative to sulfur dioxide that classifies products into three categories:  low-sulfur, mid-sulfur, and high-sulfur steel grades.  The previous permit had two categories of "normal" and "resulfurized".  The actual sulfur content varies within the "normal" and "resulfurized" categories, and within each individual grade of steel.  This new approach will help to enable Charter Steel to achieve the annual production goal of 842,100 tons of steel per year.
      
      In order to determine the amount of emission increase that is associated with the proposed project, Charter Steel included the following emissions units in their project emission increase analysis comparing current actual emissions to future projected actual emissions and factoring in the "could have accommodated" portion of emissions:
      
 B008 VTD boiler 28.576 mmBtu/hr natural gas-fired 
 F002 Facility roadways and parking areas
 F003 Handling of steel scrap furnace charge 
 F004 Dust silo 
 P029 Bar Mill reheat furnace  165 mmBtu/hr natural gas fired 
 P032  -  P034 Three natural gas fired tundish preheater rated at 12.0 mmBtu/hr each
 P035  -  P038 Four natural gas fired ladle preheaters rated at 10 mmBtu/hr each
 P041 Four natural gas fueled cut-off torches rated at 1.76 mmBtu/hr each
 P043 Vacuum Oxygen Degasser (VOD) vessel 100 ton/hour capacity
 P044 Carbon Silo 
 P045 Lime Silo - storage for lime additive for steel alloying
 P900 Electric Arc Furnace (EAF) 110 ton/hour capacity 
 P901 Ladle Metallurgy Furnace (LMF) 110 ton/hour capacity 
 P902 Continuous caster of steel 
      
      For the above emissions units, the only emissions units that will have an increase in emissions that is above their current allowable emission limits are F002, F003, P043, and P900.  All of the other emissions units were previously permitted at maximum potential to emit through the PSD PTI 13-04176 that was issued on 6/10/2004 and the limitations are not changing as a result of this proposed expansion project.  The majority of emissions for all pollutants that are emitted by Charter Steel are primarily generated by the EAF (P900).
      
 Facility Emissions and Attainment Status:
      
      Charter Steel is one of the 28 source categories that are subject to the 100 ton/year major source threshold under the Prevention of Significant Deterioration (PSD) rules.  This facility currently has the potential to emit of approximately 92 tons/year of PM/PM10, 99 tons/year of SO2, 165 tons/year of NOx, 1,330 tons/year of CO, 74 tons/year of VOC, and 1.8 tons/year of lead.  
      
      The 2015 Fee Emissions Report showed actual emissions for this facility of approximately 79 tons/year of PE, 80 tons/year of SO2, 160 tons/year of NOx, 1,158 tons/year of CO, 65 tons/year of VOC, and 0.1 ton/year of lead.
      
      Cuyahoga County is currently designated as attainment for regulated air pollutants except PM2.5 (12 ug/m[3] annual 2012 standard), and partial nonattainment for lead (0.15 ug/m[3] rolling 3-month average 2008 standard).
      
 Source Emissions:
      
      For this expansion project to increase the annual production to 842,100 tons of steel per year, the project emission increase analysis showed that SO2 and CO emissions exceed the 40 and 100 ton/year major modification thresholds, respectively, which results in PSD applicability for these pollutants.  Charter Steel performed a best available control technology (BACT) analysis for each emissions unit that is affected by this project for both SO2 and CO emissions.  The BACT limitations have been established in the permit modification for P043 (CO), and P900 (SO2 and CO).  Charter Steel also performed a modeling analysis for both SO2 and CO to demonstrate that this project will not cause a NAAQS violation.
      
      The amount of emission increase for SO2 exceeds 100 tons/year.  Since SO2 is a precursor to PM2.5, this expansion project is also subject to the Nonattainment New Source Review (NNSR) requirements for SO2.  Charter Steel performed a lowest achievable emission rate (LAER) analysis for each emissions unit affected by this project for SO2.  The LAER limitations for SO2 for P900 have been established in the permit modification.  Charter Steel is also required to secure approximately 267 tons/year of SO2 emission offsets.  Modeling has also been required to verify that the amount of SO2 emission offsets being purchased by Charter Steel are available for use to satisfy the NNSR requirements.
      
      The previous pound per hour BACT limitations that were established for PM/PM10, NOx, VOC, lead, mercury, and opacity that were established through PSD PTI 13-04176 for P900 have been retained in this permit modification.  Some adjustments have been made based on updated information provided by Charter Steel in their permit modification application.  Likewise, previous BACT limits for PM, except for the ton/year limits, for F002 and F003 have been retained.

The following are the future projected actual emissions (tons/year) for each emissions unit:
      

                                      PM
                                    (filt.)
                                      PM
                                    (cond.)
                                     PM10
                                    (filt.)
                                     PM10
                                    (cond.)
                                     PM2.5
                                    (filt.)
                                     PM2.5
                                    (cond.)
                                      SO2
                                      NOx
                                      VOC
                                      CO
                                      Pb
                                     B008
                                     0.17
                                     0.51
                                     0.17
                                     0.51
                                     0.17
                                     0.51
                                     0.05
                                     9.01
                                      0.5
                                     7.57
                                       0
                                     F002
                                     18.89
                                       0
                                     4.09
                                       0
                                     0.87
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     F003
                                     9.61
                                       0
                                     5.77
                                       0
                                     4.81
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     F004
                                     0.45
                                       0
                                     0.45
                                       0
                                     0.45
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     P029
                                     1.00
                                     2.99
                                     1.00
                                     2.99
                                     1.00
                                     2.99
                                     0.32
                                     58.92
                                     2.89
                                     44.11
                                       0
                                   P032-P034
                                       *
                                       0
                                       *
                                       0
                                       *
                                       0
                                     0.05
                                     8.13
                                     0.45
                                     6.83
                                       0
                                   P035-P038
                                       *
                                       0
                                       *
                                       0
                                       *
                                       0
                                     0.04
                                     7.35
                                      0.4
                                     6.18
                                       0
                                     P041
                                       *
                                       0
                                       *
                                       0
                                       *
                                       0
                                     0.02
                                      3.1
                                     0.18
                                     2.58
                                       0
                                     P043
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     70.18
                                       0
                                     P044
                                     0.45
                                       0
                                     0.45
                                       0
                                     0.45
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     P045
                                     0.45
                                       0
                                     0.45
                                       0
                                     0.45
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     P900
                                    * 21.87
                                     12.21
                                    * 16.62
                                     12.21
                                    * 16.19
                                     12.21
                                    313.52
                                    138.95
                                     84.21
                                    1364.2
                                    * 0.17
                                     P901
                                       *
                                       0
                                       *
                                       0
                                       *
                                       0
                                       0
                                     6.32
                                     0.84
                                    126.32
                                       0
                                     P902
                                       *
                                       0
                                       *
                                       0
                                       *
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     Total
                                     52.89
                                     15.72
                                     29.00
                                     15.72
                                     24.39
                                     15.72
                                    314.00
                                    231.78
                                     89.47
                                   1,627.97
                                     0.17
      
The following are the current actual emissions (tons/yr) that includes the "could have accommodated" portion:
      

                                      PM
                                    (filt.)
                                      PM
                                    (cond.)
                                     PM10
                                    (filt.)
                                     PM10
                                    (cond.)
                                     PM2.5
                                    (filt.)
                                     PM2.5
                                    (cond.)
                                      SO2
                                      NOx
                                      VOC
                                      CO
                                      Pb
                                     B008
                                     0.11
                                     0.33
                                     0.11
                                     0.33
                                     0.11
                                     0.33
                                     0.03
                                     5.78
                                     0.32
                                     4.86
                                       0
                                     F002
                                     15.94
                                       0
                                     3.45
                                       0
                                     0.74
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     F003
                                     7.46
                                       0
                                     4.48
                                       0
                                     3.73
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     F004
                                     0.42
                                       0
                                     0.42
                                       0
                                     0.42
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     P029
                                     0.91
                                     2.73
                                     0.91
                                     2.73
                                     0.91
                                     2.73
                                     0.29
                                     53.72
                                     2.63
                                     40.22
                                       0
                                   P032-P034
                                       *
                                       0
                                       *
                                       0
                                       *
                                       0
                                     0.04
                                     6.86
                                     0.38
                                     5.76
                                       0
                                   P035-P038
                                       *
                                       0
                                       *
                                       0
                                       *
                                       0
                                     0.04
                                     6.21
                                     0.34
                                     5.21
                                       0
                                     P041
                                       *
                                       0
                                       *
                                       0
                                       *
                                       0
                                     0.02
                                     4.11
                                     0.23
                                     3.45
                                       0
                                     P043
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     45.03
                                       0
                                     P044
                                     0.04
                                       0
                                     0.04
                                       0
                                     0.04
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     P045
                                     0.08
                                       0
                                     0.08
                                       0
                                     0.08
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     P900
                                    * 16.02
                                     10.3
                                    * 12.17
                                     10.3
                                    * 11.85
                                     10.3
                                     96.26
                                    117.25
                                     71.06
                                    1153.79
                                    * 0.05
                                     P901
                                       *
                                       0
                                       *
                                       0
                                       *
                                       0
                                       0
                                     5.33
                                     0.71
                                    106.59
                                       0
                                     P902
                                       *
                                       0
                                       *
                                       0
                                       *
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                     Total
                                     40.98
                                     13.36
                                     21.66
                                     13.36
                                     17.88
                                     13.36
                                     96.69
                                    199.26
                                     75.67
                                   1,364.91
                                     0.05


                                      PM
                                    (filt.)
                                      PM
                                    (cond.)
                                     PM10
                                    (filt.)
                                     PM10
                                    (cond.)
                                     PM2.5
                                    (filt.)
                                     PM2.5
                                    (cond.)
                                      SO2
                                      NOx
                                      VOC
                                      CO
                                      Pb
                           Project Emission Increase
                                     11.91
                                     2.36
                                     7.34
                                     2.36
                                     6.51
                                     2.36
                                    217.31
                                     32.52
                                     13.8
                                    263.06
                                     0.12
                                 NSR threshold
                                      N/A
                                      N/A
                                      15
                                      10
                                      40
                                      40
                                      40
                                      100
                                      0.6
                                NSR triggered?
                                      N/A
                                      N/A
                                      no
                                      no
                                      yes
                                      no
                                      no
                                      yes
                                      no

      * The particulate and lead amounts listed for P900 represent the total amount for the melt shop baghouse outlet for P032  -  P038, P041, and P900  -  P902 combined, and also includes the amount of fugitive emissions from these emissions units.
      
 Conclusion:
      
      The emission increase for the proposed project at Charter Steel exceeds the major modification PSD thresholds for SO2 and CO, as well as exceeding 100 tons/year of SO2 for NNSR.  Charter Steel performed the necessary BACT analysis for SO2 and CO for each affected emissions unit and the BACT limits have been established in this permit modification.  Likewise, Charter Steel performed a LAER analysis for SO2 for each affected emissions unit and the LAER limits have been established in this permit modification.  The air quality modeling analysis also demonstrated that the emission increase for this project will not cause a NAAQS violation.  Charter Steel purchased 324 tons/year of sulfur dioxide emission offsets as required under the NNSR rules.
      
 Please provide additional notes or comments as necessary:
      
      Charter Steel noted in their air quality modeling analysis document that "Ohio EPA has stated that no secondary impact analysis for PM2.5 (due to sulfur dioxide emissions) would be necessary for this project".

      
      
 Total Permit Allowable Emissions Summary (for informational purposes only):
      
                                   Pollutant
                                 Tons Per Year
                              PE/PM (filterable)
                                     75.45
                               PM10 (filterable)
                                     34.19
                              PM2.5 (filterable)
                                     18.72
                          PM/PM10/PM2.5 (condensable)
                                     12.21
                                      SO2
                                     314.0
                                      NOx
                                    236.11
                                      CO
                                    1631.74
                                      VOC
                                     89.47
                                      Hg
                                     0.24
                                      Pb
                                     0.17





                                                                              	

                                 PUBLIC NOTICE
                                       
The following matters are the subject of this public notice by the Ohio Environmental Protection Agency.  The complete public notice, including any additional instructions for submitting comments, requesting information, a public hearing, or filing an appeal may be obtained at: http://epa.ohio.gov/actions.aspx  or Hearing Clerk, Ohio EPA, 50 W. Town St., Columbus, Ohio 43215.  Ph: 614-644-2129 email: HClerk@epa.ohio.gov
                                       
      Draft Air Pollution Permit-to-Install OAC Chapter 3745-31 Modification
      Charter Steel - Cleveland Inc
            4300 East 49th Street,, Cuyahoga Heights, OH 44125-1004
         ID#:P0120585
         Date of Action: 6/12/2017
            Permit Desc:Chapter 31 modification permit for emissions units B008 (natural gas-fired boiler), F002 (roadways), F003 (charge handling), F004 (dust silo), P029 (reheat furnace), P041 (cut off torch), P043 (vacuum tank degasser), P044 (carbon silo), P045 (lime silo), P046 (cooling towers), P048 (ladle preheater), P900 (electric arc furnace), P901 (ladle metallurgy furnace), P902 (continuous caster), P035 - P038 (ladle preheaters), and P032 - P034 (tundish preheaters).   The modification is due to a projected increase in the rolling, 12-month steel production limit and a revision to the SO2 emissions estimate methodology for the melt shop expansion project.. 
            The permit and complete instructions for requesting information or submitting comments may be obtained at: http://epa.ohio.gov/dapc/permitsonline.aspx by entering the ID # or: David Hearne, Cleveland Division of Air Quality, 2nd Floor 75 Erieview Plaza, Cleveland, OH 44114. Ph: (216)664-2297






                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                     DRAFT
                                       
                       Division of Air Pollution Control
                               Permit-to-Install
                                      for
                         Charter Steel - Cleveland Inc












   Facility ID:  	1318171623
   Permit Number: 	P0120585
   Permit Type: 	OAC Chapter 3745-31 Modification
   Issued:  	6/12/2017
   Effective:  	To be entered upon final issuance



                       Division of Air Pollution Control
                               Permit-to-Install
                                      for
                         Charter Steel - Cleveland Inc
                                       
                               Table of Contents

Authorization	1
A.	Standard Terms and Conditions	5
1.	Federally Enforceable Standard Terms and Conditions	6
2.	Severability Clause	6
3.	General Requirements	6
4.	Monitoring and Related Record Keeping and Reporting Requirements	7
5.	Scheduled Maintenance/Malfunction Reporting	8
6.	Compliance Requirements	8
7.	Best Available Technology	9
8.	Air Pollution Nuisance	10
9.	Reporting Requirements	10
10.	Applicability	10
11.	Construction of New Sources(s) and Authorization to Install	10
12.	Permit-To-Operate Application	11
13.	Construction Compliance Certification	12
14.	Public Disclosure	12
15.	Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations	12
16.	Fees	12
17.	Permit Transfers	12
18.	Risk Management Plans	12
19.	Title IV Provisions	12
B.	Facility-Wide Terms and Conditions	13
C.	Emissions Unit Terms and Conditions	20
1.	B008, VTD Boiler	21
2.	F002, Roadways and Parking	28
3.	F003, Charge Handling	36
4.	F004, Dust Silo	41
5.	P029, Bar Mill Reheat Furnace	44
6.	P041, Cut Off Torch	50
7.	P043, Vacuum Tank Degasser (VTD)	56
8.	P044, Carbon Silo	61
9.	P045, Lime Silo	65
10.	P046, Cooling Towers (6)	69
11.	P048, Ladle Preheater #5	73
12.	P900, Electric Arc Furnace	77
13.	P901, Ladle Metallurgy Furnace	97
14.	P902, Continuous Caster	107
15.	Emissions Unit Group -10 mmBtu/hr ladle preheaters:  P035,P036,P037,P038	114
16.	Emissions Unit Group -12.0 mmBtu/hr tundish preheaters:  P032,P033,P034,	121


Authorization

Facility ID:  				1318171623
Facility Description:  	Steel Billet manufacturing.
Application Number(s):  	A0055464, A0058016, A0058539
Permit Number:  		P0120585
Permit Description: 	Chapter 31 modification permit for emissions units B008 (natural gas-fired boiler), F002 (roadways), F003 (charge handling), F004 (dust silo), P029 (reheat furnace), P041 (cut off torch), P043 (vacuum tank degasser), P044 (carbon silo), P045 (lime silo), P046 (cooling towers), P048 (ladle preheater), P900 (electric arc furnace), P901 (ladle metallurgy furnace), P902 (continuous caster), P035 - P038 (ladle preheaters), and P032 - P034 (tundish preheaters).   The modification is due to a projected increase in the rolling, 12-month steel production limit and a revision to the SO2 emissions estimate methodology for the melt shop expansion project.
Permit Type:  			OAC Chapter 3745-31 Modification
Permit Fee:  			$11,125.00  DO NOT send payment at this time, subject to change before final issuance
Issue Date:  			6/12/2017
Effective Date:  			To be entered upon final issuance

This document constitutes issuance to:
      
Charter Steel - Cleveland Inc
4300 East 49th Street
Cuyahoga Heights, OH 44125-1004
      
of a Permit-to-Install for the emissions unit(s) identified on the following page.
      
Ohio Environmental Protection Agency (EPA) District Office or local air agency responsible for processing and administering your permit:

Cleveland Division of Air Quality
2nd Floor
75 Erieview Plaza
Cleveland, OH 44114
(216)664-2297

The above named entity is hereby granted a Permit-to-Install for the emissions unit(s) listed in this section pursuant to Chapter 3745-31 of the Ohio Administrative Code. Issuance of this permit does not constitute expressed or implied approval or agreement that, if constructed or modified in accordance with the plans included in the application, the emissions unit(s) of environmental pollutants will operate in compliance with applicable State and Federal laws and regulations, and does not constitute expressed or implied assurance that if constructed or modified in accordance with those plans and specifications, the above described emissions unit(s) of pollutants will be granted the necessary permits to operate (air) or NPDES permits as applicable.

This permit is granted subject to the conditions attached hereto.

Ohio Environmental Protection Agency



Craig W. Butler
Director
                           Authorization (continued)

Permit Number:	P0120585
Permit Description:	Chapter 31 modification permit for emissions units B008 (natural gas-fired boiler), F002 (roadways), F003 (charge handling), F004 (dust silo), P029 (reheat furnace), P041 (cut off torch), P043 (vacuum tank degasser), P044 (carbon silo), P045 (lime silo), P046 (cooling towers), P048 (ladle preheater), P900 (electric arc furnace), P901 (ladle metallurgy furnace), P902 (continuous caster), P035 - P038 (ladle preheaters), and P032 - P034 (tundish preheaters).   The modification is due to a projected increase in the rolling, 12-month steel production limit and a revision to the SO2 emissions estimate methodology for the melt shop expansion project.

Permits for the following Emissions Unit(s) or groups of Emissions Units are in this document as indicated below:

Emissions Unit ID:
B008
	Company Equipment ID:
VTD Boiler
	Superseded Permit Number:
13-04176
	General Permit Category and Type:
Not Applicable 


Emissions Unit ID:
F002
	Company Equipment ID:
Roadways and Parking
	Superseded Permit Number:
13-04176
	General Permit Category and Type:
Not Applicable 


Emissions Unit ID:
F003
	Company Equipment ID:
Charge Handling
	Superseded Permit Number:
13-04176
	General Permit Category and Type:
Not Applicable 


Emissions Unit ID:
F004
	Company Equipment ID:
Dust Silo
	Superseded Permit Number:

	General Permit Category and Type:
Not Applicable 


Emissions Unit ID:
P029
	Company Equipment ID:
Bar Mill Reheat Furnace
	Superseded Permit Number:
13-02840
	General Permit Category and Type:
Not Applicable 


Emissions Unit ID:
P041
	Company Equipment ID:
Cut Off Torch
	Superseded Permit Number:
P0107611
	General Permit Category and Type:
Not Applicable 


Emissions Unit ID:
P043
	Company Equipment ID:
Vacuum Tank Degasser (VTD)
	Superseded Permit Number:
P0109216
	General Permit Category and Type:
Not Applicable 


Emissions Unit ID:
P044
	Company Equipment ID:
Carbon Silo
	Superseded Permit Number:
13-04176
	General Permit Category and Type:
Not Applicable 



Emissions Unit ID:
P045
	Company Equipment ID:
Lime Silo
	Superseded Permit Number:
13-04176
	General Permit Category and Type:
Not Applicable 


Emissions Unit ID:
P046
	Company Equipment ID:
Cooling Towers (6)
	Superseded Permit Number:
13-04176
	General Permit Category and Type:
Not Applicable 


Emissions Unit ID:
P900
	Company Equipment ID:
Electric Arc Furnace
	Superseded Permit Number:
P0111766
	General Permit Category and Type:
Not Applicable 


Emissions Unit ID:
P901
	Company Equipment ID:
Ladle Metallurgy Furnace
	Superseded Permit Number:
P0111766
	General Permit Category and Type:
Not Applicable 


Emissions Unit ID:
P902
	Company Equipment ID:
Continuous Caster
	Superseded Permit Number:
P0111766
	General Permit Category and Type:
Not Applicable 


     
   Group Name:	10 mmBtu/hr ladle preheaters
Emissions Unit ID:
P035
	Company Equipment ID:
Ladle Preheater #1
	Superseded Permit Number:
P0107611
	General Permit Category and Type:
Not Applicable 
Emissions Unit ID:
P036
	Company Equipment ID:
Ladle Preheater #2
	Superseded Permit Number:
P0107611
	General Permit Category and Type:
Not Applicable 
Emissions Unit ID:
P037
	Company Equipment ID:
Ladle Preheater #3
	Superseded Permit Number:
P0107611
	General Permit Category and Type:
Not Applicable 
Emissions Unit ID:
P038
	Company Equipment ID:
Ladle Preheater #4
	Superseded Permit Number:
P0107611
	General Permit Category and Type:
Not Applicable 
Emissions Unit ID:
P048
	Company Equipment ID:
Ladle Preheater #5
	Superseded Permit Number:
P0120122
	General Permit Category and Type:
Not Applicable 

     
   Group Name:	12.0 mmBtu/hr tundish preheaters
Emissions Unit ID:
P032
	Company Equipment ID:
Tundish Preheater #1
	Superseded Permit Number:
P0107543
	General Permit Category and Type:
Not Applicable 
Emissions Unit ID:
P033
	Company Equipment ID:
Tundish Preheater #2
	Superseded Permit Number:
P0107543
	General Permit Category and Type:
Not Applicable 
Emissions Unit ID:
P034
	Company Equipment ID:
Tundish Preheater #3
	Superseded Permit Number:
P0107543
	General Permit Category and Type:
Not Applicable 




A.	Standard Terms and Conditions
Federally Enforceable Standard Terms and Conditions
All Standard Terms and Conditions are federally enforceable, with the exception of those listed below which are enforceable under State law only:
 Standard Term and Condition A.2.a), Severability Clause
 Standard Term and Condition A.3.c) through A. 3.e) General Requirements
 Standard Term and Condition A.6.c) and A. 6.d), Compliance Requirements
 Standard Term and Condition A.9., Reporting Requirements
 Standard Term and Condition A.10., Applicability
 Standard Term and Condition A.11.b) through A.11.e), Construction of New Source(s) and Authorization to Install
 Standard Term and Condition A.14., Public Disclosure
 Standard Term and Condition A.15., Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations
 Standard Term and Condition A.16., Fees
 Standard Term and Condition A.17., Permit Transfers
Severability Clause
A determination that any term or condition of this permit is invalid shall not invalidate the force or effect of any other term or condition thereof, except to the extent that any other term or condition depends in whole or in part for its operation or implementation upon the term or condition declared invalid.
All terms and conditions designated in parts B and C of this permit are federally enforceable as a practical matter, if they are required under the Act, or any of its applicable requirements, including relevant provisions designed to limit the potential to emit of a source, are enforceable by the Administrator of the U.S. EPA and the State and by citizens (to the extent allowed by section 304 of the Act) under the Act.  Terms and conditions in parts B and C of this permit shall not be federally enforceable and shall be enforceable under State law only, only if specifically identified in this permit as such.
General Requirements
Any noncompliance with the federally enforceable terms and conditions of this permit constitutes a violation of the Act, and is grounds for enforcement action or for permit revocation, revocation and re-issuance, or modification.
It shall not be a defense for the 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 federally enforceable terms and conditions of this permit.
This permit may be modified, revoked, or revoked and reissued, for cause.  The filing of a request by the permittee for a permit modification, revocation and reissuance, or revocation, or of a notification of planned changes or anticipated noncompliance does not stay any term and condition of this permit.
This permit does not convey any property rights of any sort, or any exclusive privilege.
The permittee shall furnish to the Director of the Ohio EPA, or an authorized representative of the Director, upon receipt of a written request and within a reasonable time, any information that may be requested to determine whether cause exists for modifying or revoking this permit or to determine compliance with this permit.  Upon request, the permittee shall also furnish to the Director or an authorized representative of the Director, copies of records required to be kept by this permit.  For information claimed to be confidential in the submittal to the Director, if the Administrator of the U.S. EPA requests such information, the permittee may furnish such records directly to the Administrator along with a claim of confidentiality.
Monitoring and Related Record Keeping and Reporting Requirements
Except as may otherwise be provided in the terms and conditions for a specific emissions unit, the permittee shall maintain records that include the following, where applicable, for any required monitoring under this permit:
 The date, place (as defined in the permit), and time of sampling or measurements.
 The date(s) analyses were performed.
 The company or entity that performed the analyses.
 The analytical techniques or methods used.
 The results of such analyses.
 The operating conditions existing at the time of sampling or measurement. 
Each record of any monitoring data, testing data, and support information required pursuant to this permit shall be retained for a period of five years from the date the record was created.  Support information shall include, but not be limited to all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit.  Such records may be maintained in computerized form.
Except as may otherwise be provided in the terms and conditions for a specific emissions unit, the permittee shall submit required reports in the following manner:
 Reports of any required monitoring and/or recordkeeping of federally enforceable information shall be submitted to the Cleveland Division of Air Quality.
 Quarterly written reports of (i) any deviations from federally enforceable emission limitations, operational restrictions, and control device operating parameter limitations, excluding deviations resulting from malfunctions reported in accordance with OAC rule 3745-15-06, that have been detected by the testing, monitoring and recordkeeping requirements specified in this permit, (ii) the probable cause of such deviations, and (iii) any corrective actions or preventive measures taken, shall be made to the Cleveland Division of Air Quality.  The written reports shall be submitted quarterly, by January 31, April 30, July 31, and October 31 of each year and shall cover the previous calendar quarters.  See A.15. below if no deviations occurred during the quarter.
 Written reports, which identify any deviations from the federally enforceable monitoring, recordkeeping, and reporting requirements contained in this permit shall be submitted to the Cleveland Division of Air Quality every six months, by January 31 and July 31 of each year for the previous six calendar months.  If no deviations occurred during a six-month period, the permittee shall submit a semi-annual report, which states that no deviations occurred during that period.
 This permit is for an emissions unit located at a Title V facility.  Each written report shall be signed by a responsible official certifying that, based on information and belief formed after reasonable inquiry, the statements and information in the report are true, accurate, and complete.
The permittee shall report actual emissions pursuant to OAC Chapter 3745-78 for the purpose of collecting Air Pollution Control Fees.
Scheduled Maintenance/Malfunction Reporting
       Any scheduled maintenance of air pollution control equipment shall be performed in accordance with paragraph (A) of OAC rule 3745-15-06.  The malfunction, i.e., upset, of any emissions units or any associated air pollution control system(s) shall be reported to the Cleveland Division of Air Quality in accordance with paragraph (B) of OAC rule 3745-15-06.  (The definition of an upset condition shall be the same as that used in OAC rule 3745-15-06(B)(1) for a malfunction.)  The verbal and written reports shall be submitted pursuant to OAC rule 3745-15-06.
       Except as provided in that rule, any scheduled maintenance or malfunction necessitating the shutdown or bypassing of any air pollution control system(s) shall be accompanied by the shutdown of the emission unit(s) that is (are) served by such control system(s).
Compliance Requirements
All applications, notifications or reports required by terms and conditions in this permit to be submitted or "reported in writing" are to be submitted to Ohio EPA through the Ohio EPA's eBusiness Center: Air Services web service ("Air Services").  Ohio EPA will accept hard copy submittals on an as-needed basis if the permittee cannot submit the required documents through the Ohio EPA eBusiness Center. In the event of an alternative hard copy submission in lieu of the eBusiness Center, the post-marked date or the date the document is delivered in person will be recognized as the date submitted. Electronic submission of applications, notifications or reports required to be submitted to Ohio EPA fulfills the requirement to submit the required information to the Director, the appropriate Ohio EPA District Office or contracted local air agency, and/or any other individual or organization specifically identified as an additional recipient identified in this permit unless otherwise specified. Consistent with OAC rule 3745-15-03, the electronic signature date shall constitute the date that the required application, notification or report is considered to be "submitted". Any document requiring signature may be represented by entry of the personal identification number (PIN) by responsible official as part of the electronic submission process or by the scanned attestation document signed by the Authorized Representative that is attached to the electronically submitted written report.
            Any document (including reports) required to be submitted and required by a federally applicable requirement in this permit shall include a certification by a Responsible Official that, based on information and belief formed after reasonable inquiry, the statements in the document are true, accurate, and complete
Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Director of the Ohio EPA or an authorized representative of the Director to:
 At reasonable times, enter upon the permittee's premises where a source is located or the emissions-related activity is conducted, or where records must be kept under the conditions of this permit.
 Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit, subject to the protection from disclosure to the public of confidential information consistent with ORC section 3704.08.
 Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit.
 As authorized by the Act, sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with the permit and applicable requirements.
The permittee shall submit progress reports to the Cleveland Division of Air Quality concerning any schedule of compliance for meeting an applicable requirement.  Progress reports shall be submitted semiannually or more frequently if specified in the applicable requirement or by the Director of the Ohio EPA.  Progress reports shall contain the following:
 Dates for achieving the activities, milestones, or compliance required in any schedule of compliance, and dates when such activities, milestones, or compliance were achieved.
 An explanation of why any dates in any schedule of compliance were not or will not be met, and any preventive or corrective measures adopted.
Best Available Technology
       As specified in OAC Rule 3745-31-05, new sources that must employ Best Available Technology (BAT) shall comply with the Applicable Emission Limitations/Control Measures identified as BAT for each subject emissions unit.

Air Pollution Nuisance
       The air contaminants emitted by the emissions units covered by this permit shall not cause a public nuisance, in violation of OAC rule 3745-15-07.
Reporting Requirements
       The permittee shall submit required reports in the following manner:
Reports of any required monitoring and/or recordkeeping of state-only enforceable information shall be submitted to the Cleveland Division of Air Quality.
Except as otherwise may be provided in the terms and conditions for a specific emissions unit, quarterly written reports of (a) any deviations (excursions) from state-only required emission limitations, operational restrictions, and control device operating parameter limitations that have been detected by the testing, monitoring, and recordkeeping requirements specified in this permit, (b) the probable cause of such deviations, and (c) any corrective actions or preventive measures which have been or will be taken, shall be submitted to the Cleveland Division of Air Quality.  If no deviations occurred during a calendar quarter, the permittee shall submit a quarterly report, which states that no deviations occurred during that quarter.  The reports shall be submitted quarterly, by January 31, April 30, July 31, and October 31 of each year and shall cover the previous calendar quarters.  (These quarterly reports shall exclude deviations resulting from malfunctions reported in accordance with OAC rule 3745-15-06.)
Applicability
       This Permit-to-Install is applicable only to the emissions unit(s) identified in the Permit-to-Install.  Separate application must be made to the Director for the installation or modification of any other emissions unit(s) not exempt from the requirement to obtain a Permit-to-Install.
Construction of New Sources(s) and Authorization to Install
This permit does not constitute an assurance that the proposed source will operate in compliance with all Ohio laws and regulations.   This permit does not constitute expressed or implied assurance that the proposed facility has been constructed in accordance with the application and terms and conditions of this permit.  The action of beginning and/or completing construction prior to obtaining the Director's approval constitutes a violation of OAC rule 3745-31-02.  Furthermore, issuance of this permit does not constitute an assurance that the proposed source will operate in compliance with all Ohio laws and regulations.  Issuance of this permit is not to be construed as a waiver of any rights that the Ohio Environmental Protection Agency (or other persons) may have against the applicant for starting construction prior to the effective date of the permit.  Additional facilities shall be installed upon orders of the Ohio Environmental Protection Agency if the proposed facilities cannot meet the requirements of this permit or cannot meet applicable standards.
If applicable, authorization to install any new emissions unit included in this permit shall terminate within eighteen months of the effective date of the permit if the owner or operator has not undertaken a continuing program of installation or has not entered into a binding contractual obligation to undertake and complete within a reasonable time a continuing program of installation.  This deadline may be extended by up to 12 months if application is made to the Director within a reasonable time before the termination date and the permittee shows good cause for any such extension.
The permittee may notify Ohio EPA of any emissions unit that is permanently shut down (i.e., the emissions unit has been physically removed from service or has been altered in such a way that it can no longer operate without a subsequent "modification" or "installation" as defined in OAC Chapter 3745-31) by submitting a certification from the authorized official that identifies the date on which the emissions unit was permanently shut down. Authorization to operate the affected emissions unit shall cease upon the date certified by the authorized official that the emissions unit was permanently shut down.  At a minimum, notification of permanent shut down shall be made or confirmed by marking the affected emissions unit(s) as "permanently shut down" in "Air Services" along with the date the emissions unit(s) was permanently removed and/or disabled. Submitting the facility profile update electronically will constitute notifying the Director of the permanent shutdown of the affected emissions unit(s).
The provisions of this permit shall cease to be enforceable for each affected emissions unit after the date on which an emissions unit is permanently shut down (i.e., emissions unit has been physically removed from service or has been altered in such a way that it can no longer operate without a subsequent "modification" or "installation" as defined in OAC Chapter 3745-31).  All records relating to any permanently shutdown emissions unit, generated while the emissions unit was in operation, must be maintained in accordance with law.  All reports required by this permit must be submitted for any period an affected emissions unit operated prior to permanent shut down.  At a minimum, the permit requirements must be evaluated as part of the reporting requirements identified in this permit covering the last period the emissions unit operated.
             Unless otherwise exempted, no emissions unit certified by the responsible official as being permanently shut down may resume operation without first applying for and obtaining a permit pursuant to OAC Chapter 3745-31 and OAC Chapter 3745-77 if the restarted operation is subject to one or more applicable requirements.
The permittee shall comply with any residual requirements related to this permit, such as the requirement to submit a deviation report, air fee emission report,  or other any reporting required by this permit for the period the operating provisions of this permit were enforceable, or as required by regulation or law.  All reports shall be submitted in a form and manner prescribed by the Director. All records relating to this permit must be maintained in accordance with law.
Permit-To-Operate Application
       The permittee is required to apply for a Title V permit pursuant to OAC Chapter 3745-77.  The permittee shall submit a complete Title V permit application or a complete Title V permit modification application within twelve (12) months after commencing operation of the emissions units covered by this permit. However, if operation of the proposed new or modified source(s) as authorized by this permit would be prohibited by the terms and conditions of an existing Title V permit, a Title V permit modification of such new or modified source(s) pursuant to OAC rule 3745-77-04(D) and OAC rule 3745-77-08(C)(3)(d) must be obtained before operating the source in a manner that would violate the existing Title V permit requirements.

Construction Compliance Certification
       The applicant shall identify the following dates in the "Air Services" facility profile for each new emissions unit identified in this permit.
Completion of initial installation date shall be entered upon completion of construction and prior to start-up.
Commence operation after installation or latest modification date shall be entered within 90 days after commencing operation of the applicable emissions unit.
Public Disclosure
       The facility is hereby notified that this permit, and all agency records concerning the operation of this permitted source, are subject to public disclosure in accordance with OAC rule 3745-49-03.
Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations
       If no deviations occurred during a calendar quarter, the permittee shall submit a quarterly report, which states that no deviations occurred during that quarter.  The reports shall be submitted quarterly by January 31, April 30, July 31, and October 31 of each year and shall cover the previous calendar quarters.
Fees
       The permittee shall pay fees to the Director of the Ohio EPA in accordance with ORC section 3745.11 and OAC Chapter 3745-78.  The permittee shall pay all applicable permit-to-install fees within 30 days after the issuance of any permit-to-install.  The permittee shall pay all applicable permit-to-operate fees within thirty days of the issuance of the invoice.
Permit Transfers
       Any transferee of this permit shall assume the responsibilities of the prior permit holder.  The new owner must update and submit the ownership information via the "Owner/Contact Change" functionality in "Air Services" once the transfer is legally completed.  The change must be submitted through "Air Services" within thirty days of the ownership transfer date. 
Risk Management Plans
       If the permittee is required to develop and register a risk management plan pursuant to section 112(r) of the Clean Air Act, as amended, 42 U.S.C. 7401 et seq. ("Act"), the permittee shall comply with the requirement to register such a plan.
Title IV Provisions
       If the permittee is subject to the requirements of 40 CFR Part 72 concerning acid rain, the permittee shall ensure that any affected emissions unit complies with those requirements.  Emissions exceeding any allowances that are lawfully held under Title IV of the Act, or any regulations adopted thereunder, are prohibited.


B.	Facility-Wide Terms and Conditions



 
 All the following facility-wide terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only:
 None.
The following emissions unit contained in this permit is subject to 40 CFR Part 63, Subpart YYYYY: P900. The complete MACT requirements, including the General Provisions may be accessed via the internet from the Electronic Code of Federal Regulations (e-CFR) website http://www.ecfr.gov or by contacting the Cleveland Division of Air Quality.
For the dust-handling system located at this facility, including dust-handling equipment associated with P900 and F004, the permittee shall not discharge into the atmosphere any gases that exhibit 10 percent opacity or greater. In accordance with 40 CFR Part 60, Subpart AAa, the definition of "dusthandling system" is as follows:
       Dust-handling system means equipment used to handle particulate matter collected by the control device for an electric arc furnace or AOD vessel subject to this subpart. For the purposes of this subpart, the dust-handling system shall consist of the control device dust hoppers, the dust-conveying equipment, any central dust storage equipment, the dust-treating equipment (e.g., pug mill, pelletizer), dust transfer equipment (from storage to truck), and any secondary control devices used with the dust transfer equipment.
       Compliance shall be determined through visible emission observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in 40 CFR Part 60 Subpart AAa.
This permit-to-install covers the Melt Shop Expansion Project proposed by the permittee to increase steel production by the electric arc furnace.  The permittee is proposing several projects over the next one to five years that will include purchasing an additional crane for the scrap yard, bin modifications, replacing the lining of the charging ladles in a manner that will increase the ladle size, modifying the turret to accommodate heavier ladles, purchasing an additional crane for the billet yard, and modifying the billet rack system.
       The permittee performed a project emission increase analysis to determine the difference between the future projected actual emissions and the current actual emissions (including the "could have accommodated" portion).  This evaluation included emissions units B008, F002  -  F004, P029, P032  -  P038, P041, P043  -  P045, P046, and P900  -  P902.
       The permittee has proposed that the amount of emissions increase, which is the difference between the future projected actual emissions and current actual emissions (including those emissions that the source could have accommodated per OAC rule 3745-331-01(GGGGG)(3)), as a result of this project will be less than 40 tons NOx/year, less than 40 tons VOC/year, less than 15 tons PM10/year, less than 10 tons PM2.5/year, and less than 0.6 ton lead/year. In accordance with OAC rule 3745-31-10(A)(3), the permittee shall maintain records for 5 years after completing the modifications that demonstrate that the amount of actual emissions increase (taking into account what the source could have accommodated prior to the Melt Shop Expansion Project) stays below these major modification thresholds.
       The analysis shows that both SO2 and CO exceed the significance thresholds for this project that triggers the PSD requirements for both pollutants and NNSR for SO2 as a precursor for PM2.5.  The permittee performed a BACT analysis for both pollutants and a LAER analysis for SO2 for the emissions units identified above.  The following provides a summary of the project emission increase analysis:
       

                                      PM
                                    (filt.)
                                    ton/yr
                                      PM
                                    (cond.)
                                    ton/yr
                                     PM10
                                    (filt.)
                                    ton/yr
                                     PM10
                                    (cond.)
                                    ton/yr
                                     PM2.5
                                    (filt.)
                                    ton/yr
                                     PM2.5
                                    (cond.)
                                    ton/yr
                                      SO2
                                    ton/yr
                                      NOx
                                    ton/yr
                                      VOC
                                    ton/yr
                                      CO
                                    ton/yr
                                      Pb
                                    ton/yr
Future
Projected
Actual
Total
                                     52.89
                                     15.72
                                     29.00
                                     15.72
                                     24.38
                                     15.72
                                      314
                                    231.78
                                     89.45
                                   1,627.92
                                     0.17
Current
Actual
(including
"could have
accomm.")
Total
                                     40.96
                                     13.36
                                     21.65
                                     13.36
                                     17.87
                                     13.36
                                     96.69
                                    199.26
                                     75.67
                                   1,364.91
                                     0.05
Project
Emission
Increase
                                     11.92
                                     2.36
                                     7.35
                                     2.36
                                     6.51
                                     2.36
                                    217.31 
                                     32.52
                                     13.79
                                    263.06
                                     0.12
NSR
threshold
                                      N/A
                                      N/A
                                      15
                                      10
                                      40
                                      40
                                      40
                                      100
                                      0.6
NSR
triggered?
                                      N/A
                                      N/A
                                      no
                                      no
                                      yes
                                      no
                                      no
                                      yes
                                      no
       
      For the emissions units noted above, the only emissions units that will have an increase in emissions that is above their current allowable emission limits are F002, F003, P043, P900, and P901.  All of the other emissions units were previously permitted at maximum potential to emit through the PSD PTI 13-04176 that was issued on 6/10/2004 and the limitations are not changing as a result of this proposed expansion project.  The majority of emissions for all pollutants that are emitted by Charter Steel are primarily generated by the melt shop and emitted through the melt shop baghouse.
This facility has emission limitations that have been established in previous permits for the total amount of emissions that are emitted through the Melt Shop baghouse.  These emission limits (with the exception of PM2.5) have been established as best available control technology (BACT) through OAC rules 3745-31-10 through 20 in accordance with the Prevention of Significant Deterioration requirements, and lowest achievable emission rate (LAER) for SO2 through OAC rules 3745-31-21 through 27 in accordance with the Nonattainment New Source Review requirements.  These BACT limits are being updated through this permit to reflect the changed emission profile resulting from the Melt Shop Expansion Project.  The BACT and LAER limits included in this permit supersede the limits in PTI #13-04176.  The emission limits for PM2.5 have been established as BAT through OAC rule 3745-31-05(A)(3).
The emissions from emissions units P032-P038, P041, P048, and P900-P902 that vent to the Melt Shop Baghouse shall not exceed the following BACT/BAT emission limits from the baghouse outlet:
PM emissions shall not exceed 4.31 lbs/hr and 0.00069 grains/dscf (filterable) 
PM10 emissions shall not exceed 3.27 lbs/hr and 0.00052 grains/dscf (filterable)
PM2.5 emissions shall not exceed 3.19 lbs/hr and 0.00051 grains/dscf (filterable)
Nitrogen oxide (NOx) emissions shall not exceed 47.09 lbs/hr 
Volatile organic compounds (VOC) emissions shall not exceed 22.71 lbs/hr 
Lead (Pb) emissions shall not exceed 0.03 lb/hr 
Mercury (Hg) emissions shall not exceed 0.052 lb/hr 
3 percent opacity, as a 6-minute average, from the Melt Shop baghouse stack exit
These lb/hr, gr/dscf, and opacity BACT limits were originally established through the PSD PTI 13-04176 issued on 6/10/2004, with the exception of the PM2.5 limit which was first included as part of this permitting action as a BAT limit.  The ton/year limits have been eliminated since the annual emissions are increasing as a result of this permit modification.  The PM, PM10, PM2.5, and lead limits have been included and adjusted based on updated information from the permittee in their permit application.  These limits supersede the limits in PTI 13-04176.
The emissions from emissions units P032-P038, P041, P043, P048, and P900-P902 that vent to the Melt Shop Baghouse shall not exceed the following BACT/LAER (for SO2) from the baghouse outlet:
Sulfur dioxide (SO2) emissions shall not exceed 166.16 lbs/hr and 314 tons per year per rolling 12-month period.  BACT emission limits for SO2 also include the following:
 "low-sulfur steel grades"  -  no sulfur addition and carbon specification less than 0.6% carbon per heat with emission limit of 0.4 lb SO2/ton of steel;
 "mid-sulfur steel grades"  -  sulfur addition less than 0.1% and carbon specification greater than or equal to 0.6% carbon per heat with emission limit of 0.75 lb SO2/ton of steel; and
 "high-sulfur steel grades"  -  sulfur addition greater than or equal to 0.1% with emission limit of 1.51 lbs SO2/ton of steel.
      The terms "low-sulfur steel grades", "mid-sulfur steel grades," and "high-sulfur steel grades" 
            are not industry standard terms, but rather reflect the relative magnitude of SO2 emissions resulting from the addition of sulfur and/or carbon to meet product specifications.
            
The emissions from emissions units P032-P038, P041, P048, and P900-P902 that vent to the Melt Shop Baghouse shall not exceed the following BACT limit (for CO) from the baghouse outlet:
      Carbon monoxide (CO) emissions shall not exceed 397.06 lbs/hr 
Visible emissions of fugitive dust from the Melt Shop building shall not exceed 6 percent opacity, as a 6-minute average.
This visible emission limitation was established as BACT through the PSD PTI 13-04176 and remains in effect.
Compliance with the lb/hr, lb/ton, and gr/dscf emission limits above shall be based upon the results of the emission testing specified in B.5.g) below.  The emission testing shall be performed in accordance with the requirements of 40 CFR Part 60 Subpart AAa and 40 CFR Part 63 Subpart YYYYY
Compliance with the stack and fugitive opacity limitations above shall be determined through visible emission observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B).
Emissions testing to demonstrate compliance with the melt shop particulate and lead (Pb) limits shall be conducted in accordance with the test schedule set forth in the permittee's Title V permit.   
              Emission testing shall be conducted to demonstrate compliance with the SO2 limits of 0.4 lb SO2/ton, 0.75 lb SO2/ton, and 1.51 lb SO2/ton within 180 days of permit issuance. 
The test(s) shall be conducted while emissions units P032-P038, P041, P048, and P900-P902 are operating simultaneously at or near their maximum capacity, unless otherwise specified or approved by the Cleveland DAQ.  The tests shall be conducted in accordance with the requirements of 40 CFR Part 60.275a.
For the sulfur dioxide testing, the permittee shall perform three test runs for each category of steel that is produced:  low-sulfur, mid-sulfur, and high-sulfur.  The tests shall be performed to demonstrate compliance with the LAER emission limits that have been established for the Melt Shop baghouse for each category of steel in lbs SO2/ton of steel produced.
Compliance with the annual sulfur dioxide emission limit for emissions units P032  -  P038, P041, P043, P048, and P900  -  P902 combined shall be demonstrated using the following equation: 
                  Total SO2 emissions = ((0.40 lb SO2/ton steel * a) + (0.75 lb SO2/ton steel * b) + (1.51 lb SO2/ton steel * c))/2000
                        Where:
                        a = tons of low-sulfur steel grades produced by the melt shop in the preceding 12-month period
                        b = tons of mid-sulfur steel grades produced by the melt shop in the preceding 12-month period
                        c = tons of high-sulfur steel grades produced by the melt shop in the preceding 12-month period
             The permittee shall use the lb SO2/ton steel emission factor determined from the most recent performance test that demonstrated compliance in the above formula for each category of steel.
             The permittee shall maintain monthly records for the melt shop of the tons of steel produced for each category of steel (i.e., low-sulfur, mid-sulfur, and high-sulfur) for each calendar month, the rolling, 12-month summation of the steel produced for each category, and the rolling, 12-month SO2 totals.
During performance tests, the permittee shall not add gaseous diluents to the effluent gas stream after the fabric in any pressurized fabric filter collector unless the amount of dilution is separately determined and considered in the determination of emissions.
The following test methods shall be employed to demonstrate compliance with the emission limitations: 
Methods 1 through 5 of 40 CFR Part 60, Appendix A for particulates; 
Methods 1 through 4 and 6 of 40 CFR Part 60, Appendix A for SO2; 
Methods 1 through 4 and 12 or 29 of 40 CFR Part 60, Appendix A for lead (Pb); and
Alternative U.S. EPA-approved test methods may be used with prior approval from the Ohio EPA.
The performance test protocol (i.e., Ohio EPA Intent to Test) shall specify the baghouse pressure set point that will be utilized during the test.   The performance test report of results shall include data that proves the baghouse was tested at the requested set point.
During the emissions testing, the emissions unit shall be operated under operational conditions approved in advance by the Cleveland DAQ.  Operational conditions that may need to be approved include, but are not limited to, the production rate, the type of material processed, material make-up (solvent content, etc.), or control equipment operational limitations (burner temperature, precipitator voltage, etc.).  In general, testing shall be done under "worst case" conditions expected during the life of the permit.  As part of the information provided in the "Intent to Test" notification form described below, the permittee shall provide a description of the emissions unit operational conditions they will meet during the emissions testing and describe why they believe "worst case" operating conditions will be met.  Prior to conducting the test(s), the permittee shall confirm with the Cleveland DAQ that the proposed operating conditions constitute "worst case".  Failure to test under the approved conditions may result in Ohio EPA not accepting the test results as a demonstration of compliance.
Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test" notification to the Cleveland DAQ.  The "Intent to Test" notification shall describe in detail the proposed test methods and procedures, the emissions unit operating parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s).  Failure to submit such notification for review and approval prior to the test(s) may result in the Cleveland DAQ's refusal to accept the results of the emission test(s).
Personnel from the Cleveland DAQ shall be permitted to witness the test(s), examine the testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the performance of the control equipment.
A comprehensive written report on the results of the emissions test(s) shall be signed by the person or persons responsible for the tests and submitted to the Cleveland DAQ within 30 days following completion of the test(s).  The permittee may request additional time for the submittal of the written report, where warranted, with prior approval from the Cleveland DAQ.
Emissions Offset Requirements
       As of the effective date of this Permit, the permittee has obtained legal ownership of 324 tons/year of creditable sulfur dioxide emission offsets from the First Energy Eastlake Plant (Facility ID# 0243160009) in accordance with rule OAC rule 3745-31. 
 Pollutant
 Offset Amount Available (tons/yr)
 Facility Name
 Ohio EPA Facility Number
 Emissions Units Involved
 Sulfur dioxide
                                      324
 First Energy Eastlake 
 02-43-16-0009
 B005
       
       Of the total 324 tons/year in sulfur dioxide offsets purchased, 314 tons/year are required in support of the Melt Shop Expansion Project, leaving the permittee with an extra 10 tons/year in creditable offsets that can be used at another time or sold. 


C.	Emissions Unit Terms and Conditions
 B008, VTD Boiler
		Operations, Property and/or Equipment Description:  
            28.576 mmBtu/hr natural gas boiler for the VTD system equipped with a low NOx burner
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
 None.
 Applicable Emissions Limitations and/or Control Requirements
 The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
OAC rule 3745-31-05(A)(3) 
05/01/2016
See g)(1) below.
Sulfur dioxide (SO2) emissions shall not exceed 0.02 lb/hr and 0.05 ton/year.
The requirements of this rule also include compliance with the requirements of OAC rule 3745-31-10 through 20, OAC rule 3745-18-06(A), and OAC rule 3745-17-07(A)(1).
b.
OAC rule 3745-31-10 through 20

PM/PM10 emissions shall not exceed 0.21 lb/hr and 0.68 ton/year.
Carbon monoxide (CO) emissions shall not exceed 2.35 lbs/hr and 7.57 tons/year.
Organic compound (OC) emissions shall not exceed 0.31 lbs/hr and 0.99 ton/year.
Nitrogen oxide (NOx) emissions shall not exceed 2.80 lbs/hr and 9.01 tons/year.
Volatile Organic Compounds (VOC) emissions shall not exceed 0.15 lb/hr and 0.5 ton/year.
The requirements of this rule also include compliance with the requirements of OAC rule 3745-17-07(A).
See b)(2)b. below.
c.
OAC rule 3745-17-07(A)(1)

Visible particulate emissions shall not exceed 20% opacity, as a 6-minute average, except as provided by rule.
d.
OAC rule 3745-17-10(B)(1)

The particulate emission limitation specified by this rule is less stringent than the particulate emission limitation established pursuant to OAC rule 3745-31-05(A)(3).
e.
OAC rule 3745-18-06(A)

Exempt pursuant to OAC rule 3745-18-06(A) when burning natural gas
f.
40 CFR 60 Subpart Dc
See b)(2)a. below.
g.
OAC rule 3745-110-03(C)
See d)(2) below.

 Additional Terms and Conditions
 So long as only natural gas fuel is burned, this emissions unit is not subject to the emission limits listed in 40 CFR Part 60, Subpart Dc.
 Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted to ensure the application of "Best Available Control Technology" (BACT) through PTI #13-0416 issued on 6/10/2004, it has been determined that the use of natural gas as fuel, acceptance of a NOx limitation of 100 lb of NOx/MMcf and acceptance of a CO limitation of 84 lb of CO/MMcf constitutes BACT for this emission unit.  The emissions limits based on the BACT requirements are listed under OAC rule 3745-31-10 through 20 above.
There is no increase of the previous allowable emission limits as a result of the proposed Melt Shop expansion project for this emissions unit.  Instead, the permittee has  requested a reduction of the annual allowable emission limit pursuant to the project emission increase analysis that was performed.
 Operational Restrictions
 The permittee shall burn only natural gas in this emissions unit.
 Monitoring and/or Recordkeeping Requirements
 For each day during which the permittee burns a fuel other than natural gas, the permittee shall maintain a record of the type and quantity of fuel burned in this emissions unit.
 The owner or operator of a small boiler must annually perform a tune-up and maintain, in a permanently bound log book, or other format approved in writing by the director the following information:
 the date of the last tune-up;
 the name, title and affiliation of the person who performed the tune-up and made any adjustments; and
 any other information which the Ohio Environmental Protection agency may require as a condition of approval of any permit for the boiler.
 Reporting Requirements
 The permittee shall submit deviation (excursion) reports to the Cleveland Division of Air Quality (Cleveland DAQ) that identify each day when a fuel other than natural gas was burned in this emissions unit.  Each report shall be submitted within 30 days after the deviation occurs.
 Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center:  Air Services online web portal.
 Testing Requirements
 Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:
 Emission Limitation:
                         Visible particulate emissions shall not exceed 20% opacity, as a 6-minute average, except as provided by rule.
Applicable Compliance Method:
Compliance shall be determined through visible emission observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).
 Emission Limitation:
                         PM/PM10 emissions shall not exceed 0.21 lb/hr.
Applicable Compliance Method:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 7.6 lbs of particulates/mmcf (filterable plus condensable) by the emissions unit's maximum hourly natural gas firing rate (0.02802 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
If required, the permittee shall demonstrate compliance with this emission limitation in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(9) while firing natural gas.
 Emission Limitation:    
                         0.68 TPY of PM/PM10 
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 7.6 lbs of PM/PM10/mmcf (filterable plus condensable) by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000178 mmcf/ton.
 Emission Limitation:
                         CO emissions shall not exceed 2.35 lbs/hr.
Applicable Compliance Method:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 84 lbs of CO/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.02802 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-1 (7/98).
If required, the permittee shall demonstrate compliance with the lbs/hr emission limitation in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 10 while firing natural gas.  
 Emission Limitation:    
                         7.57 TPY of CO emissions 
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 84 lbs of CO/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000178 mmcf/ton.
 Emission Limitation:
                         NOx emissions shall not exceed 2.80 lbs/hr.
Applicable Compliance Method(s):
When firing natural gas, compliance shall be determined by multiplying an emission factor of 100 lbs of NOx/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.02802 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-1 (7/98).
If required, the permittee shall demonstrate compliance with the lbs/hr emission limitation in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 7 while firing natural gas.
 Emission Limitation:    
                         9.01 TPY of NOx emissions 
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 100 lbs of NOx/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000178 mmcf/ton.
 Emission Limitation:
                         OC emissions shall not exceed 0.31 lb/hr.
Applicable Compliance Method:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 11 lbs of OC/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.02802 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
 Emission Limitation:    
                         0.99 TPY of OC emissions 
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 11 lbs of OC/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000178 mmcf/ton.
 Emission Limitation:
                         VOC emissions shall not exceed 0.15 lb/hr.
Applicable Compliance Method(s):
When firing natural gas, compliance shall be determined by multiplying an emission factor of 5.5 lbs of VOC/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.02802 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
If required, the permittee shall demonstrate compliance with the lbs/hr emission limitation in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 25 or 25A while firing natural gas.
 Emission Limitation:    
                         0.5 TPY of VOC emissions 
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 5.5 lbs of VOC/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000178 mmcf/ton.
 Emission Limitation:
                         SO2 emissions shall not exceed 0.02 lb/hr.
Applicable Compliance Method(s):
When firing natural gas, compliance shall be determined by multiplying an emission factor of 0.6 lb of SO2/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.02802 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
If required, the permittee shall demonstrate compliance with the lbs/hr emission limitation in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 6 while firing natural gas.

 Emission Limitation:    
                         0.05 TPY of SO2 emissions 
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 0.6 lb of SO2/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000178 mmcf/ton.
 Miscellaneous Requirements
The following PTIs were previously issued for emissions unit B008:
PTI #13-04176 issued on 6/10/2004; and
PTI admin mod #13-04176 issued on 2/12/2008.
The above PTIs are superseded by this permit for this emissions unit.

 F002, Roadways and Parking
		Operations, Property and/or Equipment Description:  
            Paved and unpaved roadways and parking areas
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
None.
Applicable Emissions Limitations and/or Control Requirements
The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
Paved roadways and parking areas

i.
ORC 3704.03(T)
OAC rule 3745-31-05(A)(3)
05/01/2016 
See g)(1) below.
Particulate matter (PM) emissions shall not exceed 1.33 tons/month averaged over a 12-month rolling period.

ii.
ORC 3704.03(T)
OAC rule 3745-31-05(A)(3)
05/01/2016
See g)(1) below.
PM10 emissions shall not exceed 0.27 ton/month averaged over a 12-month rolling period.
See b)(2)k. below.
iii.
OAC rule 3745-31-05(A)(3)(a)(ii)
05/01/2016
The Best Available Technology (BAT) requirements under OAC rule 3745-31-05(A)(3) do not apply to the PM10 emissions from the paved roadways and parking areas since the potential to emit is less than 10 tons/year.
See b)(2)l. below.
iv.
OAC rules 3745-31-10 through 20 (PSD)
These BACT limits were originally established through the PSD PTI 13-04176 issued on 6/10/2004 and remain in effect.  The ton/year limits have been replaced with new BAT limits since BACT was not triggered for these pollutants for this permit modification.
There shall be no visible emissions of fugitive dust from any paved roadway or parking area except for one minute during any 60-minute period.
The permittee shall employ best available control measures that are sufficient to minimize or eliminate visible emissions of fugitive dust (see b)(2)c.,  and b)(2)e. through b)(2)i. below).
See b)(2)j. below.
v.
OAC rule 3745-17-07(B)(4)
The visible emission limitation specified by this rule is less stringent than the visible emission limitation established pursuant to OAC rules 3745-31-10 through 20 per b)(1)a.iv..
vi.
OAC rule 3745-17-08(B), (B)(8), 
(B)(9)
The control measures specified by these rules are less stringent than the control measures established pursuant to OAC rules 3745-31-10 through 20 per b)(1)a.iv..
b.
Unpaved roadways and parking areas

i.
ORC 3704.03(T)
OAC rule 3745-31-05(A)(3)
05/01/2016
See g)(1) below.
Particulate matter (PM) emissions shall not exceed 0.24 ton/month averaged over a 12-month rolling period.
PM10 emissions shall not exceed 0.074 ton/month averaged over a 12-month rolling period.
See b)(2)k. below.
ii.
OAC rule 3745-31-05(A)(3)(a)(ii)
June 30, 2008
The Best Available Technology (BAT) requirements under OAC rule 3745-31-05(A)(3) do not apply to the PM and PM10 emissions from the unpaved roadways and parking areas since the potential to emit is less than 10 tons/year.
See b)(2)l. below.
iii.
OAC rules 3745-31-10 through 20 (PSD)
These BACT limits were originally established through the PSD PTI 13-04176 issued on 6/10/2004 and remain in effect.  The ton/year limits have been replaced with new BAT limits since BACT was not triggered for these pollutants for this permit modification.
There shall be no visible emissions of fugitive dust from any unpaved roadway or parking area except for three minutes during any 60-minute period.
The permittee shall employ best available control measures that are sufficient to minimize or eliminate visible emissions of fugitive dust (see b)(2)d. through b)(2)i. below).
See b)(2)j. below.
iv.
OAC rule 3745-17-07(B)(5)
The visible emission limitation specified by this rule is less stringent than the visible emission limitation established pursuant to OAC rules 3745-31-10 through 20 per b)(1)b.iii..
v.
OAC rule 3745-17-08(B), (B)(2)
The control measures specified by these rules are less stringent than the control measures established pursuant to OAC rules 3745-31-10 through 20 per b)(1)b.iii..

Additional Terms and Conditions
The paved roadways and parking areas that are covered by this permit and subject to the above-mentioned requirements are listed below:
                        3.01 miles of paved roadways 
 The unpaved roadways and parking areas that are covered by this permit and subject to the above-mentioned requirements are listed below:
                        0.6 miles of unpaved roadways
 The permittee shall employ best available control measures on all paved roadways and parking areas for the purpose of ensuring compliance with the above-mentioned applicable requirements.  In accordance with the permittee's permit application, the permittee has committed to treat the paved roadways and parking areas by flushing with water at sufficient treatment frequencies to ensure compliance.  Nothing in this paragraph shall prohibit the permittee from employing other control measures to ensure compliance.
 The permittee shall employ best available control measures on all unpaved roadways and parking areas for the purpose of ensuring compliance with the above-mentioned applicable requirements.  In accordance with the permittee's permit application, the permittee has committed to treat the unpaved roadways and parking areas with water at sufficient treatment frequencies to ensure compliance.  Nothing in this paragraph shall prohibit the permittee from employing other control measures to ensure compliance.
 The needed frequencies of implementation of the control measures shall be determined by the permittee's inspections pursuant to the monitoring section of this permit.  Implementation of the control measures shall not be necessary for a paved or unpaved roadway or parking area that is covered with snow and/or ice or if precipitation has occurred that is sufficient for that day to ensure compliance with the above-mentioned applicable requirements.  Implementation of any control measure may be suspended if unsafe or hazardous driving conditions would be created by its use.
 Any unpaved roadway or parking area, which during the term of this permit is paved or takes the characteristics of a paved surface due to the application of certain types of dust suppressants, may be controlled with the control measure(s) specified above for paved surfaces.  Any unpaved roadway or parking area that takes the characteristics of a paved roadway or parking area due to the application of certain types of dust suppressants shall remain subject to the visible emission limitation for unpaved roadways and parking areas.  Any unpaved roadway or parking area that is paved shall be subject to the visible emission limitation for paved roadways and parking areas.
 The permittee shall promptly remove, in such a manner as to minimize or prevent resuspension, earth and/or other material from paved streets onto which such material has been deposited by trucking or earth moving equipment or erosion by water or other means.
 Open-bodied vehicles transporting materials likely to become airborne shall have such materials covered at all times if the control measure is necessary for the materials being transported.
Implementation of the above-mentioned control measures in accordance with the terms and conditions of this permit is appropriate and sufficient to satisfy the best available control technology requirements of OAC rules 3745-31-10 through 20.
Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted to ensure the application of "Best Available Control Technology" (BACT) through PTI #13-04176 issued on 6/10/2004, it has been determined that the use of reduced speed limits and water flushing for control constitutes BACT for this emission unit. The emissions limits based on the BACT requirements are listed under OAC rules 3745-31-10 through 20 above for both the paved and unpaved roadways and parking areas.  
This Best Available Technology (BAT) emission limit applies until U.S. EPA approves Ohio Administrative Code (OAC) paragraph 3745-31-05(A)(3)(a)(ii) (the less than 10 tons per year BAT exemption) into the Ohio State Implementation Plan (SIP).
These requirements apply once U.S. EPA approves OAC paragraph 3745-31-05(A)(3)(a)(ii) (the less than 10 tons per year BAT exemption) as part of the Ohio SIP. 
Operational Restrictions
None.
Monitoring and/or Recordkeeping Requirements
Except as otherwise provided in this section, the permittee shall perform daily inspections of all the roadways and parking areas.
 The purpose of the inspections is to determine the need for implementing the above-mentioned control measures. The inspections shall be performed during representative, normal traffic conditions.  No inspection shall be necessary for a roadway or parking area that is covered with snow and/or ice or if precipitation has occurred that is sufficient for that day to ensure compliance with the above-mentioned applicable requirements.  Any required inspection that is not performed due to any of the above-identified events shall be performed as soon as such event(s) has (have) ended, except if the next required inspection is within one week.
 The permittee may, upon receipt of written approval from the Cleveland Division of Air Quality, modify the above-mentioned inspection frequencies if operating experience indicates that less frequent inspections would be sufficient to ensure compliance with the above-mentioned applicable requirements.
 The permittee shall maintain records of the following information:
 the date and reason any required inspection was not performed, including those inspections that were not performed due to snow and/or ice cover or precipitation;
 the date of each inspection where it was determined by the permittee that it was necessary to implement the control measures; 
 the dates the control measures were implemented; and
 on a calendar quarter basis, the total number of days the control measures were implemented and the total number of days where snow and/or ice cover or precipitation were sufficient to not require the control measures.
The information required in d)(4)d. shall be kept separately for (i) the paved roadways and parking areas and (ii) the unpaved roadways and parking areas, and shall be updated on a calendar quarter basis within 30 days after the end of each calendar quarter.

Reporting Requirements
The permittee shall submit quarterly deviation reports to the Cleveland Division of Air Quality that identify any of the following occurrences:
each day during which an inspection was not performed by the required frequency, excluding an inspection which was not performed due to an exemption for snow and/or ice cover or precipitation; and
each instance when a control measure, that was to be implemented as a result of an inspection, was not implemented.
The deviation reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.
Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center:  Air Services online web portal.
Testing Requirements
Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:
Emission Limitation:
                         Paved Roads
                         PM emissions shall not exceed 1.33 tons/month averaged over a 12-month rolling period.
                         PM10 emissions shall not exceed 0.27 ton/month averaged over a 12-month rolling period.
Applicable Compliance Method:
The ton/month average emission limitation shall be based on calculations using the equation 1 for Paved Roadways and Parking areas taken from U.S. EPA reference document AP-42, 5th edition, Compilation of Air Pollution Emission Factors, Section 13.2.1 (1/2011) to establish the emission factor in lb/VMT.  The calculated emission factors are 2.08 lb/VMT (trucks) and 0.12 lb/VMT (cars) for PM emissions and 0.42 lb/VMT (trucks) and 0.02 lb/VMT (cars) for PM10 emissions.  This emission factor is multiplied by the annual vehicle miles traveled (VMT) and (1 - 0.80) to account for the 80% vehicle speed control efficiency and divided by the factor of 2,000 lbs/ton.  Then divide by 12 months to determine the monthly average emission rate.

Emission Limitation:
                        There shall be no visible emissions of fugitive dust from any paved roadway or parking area except for one minute during any 60-minute period.
                        Applicable Compliance Method:
                         Compliance with the emission limitation for the paved roadways and parking areas identified above shall be determined in accordance with Test Method 22 as set forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources," as such Appendix existed on July 1, 1996, and the modifications listed in paragraphs (B)(4)(a) through (B)(4)(d) of OAC rule 3745-17-03.
Emission Limitation:    
                         Unpaved Roads
                         PM emissions shall not exceed 0.24 ton/month averaged over a 12-month rolling period.
                         PM10 emissions shall not exceed 0.074 ton/month averaged over a 12-month rolling period. 
Applicable Compliance Method:
The ton/month average emission limitation shall be based on calculations using the equation 1 for Unpaved Roadways and Parking areas taken from U.S. EPA reference document AP-42, 5th edition, Compilation of Air Pollution Emission Factors, Section 13.2.2 (1/2011) to establish the emission factor in lb/VMT.  The emission factors are 7.71 lb/VMT for PM emissions and 2.38 lb/VMT for PM10 emissions.  This emission factor is multiplied by the annual vehicle miles traveled (VMT) and (1 - 0.50) to account for the 50% watering emission control efficiency and (1 - 0.80) to account for the 80% vehicle speed control efficiency and divided by the factor of 2,000 lbs/ton.  Then divide by 12 months to determine the monthly average emission rate.
Emission Limitation:
                         There shall be no visible emissions of fugitive dust from any unpaved roadway or parking area except for three minutes during any 60-minute period.
Applicable Compliance Method:
Compliance with the emission limitation for the unpaved roadways and parking areas identified above shall be determined in accordance with Test Method 22 as set forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources," as such Appendix existed on July 1, 1996, and the modifications listed in paragraphs (B)(4)(a) through (B)(4)(d) of OAC rule 3745-17-03.
Miscellaneous Requirements
The following PTIs were previously issued for emissions unit F002:
PTI #13-04176 issued on 6/10/2004; and
PTI admin mod #13-04176 issued on 2/12/2008.
The above PTIs are superseded by this permit for this emissions unit.
 F003, Charge Handling
		Operations, Property and/or Equipment Description:  
            Charge handling of steel scrap furnace charge conducted inside of a building.  
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
None.
Applicable Emissions Limitations and/or Control Requirements
The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
ORC 3704.03(T)
OAC rule 3745-31-05(A)(3)
05/01/2016
See g)(1) below.
Particulate matter (PM) emissions shall not exceed 0.80 ton/month averaged over a 12-month rolling period.
PM10 emissions shall not exceed 0.48 ton/month averaged over a 12-month rolling period.
PM2.5 emissions shall not exceed 0.40 ton/month averaged over a 12-month rolling period.
See b)(2)a. below.
b.
OAC rule 3745-31-05(A)(3)(a)(ii)
05/01/2016
The Best Available Technology (BAT) requirements under OAC rule 3745-31-05(A)(3) do not apply to the PM, PM10, and PM2.5 emissions from this emissions unit since the potential to emit is less than 10 tons/year for each pollutant.
See b)(2)b. below.
c.
OAC rules 3745-31-10 through 20 (PSD) 
These BACT limits were originally established through the PSD PTI 13-04176 issued on 6/10/2004 and remain in effect.  The ton/year limits have been replaced with new BAT limits since BACT was not triggered for these pollutants for this permit modification.
PM/PM10 emissions shall not exceed 2.19 lbs/hr. 
Visible emissions of fugitive dust shall not exceed 5% opacity as a six-minute average.
The permittee shall employ best available control measures that are sufficient to minimize or eliminate visible emissions of fugitive dust.
See b)(2)c. below.
d.
OAC rule 3745-17-07(B)(1)
The visible emission limitation specified by this rule is less stringent than the visible emission limitation established pursuant to OAC rules 3745-31-10 through 20.
e.
OAC rule 3745-17-08(B)
The control measures specified by this rule are equivalent to the control measures established pursuant to OAC rules 3745-31-10 through 20.
f.
OAC rule 3745-17-11
The emission limitation specified by this rule is less stringent than the emission limitation established pursuant to OAC rules 3745-31-10 through 20.

Additional Terms and Conditions
This Best Available Technology (BAT) emission limit applies until U.S. EPA approves Ohio Administrative Code (OAC) paragraph 3745-31-05(A)(3)(a)(ii) (the less than 10 tons per year BAT exemption) into the Ohio State Implementation Plan (SIP).
These requirements apply once U.S. EPA approves OAC paragraph 3745-31-05(A)(3)(a)(ii) (the less than 10 tons per year BAT exemption) as part of the Ohio SIP.
Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted to ensure the application of "Best Available Control Technology" (BACT) through PTI #13-04176 issued on 6/10/2004, it has been determined that the use of a building for partial capture along with work practices constitutes BACT for this emission unit. The emissions limits based on the BACT requirements are listed under OAC rules 3745-31-10 through 20 above. 
Operational Restrictions
The maximum annual charge rate for this emissions unit shall not exceed 915,326 tons, based upon a rolling, 12-month summation of the tons of scrap steel charged per month.
The permittee shall operate this emissions unit in accordance with the Scrap Management Program (SMP) submitted on July 3, 2008 to the Cleveland Division of Air Quality (Cleveland DAQ) to allow the minimal use of scrap charged in the EAF that contains mercury, lead, oils, plastics, and organic materials.  The SMP shall be viewed as an operational restriction for the EAF.  Any future change to the SMP that would increase the amount of these compounds present in the scrap, or result in the emissions of an air contaminant not previously emitted, must be approved by the Cleveland DAQ.
All grades of scrap shall be free of excessive dirt, oil, and grease.  Heavily oiled scrap shall not be used.  As part of the SMP, the permittee shall install a radionuclide detector which will be used to inspect all incoming scrap material into the facility.  Radioactive scrap material shall not be used at this facility.  Any scrap material which is determined to be radioactive shall be disposed of in accordance with the Nuclear Regulatory Commission's (NRC) requirements.
Monitoring and/or Recordkeeping Requirements
The permittee shall maintain daily charge rate records for this emissions unit.  These records, at a minimum, shall contain the following information:
 the number of hours this emissions unit was in operation; and
 the tons of steel scrap charged.
The permittee shall maintain monthly records of the tons of steel scrap charged during each calendar month, as well as the rolling, 12-month summation of scrap charged.
Reporting Requirements
The permittee shall submit deviation (excursion) reports to the Cleveland DAQ which identify all exceedances of the rolling, 12-month steel scrap charge rate limitation.  Each deviation report shall be submitted to the Cleveland DAQ within 30 days after the deviation occurs.
Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center:  Air Services online web portal.
Testing Requirements
Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:
Emission Limitation:
                         PM emissions shall not exceed 0.80 ton/month averaged over a 12-month rolling period.
Applicable Compliance Method:
The ton per month average emissions shall be determined by multiplying the emission factor taken from the "Inventory of Iron Foundry Emissions", A.T. Kearney Report for Raw material handling and Charge make-up (0.07 lb PM/ton) by the actual annual steel scrap charge rate for the emissions unit, (1 - 0.70) which is the 70% control efficiency of scrap steel handling conducted inside of the building enclosure as well as work practices and divide by 2,000 pounds/ton.  Then divide by 12 months to determine the monthly average emission rate.  Therefore, compliance with the ton/month average emission limitation shall be demonstrated provided compliance with the annual steel scrap charge limitation based upon a rolling, 12-month summation is met.
Emission Limitation:
                         PM10 emissions shall not exceed 0.48 ton/month averaged over a 12-month rolling period.
Applicable Compliance Method:
The ton per month average emissions shall be determined by multiplying the emission factor taken from the "Inventory of Iron Foundry Emissions", A.T. Kearney Report for Raw material handling and Charge make-up (0.07 lb PM/ton) by an adjustment factor of 0.6 to determine the PM10 portion, then multiply by the actual annual steel scrap charge rate for the emissions unit, (1 - 0.70) which is the 70% control efficiency of scrap steel handling conducted inside of the building enclosure as well as work practices and divide by 2,000 pounds/ton.  Then divide by 12 months to determine the monthly average emission rate.   Therefore, compliance with the ton/month average emission limitation shall be demonstrated provided compliance with the annual steel scrap charge limitation based upon a rolling, 12-month summation is met.
Emission Limitation:
                         PM2.5 emissions shall not exceed 0.40 ton/month averaged over a 12-month rolling period.
Applicable Compliance Method:
The ton per month average emissions shall be determined by multiplying the emission factor taken from the "Inventory of Iron Foundry Emissions", A.T. Kearney Report for Raw material handling and Charge make-up (0.07 lb PM/ton) by an adjustment factor of 0.5 to determine the PM2.5 portion, then multiply by the actual annual steel scrap charge rate for the emissions unit, (1 - 0.70) which is the 70% control efficiency of scrap steel handling conducted inside of the building enclosure as well as work practices and divide by 2,000 pounds/ton.  Then divide by 12 months to determine the monthly average emission rate.  Therefore, compliance with the ton/month average emission limitation shall be demonstrated provided compliance with the annual steel scrap charge limitation based upon a rolling, 12-month summation is met.
Emission Limitation:
                         PM/PM10 emissions shall not exceed 2.19 lbs/hr.
Applicable Compliance Method:
Compliance with the hourly emission limitation may be determined through the use of the emission factor taken from the "Inventory of Iron Foundry Emissions", A.T. Kearney Report for Raw material handling and Charge make-up (0.07 lb/ton) which is multiplied by the maximum hourly charge rate for the emissions unit (120 tons/hr) and (1 - 0.70) which is the 70% control efficiency of scrap steel handling conducted inside of the building enclosure as well as work practices.
Emission Limitation:
                         Visible emissions of fugitive dust shall not exceed 5% opacity as a six-minute average. 
Applicable Compliance Method:    
                         Compliance with the visible emission limitations  shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix existed on July 1, 1996, and the modifications listed in paragraphs (B)(4)(a) through (B)(4)(c) of OAC rule 3745-17-03.
Miscellaneous Requirements
The following PTIs were previously issued for emissions unit F003:
PTI #13-04176 issued on 6/10/2004; and
PTI admin mod #13-04176 issued on 2/12/2008.
The above PTIs are superseded by this permit for this emissions unit.

 F004, Dust Silo
		Operations, Property and/or Equipment Description:  
            Dust silo equipped with a bin vent for control of particulate emissions from the Melt Shop baghouse.  
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
None.
Applicable Emissions Limitations and/or Control Requirements
The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
OAC rule 3745-31-05(A)(3)
See g)(1) below.
The requirements of this rule also include compliance with the requirements and OAC rule 3745-31-10 through 20, and 40 CFR Part 60 Subpart AAa.
b.
OAC rule 3745-31-10 through 20
0.01 grain/dry standard cubic feet of exhaust gases and 0.10 pound/hour and 0.45 TPY of PM/PM10 emissions
See b)(2)a. below.
c.
OAC rule 3745-17-07(A)
The visible emission limitation specified by this rule is less stringent than the visible emission limitation established pursuant to 40 CFR Part 60 Subpart AAa.
d.
OAC rule 3745-17-11(B)
The particulate emission limitation specified by this rule is less stringent than the particulate emission limitation established pursuant to OAC rule 3745-31-05(A)(3).
e.
40 CFR Part 60 Subpart AAa
Visible particulate emissions shall not exceed 10% opacity as a 6-minute average.

Additional Terms and Conditions
Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted to ensure the application of "Best Available Control Technology" (BACT) through PTI #13-0416 issued on 6/10/2004, it has been determined that the use of a bin vent filter with an emission limit of 0.01 gr/dscf of exhaust gases constitutes BACT for this emission unit. The emissions limits based on the BACT requirements are listed under OAC rule 3745-31-(10) thru (20) above.
There is no increase of the previous allowable emission limits as a result of the proposed Melt Shop expansion project for this emissions unit.
Operational Restrictions
None.
Monitoring and/or Recordkeeping Requirements
The permittee shall perform daily checks, when the emissions unit is in operation and when the weather conditions allow, for any visible particulate emissions from the stack serving this emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following in the operations log:
the color of the emissions;
whether the emissions are representative of normal operations;
if the emissions are not representative of normal operations, the cause of the abnormal emissions;
the total duration of any visible emission incident; and
any corrective actions taken to eliminate the visible emissions.
Reporting Requirements
The permittee shall submit semiannual written reports that (a) identify all days during which any visible particulate emissions were observed from the stack serving this emissions unit and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall be submitted to the Director (the appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each year and shall cover the previous 6-month period.
Testing Requirements
Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitation:
Visible PE shall not exceed 10% opacity, as a 6-minute average, except as provided by rule.
Applicable Compliance Method:
Compliance shall be determined through visible emission observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).
Emission Limitation:
PM/PM10 emissions shall not exceed 0.01 grain/dry standard cubic feet of exhaust gases and 0.10 pounds/hour
Applicable Compliance Method:
Compliance with the emission limitation may be determined by the use of the calculation below using the control equipment manufacturer's outlet rate of 0.01 gr/dscf and gas flow rate of 1200 acfm at ambient temperature. 
(0.01 grains/dscf)*(1200 acfm) * (70+460)/(70+460)*(1 lb/7000 grains)*(60 min/1 hr) = 0.10 lb/hr
If required, the permittee shall demonstrate compliance with this emission limitation in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(9).
Emission Limitation:
0.45 TPY of PM/PM10 emissions
Applicable Compliance Method:
The ton per year limitation was developed by multiplying the hourly particulate emission rate by the maximum operating schedule of 8760 hours/year, and dividing by 2000 pounds/ton. Therefore, compliance with the annual emission limitation shall be assumed provided compliance is maintained with the lb/hr limitation.
Miscellaneous Requirements
The following PTIs were previously issued for emissions unit F004:
PTI #13-04176 issued on 6/10/2004; and
PTI admin mod #13-04176 issued on 2/12/2008.
The above PTIs are superseded by this permit for this emissions unit.
 P029, Bar Mill Reheat Furnace
		Operations, Property and/or Equipment Description:  
            Bar Mill reheat furnace, 165 mmBtu/hr natural gas-fired, to equalize billet temperature prior to rolling
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
None.
Applicable Emissions Limitations and/or Control Requirements
The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
OAC rule 3745-31-05(A)(3)
See g)(1) below.
Particulate emissions (PE) shall not exceed 1.23 lbs/hr (filterable plus condensable) and 3.99 tons/year (filterable plus condensable).
Carbon monoxide (CO) emissions shall not exceed 13.60 lbs/hr and 44.11 tons/year.
Nitrogen oxide (NOx) emissions shall not exceed 18.15 lbs/hr and 58.92 tons/year.
Volatile Organic Compounds (VOC) emissions shall not exceed 0.89 lb/hr and 2.89 tons/year.
Sulfur dioxide (SO2) emissions shall not exceed 0.10 lb/hr and 0.32 ton/year.
Visible particulate emissions shall not exceed 5% opacity, as a 6-minute average.
b.
OAC rule 3745-17-07(A)(1)

The visible particulate emission limitation specified by this rule is less stringent than the visible particulate emission limitation established pursuant to OAC rule 3745-31-05(A)(3).
c.
OAC rule 3745-17-11(B)

The particulate emission limitation specified by this rule is less stringent than the particulate emission limitation established pursuant to OAC rule 3745-31-05(A)(3).
d.
OAC rule 3745-110-03(Q)
Nitrogen oxide (NOx) emissions shall not exceed 0.11 lb/mmBtu of actual heat input.

Additional Terms and Conditions
PTI #13-02840 contained emission limits for lead. The permittee has determined that lead emissions are due only to natural gas combustion and amounts to 0.0003 ton/year at maximum potential to emit.  The permittee no longer produces leaded steel.  The lead limit for this unit has therefore been removed and the limit in PTI #13-02840 is no longer applicable.  
There is no increase of the previous allowable emission limits as a result of the proposed Melt Shop expansion project for this emissions unit.  Instead, the permittee has requested a reduction of the annual allowable emission limit pursuant to the project emission increase analysis that was performed.
Operational Restrictions
The permittee shall burn only natural gas in this emissions unit.
Monitoring and/or Recordkeeping Requirements
For each day during which the permittee burns a fuel other than natural gas, the permittee shall maintain a record of the type and quantity of fuel burned in this emissions unit.
The permittee shall maintain records of the annual amount of steel processed in this emissions unit.
Reporting Requirements
The permittee shall submit deviation (excursion) reports to the Cleveland Division of Air Quality (Cleveland DAQ) that identify each day when a fuel other than natural gas was burned in this emissions unit.  Each report shall be submitted within 30 days after the deviation occurs.
Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center:  Air Services online web portal.
Testing Requirements
Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:
Emission Limitation:
Visible particulate emissions shall not exceed 5% opacity, as a 6-minute average.
Applicable Compliance Method:
Compliance shall be determined through visible emission observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).
Emission Limitation:
Particulate emissions shall not exceed 1.23 lbs/hr (filterable plus condensable).
Applicable Compliance Method:
When firing natural gas, compliance may be determined by multiplying an emission factor of 7.6 lbs of PM/mmcf (filterable plus condensable) by the emissions unit's maximum hourly natural gas firing rate (0.162 mmcf/hr).  The emission factor is specified in USEPA reference document AP 42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
If required, the permittee shall demonstrate compliance with this emission limitation in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745 17 03(B)(9) while firing natural gas.
Emission Limitation:    
3.99 TPY of particulate emissions 
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 7.6 lbs of PM/mmcf (filterable plus condensable) by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the reheat furnace (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.00120 mmcf/ton.
Emission Limitation:
CO emissions shall not exceed 13.60 lbs/hr.
Applicable Compliance Methods:
When firing natural gas, compliance may be determined by multiplying an emission factor of 84 lbs of CO/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.162 mmcf/hr).  The emission factor is specified in USEPA reference document AP 42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
If required, the permittee shall demonstrate compliance with the lbs/hr emission limitation in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 10 while firing natural gas.
Emission Limitation:    
44.11 TPY of CO emissions 
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 84 lbs of CO/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the reheat furnace (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.00120 mmcf/ton.
 Emission Limitation:
NOx emissions shall not exceed 18.15 lbs/hr.
Applicable Compliance Methods:
The permittee performed emissions testing in 2002 and 2011 which provided an emission factor of 112.2 lb of NOx emissions/mmcf.  Compliance may be determined by multiplying this emission factor by the by the emissions unit's maximum hourly natural gas firing rate (0.162 mmcf/hr).
If required, the permittee shall demonstrate compliance with the lbs/hr emission limitation in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 7 while firing natural gas.
Emission Limitation:    
58.92 TPY of NOx emissions 

Applicable Compliance Method:
Compliance shall be determined by multiplying the stack test emission factor of 112.2 lbs of NOx/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the reheat furnace (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.00120 mmcf/ton.
Emission Limitation:
VOC emissions shall not exceed 0.89 lb/hr.
Applicable Compliance Method:
When firing natural gas, compliance may be determined by multiplying an emission factor of 5.5 lbs of VOC/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.162 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP 42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
If required, the permittee shall demonstrate compliance with the lbs/hr emission limitation in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 25 or 25A while firing natural gas.
Emission Limitation:    
2.89 TPY of VOC emissions 
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 5.5 lbs of VOC/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the reheat furnace (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.00120 mmcf/ton.
Emission Limitation:
SO2 emissions shall not exceed 0.10 lb/hr.
 Applicable Compliance Methods:
When firing natural gas, compliance may be determined by multiplying an emission factor of 0.6 lb of SO2/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.162 mmcf/hr). The emission factor is specified in USEPA reference document AP 42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
If required, the permittee shall demonstrate compliance with the lb/hr emission limitation in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 6 while firing natural gas.
Emission Limitation:    
0.32 TPY of SO2 emissions 
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 0.6 lb of SO2/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the reheat furnace (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.00120 mmcf/ton.
Emission Limitation:    
NOx emissions shall not exceed 0.11 lb/mmBtu of actual heat input. 
Applicable Compliance Method(s):
The permittee shall demonstrate compliance with the lb/mmBtu emission limitation through stack testing in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 7 while firing natural gas.  Emission testing shall be performed in accordance with the permittee's Title V permit.

Miscellaneous Requirements
The following PTIs were previously issued for emissions unit P029:
PTI #13-02840 issued March 25, 1994; and
PTI #13-02840 modification issued March 2, 2004.
The above PTIs are superseded by this permit for this emissions unit.


 P041, Cut Off Torch
		Operations, Property and/or Equipment Description:  
            Four natural gas fueled cut-off torches rated at 1.76 mmBtu/hr each for a total of 7.04 mmBtu/hr and controlled by the melt shop baghouse.  The P041 melt shop baghouse capture system includes a hood over the cutter and caster roof canopy.  
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
None.
Applicable Emissions Limitations and/or Control Requirements
The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
OAC rule 3745-31-05(A)(3)
See g)(1) below.
Sulfur dioxide (SO2) emissions shall not exceed 0.004 lb/hr and 0.02 ton/year.
The requirements of this rule also include compliance with the requirements of OAC rules 3745-31-10 through 20, and OAC rule 3745-18-06(A).
b.
OAC rules 3745-31-10 through 20 (PSD)
PM/PM10 emissions (PE) shall not exceed 0.05 lb/hr and 0.23 ton/year (filterable plus condensable).
Carbon monoxide (CO) emissions shall not exceed 0.59 lb/hr and 2.58 tons/year.
Nitrogen oxide (NOx) emissions shall not exceed 0.70 lb/hr and 3.1 tons/year.
Volatile Organic Compounds (VOC) emissions shall not exceed 0.04 lb/hr and 0.18 ton/year.
Organic compound (OC) emissions shall not exceed 0.08 lb/hr and 0.35 ton/year.
See b)(2)a. below.
Total hourly emissions of these pollutants from the Melt Shop baghouse shall not exceed the limits identified in section B.5.
c.
OAC rule 3745-17-07(A)(1)
The stack opacity limitation specified by this rule is less stringent than the stack opacity limitation established pursuant to OAC rules 3745- 31-10 through 20 per section B.5.
d.
OAC rule 3745-17-10(B)(1)
The particulate emission limitation specified by this rule is less stringent than the particulate emission limitation established pursuant to OAC rules 3745-31-10 through 20 per b)(1)b.
e.
OAC rule 3745-18-06(A)
Exempt pursuant to OAC rule 3745-18-06(A) when burning natural gas.

Additional Terms and Conditions
Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted through PTI #13-04176 issued 6/10/2004 to ensure the application of "Best Available Control Technology" (BACT), it has been determined that the use of natural gas as fuel, acceptance of a NOx limitation of 100 lb of NOx/MMcf and acceptance of a CO limitation of 84 lb of CO/MMcf constitutes BACT for this emission unit. The emission limits based on the BACT requirements are listed under OAC rules 3745-31-10 through 20 above.
There is no increase of the previous allowable emission limits as a result of the proposed Melt Shop expansion project for this emissions unit.
Operational Restrictions
The permittee shall burn only natural gas in this emissions unit.
The emissions from P041 shall be vented to the melt shop baghouse.  
Monitoring and/or Recordkeeping Requirements
For each day during which the permittee burns a fuel other than natural gas, the permittee shall maintain a record of the type and quantity of fuel burned in this emissions unit.
Reporting Requirements
The permittee shall submit deviation (excursion) reports to the Cleveland Division of Air Quality (Cleveland DAQ) that identify each day when a fuel other than natural gas was burned in this emissions unit.  Each report shall be submitted within 30 days after the deviation occurs.
Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center:  Air Services online web portal.
Testing Requirements
Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:
Emission Limitation:
PM/PM10 emissions shall not exceed 0.05 lb/hr (filterable plus condensable).
Applicable Compliance Method:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 7.6 lbs of particulates/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.007 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP 42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
If required, the permittee may demonstrate compliance with this emission limitation in accordance with the testing requirement for the combined allowable emissions as described in section B.5.
Emission Limitation:    
 0.23 TPY of PM/PM10 emissions (filterable plus condensable) 
Applicable Compliance Method:
The ton per year limitation was developed by multiplying the hourly particulate emission rate by the maximum operating schedule of 8760 hours/year, and dividing by 2000 pounds/ton.  Therefore, compliance with the annual emission limitation shall be demonstrated provided compliance is maintained with the lb/hr limitation.
Emission Limitation:
CO emissions shall not exceed 0.59 lb/hr.
Applicable Compliance Method(s):
When firing natural gas, compliance shall be determined by multiplying an emission factor of 84 lbs of CO/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.007 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP 42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-1 (7/98).
If required, the permittee may demonstrate compliance with this emission limitation in accordance with the testing requirement for the combined allowable emissions as described in section B.5.
Emission Limitation:    
 2.58 TPY of CO emissions 
Applicable Compliance Method:
The ton per year limitation was developed by multiplying the hourly CO emission rate by the maximum operating schedule of 8760 hours/year, and dividing by 2000 pounds/ton.  Therefore, compliance with the annual emission limitation shall be demonstrated provided compliance is maintained with the lb/hr limitation.
Emission Limitation:
NOx emissions shall not exceed 0.70 lb/hr.
Applicable Compliance Method(s):
When firing natural gas, compliance shall be determined by multiplying an emission factor of 100 lbs of NOx/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.007 mmcf/hr). The emission factor is specified in U.S. EPA reference document AP 42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-1 (7/98).
If required, the permittee may demonstrate compliance with this emission limitation in accordance with the testing requirement for the combined allowable emissions as described in section B.5.
Emission Limitation:    
 3.1 TPY of NOx emissions 
Applicable Compliance Method(s):
The ton per year limitation was developed by multiplying the hourly particulate emission rate by the maximum operating schedule of 8760 hours/year, and dividing by 2000 pounds/ton.  Therefore, compliance with the annual emission limitation shall be demonstrated provided compliance is maintained with the lb/hr limitation.
Emission Limitation:
VOC emissions shall not exceed 0.04 lb/hr.

Applicable Compliance Method(s):
When firing natural gas, compliance shall be determined by multiplying an emission factor of 5.5 lbs of VOC/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.007 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP 42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
If required, the permittee may demonstrate compliance with this emission limitation in accordance with the testing requirement for the combined allowable emissions as described in section B.5.
Emission Limitation:    
 0.18 TPY of VOC emissions 
Applicable Compliance Method:
The ton per year limitation was developed by multiplying the hourly VOC emission rate by the maximum operating schedule of 8760 hours/year, and dividing by 2000 pounds/ton.  Therefore, compliance with the annual emission limitation shall be demonstrated provided compliance is maintained with the lb/hr limitation.
Emission Limitation:
SO2 emissions shall not exceed 0.004 lb/hr.
Applicable Compliance Method(s):
When firing natural gas, compliance shall be determined by multiplying an emission factor of 0.6 lb of SO2/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.007 mmcf/hr). The emission factor is specified in U.S. EPA reference document AP 42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
If required, the permittee may demonstrate compliance with this emission limitation in accordance with the testing requirement for the combined allowable emissions as described in section B.5.
Emission Limitation:    
 0.02 TPY of SO2 emissions 
Applicable Compliance Method:
The ton per year limitation was developed by multiplying the hourly SO2 emission rate by the maximum operating schedule of 8760 hours/year, and dividing by 2000 pounds/ton.  Therefore, compliance with the annual emission limitation shall be demonstrated provided compliance is maintained with the lb/hr limitation.
Emission Limitation:
OC emissions shall not exceed 0.08 lb/hr.
Applicable Compliance Method:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 11 lbs of OC/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.007 mmcf/hr). The emission factor is specified in U.S. EPA reference document AP 42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
Emission Limitation:    
 0.35 TPY of OC emissions 
Applicable Compliance Method:
The ton per year limitation was developed by multiplying the hourly particulate emission rate by the maximum operating schedule of 8760 hours/year, and dividing by 2000 pounds/ton.  Therefore, compliance with the annual emission limitation shall be demonstrated provided compliance is maintained with the lb/hr limitation.
Miscellaneous Requirements
The following PTIs were previously issued for emissions unit P041:
PTI #13-04176 issued on 6/10/2004;
PTI admin mod #13-04176 issued on 2/12/2008; and
PTI admin mod #P0107611 issued on 3/10/2011.
The above PTIs are superseded by this permit for this emissions unit.





 P043, Vacuum Tank Degasser (VTD)
		Operations, Property and/or Equipment Description:  
            Vacuum Tank Degasser (VTD) vessel, 100 TPH capacity, for low carbon steel production and decarburization of the steel.  Emissions from sulfur and carbon addition are captured by the melt shop baghouse when not under vacuum.  The P043 melt shop baghouse capture system includes multiple roof canopies (EAF canopies and caster canopy).  
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
None.
Applicable Emissions Limitations and/or Control Requirements
The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
ORC 3704.03(T)
OAC rule 3745-31-05(A)(3)
05/01/2016
See g)(1) below.
The requirements of this rule also include compliance with the requirements and OAC rules 3745-31-10 through 20.
b.
OAC rules 3745-31-10 through 20 (PSD)
Emissions from the natural decarburization of the steel (uncontrolled):
Carbon monoxide (CO) emissions shall not exceed 16.7 lbs/hr and 70.32 TPY.
See b)(2)a. below.
Emissions from the addition of sulfur or carbon at P043, P900, and P901 combined (controlled by melt shop baghouse):
Sulfur dioxide (SO2) emissions shall not exceed 44.0 lbs/hr during the production of low-sulfur grade steel.

Sulfur dioxide (SO2) emissions shall not
exceed 82.5 lbs/hr during the production of mid-sulfur grade steel.
Sulfur dioxide (SO2) emissions shall not exceed 166.1 lbs/hr during the production of high-sulfur grade steel.
Total annual emissions of SO2 from the Melt Shop baghouse shall not exceed the limit identified in section B.5..

Additional Terms and Conditions
The permittee performed a Best Available Control Technology (BACT) review for CO for this permit modification.  The emissions limits based on the BACT requirements are listed under OAC rules 3745-31-10 through 20 in b)(1) above.  The following determination has been made for this emissions unit:
CO emission limit of 0.167 lb CO/ton of steel produced
Operational Restrictions
The maximum annual process rate for the low carbon steel production  and decarburization of the steel in this emissions unit shall not exceed  842,100 tons of steel, based upon a rolling, 12-month summation of the tons of steel produced per month.
Monitoring and/or Recordkeeping Requirements
The permittee shall maintain monthly production records for this emissions unit.  These records, at a minimum, shall contain the following information:
the number of hours this emissions unit was in operation; and
the tons of steel processed.
The permittee shall maintain monthly records of the tons of steel processed during each calendar month, as well as the rolling, 12-month summation of the amount of steel processed.
The permittee shall maintain monthly production records for the melt shop for each category of steel produced (low-sulfur, mid-sulfur, and high-sulfur, as defined in Section B).  These records, at a minimum, shall contain the following information:
the tons of steel produced during the low-sulfur grade production;
the tons of steel produced during the mid-sulfur grade production; and
the tons of steel produced during the high-sulfur grade production.
Reporting Requirements
The permittee shall submit deviation (excursion) reports to the Cleveland DAQ which identify all exceedances of the rolling, 12-month steel process rate limitation.  Each report shall be submitted to the Cleveland DAQ within 30 days after the deviation occurs.
Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center:  Air Services online web portal.
Testing Requirements
Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:
Emission Limitation: 
                         Carbon monoxide (CO) emissions from the natural decarburization of the steel (uncontrolled) shall not exceed 16.7 lbs/hr
Applicable Compliance Method:	
Compliance shall be determined by multiplying the emission factor for CO (0.167 lb of CO/ton of steel produced) by the maximum process rate of the emissions unit (100 tons/hour) to arrive at the lb/hr emission rate.  Stack testing was performed in accordance with the requirements of f)(2) in June 2007 with results showing compliance with the allowable lb/hr emission limitation.	
If required, the permittee shall demonstrate compliance with the lbs/hr emission limitation in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 10.  See f)(2).
Emission Limitation: 
                         CO emissions from the natural decarburization of the steel (uncontrolled) shall not exceed 70.32 TPY 
Applicable Compliance Method:
The ton per year limitation was developed by dividing the lb/hr CO emission rate established through the emissions testing requirement in f)(2) by the maximum process rate of the emissions unit (100 tons/hr). This lb/ton emission factor is multiplied by the annual production rate restriction (842,100 tons of steel production) and divided by the factor of 2,000 pounds/ton. Compliance shall be determined by multiplying the emission factor from the most recent stack test which demonstrated compliance by the actual annual amount of steel processed.

Emission Limitation: 
CO emissions from the natural decarburization of the steel (uncontrolled) shall not exceed 0.167 lb CO/ton of steel produced
Applicable Compliance Method:
If required, the permittee shall demonstrate compliance with the lb/ton emission limitation in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 10.  See f)(2).
Emission Limitation:
                        SO2 emissions shall not exceed 44.0 lbs/hr	(low-sulfur steel grades) for P043, P900, and P901 combined 
                        Applicable Compliance Method:
                        Compliance with this emission limitation may be determined through the use of the emission factor for low-sulfur steel processing (0.40 lb SO2/ton steel) which is multiplied by the maximum hourly steel process rate of the melt shop (110 tons per hour).
 Emission Limitation:
                        SO2 emissions shall not exceed 82.50 lbs/hr (mid-sulfur steel grades) for P043, P900, and P901 combined
                        Applicable Compliance Method:
                        Compliance with this emission limitation may be determined through the use of the emission factor for mid-sulfur steel processing (0.75 lb SO2/ton steel) which is multiplied by the maximum hourly steel process rate of the melt shop (110 tons per hour).
Emission Limitation:
                        SO2 emissions shall not exceed 166.1 lbs/hr (high-sulfur steel grades) for P043, P900, and P901 combined
                        Applicable Compliance Method:
                        Compliance with this emission limitation may be determined through the use of the emission factor for high-sulfur steel processing (1.51 lb SO2/ton steel) which is multiplied by the maximum hourly steel process rate of the melt shop (110 tons per hour).
The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the permittee's Title V permit.

Miscellaneous Requirements
The following PTIs were previously issued for emissions unit P043:
PTI #13-04176 issued on 6/10/2004;
PTI admin mod #13-04176 issued on 2/12/2008; and
PTI admin mod #P0109216 issued on 2/1/2012.
The above PTIs are superseded by this permit for this emissions unit.

 P044, Carbon Silo
		Operations, Property and/or Equipment Description:  
            Carbon Silo - storage of carbon additive for steel alloying equipped with a bin vent for control of particulate emissions
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
None.
Applicable Emissions Limitations and/or Control Requirements
The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
OAC rule 3745-31-05(A)(3)
See g)(1) below.
The requirements of this rule also include compliance with the requirements and OAC rule 3745-31-10 through 20.
b.
OAC rule 3745-31-10 through 20
0.01 grain/dry standard cubic feet of exhaust gases and 0.10 pound/hour and 0.45 TPY of PM/PM10 emissions
Visible particulate emissions shall not exceed 10% opacity, as a 6-minute average. 
See b)(2)a. below.
c.
OAC rule 3745-17-07(A)
The visible particulate emission limitation specified by this rule is less stringent than the visible particulate emission limitation established pursuant to OAC rule 3745-31-05(A)(3).
d.
OAC rule 3745-17-11(B)
The particulate emission limitation specified by this rule is less stringent than the particulate emission limitation established pursuant to OAC rule 3745- 31-05(A)(3).

Additional Terms and Conditions
Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted to ensure the application of "Best Available Control Technology" (BACT) through PTI #13-04176 issued 6/10/2004, it has been determined that the use of a bin vent filter with an emission limit of 0.01 gr/dscf of exhaust gases constitutes BACT for this emission unit. The emissions limits based on the BACT requirements are listed under OAC rule 3745-31-10 through 20 above.
There is no increase of the previous allowable emission limits as a result of the proposed Melt Shop expansion project for this emissions unit.
Operational Restrictions
None.
Monitoring and/or Recordkeeping Requirements
The permittee shall perform daily checks, when the emissions unit is in operation and when the weather conditions allow, for any visible particulate emissions from the stack serving this emissions unit.  The presence or absence of any visible emissions shall be noted in an operations log.  If visible emissions are observed, the permittee shall also note the following in the operations log:
the color of the emissions;
whether the emissions are representative of normal operations;
if the emissions are not representative of normal operations, the cause of the abnormal emissions;
the total duration of any visible emission incident; and
any corrective actions taken to eliminate the visible emissions.
Reporting Requirements
The permittee shall submit semiannual written reports that:
identify all days during which any visible particulate emissions were observed from the stack serving this emissions unit; and 
describe any corrective actions taken to eliminate the visible particulate emissions.  
These reports shall be submitted to the Cleveland Division of Air Quality by January 31 and July 31 of each year and shall cover the previous 6-month period.

Testing Requirements
Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:
Emission Limitation:
                         Visible PE shall not exceed 10% opacity, as a 6-minute average.
                         Applicable Compliance Method:
                         Compliance shall be determined through visible emissions observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745 17 03 (B)(1).
Emission Limitation:
                         PM/PM10 emissions shall not exceed 0.01 grain/dry standard cubic feet of exhaust gases and 0.10 pound/hour
                         Applicable Compliance Method:
                         Compliance with the emission limitation may be determined by the use of the calculation below using the control equipment manufacturer's outlet rate of 0.01 gr/dscf and gas flow rate of 1200 acfm at ambient temperature.
                         
                         (0.01 grains/dscf)*(1200 acfm) * (70+460)/(70+460)*(1 lb/7000 grains)*(60 min/1 hr) =  0.10 lb/hr 
                         If required, the permittee shall demonstrate compliance with this emission limitation in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(9). 
Emission Limitation:	
                         0.45 TPY of PM/PM10 emissions
                         Applicable Compliance Method:
                         The ton per year limitation was developed by multiplying the hourly particulate emission rate by the maximum operating schedule of 8760 hours/year, and dividing by 2000 pounds/ton.  Therefore, compliance with the annual emission limitation shall be demonstrated provided compliance is maintained with the lb/hr limitation.
Miscellaneous Requirements
The following PTIs were previously issued for emissions unit P044:
PTI #13-04176 issued on 6/10/2004; and
PTI admin mod #13-04176 issued on 2/12/2008.
The above PTIs are superseded by this permit for this emissions unit.

 P045, Lime Silo
		Operations, Property and/or Equipment Description:  
            Lime Silo - storage for lime additive for steel alloying equipped with a bin vent for control of particulate emissions
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
None.
Applicable Emissions Limitations and/or Control Requirements
The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
OAC rule 3745-31-05(A)(3)
See g)(1) below.
The requirements of this rule also include compliance with the requirements and OAC rule 3745-31-10 through 20.
b.
OAC rule 3745-31-10 through 20
0.01 grain/dry standard cubic feet of exhaust gases and 0.10 pound/hour and 0.45 TPY OF PM/PM10 emissions
Visible particulate emissions shall not exceed 10% opacity, as a 6-minute average.
See b)(2)a. below.
c.
OAC rule 3745-17-07(A)
The visible particulate emission limitation specified by this rule is less stringent than the visible particulate emission limitation established pursuant to OAC rule 3745- 31-05(A)(3).
d.
OAC rule 3745-17-11(B)
The particulate emission limitation specified by this rule is less stringent than the particulate emission limitation established pursuant to OAC rule 3745- 31-05(A)(3).

Additional Terms and Conditions
Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted to ensure the application of "Best Available Control Technology" (BACT) through PTI #13-04176 issued 6/10/2004, it has been determined that the use of a bin vent filter with an emission limit of 0.01 gr/dscf of exhaust gases constitutes BACT for this emission unit. The emissions limits based on the BACT requirements are listed under OAC rule 3745-31-(10) thru (20) above.
There is no increase of the previous allowable emission limits as a result of the proposed Melt Shop expansion project for this emissions unit.
Operational Restrictions
None.
Monitoring and/or Recordkeeping Requirements
The permittee shall perform daily checks, when the emissions unit is in operation and when the weather conditions allow, for any visible particulate emissions from the stack serving this emissions unit.  The presence or absence of any visible emissions shall be noted in an operations log.  If visible emissions are observed, the permittee shall also note the following in the operations log:
the color of the emissions;
whether the emissions are representative of normal operations;
if the emissions are not representative of normal operations, the cause of the abnormal emissions;
the total duration of any visible emission incident; and
any corrective actions taken to eliminate the visible emissions.
Reporting Requirements
The permittee shall submit semiannual written reports that:
identify all days during which any visible particulate emissions were observed from the stack serving this emissions unit; and 
describe any corrective actions taken to eliminate the visible particulate emissions.  
These reports shall be submitted to the Cleveland Division of Air Quality by January 31 and July 31 of each year and shall cover the previous 6-month period.

Testing Requirements
Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:
Emission Limitation:
                         Visible PE shall not exceed 10% opacity, as a 6-minute average.
                         Applicable Compliance Method:
                         Compliance shall be determined through visible emissions observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).
Emission Limitation:
                         PM/PM10 emissions shall not exceed 0.01 grain/dry standard cubic feet of exhaust gases and 0.10 pound/hour
                         Applicable Compliance Method:
                         Compliance with the emission limitation may be determined by the use of the calculation below using the control equipment manufacturer's outlet rate of 0.01 gr/dscf and gas flow rate of 1200 acfm at ambient temperature.
                         
                         (0.01 grains/dscf)*(1200 acfm) * (70+460)/(70+460)*(1 lb/7000 grains)*(60 min/1 hr) =  0.10 lb/hr 
                         If required, the permittee shall demonstrate compliance with this emission limitation in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(9). 
Emission Limitation:	
                         0.45 TPY of PM/PM10 emissions
                         Applicable Compliance Method:
                         The ton per year limitation was developed by multiplying the hourly particulate emission rate by the maximum operating schedule of 8760 hours/year, and dividing by 2000 pounds/ton.  Therefore, compliance with the annual emission limitation shall be demonstrated provided compliance is maintained with the lb/hr limitation.
Miscellaneous Requirements
The following PTIs were previously issued for emissions unit P044:
PTI #13-04176 issued on 6/10/2004; and
PTI admin mod #13-04176 issued on 2/12/2008.
The above PTIs are superseded by this permit for this emissions unit.

 P046, Cooling Towers (6)
		Operations, Property and/or Equipment Description:  
            6 cooling towers with a total throughput of 25,000 gpm and 1.5 MM gallons/hr for cooling of process water
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
 None.
 Applicable Emissions Limitations and/or Control Requirements
 The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
OAC rule 3745-31-05(A)(3)
See g)(1) below.
The requirements of this rule also include compliance with the requirements and OAC rule 3745-31-10 through 20.
b.
OAC rule 3745-31-10 through 20
PM/PM10 emissions shall not exceed 1.5 lbs/hr and 6.6 TPY
OC emissions shall not exceed 0.15 lb/hr and 0.66 TPY
Visible particulate emissions shall not exceed 10% opacity as a six-minute average
c.
OAC rule 3745-17-07(A)
The visible emission limitation specified by this rule is less stringent than the visible emission limitation established pursuant to OAC rule 3745 31 05(A)(3).
d.
OAC rule 3745-17-11(B)
The particulate emission limitation specified by this rule is less stringent than the particulate emission limitation established pursuant to OAC rule 3745 31 05(A)(3).


 Additional Terms and Conditions
 There is no increase of the previous allowable emission limits as a result of the proposed Melt Shop expansion project for this emissions unit.
 Operational Restrictions
The total water flow rate of the cooling towers shall not exceed 25,000 gpm.  
The monthly average concentration of total dissolved solids (TDS) in the cooling tower water shall not exceed 5,682 mg/gallon.
The monthly average concentration of organics in the cooling tower water shall not exceed 568 mg/gallon.
The cooling towers will be equipped with drift eliminators to reduce drift water droplets by inertial separation.
 Monitoring and/or Recordkeeping Requirements
 The permittee shall properly operate and maintain equipment to monitor the cooling towers water flow rate. The monitoring devices and any recorders shall be, calibrated, operated and maintained in accordance with the manufacturer's recommendations, instructions and operating manuals. The permittee shall monitor and record the cooling towers water flow rate, in gallons per minute, at a minimum frequency of once/day.
 The permittee shall sample the cooling towers water monthly to adequately demonstrate compliance with the monthly average concentration of total dissolved solids (TDS) limitation.
 The permittee shall sample the cooling towers water monthly to adequately demonstrate compliance with the monthly average concentration of organics limitation.
 Reporting Requirements
 The permittee shall submit quarterly deviation (excursion) reports to the Cleveland DAQ that identify all periods of time during which the:
cooling towers water flow rate exceeds 25,000 gpm;
the monthly average concentration of total dissolved solids (TDS) in the cooling towers water exceeds 5,682 mg/gallon; and
the monthly average concentration of organics in the cooling towers water exceeds 568 mg/gallon.
 Testing Requirements
 Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:
Emission Limitation:
Visible particulate emissions from any stack shall not exceed 10% opacity as a six-minute average.
Applicable Compliance Method:
If required, compliance shall be determined through visible emissions observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745 17 03 (B)(1).
Emission Limitation:    
 PM/PM10 emissions shall not exceed 1.5 lbs/hr 
Applicable Compliance Method:
Compliance with the hourly emission limitation may be determined by use of the following formulas:  
circulation rate (gal/min) x drift factor (%) = Drift Rate
(25,000 gal/min) x (0.008/100) = 2 gal/min or 454.2 liters/hr
solids concentration of make-up water (mg/liter) x number of concentration cycles for the cooling towers 
= TDS 
500 mg/liter x 3 = 1500 mg/liter
Drift rate x TDS x 1 lb/453,592 mg= emission rate in lb/hr 
Emission Limitation:    
 6.6 TPY of PM/PM10 emissions 
Applicable Compliance Method:
The ton per year limitation was developed by multiplying the hourly particulate emission rate by the maximum operating schedule of 8760 hours/year, and dividing by 2000 pounds/ton.  Therefore, compliance with the annual emission limitation shall be demonstrated provided compliance is maintained with the lb/hr limitation.
Emission Limitation:    
 OC emissions shall not exceed 0.15 lb/hr. 

Applicable Compliance Method:
Compliance with the hourly emission limitation may be determined by use of the following formulas:  
circulation rate (gal/min) x drift factor (%) = Drift Rate
(25,000 gal/min) x (0.008/100) = 2 gal/min or 454.2 liters/hr
organic concentration of make-up water (mg/liter) x number of concentration cycles for the cooling towers 
=   TOC
 50 mg/liter x 3 = 150 mg/liter
 Drift rate x TOC x 1 lb/453,592 mg= emission rate in lb/hr
Emission Limitation:    
 0.66 TPY of OC emissions  
Applicable Compliance Method:
The ton per year limitation was developed by multiplying the hourly OC emission rate by the maximum operating schedule of 8760 hours/year, and dividing by 2000 pounds/ton. Therefore, compliance with the annual emission limitation shall be demonstrated provided compliance is maintained with the lb/hr limitation
Miscellaneous Requirements
The following PTIs were previously issued for emissions unit P046:
PTI #13-04176 issued on 6/10/2004; and
PTI Admin Mod #13-04176 issued on 2/12/2008.
The above PTIs are superseded by this permit for this emissions unit.
 P048, Ladle Preheater #5
		Operations, Property and/or Equipment Description:  
             Number 5 natural gas fired ladle preheater and dryer rated at 10 mmBtu/hr.  P048 is controlled by the melt shop baghouse.  The P048 melt shop baghouse capture system includes multiple roof canopies (EAF canopies and caster canopy).  
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
b)(1)b., b)(2)b.
Applicable Emissions Limitations and/or Control Requirements
The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
OAC rule 3745-31-05(A)(3)
05/01/2016
See g)(1) below.
Carbon monoxide (CO) emissions from this emissions unit shall not exceed 0.30 ton per month averaged over a 12-month rolling period.
Nitrogen oxide (NOx) emissions from this emissions unit shall not exceed 0.36 ton per month averaged over a 12-month rolling period.
See b)(2)a. below.
b.
OAC rule 3745-31-05(A)(3)(a)(ii)

The best available technology (BAT) requirements under OAC rule 3745-31-05(A)(3) do not apply to the CO and NOx emissions from this emissions unit since the potential to emit is less than 10 tons/year.
See b)(2)b. below.
c.
OAC rule 3745-17-07(A)(1)

The stack opacity limitation specified by this rule is less stringent than the stack opacity limitation established for the melt shop baghouse pursuant to OAC rules 3745-31-10 through 20 per section B.5. 
d.
OAC rule 3745-17-10(B)(1)
Particulate emissions shall not exceed 0.020 lb/mmBtu of actual heat input.
e.
OAC rule 3745-18-06(A)
Exempt pursuant to OAC rule 3745-18-06(A) when burning natural gas.

Additional Terms and Conditions
This Best Available Technology (BAT) emission limit applies until U.S. EPA approves Ohio Administrative Code (OAC) paragraph 3745-31-05(A)(3)(a)(ii) (the less than 10 tons per year BAT exemption) into the Ohio State Implementation Plan (SIP).
These requirements apply once U.S. EPA approves OAC paragraph 3745-31-05(A)(3)(a)(ii) (the less than 10 tons per year BAT exemption) as part of the Ohio SIP.
BAT emissions limits for SO2, PM/PM10, and VOC were not established because the maximum uncontrolled potential to emit for each pollutant is less than 0.5 ton/year.
There is no increase of the previous allowable emission limits as a result of the proposed Melt Shop expansion project for this emissions unit.
Operational Restrictions
The permittee shall burn only natural gas in this emissions unit.
The emissions from P048 shall be vented to the melt shop baghouse.  
Monitoring and/or Recordkeeping Requirements
For each day during which the permittee burns a fuel other than natural gas, the permittee shall maintain a record of the type and quantity of fuel burned in this emissions unit.
Reporting Requirements
The permittee shall submit deviation (excursion) reports to the Cleveland Division of Air Quality (Cleveland DAQ) that identify each day when a fuel other than natural gas was burned in this emissions unit.  Each report shall be submitted within 30 days after the deviation occurs.
Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center:  Air Services online web portal.
Testing Requirements
Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:
Emission Limitation:
                         CO emissions shall not exceed 0.30 ton per month averaged over a 12-month rolling period.
Applicable Compliance Method:
The emission limit was established at maximum potential to emit when firing natural gas.  Compliance shall be determined by multiplying an emission factor of 84 lbs of CO/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.009804 mmcf/hr), multiplying by 8760 hours/year of operation and divide by 2000 lbs/ton, and dividing by 12 months/year.  
The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-1 (7/98).
Emission Limitation:
                         NOX emissions shall not exceed 0.36 ton per month averaged over a 12-month rolling period.
Applicable Compliance Method:
The emission limit was established at maximum potential to emit when firing natural gas.  Compliance shall be determined by multiplying an emission factor of 100 lbs of NOx/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.009804 mmcf/hr), multiplying by 8760 hours/year of operation and divide by 2000 lbs/ton, and dividing by 12 months/year.
The emission factor is specified in U.S. EPA reference document AP 42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-1 (7/98).
Emission Limitation:
                         Particulate emissions shall not exceed 0.020 lb/mmBtu of actual heat input.
                         
Applicable Compliance Method:
If required compliance shall be determined by stack testing in accordance with U.S. EPA Reference Methods 1-5  of 40 CFR Part 60, Appendix A, and the procedures specified in OAC rule 3745-17-03(B)(9).

Miscellaneous Requirements
The following PTIs were previously issued for emissions unit P048:
PTI #P0120122 issued on February 17, 2016
The above PTI is superseded by this permit for this emissions unit.
 P900, Electric Arc Furnace
		Operations, Property and/or Equipment Description:  
            Electric Arc Furnace (EAF), 110 TPH capacity, for the melting of scrap steel with direct evacuation control (DEC) for capture and control of CO emissions, and a baghouse for control of particulate emissions.  The P900 Melt Shop baghouse capture system includes a furnace roof control (Direct Evacuation Capture) system, a common roof canopy, and a scavenger canopy. 
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
None.
Applicable Emissions Limitations and/or Control Requirements
The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
ORC 3704.03(T)
OAC rule 3745-31-05(A)(3)
05/01/2016
See g)(1) below.
PM (filterable) emissions shall not exceed
1.57 tons/month averaged over a 12-month rolling period (total for melt shop
baghouse).

PM10 (filterable) emissions shall not exceed 1.19 tons/month averaged over a 12-month rolling period (total for melt shop baghouse).

PM2.5 (filterable) emissions shall not exceed 1.16 tons/month averaged over a 12-month rolling period (total for melt shop baghouse).

PM/PM10/PM2.5 (condensable) emissions shall not exceed 1.02 tons/month averaged over a 12-month rolling period. 

Nitrogen oxide (NOx) emissions shall not
exceed 11.58 tons/month averaged over
a 12-month rolling period.

Volatile organic compound (VOC)
emissions shall not exceed 7.02
tons/month averaged over a 12-month
rolling period.

The requirements of this rule also include
compliance with the requirements 
OAC rules 3745-31-10 through 20 for SO2
and CO in b)(1)e. and f. and NSPS 40
CFR Part 60 Subpart AAa.
b.
ORC 3704.03(T)
OAC rule 3745-31-05(A)(3)
05/01/2016
See g)(1) below.
Mercury (Hg) emissions shall not exceed 0.02 ton/month averaged over a 12-month rolling period.  See b)(2)d. below.
Lead (Pb) emissions shall not exceed 0.014 ton/month averaged over a 12-month rolling period for all emissions units controlled by the melt shop baghouse combined.
See b)(2)e. below.
c.
OAC rule 3745-31-05(A)(3)(a)(ii)
05/01/2016
The Best Available Technology (BAT) requirements under OAC rule 3745-31-05(A)(3) do not apply to the mercury and lead emissions from this emissions unit since the potential to emit is less than 10 tons/year.
See b)(2)f. below.
d.
OAC rules 3745-31-10 through 20 (PSD)

These lb/hr BACT limits were originally established through the PSD PTI 13-04176 and remain in effect.  The ton/year limits have been replaced with new BAT limits since BACT was not triggered for these pollutants for this permit modification.
Emissions from the EAF shall not exceed
the following: 

PM emissions shall not exceed 13.05 lbs/hr (filterable, stack and fugitive combined). 

PM10 emissions shall not exceed 9.91 lbs/hr (filterable, stack and fugitive combined).

Nitrogen oxide (NOx) emissions shall not exceed 36.30 lbs/hr. 

Volatile organic compounds (VOC) emissions shall not exceed 22.0 lbs/hr.

Lead (Pb) emissions shall not exceed
0.04 lb/hr and 0.17 TPY (for all units controlled by the melt shop baghouse combined).

See b)(2)b. below.

Total hourly emissions of these pollutants
from the Melt Shop baghouse shall not
exceed the limits identified in 
section B.5.
e.
OAC rules 3745-31-10 through 20 (PSD)
OAC rules 3745-31-21 through 27 (Nonattainment NSR)
SO2 emissions exceeded the significant threshold for this permit modification and are subject to BACT and LAER.
The following limits apply to P043, P900, and P901 combined:
Sulfur dioxide (SO2) emissions shall not exceed 44.0 lbs/hr during the production of low-sulfur grade steel.

Sulfur dioxide (SO2) emissions shall not
exceed 82.5 lbs/hr during the production of mid-sulfur grade steel.
Sulfur dioxide (SO2) emissions shall not exceed 166.1 lbs/hr during the production of high-sulfur grade steel.

Total annual emissions of SO2 from the Melt Shop baghouse shall not exceed the limit identified in section B.5..

f.
OAC rules 3745-31-10 through 20 (PSD)
CO emissions exceeded the significant threshold for this permit modification and are subject to BACT.
Carbon monoxide (CO) emissions shall not exceed 356.4 lbs/hr and 1364.20 tons per rolling 12-month period.
See b)(2)d. below.
Total hourly emissions of CO from the
Melt Shop baghouse shall not exceed the
limit identified in section B.5..
g.
OAC rule 3745-17-07(A)(1)

The stack opacity limitation specified by this rule is less stringent than the stack opacity limitation established pursuant to OAC rules 3745-31-10 through 20 per section B.5..
h.
OAC rule 3745-17-11(B)

The particulate emission limitation
specified by this rule is less stringent than
the particulate emission limitation
established pursuant to OAC rules
3745-31-10 through 20 per b)(1)d.
i.
OAC rule 3745-18-06(E)(1)

The sulfur dioxide emission limitation
specified by this rule is less stringent than
the sulfur dioxide emission limitation
established pursuant to OAC rules
3745-31-21 through 27 per b)(1)e..
j.
NSPS 40 CFR Part 60, Subpart AAa
The particulate emission limitation
specified by this rule is less stringent than
the particulate emission limitation 
established pursuant to OAC rules
3745-31-10 through 20 per section B.5.. 

The opacity limitations specified by this rule are equivalent to the opacity limitations established pursuant to OAC rules 3745-31-10 through 20 per section B.5..
k.
40 CFR Part 63, Subpart YYYYY
The particulate emission limitation
specified by this rule is less stringent than
the particulate emission limitation
established pursuant to OAC rules 3745-
31-10 through 20 per section B.5..

The fugitive dust opacity limitation for the Melt Shop building specified by this rule is equivalent to the fugitive dust opacity limitation established pursuant to OAC rules 3745-31-10 05(A)(3)through 20 per section B.5..
l.
40 CFR Part 63, Subpart A
Table 1 to Subpart YYYYY of 40 CFR
Part 63- Applicability of General
Provisions to Subpart YYYYY.
m.
40 CFR Part 64
Compliance Assurance Monitoring (CAM)
See d)(15) below.

Additional Terms and Conditions
Mercury emissions shall be controlled by using the baghouse and by restricting the amount of mercury containing scrap used in the process.  For purposes of this permit to install, "mercury containing scrap" is defined as #2 bundles or shredded (frag) scrap consisting in part of either automobile or white goods scrap obtained from a source where the readily accessible mercury containing devices have not been removed prior to crushing or shredding.
The permittee performed a Best Available  Control Technology (BACT) review for NOx, CO, PM/PM10, lead, and VOC through PTI 13-04176 issued on 6/10/2004, with the exception of the PM2.5 limit which is included as part of this permitting action as a BAT limit.  The emissions limits based on the BACT requirements are listed under OAC rules 3745-31-10 through 20 in b)(1)d. above.  The following determinations were made for this emissions unit:
PM - Use of a baghouse with an emission limit of 0.00069 gr/dscf of exhaust gases
PM10 - Use of a baghouse with an emission limit of 0.00052 gr/dscf of exhaust gases
PM2.5 - Use of a baghouse with an emission limit of 0.00051 gr/dscf of exhaust gases
Lead -	Use of a baghouse with an emission limit of 0.03 lb/hr 
NOx -	Use of Direct Evacuation Control (DEC) system, low NOx oxy-fuel burners and monitoring of specific process variables.  
VOC -	Use of Direct Evacuation Control (DEC) system
                         CO -	Use of Direct Evacuation Control (DEC) system
                         The PM, PM10, PM2.5, and lead limits have been included and adjusted based on updated information from the permittee in their permit application.  The adjusted limits in this permit supersede the limits established in PTI #13-04176.
The permittee performed a Best Available Control Technology (BACT) and Lowest Achievable Emission Rate (LAER) review for SO2 for this permit modification.  The emissions limits based on the BACT/LAER requirements are listed under OAC rules 3745-31-10 through 20 in b)(1)e. above.  The following determinations have been made for this emissions unit:
SO2  -  scrap management, selection and use of low-sulfur containing charge materials to produce normal, non-sulfurized steel grades, and optimization of the foamy slag process.  
See section B.5.b) for BACT/LAER emission limits for SO2.
The permittee performed a Best Available Control Technology (BACT) review for CO for this permit modification.  The emissions limits based on the BACT requirements are listed under OAC rules 3745-31-10 through 20 in b)(1)f. above.  The following determination has been made for this emissions unit:
CO  -  Use of Direct Evacuation Control (DEC) system with adjustable air gap and water-cooled elbow and duct with emission limit of 3.24 lbs CO/ton of steel.
This Best Available Technology (BAT) emission limit applies until U.S. EPA approves Ohio Administrative Code (OAC) paragraph 3745-31-05(A)(3)(a)(ii) (the less than 10 tons per year BAT exemption) into the Ohio State Implementation Plan (SIP).
These requirements apply once U.S. EPA approves OAC paragraph 3745-31-05(A)(3)(a)(ii) (the less than 10 tons per year BAT exemption) as part of the Ohio SIP.
The permittee shall employ the lowest achievable emission rate (LAER) measures for fugitive sulfur dioxide emissions escaping the melt shop building.  Escaping visible fugitive dust emissions shall be used as the indicator for the existence of conditions that are also conducive to the escape of fugitive sulfur dioxide emissions, if present.  The LAER measures shall be sufficient to minimize or eliminate visible emissions of fugitive dust from the door opening at the west end of the melt shop.  The permittee shall operate the west end door when the EAF (P900) is in operation such that it remains closed to 6 feet above grade or less except when scrap cars are entering or exiting the melt shop. The presence of visible emissions of fugitive dust escaping the west end door is not a deviation of the LAER requirement provided the permittee complies with this additional term and condition and the operating restrictions, monitoring and recordkeeping, and reporting requirements set forth in, c)(8), d)(17) through d)(19), and e)(7) and e)(8) below.

Operational Restrictions
The minimum inlet plenum pressure across the Melt Shop baghouse, when this emissions unit is operating, shall be maintained at or above 4.0 inches of water, based on 15-minute averages. This baghouse inlet plenum pressure shall be monitored and recorded at least every 15 seconds.
The cleaning "set point"* for the baghouse shall be maintained at or below a maximum of 8.0 inches of water.  Charter Steel may use a higher cleaning set point for the baghouse if subsequent particulate emission performance tests demonstrate compliance at the requested higher set point.
                  * The cleaning "set point" is an inlet plenum pressure reading across all of the baghouse compartments. The baghouse compartments are on a continuous automatic cleaning cycle rotation. Once the inlet plenum transmitter reading falls below the established cleaning "set point", then the cleaning cycle stops.  In essence, sufficient cleaning has occurred once that cleaning "set point" has been reached. The cleaning cycle continues as long as the reading exceeds 8.0 inches. Once it goes below 8.0 inches, the cleaning cycle can stop.  Typically, at least one of the 12 compartments on the baghouse is in a cleaning mode at any given time, so the cleaning cycle essentially remains on continuously.  There are 300 bags in each compartment.
 The emissions from P900 shall be vented to the Melt Shop baghouse.     
 The maximum annual production rate for this emissions unit shall not exceed 842,100 tons of steel, based upon a rolling, 12-month summation of the tons of steel produced per month.  		  
 The permittee shall operate this emissions unit in accordance with the Scrap Management Program (SMP) submitted to the Cleveland Division of Air Quality (Cleveland DAQ) to allow the minimal use of scrap charged in the EAF that contains mercury, lead, oils, plastics, and organic materials.  The SMP shall be viewed as an operational restriction for the EAF.  Prior to operation under this permit modification, the permittee shall obtain an approved SMP, which shall be updated as needed in conjunction with the Title V permit renewal process.  Any future change to the SMP that would increase the amount of these compounds present in the scrap, or result in the emissions of an air contaminant not previously emitted, must be approved by the Cleveland DAQ.
                  All grades of scrap shall be free of excessive dirt, oil, and grease.  Heavily oiled scrap shall not be used.  As part of the SMP, the permittee shall install a radionuclide detector which will be used to inspect all incoming scrap material into the facility.  Radioactive scrap material shall not be used at this facility.  Any scrap material which is determined to be radioactive shall be disposed of in accordance with the Nuclear Regulatory Commission's (NRC) requirements.
 The following standards are requirements of the NSPS Subpart AAa and BACT.  The application and enforcement of the NSPS standards are delegated to the Ohio EPA.  The requirements of 40 CFR Part 60 are also federally enforceable.  Visible emissions shall not exceed the following limits as a six-minute average:
 3 percent opacity from the baghouse exit; and,
 6 percent opacity from the melt shop 
                  [Note: The melt shop opacity limit in b. above is more restrictive than the NSPS limit which only limits emissions due solely to the operation of an EAF(s) or AOD vessel(s). This limit in b. above is for visible emissions of fugitive dust from the entire melt shop building.]
The permittee shall comply with the applicable restrictions required under 40 CFR Part 63, Subpart YYYYY, including the following sections:
 63.10685 (a)(1)
 Pollution prevention plan for metallic scrap
 63.10685 (a)(2)
 Restricted metallic scrap
 63.10685 (b)
 Mercury requirements
                   
When the EAF (P900) is in operation, the permittee shall restrict the periods of time during which the door at the west end of the melt shop is open more than 6 feet above grade to the shortest period of time practicable (both in duration and frequency) to allow scrap cars to enter or exit the melt shop, including the following:
If the west end melt shop door remains open more than 6 feet above grade for more than five minutes while the EAF is in operation, then an automated alarm notification shall be sent to the melt shop operators.  The permittee shall take prompt action to have the west end door closed to 6 feet above grade or less.
In the event the west end melt shop door becomes inoperable or is obstructed such that it is stuck open more than 6 feet above grade and cannot be closed, the permittee shall comply with the malfunction provisions of OAC rule 3745-15-06, as well as the following: 
If the west end door remains open more than 6 feet above grade for one hour or more, during normal business hours, the permittee shall notify within one hour the Ohio EPA, DAPC, Central Office SIP Manager via email and the Cleveland Division of Air Quality Enforcement Chief via the malfunction hotline.  During periods other than normal business hours, the foregoing notifications may be made the next business day.  
The permittee shall perform visible emission inspections once per heat (during melting or refining) for a minimum of five minutes in duration. If visible fugitive dust emissions are escaping through the west end door, and the door is unable to be closed to 6 feet above grade or less, the permittee shall implement corrective action(s) to eliminate or minimize the fugitive dust emissions in accordance with the permittee's malfunction abatement plan.  The plan shall include provisions for the cessation of sulfur addition at the EAF as soon as practicable consistent with the orderly transition away from the production of high-sulfur grades of steel, unless the Director of Ohio EPA has approved the addition of sulfur while the west end door is inoperable.
Monitoring and/or Recordkeeping Requirements
The following are requirements of the NSPS Subpart AAa.  Observations of the opacity of the visible emissions from the Melt Shop baghouse shall be performed by a certified visible emission observer as follows:
 Visible emission observations shall be conducted at least once per day of operation.  The observations shall occur when the furnace is operating in the charging, melting, tapping or refining period.  These observations shall be taken in accordance with Method 9 of 40 CFR Part 60, Appendix A and, for at least three 6-minute periods, the opacity shall be recorded for point(s) where the greatest opacity visible emissions are observed, and that portion of the plume where the condensed water phase is not present in accordance with the procedures listed in Method 9 of 40 CFR Part 60, Appendix A.  Where it is possible to determine that a number of visible emission sites relate to only one incident of the visible emission, only one set of three 6-minute observations will be required.  In this case, Method 9 observations must be made for the site of highest opacity that directly relates to the cause (or location) of visible emissions observed during a single incident.  Records shall be maintained of all shop opacity observations for visible particulate emissions.
                        The appropriate records shall be maintained in the permittee's files to identify the persons responsible for conducting the opacity readings and to verify that the Method 9 certifications are up to date for the responsible individuals.
 In accordance with NSPS Subpart AAa, the permittee shall comply with either a. or b. below:
 Visible emission observations shall be conducted by a certified visible emission observer at least once per day when the furnace is operating in the meltdown or refining period.  Shop opacity shall be determined as the arithmetic average of 24 consecutive 15-second opacity observations of emissions from the shop taken in accordance with Method 9. Where it is possible to determine that a number of visible emission sites relate to only one incident of the visible emissions, only one observation of shop opacity will be required.  In this case, the shop opacity observations must be made for the site of highest opacity that directly relates to the cause (or location) of visible emissions observed during a single incident.  The owner or operator shall maintain records of all shop observations made in accordance with the above requirements.  The appropriate records shall be maintained in the permittee's files to identify the persons responsible for conducting the opacity readings and to verify that the Method 9 certifications are up to date for the responsible individuals; or
 The permittee shall calibrate and maintain a monitoring device that allows the pressure in the free space inside the EAF to be monitored.  The monitoring device may be installed in any appropriate location in the EAF or DEC duct prior to the introduction of ambient air such that reproducible results will be obtained.  The pressure monitoring device shall have an accuracy of plus or minus 5 mm of water gauge over its normal operating range and shall be calibrated according to the manufacturer's instructions.  The maximum pressure determined during the most recent compliance demonstration shall not be exceeded by the 15-minute integrated average furnace pressure when the EAF is operating in a "meltdown and refining period," as defined in 40 CFR 60.271a.  Operation at higher pressures may be considered by the Ohio EPA, Division of Air Pollution Control (DAPC) to be unacceptable operation and maintenance of the control system.  The permittee may petition the Ohio EPA for reestablishment of the maximum pressure limit whenever the permittee can demonstrate to the Agency's satisfaction that EAF operating conditions upon which the pressures were previously established are no longer applicable.
                        The permittee shall check and record on a once-per-shift basis the furnace static pressure and either (1) check and record the control system fan motor amperes and damper positions on a once-per-shift basis; (2) install, calibrate, and maintain a monitoring device that continuously records the volumetric flow rate through each separately ducted hood; or (3) install, calibrate and maintain a monitoring device that continuously records the volumetric flow rate at the control device inlet and check and record damper positions on a once-per-shift basis..  The monitoring device may be installed in any appropriate location in the exhaust duct such that reproducible flow rate monitoring will result.  The flow rate monitoring devices shall have an accuracy of plus or minus 10 percent over their normal operating range and shall be calibrated according to the manufacturer's instructions.  The Ohio EPA, DAPC may require the permittee to demonstrate the accuracy of the monitoring devices relative to Methods 1 and 2 of Appendix A of 40 CFR Part 60.  The values of these parameters as determined during the most recent demonstration of compliance shall be maintained at the appropriate levels for each applicable period.  Operation at other than baseline values will be considered by the Ohio EPA, DAPC to be unacceptable operation and maintenance of the control system.  The permittee may petition the Ohio EPA for reestablishment of these parameters whenever the permittee can demonstrate to the Agency's satisfaction that the operating conditions upon which the parameters were previously established are no longer applicable.
 The permittee shall monitor the operation of the furnace control systems and maintain records in accordance with the following requirements:
 The permittee shall perform and maintain records of the monthly operational status inspections of the equipment that is important to the performance of the total capture systems (i.e., pressure sensors, dampers, and damper switches).  This inspection shall include observations of the physical appearance of the equipment (e.g., presence of holes in ductwork or hoods, flow constrictions caused by dents or accumulated dust in ductwork, and fan erosion.)  Any deficiencies shall be recorded and proper maintenance performed.  The permittee may petition the Ohio EPA, DAPC to approve any alternative to monthly operational status inspections that will provide a continuous record of the operation of each emission capture system; and,
 Upon approval by the U.S. EPA, an alternative method may be established to replace the monitoring and recordkeeping requirements found in (2)b., and (3)a. above.
 The permittee shall maintain monthly production records for this emissions unit.  These records, at a minimum, shall contain the following information:
 the number of hours this emissions unit was in operation; and
 the tons of steel produced.
 The permittee shall maintain monthly records of the tons of steel produced during each calendar month and the rolling, 12-month summation of the steel produced.
 The permittee shall maintain monthly production records for the melt shop for each different category (i.e., low-sulfur grades, mid-sulfur grades, and high-sulfur grades) of steel produced.  These records, at a minimum, shall contain the following information:
 the tons of steel produced during the low-sulfur grade production;
 the tons of steel produced during the mid-sulfur grade production; and
 the tons of steel produced during the high-sulfur grade production.
 The permittee shall maintain monthly records for the melt shop of the tons of steel produced for each different category (i.e., low-sulfur grades, mid-sulfur grades, and high-sulfur grades) for each calendar month, and the rolling, 12-month summation of the steel produced for each different category.
 The permittee shall properly operate and maintain a continuous parameter monitoring system (CPMS) to measure the pressure drop across the Melt Shop baghouse while the emissions unit is in operation.  The permittee shall record the pressure drop across the melt shop baghouse at least every 15-seconds and monitor the 15-minute average pressure drop using the CPMS. 
 If the minimum average inlet plenum pressure is less than 4.0 inches of water, an automated notification (email or text message) shall be sent to the Melt Shop operator and environmental engineer.  
 If the cleaning set point for the baghouse deviates from 8.0 inches of water, or a cleaning set point established by subsequent performance testing, an automated notification (email or text message) shall be sent to the Melt Shop operator and environmental engineer.
 The CPMS shall be calibrated, operated, and maintained as follows:
 Locate the pressure sensor in or as close as possible to a position that provides a representative measurement of the pressure drop and that minimizes or eliminates pulsating pressure, vibration, and internal and external corrosion;
 Verify that the cleaning cycle is operating as designed daily (baghouse compartments are in cleaning mode if the inlet plenum pressure is above the cleaning setpoint);
 Use a gauge with a minimum measurement sensitivity of 0.5 inch of water or a transducer with a minimum measurement sensitivity of 1 percent of the pressure range;
 Using a manometer, check, and record gauge calibration quarterly and transducer calibration monthly; and
 Conduct calibration checks any time the sensor exceeds the manufacturer's specified maximum operating pressure range, or immediately install a new pressure sensor.
 The permittee shall operate each CPMS as follows:
 Each CPMS must complete a minimum of one cycle of operation for each successive 1-minute period;
 Charter Steel must have a minimum of three of the required four data points to constitute a valid minute of detail;
 Each CPMS must have valid data for 100 percent of every averaging period; and
 Each CPMS must determine and record the 15-minute average of all recorded readings.
 The permittee shall obtain an analysis of the Melt Shop Baghouse dust on a monthly basis.  At a minimum, the samples shall be analyzed for chromium, magnesium, manganese, lead, zinc, and mercury content.  The results shall be reported in weight percent.  This analysis shall be conducted in accordance with U.S. EPA test methods and procedures.
The permittee shall identify the types of scrap received as mercury containing scrap or other scrap (including scrap from which mercury containing devices have been removed).  The permittee shall record the weight of mercury containing scrap, in pounds, the weight of other scrap, in pounds, and the charge identification number, for each furnace charge.  The permittee shall determine and record the percent by weight of mercury containing scrap charged to the EAF, on a daily basis.
The CAM plan for this emissions unit has been developed for particulate emissions. The CAM performance indicator for particulate emissions are:  
opacity measurements at the baghouse exit;
minimum inlet pressure for the baghouse requirement; and 
either
furnace static pressure and control system fan motor amperes and damper position; or
opacity measurements at the melt shop.
The CAM performance indicator range as measured through the EAF furnace static pressure and fan motor amperes is specified in d)(2).  If the permittee elects this compliance option, when the monitoring parameters are outside of any ranges specified in d)(2), corrective action (including, but not limited to, an evaluation of the emissions unit and the control device) will be required.        
The CAM performance indicator range as measured by visible particulate emissions readings for stack opacity is specified in c)(6).  When the opacity readings are above the limit specified in c)(6), corrective action (including, but not limited to, an evaluation of the emissions unit and the control device) will be required.      
The CAM performance indicator range as measured by visible particulate emissions readings for shop opacity is specified in c)(6).  If the permittee elects this compliance option, when the opacity readings are above the limit specified in c)(6), corrective action (including, but not limited to, an evaluation of the emissions unit and the control device) will be required.        
The CAM performance indicator range as measured by the baghouse dust collector pressure drops is specified in c)(1).  When the pressure drops are outside of the indicator range specified in c)(1), corrective action (including, but not limited to, an evaluation of the emissions unit and the control device) will be required.        

Upon detecting an excursion of any of the applicable particulate emission indicator ranges listed above, the owner or operator shall restore operation of the emissions unit (including the control devices) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion.  Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as thorough response by the computerized distribution control system), or any necessary follow-up actions to return operation to within the indicator range.

If a determination is made by the Administrator or Ohio EPA that the permittee has not used acceptable procedures in response to an excursion or exceedance based on the results of a determination made under 40 CFR Part 64.7(d)(2), the permittee may be required to develop a Quality Improvement Plan (QIP) consistent with the requirements of 40 CFR Part 64.8.

The permittee shall comply with the applicable record keeping requirements under 40 CFR Part 63, Subpart YYYYY, including the following sections:

 63. 10685 (c)
 Pollution prevention plan for metallic scrap Restricted metallic scrap                   Mercury requirements



The permittee shall install, operate, and maintain sensors at the west end melt shop door that alert the melt shop operators as to when the door is open more than 6 feet above grade for more than five minutes. .
The permittee shall install, operate, and maintain a system that electronically records the period of time (date, start time and end time) whenever the west end melt shop door remains open more than 6 feet above grade for more than five minutes while the EAF is in operation.
The permittee shall maintain daily records of the following information when the door at the west end of the melt shop remains open more than 6 feet above grade for more than five minutes while the EAF is operating:
If visible emissions of fugitive dust are escaping through the west end door, the date and time of the visual emissions observations, the corrective action(s) taken to eliminate or minimize the fugitive dust emissions, and the dates such action(s) were implemented; and
If the permittee did not implement any necessary corrective action(s) to eliminate or minimize the fugitive dust emissions, the permittee shall note the reason why such corrective actions were not implemented.
Reporting Requirements
The permittee shall submit quarterly written deviation (excursion) reports to the Cleveland Division of Air Quality (Cleveland DAQ) of all exceedances of the opacity restrictions for the Melt Shop baghouse from b)(2)a..  For the purposes of these reports, exceedances are defined as all 6-minute periods during which the average opacity exceeds these limits.
 The permittee shall submit quarterly written deviation (excursion) reports to the Cleveland DAQ that identify all exceedances of the static pressure values in the EAF established in d)(3)b. above and either operation of control system fan motor amperes at values exceeding plus 15 percent of the values established under d)(3)b. above or operation at flow rates lower than those established under d)(3)b. above.
 The permittee shall submit quarterly written deviation (excursion) reports to the Cleveland DAQ that identify all periods of time during which the inlet plenum pressure for the Melt Shop Baghouse did not comply with the minimum inlet plenum pressure reading specified in c)(1).
The permittee shall submit deviation (excursion) reports to the Cleveland DAQ which identify all exceedances of the rolling, 12-month steel production rate limitation.  Each report shall be submitted to the Cleveland DAQ within 30 days after the deviation occurs.
If the results of monitoring or record keeping data indicate that the particulate emission limitations may have been exceeded, the permittee shall submit the results of that data, and document any corrective action taken to restore operation of the emissions unit, or its control equipment to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The reports shall be submitted in accordance with the Standard Terms and Conditions of this permit.
The permittee shall comply with the applicable reporting requirements under 40 CFR Part 63, Subpart YYYYY, including the following sections:
 63. 10685 (c)
 Pollution prevention plan for metallic scrap Restricted metallic scrap                   Mercury requirements

The permittee shall submit quarterly deviation reports that identify all periods of time when a visible emissions inspection was required for the west end melt shop door but not conducted, and when a corrective action was determined to be necessary but was not implemented in accordance with d)(19).
The permittee shall submit quarterly reports that identify:  
all periods of time when the west end melt shop door was open more than 6 feet above grade for more than five minutes while the EAF was operating due to an inoperable door or obstruction that prevented the door from being closed;
all periods of time when the west end melt shop door remained open more than 6 feet above grade for more than five minutes for any other reason while the EAF was operating, but was not closed to 6 feet above grade or less within 10 minutes after it was opened; and
all periods of time when visible emissions of fugitive dust were observed escaping through the west end door during the inspections required in accordance with c)(8)b.ii.. 
Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center:  Air Services online web portal.
Testing Requirements
Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:
Emission Limitations:
PM (filterable) emissions shall not exceed 1.57 tons/month averaged over a 12-month rolling period (total for melt shop baghouse).
PM10 (filterable) emissions shall not exceed 1.19 tons/month averaged over a 12-month rolling period (total for melt shop baghouse).
PM2.5 (filterable) emissions shall not exceed 1.16 tons/month averaged over a 12-month rolling period (total for melt shop baghouse).
Applicable Compliance Method:
Compliance with the ton/month average emission limitations shall be determined by multiplying the gr/dscf for each pollutant (0.00069 gr PM/dscf, 0.00052 gr PM10/dscf, and 0.00051 gr PM2.5/dscf) by the maximum airflow rate of the baghouse (728,459 dscfm), multiply by 60 minutes/hour, divide by 7000 gr/lb, multiply by 8760 hrs/yr, and divided by 2000 lbs/ton.  Then divide by 12 months to determine the monthly average emission rate. Therefore, provided compliance is maintained with the gr/dscf limitations, then compliance shall also be determined for the ton/month average emission limitation.
Emission Limitation:
PM/PM10/PM2.5 (condensable) emissions shall not exceed 1.02 tons/month averaged over a 12-month rolling period, for P900
Applicable Compliance Method:
Compliance with this ton/month average emission limitation shall be determined through the use of the controlled emission factor for the EAF steel processing (0.029 lb PM/PM10/PM2.5/ton steel) from AP-42 Table 12.5.1-2 which is multiplied by the actual annual steel process rate of the emissions unit (in tons/rolling 12 months) and dividing by the factor of (2,000 lbs/ton).  Then divide by 12 months to determine the monthly average emission rate.
Emission Limitation:
Nitrogen oxide (NOx) emissions shall not exceed 11.58 tons/month averaged over a 12-month rolling period, for P900
Applicable Compliance Method:
Compliance with this ton/month average emission limitation shall be determined through the use of the emission factor for the EAF steel processing (0.33 lb NOx/ton steel) which is multiplied by the actual annual steel process rate of the emissions unit (in tons/rolling 12 months) and dividing by the factor of (2,000 lbs/ton).  Then divide by 12 months to determine the monthly average emission rate.
Emission Limitation:
Volatile organic compound (VOC) emissions shall not exceed 7.02 tons/month averaged over a 12-month rolling period, for P900

Applicable Compliance Method:
Compliance with this ton/month average emission limitation shall be determined through the use of the emission factor for EAF steel processing (0.2 lb VOC/ton steel) which is multiplied by the actual annual steel process rate of the emissions unit (in tons/rolling 12-months) and dividing by the factor of (2,000 lbs/ton).  Then divide by 12 months to determine the monthly average emission rate.
Emission Limitation:
Mercury (Hg) emissions shall not exceed 0.02 ton/month averaged over a 12-month rolling period, for P900
Applicable Compliance Method:
An emission factor for mercury of 0.000476 lb Hg/ton of steel was developed based upon known testing and allowable emission limits of other sources.    Compliance with this ton/month average emission limitation shall be determined through the use of the emission factor for EAF steel processing (0.000476 lb Hg/ton steel) which is multiplied by the actual annual steel process rate of the emissions unit (in tons/rolling 12-months) and dividing by the factor of (2,000 lbs/ton).  Then divide by 12 months to determine the monthly average emission rate.
Emission Limitation:
Lead (Pb) emissions shall not exceed 0.014 ton/month averaged over a 12-month rolling period for all emissions units controlled by the melt shop baghouse combined
Applicable Compliance Method:
The permittee performed a mass balance analysis of the Melt Shop baghouse to determine the amount of lead emissions.  The permittee has identified a maximum emission rate of 0.03 lb lead/hr that includes a 20% safety factor from the meltshop baghouse.  Dividing this emission rate by 110 tons steel/hr results in a controlled emission factor of 0.0003 lb lead/ton steel. Compliance with this ton/month average emission limitation shall be determined through the use of the emission factor for the EAF steel processing (0.0003 lb lead/ton steel) which is multiplied by the actual annual steel process rate of the emissions unit (tons per rolling 12 months) and dividing by the factor of (2,000 lbs/ton).  Then divide by 12 months to determine the monthly average stack emission rate.  The fugitive portion of the lead emissions is calculated as 0.5 lbs lead/ton steel processed multiplied by the actual annual steel process rate of the emissions unit (tons per rolling 12 months), multiplied by the fugitive portion factor (0.05%), and dividing by the factor of 2,000 lbs/ton); then divide by 12 months to determine the monthly average fugitive emission rate.  Add the average stack and average fugitive emission rate.

 Emission Limitation:		
                        PM emissions shall not exceed 13.05 lbs/hr (filterable, stack and fugitive combined), for P900
                        PM10 emissions shall not exceed 9.91 lbs/hr (filterable, stack and fugitive combined), for P900
                        Applicable Compliance Method:
 Compliance shall be based upon the results of the emission testing specified in section B.5.  The emission testing shall be performed in accordance with the requirements of 40 CFR Part 60 Subpart AAa and 40 CFR Part 63 Subpart YYYYY.
 Emission Limitation:
                        NOx emissions shall not exceed 36.30 lbs/hr, for P900
                        Applicable Compliance Method:
                        Compliance with this emission limitation may be determined through the use of the emission factor for the EAF steel processing (0.33 lb NOx/ton steel) which is multiplied by the maximum hourly steel process rate of the emissions unit (110 tons per hour).
 Emission Limitation:
                        VOC emissions shall not exceed 22.0 lbs/hr, for P900
                        Applicable Compliance Method:
                        Compliance with this emission limitation may be determined through the use of the emission factor for EAF steel processing (0.2 lb VOC/ton steel) which is multiplied by the maximum hourly steel process rate of the emissions unit (110 tons per hour).
 Emission Limitation:
                        Lead (Pb) emissions shall not exceed 0.04 lb/hr for all emissions units controlled by the melt shop baghouse combined
                        Applicable Compliance Method:
                        Compliance shall be based upon the results of the emission testing specified in section B.5..  The emission testing shall be performed in accordance with the requirements of 40 CFR Part 60 Subpart AAa and 40 CFR Part 63 Subpart YYYYY.

Emission Limitation:
                        SO2 emissions shall not exceed 44.0 lbs/hr	(low-sulfur steel grades) for P043, P900, and P901 combined
                        Applicable Compliance Method:
                        Compliance with this emission limitation may be determined through the use of the emission factor for low-sulfur grade steel processing (0.40 lb SO2/ton steel) which is multiplied by the maximum hourly steel process rate of the melt shop (110 tons per hour).
 Emission Limitation:
                        SO2 emissions shall not exceed 82.50 lbs/hr (mid-sulfur steel grades) for P043, P900, and P901 combined
                        Applicable Compliance Method:
                        Compliance with this emission limitation may be determined through the use of the emission factor for mid-sulfur grade steel processing ( 0.75 lb SO2/ton steel) which is multiplied by the maximum hourly steel process rate of the melt shop (110 tons per hour).
Emission Limitation:
                        SO2 emissions shall not exceed 166.1 lbs/hr (high-sulfur steel grades) for P043, P900, and P901 combined
                        Applicable Compliance Method:
                        Compliance with this emission limitation may be determined through the use of the emission factor for high-sulfur grade steel processing ( 1.51 lb SO2/ton steel) which is multiplied by the maximum hourly steel process rate of the melt shop (110 tons per hour).
 Emission Limitation:
                        CO emissions shall not exceed 356.4 lbs/hr, for P900
                        Applicable Compliance Method:
                        Compliance with this emission limitation may be determined through the use of            the emission factor for the EAF steel processing (18.0 lbs CO/ton steel) which is multiplied by the maximum hourly steel process rate of the emissions unit (110 tons per hour) and (1 - 0.82) which is the control efficiency for the DEC control system.
                        18 lbs CO/ton steel x (1  -  0.82) = 3.24 lbs CO/ton steel (BACT limit)

 Emission Limitation:
                        CO emissions shall not exceed 1,364.20 tons per rolling 12-month period, for P900
                        Applicable Compliance Method:
                        Compliance with this annual emission limitation shall be determined through the use of the emission factor for the EAF steel processing (18.0 lbs CO/ton steel) which is multiplied by the actual annual steel process rate of the emissions unit (in tons/rolling 12 months), (1 - 0.82) which is the control efficiency for the DEC control system and dividing by the factor of (2,000 lbs/ton).
Emission Limitation:
CO emissions shall not exceed 3.24 lbs CO/ton of steel, for P900
Applicable Compliance Method:
If required, compliance shall be determined through stack testing using USEPA test methods 1  -  4 and 10 of 40 CFR Part 60, Appendix A. 
 Emissions testing shall be conducted in accordance with section B.5. 
Miscellaneous Requirements
The following PTIs were previously issued for emissions unit P900:
PTI #13-04176 issued on 6/10/2004;
PTI admin mod #13-04176 issued on 2/12/2008;
PTI admin mod #P0107543 issued on 3/10/2011; and
PTI admin mod #P0111766 issued on 12/28/2012. 
The above PTIs are superseded by this permit for this emissions unit.
 P901, Ladle Metallurgy Furnace
		Operations, Property and/or Equipment Description:  
            Ladle Metallurgy Furnace (LMF), 110 TPH capacity, for alloy mixing and re-sufurization of molten steel controlled by the melt shop baghouse.  The P901 melt shop baghouse capture system includes a direct furnace hood, a common roof canopy, and a scavenger canopy.  
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
None.
Applicable Emissions Limitations and/or Control Requirements
The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
OAC rule 3745-31-05(A)(3)
See g)(1) below.
The requirements of this rule also include compliance with the requirements in OAC rules 3745-31-10 through 20.
b.
OAC rules 3745-31-10 through 20 (PSD)
Emissions from the LMF shall not exceed the following:
PM emissions shall not exceed 2.31 lbs/hr and 8.84 TPY (stack and fugitive combined).
Nitrogen oxide (NOx) emissions shall not exceed 1.65 lbs/hr and 6.32 TPY.
Carbon monoxide (CO) emissions shall not exceed 33.0 lbs/hr and 126.32 TPY.
Volatile organic compounds (VOC) emissions shall not exceed 0.22 lb/hr and 0.84 TPY.
Lead (Pb) emissions shall not exceed 0.04 lb/hr and 0.17 TPY (for all emissions units controlled by the melt shop baghouse combined).
See b)(2)a. below.
Total hourly emissions of these pollutants from the Melt Shop baghouse shall not exceed the limits identified in section B.5.
Emissions from the addition of sulfur or carbon at P043, P900, and P901 combined (controlled by melt shop baghouse):
Sulfur dioxide (SO2) emissions shall not exceed 44.0 lbs/hr during the production of low-sulfur grade steel.

Sulfur dioxide (SO2) emissions shall not exceed 82.5 lbs/hr during the production of mid-sulfur grade steel.
Sulfur dioxide (SO2) emissions shall not exceed 166.1 lbs/hr during the production of high-sulfur grade steel.
Total annual emissions of SO2 from the Melt Shop baghouse shall not exceed the limit identified in section B.5.
c.
OAC rule 3745-17-07 (A)(1)
The stack opacity limitation specified by this rule is less stringent than the stack opacity limitation established pursuant to OAC rules 3745-31-10 through 20 per section B.5.
d.
OAC rule 3745-17-07 (B)(3)

The fugitive dust opacity limitation specified by this rule is less stringent than the fugitive dust opacity limitation established pursuant to OAC rules 3745-31-10 through 20 per section B.5.
. 
OAC rule 3745-17-11

The particulate emission limitation specified by this rule is less stringent than the particulate emission limitation  established pursuant to OAC rules  3745-31-10 through 20 per b)(1)b.
f.
OAC rule 3745-18-06(E)(1)
The SO2 emission limitation specified by this rule is less stringent than the SO2 emission limitation established pursuant to OAC rules 3745-31-10 through 20 per section B.5.
g.
40 CFR Part 64
Compliance Assurance Monitoring
(CAM)
See d)(8) below.

Additional Terms and Conditions
The permittee was required to perform a Best Available Control Technology (BACT) review for NOx, CO, PM/PM10, and VOC through PTI #13-04176 issued on 6/10/2004, with the exception of the PM2.5 limit which was first included as part of this permitting action as a BAT limit.  The emission limits based on the BACT requirements are listed under OAC rules 3745-31-10 through 20 above.  The following determinations have been made for this emissions unit:
PM - Use of a baghouse with an emission limit of 0.00069 gr/dscf of exhaust gases.
PM10 - Use of a baghouse with an emission limit of 0.00052 gr/dscf of exhaust gases.
PM2.5 - Use of a baghouse with an emission limit of 0.00051 gr/dscf of exhaust gases.
These BACT emission limits have been adjusted through this permit modification for the melt shop expansion project.  The adjusted limits in this PTI supersede the limits established in PTI 13-04176.
Operational Restrictions
The minimum inlet plenum pressure drop across the Melt Shop baghouse, when this emissions unit is operating, shall be maintained at or above 4.0 inches of water, based on 15-minute averages.  This baghouse inlet plenum pressure shall be monitored and recorded at least every 15 seconds.
The cleaning "set point"* for the baghouse shall be maintained at or below a maximum of 8.0 inches of water.  Charter Steel may use a higher cleaning set point for the baghouse if subsequent particulate emission performance tests demonstrate compliance at the requested higher set point. 
* The cleaning "set point" is an inlet plenum pressure reading across all of the baghouse compartments. The baghouse compartments are on a continuous automatic cleaning cycle rotation. Once the inlet plenum transmitter reading falls below the established cleaning "set point", then the cleaning cycle stops.  In essence, sufficient cleaning has occurred once that cleaning "set point" has been reached. The cleaning cycle continues as long as the reading exceeds 8.0 inches. Once it goes below 8.0 inches, the cleaning cycle can stop.  Typically, at least one of the 12 compartments on the baghouse is in a cleaning mode at any given time, so the cleaning cycle essentially remains on continuously.  There are 300 bags in each compartment.
The emissions from P901 shall be vented to the melt shop baghouse.
Monitoring and/or Recordkeeping Requirements
The permittee shall monitor the baghouse control system and maintain records in accordance with the following requirements.
The permittee shall perform monthly operational status inspections of the equipment that is important to the performance of the total capture system (i.e., pressure sensors, dampers, and damper switches).  This inspection shall include observations of the physical appearance of the equipment (e.g., presence of holes in ductwork or hoods, flow constrictions caused by dents or accumulated dust in ductwork, and fan erosion). Any deficiencies shall be noted and proper maintenance performed.
The permittee shall properly operate and maintain a continuous parameter monitoring system (CPMS) to measure the pressure drop across the Melt Shop baghouse while the emissions unit is in operation.  The permittee shall record the pressure drop across the melt shop baghouse at least every 15-seconds and monitor the 15-minute average pressure drop using the CPMS.
If the minimum average inlet plenum pressure is less than 4.0 inches of water, an automated notification (email or text message) shall be sent to the Melt Shop operator and environmental engineer.  
If the cleaning set point for the baghouse exceeds 8.0 inches of water, or a cleaning set point established by subsequent performance testing, an automated notification (email or text message) shall be sent to the Melt Shop operator and environmental engineer.
The CPMS shall be calibrated, operated, and maintained as follows:
Locate the pressure sensor in or as close as possible to a position that provides a representative measurement of the pressure drop and that minimizes or eliminates pulsating pressure, vibration, and internal and external corrosion;
Check the pressure tab for pluggage daily;
Use a gauge with a minimum measurement sensitivity of 0.5 inch of water or a transducer with a minimum measurement sensitivity of 1 percent of the pressure range;
Using a manometer, check, and record gauge calibration quarterly and transducer calibration monthly; and
Conduct calibration checks any time the sensor exceeds the manufacturer's specified maximum operating pressure range, or immediately install a new pressure sensor.

The permittee shall operate each CPMS as follows:
Each CPMS must complete a minimum of one cycle of operation for each successive 1-minute period;
Charter Steel must have a minimum of three of the required four data points to constitute a valid minute of detail;
Each CPMS must have valid data for 100 percent of every averaging period; and
Each CPMS must determine and record the 15-minute average of all recorded readings.
The permittee shall obtain an analysis of the Melt Shop Baghouse dust on a monthly basis.  At a minimum, the samples shall be analyzed for chromium, magnesium, manganese, lead, zinc, and mercury content.  The results shall be reported in weight percent.  This analysis shall be conducted in accordance with U.S. EPA test methods and procedures.
The CAM plan for this emissions unit has been developed for particulate emissions. The CAM performance indicator for particulate emissions are:  
opacity measurements at the baghouse exit; 
pressure drop range for the baghouse collector system; and 
either
control system fan motor amperes and damper position; or
opacity measurements at the melt shop.
                  The CAM performance indicator range as measured by visible particulate emissions readings for stack opacity is specified in term c)(6) for emissions unit P900.  When the opacity readings are outside the ranges specified in term c)(6) for P900, corrective action (including, but not limited to, an evaluation of the emissions unit and the control device) will be required.   
                  The CAM performance indicator range as measured by visible particulate emission readings for shop opacity is specified in c)(6) for emissions unit P900.  If the permittee elects this compliance option, when the opacity readings are above the limit specified in c)(6) for emissions unit P900, corrective action (including, but not limited to, an evaluation of the emissions unit and the control device) will be required.     
                  The CAM performance indicator range as measured by the baghouse dust collector pressure drops is specified in c)(1).  When the pressure drops are outside of the indicator range specified in c)(1), corrective action (including, but not limited to, an evaluation of the emissions unit and the control device) will be required.     
                  
                  The CAM performance indicator range as measured by the control system fan motor amperes and damper position is specified in terms d)(2)b. for emissions unit P900.  If the permittee elects this compliance option, when the monitoring parameters are outside of any of the normal operating parameters, corrective action (including, but not limited to, an evaluation of the emissions unit and the control device) will be required.         

Upon detecting an excursion of any of the applicable particulate emission indicator ranges listed above, the owner or operator shall restore operation of the emissions unit (including the control devices) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion.  Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as thorough response by the computerized distribution control system), or any necessary follow-up actions to return operation to within the indicator range.
                  If a determination is made by the Administrator or Ohio EPA that the permittee has not used acceptable procedures in response to an excursion or exceedance based on the results of a determination made under 40 CFR Part 64.7(d)(2), the permittee may be required to develop a Quality Improvement Plan (QIP) consistent with the requirements of 40 CFR Part 64.8.
                  
The permittee shall maintain monthly records of the rolling, 12-month summation of the amount, in tons, of steel produced.
The permittee shall maintain monthly production records for the melt shop for each category of steel produced (low-sulfur, mid-sulfur, and high-sulfur, as defined in Section B).  These records, at a minimum, shall contain the following information:
the tons of steel produced during the low-sulfur grade production;
the tons of steel produced during the mid-sulfur grade production; and
the tons of steel produced during the high-sulfur grade production.
Reporting Requirements
The permittee shall submit quarterly written deviation (excursion) reports to the Cleveland DAQ that identify all periods of time during which the inlet plenum pressure across the baghouse did not comply with the minimum inlet plenum pressure reading specified in c)(1).
If the results of monitoring or record keeping data indicate that the particulate emission limitations may have been exceeded, the permittee shall submit the results of that data, and document any corrective action taken to restore operation of the emissions unit, or its control equipment to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions.  The reports shall be submitted in accordance with the Standard Terms and Conditions of this permit.
Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center:  Air Services online web portal.
Testing Requirements
Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:
Emission Limitation:
PM emissions shall not exceed 2.31 lbs/hr (stack and fugitive combined)   P901
Applicable Compliance Method:
Compliance with this emission limitation may be determined through the use of the emission factor for LMF steel processing (2.0 lb/ton) which is multiplied by the maximum hourly steel process rate of the emissions unit (110 tons per hour), multiplied by (0.9995) which is the capture efficiency, and (1-0.99) which is the control efficiency for the baghouse for the stack portion of the PM emissions.  Use the emission factor for LMF steel processing (2.0 lb/ton) which is multiplied by the maximum hourly steel process rate of the emissions unit (110 tons per hour), multiplied by (1-0.9995) for the fugitive portion of the PM emissions.  Add the stack and fugitive emissions portions.
Emission Limitation:
8.84 TPY of PM emissions (stack and fugitive combined), for P901
Applicable Compliance Method:
Compliance with this annual emission limitation shall be determined through the use of the emission factor LMF steel processing (2.0 lb/ton) which multiplied by the actual annual amount of steel produced (in tons per rolling 12 months), multiplied by (0.9995) which is the capture efficiency, (1-0.99) which is the control efficiency for the baghouse, and dividing by the factor of (2,000 lbs/ton) for the stack portion of the PM emissions.  Use the emission factor for LMF steel processing (2.0 lb/ton) which is multiplied by the actual annual amount of steel produced (in tons per rolling 12 months), multiplied by (1-0.9995), and dividing by the factor of (2,000 lbs/ton) for the fugitive portion of the PM emissions.  Add the stack and fugitive emissions portions.
Emission Limitation:
NOx emissions shall not exceed 1.65 lbs/hr, for P901

Applicable Compliance Method:
Compliance with this emission limitation may be determined through the use of the emission factor for LMF steel processing (0.015 lb/ton) which is multiplied by the maximum hourly steel process rate of the emissions unit (110 tons per hour).
Emission Limitation:
6.32 TPY of NOX emissions, for P901
Applicable Compliance Method:
Compliance with this annual emission limitation shall be determined through the use of the emission factor for LMF steel processing (0.015 lb/ton) which multiplied by the actual annual amount of steel produced (in tons per rolling 12 months) and dividing by the factor of (2,000 lbs/ton).
Emission Limitation:
CO emissions shall not exceed 33.0 lbs/hr, for P901
Applicable Compliance Method:
Compliance with this emission limitation may be determined through the use of the emission factor for LMF steel processing (0.3 lb/ton) which is multiplied by the maximum hourly steel process rate of the emissions unit (110 tons per hour).
Emission Limitation:
126.32 TPY of CO emissions, for P901
Applicable Compliance Method:
Compliance with this annual emission limitation shall be determined through the use of the emission factor for LMF steel processing (0.3 lb/ton) which multiplied by the actual annual amount of steel produced (in tons per rolling 12 months) and dividing by the factor of (2,000 lbs/ton).
Emission Limitation:
VOC emissions shall not exceed 0.22 lb/hr, for P901
Applicable Compliance Method:
Compliance with this emission limitation may be determined through the use of the emission factor for LMF steel processing (0.002 lb/ton) which multiplied by the maximum hourly steel process rate of the emissions unit (110 tons per hour).
Emission Limitation:
0.84 TPY of VOC emissions, for P901
Applicable Compliance Method:
Compliance with this annual emission limitation shall be determined through the use of the emission factor for LMF steel processing (0.002 lb/ton) which multiplied by the actual annual amount of steel produced (in tons per rolling 12 months) and dividing by the factor of (2,000 lbs/ton).
Emission Limitation:
Lead (Pb) emissions shall not exceed 0.04 lb/hr for all emissions units controlled by the melt shop baghouse combined
Applicable Compliance Method:
Compliance shall be based upon the results of the emission testing specified in section B.5.  The emission testing shall be performed in accordance with the requirements of 40 CFR Part 60 Subpart AAa and 40 CFR Part 63 Subpart YYYYY.
Emission Limitation:
0.17 TPY of Lead (Pb) emissions for all emissions units controlled by the melt shop baghouse combined
Applicable Compliance Method:
The permittee performed a mass balance analysis of the Melt Shop baghouse to determine the amount of lead emissions.  The permittee has identified a maximum emission rate of 0.03 lb lead/hr that includes a 20% safety factor from the meltshop baghouse.  Dividing this emission rate by 110 tons steel/hr results in a controlled emission factor of 0.0003 lb lead/ton steel. Compliance with this ton/year emission limitation shall be determined through the use of the emission factor for the EAF steel processing (0.0003 lb lead/ton steel) which is multiplied by the actual annual amount of steel produced (tons per rolling 12 months) and dividing by the factor of (2,000 lbs/ton).  The fugitive portion of the lead emissions is associated with P900.
Emission Limitation:
                        SO2 emissions shall not exceed 44.0 lbs/hr	(low-sulfur steel grades) for P043, P900, and P901 combined
                        Applicable Compliance Method:
                        Compliance with this emission limitation may be determined through the use of the emission factor for low-sulfur grade steel processing (0.40 lb SO2/ton steel) which is multiplied by the maximum hourly steel process rate of the melt shop (110 tons per hour).

 Emission Limitation:
                        SO2 emissions shall not exceed 82.50 lbs/hr (mid-sulfur steel grades) for P043, P900, and P901 combined
                        Applicable Compliance Method:
                        Compliance with this emission limitation may be determined through the use of the emission factor for mid-sulfur grade steel processing (0.75 lb SO2/ton steel) which is multiplied by the maximum hourly steel process rate of the melt shop (110 tons per hour).
Emission Limitation:
                        SO2 emissions shall not exceed 166.1 lbs/hr (high-sulfur steel grades) for P043, P900, and P901 combined
                        Applicable Compliance Method:
Compliance with this emission limitation may be determined through the use of the emission factor for high-sulfur grade steel processing (1.51 lb SO2/ton steel) which is multiplied by the maximum hourly steel process rate of the melt shop (110 tons per hour).
Emissions testing shall be conducted in accordance with section B.5..
Miscellaneous Requirements
The following PTIs were previously issued for emissions unit P901:
PTI #13-04176 issued on 6/10/2004;
PTI admin mod #13-04176 issued on 2/12/2008;
PTI admin mod #P0107543 issued on 3/10/2011; and
PTI admin mod #P0111766 issued on 12/28/2012.
The above PTIs are superseded by this permit for this emissions unit.


 P902, Continuous Caster
		Operations, Property and/or Equipment Description:  
            Continuous caster of steel controlled by the melt shop baghouse.  The P902 melt shop baghouse capture system includes a caster roof canopy.  
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.
None.
Applicable Emissions Limitations and/or Control Requirements
The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
OAC rule 3745-31-05(A)(3)
See g)(1) below.
The requirements of this rule also include compliance with the requirements of OAC rules 3745-31-10 through 20, and OAC rule 3745-17-08.
b.
OAC rules 3745-31-10 through 20 (PSD)
Emissions from the continuous caster shall not exceed the following: PM emissions shall not exceed 1.15 lbs/hr and 4.42 TPY (stack and fugitive combined).

See b)(2)a. below.
Total hourly particulate emissions from the Melt Shop baghouse shall not exceed the limits identified in section B.5.
c.
OAC rule 3745-17-07(A)(1)
The stack opacity limitation specified by this rule is less stringent than the stack opacity limitation established pursuant to OAC rules 3745-31-10 through 20 per section B.5.
d.
OAC rule 3745-17-07(B)(3)

The fugitive dust opacity limitation specified by this rule is less stringent than the fugitive dust opacity limitation established pursuant to OAC rules 3745-31-10 through 20 per section B.5.
e.
OAC rule 3745-17-08(B)
The permittee shall employ reasonably available control measures for the control of fugitive dust emissions.
f.
OAC rule 3745-17-11
The particulate emission limitation specified by this rule is less stringent than the particulate emission limitation established pursuant to OAC rules 3745-31-10 through 20 per b)(1)b.
g.
40 CFR Part 64 
Compliance Assurance Monitoring (CAM)
See d)(8) below.

Additional Terms and Conditions
The permittee was required to perform a Best Available Control Technology (BACT) review for NOx, CO, PM/PM10, and VOC through PTI #13-04176 issued on 6/10/2004, with the exception of the PM2.5 limit which was first included as part of this permitting action as a BAT limit.  The emission limits based on the BACT requirements are listed under OAC rules 3745-31-10 through 20 above.  The following determinations have been made for this emissions unit: 
PM - Use of a baghouse with an emission limit of 0.00069 gr/dscf of exhaust gases
                        PM10 - Use of a baghouse with an emission limit of 0.00052 gr/dscf of exhaust gases.
PM2.5 - Use of a baghouse with an emission limit of 0.00051 gr/dscf of exhaust gases.
These BACT emission limits have been adjusted through the permit modification PTI #P0120585 issued on XXXX 2017 for the melt shop expansion project.  The adjusted limits in PTI #P0120585 supersede the limits established in PTI #13-04176.
There is no increase of the previous allowable emission limits as a result of the proposed Melt Shop expansion project for this emissions unit.  Instead, the permittee has a requested a reduction of the annual allowable emission limit pursuant to the project emission increase analysis that was performed.
Operational Restrictions
The minimum inlet plenum pressure across the Melt Shop baghouse, when the emissions unit is operating, shall be maintained at or above 4.0 inches of water, based on 15-minute averages.  The inlet plenum pressure shall be monitored and recorded at least every 15 seconds.
The "set point"* for the baghouse shall be maintained at or below a maximum of 8.0 inches of water.  Charter Steel may change the set point for the baghouse from 8.0 inches of water if subsequent particulate emission performance tests demonstrate compliance at the requested higher set point. 
* The cleaning "set point" is an inlet plenum pressure reading across all of the baghouse compartments. The baghouse compartments are on a continuous automatic cleaning cycle rotation. Once the inlet plenum transmitter reading falls below the established cleaning "set point", then the cleaning cycle stops.  In essence, sufficient cleaning has occurred once that cleaning "set point" has been reached. The cleaning cycle continues as long as the reading exceeds 8.0 inches. Once it goes below 8.0 inches, the cleaning cycle can stop.  Typically, at least one of the 12 compartments on the baghouse is in a cleaning mode at any given time, so the cleaning cycle essentially remains on continuously.  There are 300 bags in each compartment.
The emissions from P902 shall be vented to the Melt Shop baghouse.
Monitoring and/or Recordkeeping Requirements
The permittee shall monitor the baghouse control system and maintain records in accordance with the following requirements.
The permittee shall perform monthly operational status inspections of the equipment that is important to the performance of the total capture system (i.e., pressure sensors, dampers, and damper switches).  This inspection shall include observations of the physical appearance of the equipment (e.g., presence of holes in ductwork or hoods, flow constrictions caused by dents or accumulated dust in ductwork, and fan erosion). Any deficiencies shall be noted and proper maintenance performed.
The permittee shall properly operate and maintain a continuous parameter monitoring system (CPMS) to measure the inlet plenum pressure across the Melt Shop baghouse while the emissions unit is in operation.  The permittee shall record the inlet plenum pressure across the melt shop baghouse at least every 15-seconds and monitor the 15-minute average pressure drop using the CPMS.
If the minimum average inlet plenum pressure is less than 4.0 inches of water, an automated notification (email or text message) shall be sent to the Melt Shop operator and environmental engineer.  
If the cleaning set point for the baghouse exceeds 8.0 inches of water, or a set point established by subsequent performance testing, an automated notification (email or text message) shall be sent to the Melt Shop operator and environmental engineer.
The CPMS shall be calibrated, operated, and maintained as follows:
Locate the pressure sensor in or as close as possible to a position that provides a representative measurement of the pressure drop and that minimizes or eliminates pulsating pressure, vibration, and internal and external corrosion;
Check the pressure tab for pluggage daily;
Use a gauge with a minimum measurement sensitivity of 0.5 inch of water or a transducer with a minimum measurement sensitivity of 1 percent of the pressure range;
Using a manometer, check, and record gauge calibration quarterly and transducer calibration monthly; and
Conduct calibration checks any time the sensor exceeds the manufacturer's specified maximum operating pressure range, or immediately install a new pressure sensor.
The permittee shall operate each CPMS as follows:
Each CPMS must complete a minimum of one cycle of operation for each successive 1-minute period;
Charter Steel must have a minimum of three of the required four data points to constitute a valid minute of detail;
Each CPMS must have valid data for 100 percent of every averaging period; and
Each CPMS must determine and record the 15-minute average of all recorded readings.
The permittee shall obtain an analysis of the Melt Shop Baghouse dust on a monthly basis.  At a minimum, the samples shall be analyzed for chromium, magnesium, manganese, lead, zinc, and mercury content.  The results shall be reported in weight percent.  This analysis shall be conducted in accordance with U.S. EPA test methods and procedures.
The CAM plan for this emissions unit has been developed for particulate emissions. The CAM performance indicator for particulate emissions are: 
the opacity measurements at the baghouse exit; 
the pressure drop range for the baghouse collector system; and 
either
control system fan motor amperes and damper position; or
opacity measurements at the melt shop.
The CAM performance indicator range as measured by visible particulate emissions readings for stack opacity is specified in term c)(6) for emissions unit P900.  When the opacity readings are above the limit specified in term c)(6) for P900, corrective action (including, but not limited to, an evaluation of the emissions unit and the control device) will be required.
                  The CAM performance indicator range as measured by visible particulate emission readings for shop opacity is specified in c)(6) for emissions unit P900.  If the permittee elects this compliance option, when the opacity readings are above the limit specified in c)(6) for emissions unit P900, corrective action (including, but not limited to, an evaluation of the emissions unit and the control device) will be required.     
The CAM performance indicator range as measured by the baghouse dust collector pressure drops is specified in c)(1).  When the pressure drops are outside of the indicator range specified in c)(1), corrective action (including, but not limited to, an evaluation of the emissions unit and the control device) will be required.     

The CAM performance indicator range as measured by the control system fan motor amperes and damper position is specified in terms d)(2)b. for emissions unit P900.  If the permittee elects this compliance option, when the monitoring parameters are outside of any of the normal operating parameters, corrective action (including, but not limited to, an evaluation of the emissions unit and the control device) will be required.         

Upon detecting an excursion of any of the applicable particulate emission indicator ranges listed above, the owner or operator shall restore operation of the emissions unit (including the control devices) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion.  Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as thorough response by the computerized distribution control system), or any necessary follow-up actions to return operation to within the indicator range.

If a determination is made by the Administrator or Ohio EPA that the permittee has not used acceptable procedures in response to an excursion or exceedance based on the results of a determination made under 40 CFR Part 64.7(d)(2), the permittee may be required to develop a Quality Improvement Plan (QIP) consistent with the requirements of 40 CFR Part 64.8.

Reporting Requirements
The permittee shall submit quarterly written deviation (excursion) reports to the Cleveland DAQ that identify all periods of time during which the inlet plenum pressure across the Melt Shop baghouse did not comply with the allowable minimum inlet plenum pressure reading specified in c)(1).
If the results of monitoring or record keeping data indicate that the particulate emission limitations may have been exceeded, the permittee shall submit the results of that data, and document any corrective action taken to restore operation of the emissions unit, or its control equipment to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions.  The reports shall be submitted in accordance with the Standard Terms and Conditions of this permit.
Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center:  Air Services online web portal.
Testing Requirements
Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:
Emission Limitation:
PM emissions shall not exceed 1.15 lbs/hr (stack and fugitive combined)   P902
Applicable Compliance Method:
Compliance with this emission limitation may be determined through the use of the emission factor for the continuous casting steel processing (1.0 lb/ton) which multiplied by the maximum hourly steel process rate of the emissions unit (110 tons per hour), multiplied by (0.9995) which is the capture efficiency, and (1-0.99) which is the control efficiency for the baghouse for the stack portion of the PM emissions. Use the emission factor for continuous casting steel processing (1.0 lb/ton) which is multiplied by the maximum hourly steel process rate of the emissions unit (110 tons per hour), multiplied by (1-0.9995) for the fugitive portion of the PM emissions.  Add the stack and fugitive emissions portions.
Emission Limitation:
4.42 TPY of PM emissions (stack and fugitive combined)    P902
Applicable Compliance Method:
Compliance with this annual emission limitation may be determined through the use of the emission factor for continuous casting steel processing (1.0 lb/ton) which multiplied by the actual annual steel process rate of the emissions unit (in tons/year), multiplied by (0.9995) which is the capture efficiency, (1-0.99) which is the control efficiency for the baghouse, and dividing by the factor of (2,000 lbs/ton) for the stack portion of the PM emissions.  Use the emission factor for continuous casting steel processing (1.0 lb/ton) which is multiplied by the actual annual amount of steel produced (in tons per rolling 12 months), multiplied by (1-0.9995), and dividing by the factor of (2,000 lbs/ton) for the fugitive portion of the PM emissions.  Add the stack and fugitive emissions portions.
Emissions testing shall be conducted in accordance with section B.5.
Miscellaneous Requirements
The following PTIs were previously issued for emissions unit P902:
PTI #13-04176 issued on 6/10/2004;
PTI admin mod #13-04176 issued on 2/12/2008;
PTI admin mod #P0107543 issued on 3/10/2011; and
PTI admin mod #P0111766 issued on 12/28/2012.
The above PTIs are superseded by this permit for this emissions unit.

 Emissions Unit Group -10 mmBtu/hr ladle preheaters:  P035,P036,P037,P038
EU ID
Operations, Property and/or Equipment Description
P035
number 1 natural gas fired ladle preheater and dryer rated at 10 mmBtu/hr  vented to the melt shop baghouse
P036
number 2 natural gas fired ladle preheater and dryer rated at 10 mmBtu/hr  vented to the melt shop baghouse
P037
number 3 natural gas fired ladle preheater and dryer rated at 10 mmBtu/hr  vented to the melt shop baghouse
P038
number 4 natural gas fired ladle preheater and dryer rated at 10 mmBtu/hr  vented to the melt shop baghouse
      
      The P035-P038 melt shop baghouse capture system includes multiple roof canopies (EAF canopies and caster canopy).  
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only:
None.
Applicable Emissions Limitations and/or Control Requirements
The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
OAC rule 3745-31-05(A)(3)
See g)(1) below.
Sulfur dioxide (SO2) emissions shall not
exceed 0.006 lb/hr and 0.01 ton/year for each emissions unit.
The requirements of this rule also include compliance with the requirements of OAC rules 3745-31-10 through 20, and OAC rule 3745-18-06(A).
b.
OAC rules 3745-31-10 through 20 (PSD)

PM/PM10 emissions shall not exceed 0.074 lb/hr and 0.14 ton/year (filterable plus condensable, stack and fugitive combined) for each emissions unit.
Carbon monoxide (CO) emissions shall not exceed 0.82 lb/hr and 1.55 tons/year for each emissions unit.
Nitrogen oxide (NOx) emissions shall not exceed 0.98 lb/hr and 1.84 tons/year for each emissions unit.
Volatile Organic Compounds (VOC) emissions shall not exceed 0.05 lb/hr and 0.1 ton/year for each emissions unit.
Organic compound (OC) emissions shall not exceed 0.1 lb/hr and 0.2 ton/year for each emissions unit.
See b)(2)a. below.
The hourly emissions of these pollutants from the Melt Shop baghouse shall not exceed the limits identified in section B.5.
c.
OAC rule 3745-17-07(A)(1)

The stack opacity limitation specified by this rule is less stringent than the stack opacity limitation established pursuant to OAC rules 3745-31-10 through 20 per section B.5.
d.
OAC rule 3745-17-10(B)(1)

The particulate emission limitation specified by this rule is less stringent than the particulate emission limitation established pursuant to OAC rules 3745-31-10 through 20 per b)(1)b.
e.
OAC rule 3745-18-06(A)

Exempt pursuant to OAC rule 3745-18- 06(A) when burning natural gas.
                  
Additional Terms and Conditions
Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted through PTI #13-04176 issued on 6/10/2004 to ensure the application of "Best Available Control Technology" (BACT), it has been determined that the use of natural gas as fuel, acceptance of a NOx emission limitation of 100 lbs/MMcf and acceptance of a CO emission limitation of 84 lbs/MMcf constitutes BACT for this emission unit. The emission limits based on the BACT requirements are listed under OAC rules 3745-31-10 through 20 above.
There is no increase of the previous allowable emission limits as a result of the proposed Melt Shop expansion project for this emissions unit.  Instead, the permittee has a requested a reduction of the annual allowable emission limit pursuant to the project emission increase analysis that was performed.
Operational Restrictions
The permittee shall burn only natural gas in this emissions unit.
The emissions from P035, P036, P037, and P038 shall be vented to the melt shop baghouse.
Monitoring and/or Recordkeeping Requirements
For each day during which the permittee burns a fuel other than natural gas, the permittee shall maintain a record of the type and quantity of fuel burned in this emissions unit.
Reporting Requirements
The permittee shall submit deviation (excursion) reports to the Cleveland Division of Air Quality (Cleveland DAQ) that identify each day when a fuel other than natural gas was burned in this emissions unit.  Each report shall be submitted within 30 days after the deviation occurs.
Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center:  Air Services online web portal.
Testing Requirements
Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:
Emission Limitation:
PM/PM10 emissions shall not exceed 0.074 lb/hr (filterable plus condensable, stack and fugitive combined) for each emissions unit.
Applicable Compliance Method:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 7.6 lbs of particulates/mmcf (filterable plus condensable) by the emissions unit's maximum hourly natural gas firing rate (0.0098 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).

Emission Limitation:    
0.14 TPY of PM/PM10 emissions (filterable plus condensable, stack and fugitive combined) for each emissions unit
Applicable Compliance Method(s):
Compliance shall be determined by multiplying the AP-42 emission factor of 7.6 lbs of PM/mmcf (filterable plus condensable) by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000146 mmcf/ton.
Emission Limitation:
CO emissions shall not exceed 0.82 lb/hr for each emissions unit.
Applicable Compliance Method:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 84 lbs of CO/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.0098 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-1 (7/98).
If required, the permittee may demonstrate compliance with this emission limitation in accordance with the testing requirement for the combined allowable emissions as described in section B.5.
Emission Limitation:    
1.55 TPY of CO emissions for each emissions unit
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 84 lbs of CO/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000146 mmcf/ton.
Emission Limitation:
NOx emissions shall not exceed 0.98 lb/hr for each emissions unit.

Applicable Compliance Methods:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 100 lbs of NOx/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.0098 mmcf/hr). The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-1 (7/98).
If required, the permittee may demonstrate compliance with this emission limitation in accordance with the testing requirement for the combined allowable emissions as described in section B.5.
Emission Limitation:    
1.84 TPY of NOx emissions for each emissions unit
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 100 lbs of NOx/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000146 mmcf/ton.
Emission Limitation:
VOC emissions shall not exceed 0.05 lb/hr for each emissions unit.
Applicable Compliance Method:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 5.5 lbs of VOC/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.0098 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
If required, the permittee may demonstrate compliance with this emission limitation in accordance with the testing requirement for the combined allowable emissions as described in section B.5.
Emission Limitation:    
0.1 TPY of VOC emissions for each emissions unit 
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 5.5 lbs of VOC/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000146 mmcf/ton.
Emission Limitation:
SO2 emissions shall not exceed 0.006 lb/hr for each emissions unit.
Applicable Compliance Method(s):
When firing natural gas, compliance shall be determined by multiplying an emission factor of 0.6 lb of SO2/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.0098 mmcf/hr). The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
If required, the permittee may demonstrate compliance with this emission limitation in accordance with the testing requirement for the combined allowable emissions as described in section B.5.
Emission Limitation:    
0.01 TPY of SO2 emissions for each emissions unit
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 0.6 lb of SO2/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000146 mmcf/ton.
Emission Limitation:
OC emissions shall not exceed 0.10 lb/hr for each emissions unit.
Applicable Compliance Method:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 11 lbs of OC/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.0098 mmcf/hr). The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
Emission Limitation:    
0.2 TPY of OC emissions for each emissions unit

Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 11 lbs of OC/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000146 mmcf/ton.
Miscellaneous Requirements
The following PTIs were previously issued for emissions units P035  -  P038:
PTI #13-04176 issued on 6/10/2004;
PTI admin mod #13-04176 issued on 2/12/2008; and
PTI admin mod #P0107611 issued on 3/10/2011.
The above PTIs are superseded by this permit for these emissions units.
 Emissions Unit Group -12.0 mmBtu/hr tundish preheaters:  P032,P033,P034,
EU ID
Operations, Property and/or Equipment Description
P032
number 1 natural gas fired tundish preheater rated at 12.0 mmBtu/hr vented to the melt shop baghouse
P033
number 2 natural gas fired tundish preheater rated at 12.0 mmBtu/hr vented to the melt shop baghouse
P034
number 3 natural gas fired tundish preheater rated at 12.0 mmBtu/hr vented to the melt shop baghouse
      
      The P032-P034 melt shop baghouse capture system includes multiple roof canopies (EAF canopies and caster canopy).  
 The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only:
None.
Applicable Emissions Limitations and/or Control Requirements
The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below.  Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements
Applicable Emissions Limitations/Control Measures
a.
OAC rule 3745-31-05(A)(3)
See g)(1) below.
Sulfur dioxide (SO2) emissions shall not exceed 0.007 lb/hr and 0.017 ton/year for each emissions unit.
The requirements of this rule also include
compliance with the requirements of
OAC rules 3745-31-10 through 20.
b.
OAC rules 3745-31-10 through 20 (PSD)

PM/PM10 emissions shall not exceed 0.09 lb/hr and 0.2 ton/year (filterable plus condensable, stack and fugitive combined) for each emissions unit.
Carbon monoxide (CO) emissions shall not exceed 0.99 lb/hr and 2.28 tons/year for each emissions unit.
Nitrogen oxide (NOx) emissions shall not exceed 1.18 lbs/hr and 2.71 tons/year for each emissions unit.
Volatile Organic Compounds (VOC) emissions shall not exceed 0.06 lb/hr and 0.15 ton/year for each emissions unit.
Organic compound (OC) emissions shall not exceed 0.13 lb/hr and 0.3 ton/year for each emissions unit.
See b)(2)a. below.
Total hourly emissions of these pollutants from the Melt Shop baghouse shall not exceed the limits identified in section B.5.
c.
OAC rule 3745-17-07(A)(1)

The stack opacity limitation specified by this rule is less stringent than the stack opacity limitation established pursuant to OAC rules 3745-31-10 through 20 per section B.5.
d.
OAC rule 3745-17-10(B)(1)
The particulate emission limitation specified by this rule is less stringent than the particulate emission limitation established pursuant to OAC rules 3745-31-10 through 20 per b)(1)b.
e.
OAC rule 3745-18-06(A)
Exempt pursuant to OAC rule 3745-18- 06(A) when burning natural gas.
                  
Additional Terms and Conditions
Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted through PTI #13-04176 issued on 6/10/2004 to ensure the application of "Best Available Control Technology" (BACT), it has been determined that the use of natural gas as fuel, acceptance of a NOx emission limitation of 100 lbs/MMcf and acceptance of a CO emission limitation of 84 lbs/MMcf constitutes BACT for this emission unit. The emission limits based on the BACT requirements are listed under OAC rules 3745-31-10 through 20 above.
There is no increase of the previous allowable emission limits as a result of the proposed Melt Shop expansion project for this emissions unit.  Instead, the permittee has a requested a reduction of the annual allowable emission limit pursuant to the project emission increase analysis that was performed.

Operational Restrictions
The permittee shall burn only natural gas in this emissions unit.
The emissions from P032, P033, and P034 shall be vented to the melt shop baghouse.
Monitoring and/or Recordkeeping Requirements
For each day during which the permittee burns a fuel other than natural gas, the permittee shall maintain a record of the type and quantity of fuel burned in this emissions unit.
Reporting Requirements
The permittee shall submit deviation (excursion) reports to the Cleveland Division of Air Quality (Cleveland DAQ) that identify each day when a fuel other than natural gas was burned in this emissions unit.  Each report shall be submitted within 30 days after the deviation occurs.
Unless other arrangements have been approved by the Director, all notifications and reports shall be submitted through the Ohio EPA's eBusiness Center:  Air Services online web portal.
Testing Requirements
Compliance with the Emissions Limitations and/or Control Requirements specified in b) of these terms and conditions shall be determined in accordance with the following methods:
Emission Limitation:
                         PM/PM10 emissions shall not exceed 0.09 lb/hr (filterable plus condensable, stack and fugitive combined) for each emissions unit.
Applicable Compliance Method:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 7.6 lbs of particulates/mmcf (filterable plus condensable) by the emissions unit's maximum hourly natural gas firing rate (0.0118 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
If required, the permittee may demonstrate compliance with this emission limitation in accordance with the testing requirement for the combined allowable emissions as described in section B.5.
Emission Limitation:    
                          0.2 TPY of PM/PM10 emissions (filterable plus condensable, stack and fugitive combined) for each emissions unit
Applicable Compliance Method(s):
Compliance shall be determined by multiplying the AP-42 emission factor of 7.6 lbs of PM/mmcf (filterable plus condensable) by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000161 mmcf/ton.
Emission Limitation:
                         CO emissions shall not exceed 0.99 lb/hr for each emissions unit.
Applicable Compliance Method:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 84 lbs of CO/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.0118 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
                         If required, the permittee may demonstrate compliance with this emission limitation in accordance with the testing requirement for the combined allowable emissions as described in section B.5.
Emission Limitation:    
                          2.28 TPY of CO emissions for each emissions unit
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 84 lbs of CO/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000161 mmcf/ton.
Emission Limitation:
                         NOx emissions shall not exceed 1.18 lbs/hr for each emissions unit.
Applicable Compliance Methods:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 100 lbs of NOx/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.0118 mmcf/hr). The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
If required, the permittee may demonstrate compliance with this emission limitation in accordance with the testing requirement for the combined allowable emissions as described in section B.5.
Emission Limitation:    
                         2.71 TPY of NOx emissions for each emissions unit
Applicable Compliance Method(s):
Compliance shall be determined by multiplying the AP-42 emission factor of 100 lbs of NOx/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000161 mmcf/ton.
Emission Limitation:
                         VOC emissions shall not exceed 0.06 lb/hr for each emissions unit.
Applicable Compliance Method:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 5.5 lbs of VOC/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.0118 mmcf/hr).  The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
                         If required, the permittee may demonstrate compliance with this emission limitation in accordance with the testing requirement for the combined allowable emissions as described in section B.5.
Emission Limitation:    
                         0.15 TPY of VOC emissions for each emissions unit
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 5.5 lbs of VOC/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000161 mmcf/ton.
Emission Limitation:
                         SO2 emissions shall not exceed 0.007 lb/hr for each emissions unit.

Applicable Compliance Methods:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 0.6 lb of SO2/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.0118 mmcf/hr). The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
                         If required, the permittee may demonstrate compliance with this emission limitation in accordance with the testing requirement for the combined allowable emissions as described in section B.5.
Emission Limitation:    
                         0.017 TPY of SO2 emissions for each emissions unit
Applicable Compliance Method(s):
Compliance shall be determined by multiplying the AP-42 emission factor of 0.6 lb of SO2/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000161 mmcf/ton.
Emission Limitation:
                         OC emissions shall not exceed 0.13 lb/hr for each emissions unit.
Applicable Compliance Method:
When firing natural gas, compliance shall be determined by multiplying an emission factor of 11 lbs of OC/mmcf by the emissions unit's maximum hourly natural gas firing rate (0.0118 mmcf/hr). The emission factor is specified in U.S. EPA reference document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.4, Table 1.4-2 (7/98).
Emission Limitation:    
                         0.3 TPY of OC emissions for each emissions unit
Applicable Compliance Method:
Compliance shall be determined by multiplying the AP-42 emission factor of 11 lbs of OC/mmcf by the actual annual amount of natural gas combusted in this emissions unit (in mmcf/year) and divide by the factor of 2000 lbs/ton.  The amount of natural gas combusted shall be determined by multiplying actual annual steel process rate of the melt shop (in tons/rolling 12 months) by the natural gas consumption to steel process ratio of 0.000161 mmcf/ton.

Miscellaneous Requirements
The following PTIs were previously issued for emissions units P032, P033, and P034:
PTI #13-04176 issued on 6/10/2004;
PTI admin mod #13-04176 issued on 2/12/2008; and
PTI admin mod #P0107543 issued on 3/10/2011.
The above PTIs are superseded by this permit for these emissions units.



       
