CERTIFIED MAIL RE: Final Title V Chapter 3745-77 permit · The No. 1 Stelter & Brinck horizontal ladle preheater is used to preheat steel ladles. B028 ... The Stelter & Brinck vertical

Street Address: Mailing Address:Lazarus Gov. Center TELE: (614) 644-3020 FAX: (614) 644-2329 Lazarus Gov. Center122 S. Front Street P.O. Box 1049Columbus, OH 43215 Columbus, OH 43216-1049

State of Ohio Environmental Protection Agency

11/01/04 CERTIFIED MAIL

14-09-01-0006AK Steel CorporationSteven L. Francis1801 Crawford StreetMiddletown, OH 45042

RE: Final Title V Chapter 3745-77 permit

Dear Steven L. Francis:

Enclosed is the Title V permit that allows you to operate the facility in the manner indicated in the permit. Because this permit maycontain several conditions and restrictions, we urge you to read it carefully.

The Ohio EPA is encouraging companies to investigate pollution prevention and energy conservation. Not only will this reducepollution and energy consumption, but it can also save you money. If you would like to learn ways you can save money whileprotecting the environment, please contact our Office of Pollution Prevention at (614) 644-3469.

You are hereby notified that this action of the Director is final and may be appealed to the Environmental Review AppealsCommission pursuant to Section 3745.04 of the Ohio Revised Code. The appeal must be in writing and set forth the actioncomplained of and the grounds upon which the appeal is based. It must be filed with the Environmental Review Appeals Commissionwithin thirty (30) days after notice of the Director's action. A copy of the appeal must be served on the Director of the OhioEnvironmental Protection Agency within three (3) days of filing with the Commission. It is also requested by the Director that a copyof the appeal be served upon the Environmental Enforcement Section of the Office of the Attorney General. An appeal may be filedwith the Environmental Review Appeals Commission at the following address:

Environmental Review Appeals Commission309 South Fourth Street, Room 222Columbus, Ohio 43215

If you have any questions, please contact Hamilton County Dept. of Environmental Services.

Sincerely,

Michael W. AhernPermit Issuance and Data Management SectionDivision of Air Pollution Control

cc: Hamilton County Dept. of Environmental ServicesFile, DAPC PMU

State of Ohio Environmental Protection Agency

FINAL TITLE V PERMIT

Issue Date: 11/01/04 Effective Date: 01/03/05 Expiration Date: 01/03/10

This document constitutes issuance of a Title V permit for Facility ID: 14-09-01-0006 to:AK Steel Corporation1801 Crawford StreetMiddletown, OH 45043-0001

Emissions Unit ID (Company ID)/Emissions Unit Activity DescriptionB007 (Boiler No.1,No.2 BH)Babcock & Wilcox Gas/Oil Industrial Boiler producessteam for consumption throughout the facility.

B008 (Boiler No.4,No.2 BH)Babcock & Wilcox Gas/Oil Industrial Boiler producessteam for consumption throughout the facility.



B021 (No. 84 Anneal)No. 84 Anneal is a batch annealing of cold rolled steelcoils operation.

B022 (Open Coil Anneal)Open Coil Anneal is a batch annealing of cold rolledsteel coils operation.



B027 (H Ladle Preheater 1)The No. 1 Stelter & Brinck horizontal ladle preheateris used to preheat steel ladles.



B030 (V Ladle Preheater)The Stelter & Brinck vertical ladle preheater is usedto preheat steel ladles.

B031 (Tundish Preheater1)The No. 1 Stelter & Brinck tundish preheater is usedto preheat tundishes.

B032 (Tundish Preheater 2)The No. 2 Stelter & Brinck tundish preheater is usedto preheat tundishes.

B918 (No.2 Coke Plant)Wilputte Underjet 76-oven Coke Battery producescoke and various coke by-products.

F001 (Roads & Park. Areas)This includes unpaved roads, paved roads, andparking lots which are treated for dust suppression.

F002 (RM Storage Piles)Material storage piles throughout the facility.

F003 (Coal Hand.-No.2CP)This includes part of the coal handling system for theWilputte Coke Battery (No. 2 Coke Plant).

F004 (Still Coal Handling)Still Coal handling (now used to feed the No. 2 CokePlant)

F005 (Coke Hand.-No.2 CP)This includes the coke handling facility for the No. 2Coke Plant.

F008 (Ore Screen. & Hand.)This includes the ore screening and handling facility.

F010 (Iron Ore Unloading)This includes the railcar, truck dump, conveyors andtransfer station for the conveyance of ore.

F011 (BOF Deslagger)The molten iron deslagging operation is used toremove slag off of the hot metal ladle.

F012 (BF Raw Matls Hand.)This includes the coke, iron bearing materials andfluxing agents handling equipment for No. 3 BlastFurnace.

F015 (Slab Scarfing/Slitting)This includes the hand scarfing and slitting of steelslabs.

F021 (Backup Quench Station)This is the quenching of hot coke operation. Backupquench station in case the main one is out of servicefor repairs.

F025 (Backup Skimmer)Backup BOF Furnace Slag Skimmer.

G001 (Plantwide Gasoline)This is the Pickler Bldg, BOF, and Main Garagediesel and gasoline dispensing facilities.

K001 (Shops Spray Paint.)

This is a miscellaneous metal parts spray paintingoperation.

P009 (No. 3 Slab Fce/WHB)Davy International walking beam slab reheat furnacereheats steel slabs, associated waste heat boiler


P011 (No. 1 Slab Fce/WHB)Salem pusher slab reheat furnace reheats steel slabs,associated waste heat boiler


P019 (No. 4 Coating Line)The No. 4 Coating Line is an aluminum coating ofsteel coils operation.

P022 (No. 3 Coating Line)The No. 3 Coating Line is a zinc coating of steel coilsoperation.

P023 (No. 5 Pickler)The Wean Unique HCI Pickler is used to removescale from hot rolled steel.

P024 (No. 4 Pickler)The Wean Unique HCI Pickler is used to removescale from hot rolled steel.

P043 (Wilp.Quench Tower)This is the quenching of hot coke operation.

P047 (HMT/Desulf. Station)This is a combination hot metal pouring anddesulfurization facility.

P062 (No. 2 EG Line)This is an electrolytic zinc coating or zinc-nickelcoating of steel coils operation.

P065 (No. 3 Cold Mill)The United 5 Stand Tandem Cold Mill is a coldrolling steel operation.

P067 (Gas Holder/Flare)The gas holder/flare is used to flare excess coke ovengas.

P068 (Wilp. Exhausters)The two Wilputte exhausters for the coke oven gas

distribution throughout the by-products facility

P070 (FC, WO Tanks & Dec)This includes the final cooler, wash oil tanks anddecanter within the by-products.

P075 (Wilp. Tar & FL Vess.)This includes the Wilputte tar and flushing liquorprocessing vessels within the by-products.

P091 (No. 5 Temper Mill)This equipment includes a four high set of rolls usedfor cold working (tempering) steel.

P092 (No. 6 Temper Mill)This equipment includes a four high set of rolls usedfor cold working (tempering) steel.

P093 (No. 1 CR Line)This equipment includes payoff reel, shears,inspection station, oiler, and a winding reel.

P094 (Hot Strip Mill)

The Hot Strip Mill is a hot rolling of steel slabsoperation.

P095 (No. 7 Temper Mill)This equipment includes a two high set of rolls usedfor cold working (tempering) steel.

P901 (Flux Handling)This includes the unloading and conveying of fluxmaterial to the BOF.

P902 (Continuous Caster)Molten steel is continuous cast into steel slabs at thisoperation.

P925 (No. 3 Blast Furnace)Arthur G. McKee unique blast furnace produces hotmetal.

P926 (No. 15 Vessel)The No. 15 basic oxygen furnace produces moltensteel.

P927 (No. 16 Vessel)The No. 16 basic oxygen furnace produces moltensteel.

P934 (CAS/OB)This is a steel refining station using argon stirring andoxygen blowing for certain steel grades.

P935 (Vacuum Degasser)The vacuum degassing system is a molten steelrefining station for certain steel grades.

P956 (Desul. Station)This is a spare desulfurization facility used duringroutine maintenance of the main operation.

T002 (E.Tar Storage Tank)The east tar storage tank is used to store tar, a cokeby-product.

You will be contacted approximately eighteen (18) months prior to the expiration date regarding the renewal of this permit. If you arenot contacted, please contact the appropriate Ohio EPA District Office or local air agency listed below. This permit and theauthorization to operate the air contaminant sources (emissions units) at this facility shall expire at midnight on the expiration dateshown above. If a renewal permit is not issued prior to the expiration date, the permittee may continue to operate pursuant to OACrule 3745-77-08(E) and in accordance with the terms of this permit beyond the expiration date, provided that a complete renewalapplication is submitted no earlier than eighteen (18) months and no later than one-hundred eighty (180) days prior to the expirationdate.

Described below is the current Ohio EPA District Office or local air agency that is responsible for processing and administering yourTitle V permit:

Hamilton County Dept. of Environmental Services250 William Howard Taft RdCincinnati, OH 45219-2660(513) 946-7777

OHIO ENVIRONMENTAL PROTECTION AGENCY

Christopher JonesDirector

Facility Name: AK Steel CorporationFacility ID: 14-09-01-0006

Final Title V Permit - General Terms and Conditions Page 1

PART I - GENERAL TERMS AND CONDITIONS

A. State and Federally Enforceable Section

1. Monitoring and Related Record Keeping and Reporting Requirements

a. Except as may otherwise be provided in the terms and conditions for a specific emissions unit, i.e., inSection A.III of Part III of this Title V permit, the permittee shall maintain records that include thefollowing, where applicable, for any required monitoring under this permit:

i. The date, place (as defined in the permit), and time of sampling or measurements.ii. The date(s) analyses were performed.iii. The company or entity that performed the analyses.iv. The analytical techniques or methods used.v. The results of such analyses.vi. The operating conditions existing at the time of sampling or measurement. (Authority for term: OAC rule 3745-77-07(A)(3)(b)(i))

b. Each record of any monitoring data, testing data, and support information required pursuant to this permitshall be retained for a period of five years from the date the record was created. Support informationshall include all calibration and maintenance records and all original strip-chart recordings for continuousmonitoring instrumentation, and copies of all reports required by this permit. Such records may bemaintained in computerized form.(Authority for term: OAC rule 3745-77-07(A)(3)(b)(ii))

c. The permittee shall submit required reports in the following manner:

i. All reporting required in accordance with OAC rule 3745-77-07(A)(3)(c) for deviationscaused by malfunctions shall be submitted in the following manner:

Any malfunction, as defined in OAC rule 3745-15-06(B)(1), shall be promptly reported to theOhio EPA in accordance with OAC rule 3745-15-06. In addition, to fulfill the OAC rule 3745-77-07(A)(3)(c) deviation reporting requirements for malfunctions, written reports that identifyeach malfunction that occurred during each calendar quarter (including each malfunctionreported only verbally in accordance with OAC rule 3745-15-06) shall be submitted by January31, April 30, July 31, and October 31 of each year in accordance with General Term andCondition A.1.c.ii below; and each report shall cover the previous calendar quarter.

In accordance with OAC rule 3745-15-06, a malfunction constitutes a violation of an emissionlimitation (or control requirement) and, therefore, is a deviation of the federally enforceablepermit requirements. Even though verbal notifications and written reports are required formalfunctions pursuant to OAC rule 3745-15-06, the written reports required pursuant to this termmust be submitted quarterly to satisfy the prompt reporting provision of OAC rule 3745-77-07(A)(3)(c).

In identifying each deviation caused by a malfunction, the permittee shall specify the emissionlimitation(s) (or control requirement(s)) for which the deviation occurred, describe eachdeviation, and provide the magnitude and duration of each deviation. For a specific malfunction,if this information has been provided in a written report that was submitted in accordance withOAC rule 3745-15-06, the permittee may simply reference that written report to identify thedeviation. Nevertheless, all malfunctions, including those reported only verbally in accordancewith OAC rule 3745-15-06, must be reported in writing on a quarterly basis.



Any scheduled maintenance, as referenced in OAC rule 3745-15-06(A)(1), that results in adeviation from a federally enforceable emission limitation (or control requirement) shall bereported in the same manner as described above for malfunctions.(Authority for term: OAC rule 3745-77-07(A)(3)(c))

ii. Except as may otherwise be provided in the terms and conditions for a specific emissionsunit, i.e., in Section A.IV of Part III of this Title V permit or, in some cases, in Part II ofthis Title V permit, all reporting required in accordance with OAC rule 3745-77-07(A)(3)(c) for deviations of the emission limitations, operational restrictions, and controldevice operating parameter limitations shall be submitted in the following manner:

Written reports of (a) any deviations from federally enforceable emission limitations, operationalrestrictions, and control device operating parameter limitations, (b) the probable cause of suchdeviations, and (c) any corrective actions or preventive measures taken, shall be promptly madeto the appropriate Ohio EPA District Office or local air agency. Except as provided below, thewritten reports shall be submitted by January 31, April 30, July 31, and October 31 of each year;and each report shall cover the previous calendar quarter.

In identifying each deviation, the permittee shall specify the emission limitation(s), operationalrestriction(s), and/or control device operating parameter limitation(s) for which the deviationoccurred, describe each deviation, and provide the estimated magnitude and duration of eachdeviation.

These written reports shall satisfy the requirements (in part) of OAC rule 3745-77-07(A)(3)(c)pertaining to the submission of monitoring reports every six months and to the prompt reportingof all deviations. OAC rule 3745-77-07(A)(3)(c) is not fully satisfied until the permitteeaddresses all other deviations of the federally enforceable requirements specified in the permit.

If an emissions unit has a deviation reporting requirement for a specific emission limitation,operational restriction, or control device operating parameter limitation that is not on a quarterlybasis (e.g., within 30 days following the end of the calendar month, or within 30 or 45 days afterthe exceedance occurs), that deviation reporting requirement overrides the reportingrequirements specified in this General Term and Condition for that specific emission limitation,operational restriction, or control device parameter limitation. Following the provisions of thatnon-quarterly deviation reporting requirement will also satisfy the requirements (in part) of OACrule 3745-77-07(A)(3)(c) pertaining to the submission of monitoring reports every six monthsand to the prompt reporting of all deviations, and additional quarterly deviation reports for thatspecific emission limitation, operational restriction, or control device parameter limitation arenot required pursuant to this General Term and Condition.

See B.6 below if no deviations occurred during the quarter.(Authority for term: OAC rule 3745-77-07(A)(3)(c))

iii. All reporting required in accordance with the OAC rule 3745-77-07(A)(3)(c) for otherdeviations of the federally enforceable permit requirements which are not reported inaccordance with General Term and Condition A.1.c.ii above shall be submitted in thefollowing manner:

Written reports that identify all other deviations of the federally enforceable requirementscontained in this permit, including the monitoring, record keeping, and reporting requirements,which are not reported in accordance with General Term and Condition A.1.c.ii above shall be



submitted to the appropriate Ohio EPA District Office or local air agency by January 31 and July31 of each year; and each report shall cover the previous six calendar months.

In identifying each deviation, the permittee shall specify the federally enforceable requirementfor which the deviation occurred, describe each deviation, and provide the magnitude andduration of each deviation.

These semi-annual written reports shall satisfy the reporting requirements of OAC rule 3745-77-07(A)(3)(c) for any deviations from the federally enforceable requirements contained in thispermit that are not reported in accordance with General Term and Condition A.1.c.ii above.

If no such deviations occurred during a six-month period, the permittee shall submit a semi-annual report which states that no such deviations occurred during that period.(Authority for term: OAC rules 3745-77-07(A)(3)(c)(i) and (ii))

iv. Each written report shall be signed by a responsible official certifying that, "based oninformation and belief formed after reasonable inquiry, the statements and information in thereport (including any written malfunction reports required by OAC rule 3745-15-06 that arereferenced in the deviation reports) are true, accurate, and complete."(Authority for term: OAC rule 3745-77-07(A)(3)(c)(iv))

v. Reports of any required monitoring and/or record keeping information shall be submitted to theappropriate Ohio EPA District Office or local air agency.(Authority for term: OAC rule 3745-77-07(A)(3)(c))

2. Scheduled MaintenanceAny scheduled maintenance of air pollution control equipment shall be performed in accordance with paragraph(A) of OAC rule 3745-15-06. Except as provided in OAC rule 3745-15-06(A)(3), any scheduled maintenancenecessitating the shutdown or bypassing of any air pollution control system(s) shall be accompanied by theshutdown of the emissions unit(s) that is (are) served by such control system(s). Any scheduled maintenance, asdefined in OAC rule 3745-15-06(A)(1), that results in a deviation from a federally enforceable emissionlimitation (or control requirement) shall be reported in the same manner as described for malfunctions in GeneralTerm and Condition A.1.c.i above.(Authority for term: OAC rule 3745-77-07(A)(3)(c))

3. Risk Management PlansIf applicable, the permittee shall develop and register a risk management plan pursuant to section 112(r) of theClean Air Act, as amended, 42 U.S.C. § 7401 et seq. (“Act”); and, pursuant to 40 C.F.R. 68.215(a), the permitteeshall submit either of the following:

a. a compliance plan for meeting the requirements of 40 C.F.R. Part 68 by the date specified in 40C.F.R. 68.10(a) and OAC 3745-104-05(A); or

b. as part of the compliance certification submitted under 40 C.F.R. 70.6(c)(5), a certificationstatement that the source is in compliance with all requirements of 40 C.F.R. Part 68 and OACChapter 3745-104, including the registration and submission of the risk management plan.

(Authority for term: OAC rule 3745-77-07(A)(4))

4. Title IV ProvisionsIf the permittee is subject to the requirements of 40 CFR Part 72 concerning acid rain, the permittee shall ensurethat any affected emissions unit complies with those requirements. Emissions exceeding any allowances that arelawfully held under Title IV of the Act, or any regulations adopted thereunder, are prohibited.




5. Severability ClauseA determination that any term or condition of this permit is invalid shall not invalidate the force or effect of anyother term or condition thereof, except to the extent that any other term or condition depends in whole or in partfor its operation or implementation upon the term or condition declared invalid.(Authority for term: OAC rule 3745-77-07(A)(6))

6. General Requirementsa. The permittee must comply with all terms and conditions of this permit. Any noncompliance with the

federally enforceable terms and conditions of this permit constitutes a violation of the Act, and isgrounds for enforcement action or for permit revocation, revocation and reissuance, or modification, orfor denial of a permit renewal application.

b. It shall not be a defense for the permittee in an enforcement action that it would have been necessary tohalt or reduce the permitted activity in order to maintain compliance with the federally enforceable termsand conditions of this permit.

c. This permit may be modified, reopened, revoked, or revoked and reissued, for cause, in accordance withA.10 below. The filing of a request by the permittee for a permit modification, revocation andreissuance, or revocation, or of a notification of planned changes or anticipated noncompliance does notstay any term and condition of this permit.

d. This permit does not convey any property rights of any sort, or any exclusive privilege.

e. The permittee shall furnish to the Director of the Ohio EPA, or an authorized representative of theDirector, upon receipt of a written request and within a reasonable time, any information that may berequested to determine whether cause exists for modifying, reopening or revoking this permit or todetermine compliance with this permit. Upon request, the permittee shall also furnish to the Director oran authorized representative of the Director, copies of records required to be kept by this permit. Forinformation 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 Administratoralong with a claim of confidentiality.


7. FeesThe permittee shall pay fees to the Director of the Ohio EPA in accordance with ORC section 3745.11 and OACChapter 3745-78.(Authority for term: OAC rule 3745-77-07(A)(8))

8. Marketable Permit ProgramsNo revision of this permit is required under any approved economic incentive, marketable permits, emissionstrading, and other similar programs or processes for changes that are provided for in this permit.(Authority for term: OAC rule 3745-77-07(A)(9))

9. Reasonably Anticipated Operating ScenariosThe permittee is hereby authorized to make changes among operating scenarios authorized in this permit withoutnotice to the Ohio EPA, but, contemporaneous with making a change from one operating scenario to another, thepermittee must record in a log at the permitted facility the scenario under which the permittee is operating. Thepermit shield provided in these general terms and conditions shall apply to all operating scenarios authorized inthis permit.(Authority for term: OAC rule 3745-77-07(A)(10))



10. Reopening for CauseThis Title V permit will be reopened prior to its expiration date under the following conditions:

a. Additional applicable requirements under the Act become applicable to one or more emissions unitscovered by this permit, and this permit has a remaining term of three or more years. Such a reopeningshall be completed not later than eighteen (18) months after promulgation of the applicable requirement. No such reopening is required if the effective date of the requirement is later than the date on which thepermit is due to expire, unless the original permit or any of its terms and conditions has been extendedpursuant to paragraph (E)(1) of OAC rule 3745-77-08.

b. This permit is issued to an affected source under the acid rain program and additional requirements(including excess emissions requirements) become applicable. Upon approval by the Administrator,excess emissions offset plans shall be deemed to be incorporated into the permit, and shall not require areopening of this permit.

c. The Director of the Ohio EPA or the Administrator of the U.S. EPA determines that the federallyapplicable requirements in this permit are based on a material mistake, or that inaccurate statements weremade in establishing the emissions standards or other terms and conditions of this permit related to suchfederally applicable requirements.

d. The Administrator of the U.S. EPA or the Director of the Ohio EPA determines that this permit must berevised or revoked to assure compliance with the applicable requirements.

(Authority for term: OAC rules 3745-77-07(A)(12) and 3745-77-08(D))

11. Federal and State Enforceability Only those terms and conditions designated in this permit as federally enforceable, that are required under theAct, or any of its applicable requirements, including relevant provisions designed to limit the potential to emit ofa source, are enforceable by the Administrator of the U.S. EPA, the State, and citizens under the Act. All otherterms and conditions of this permit shall not be federally enforceable and shall be enforceable under State lawonly.(Authority for term: OAC rule 3745-77-07(B))

12. Compliance Requirementsa. Any document (including reports) required to be submitted and required by a federally applicable

requirement in this Title V permit shall include a certification by a responsible official that, based oninformation and belief formed after reasonable inquiry, the statements in the document are true, accurate,and complete.

b. Upon presentation of credentials and other documents as may be required by law, the permittee shallallow the Director of the Ohio EPA or an authorized representative of the Director to:

i. At reasonable times, enter upon the permittee's premises where a source is located or theemissions-related activity is conducted, or where records must be kept under the conditions ofthis permit.

ii. Have access to and copy, at reasonable times, any records that must be kept under the conditionsof this permit, subject to the protection from disclosure to the public of confidential informationconsistent with paragraph (E) of OAC rule 3745-77-03.

iii. Inspect at reasonable times any facilities, equipment (including monitoring and air pollutioncontrol equipment), practices, or operations regulated or required under this permit.

iv. As authorized by the Act, sample or monitor at reasonable times substances or parameters for thepurpose of assuring compliance with the permit and applicable requirements.



c. The permittee shall submit progress reports to the appropriate Ohio EPA District Office or local airagency concerning any schedule of compliance for meeting an applicable requirement. Progress reportsshall be submitted semiannually, or more frequently if specified in the applicable requirement or by theDirector of the Ohio EPA. Progress reports shall contain the following:

i. Dates for achieving the activities, milestones, or compliance required in any schedule ofcompliance, and dates when such activities, milestones, or compliance were achieved.

ii. An explanation of why any dates in any schedule of compliance were not or will not be met, andany preventive or corrective measures adopted.

d. Compliance certifications concerning the terms and conditions contained in this permit that are federallyenforceable emission limitations, standards, or work practices, shall be submitted to the Director (theappropriate Ohio EPA District Office or local air agency) and the Administrator of the U.S. EPA in thefollowing manner and with the following content:

i. Compliance certifications shall be submitted annually on a calendar year basis. The annualcertification shall be submitted on or before April 30th of each year during the permit term.

ii. Compliance certifications shall include the following:(a) An identification of each term or condition of this permit that is the basis of the

certification.(b) The permittee's current compliance status.(c) Whether compliance was continuous or intermittent.(d) The method(s) used for determining the compliance status of the source currently and

over the required reporting period.(e) Such other facts as the Director of the Ohio EPA may require in the permit to determine

the compliance status of the source.iii. Compliance certifications shall contain such additional requirements as may be specified

pursuant to sections 114(a)(3) and 504(b) of the Act.(Authority for term: OAC rules 3745-77-07(C)(1),(2),(4) and (5) and ORC section 3704.03(L))

13. Permit Shielda. Compliance with the terms and conditions of this permit (including terms and conditions established for

alternate operating scenarios, emissions trading, and emissions averaging, but excluding terms andconditions for which the permit shield is expressly prohibited under OAC rule 3745-77-07) shall bedeemed compliance with the applicable requirements identified and addressed in this permit as of thedate of permit issuance.

b. This permit shield provision shall apply to any requirement identified in this permit pursuant to OAC rule3745-77-07(F)(2), as a requirement that does not apply to the source or to one or more emissions unitswithin the source.

(Authority for term: OAC rule 3745-77-07(F))

14. Operational FlexibilityThe permittee is authorized to make the changes identified in OAC rule 3745-77-07(H)(1)(a) to (H)(1)(c) withinthe permitted stationary source without obtaining a permit revision, if such change is not a modification underany provision of Title I of the Act [as defined in OAC rule 3745-77-01(JJ)], and does not result in an exceedanceof the emissions allowed under this permit (whether expressed therein as a rate of emissions or in terms of totalemissions), and the permittee provides the Administrator of the U.S. EPA and the appropriate Ohio EPA DistrictOffice or local air agency with written notification within a minimum of seven days in advance of the proposedchanges, unless the change is associated with, or in response to, emergency conditions. If less than seven daysnotice is provided because of a need to respond more quickly to such emergency conditions, the permittee shallprovide notice to the Administrator of the U.S. EPA and the appropriate District Office of the Ohio EPA or local



air agency as soon as possible after learning of the need to make the change. The notification shall contain theitems required under OAC rule 3745-77-07(H)(2)(d).(Authority for term: OAC rules 3745-77-07(H)(1) and (2))

15. EmergenciesThe permittee shall have an affirmative defense of emergency to an action brought for noncompliance withtechnology-based emission limitations if the conditions of OAC rule 3745-77-07(G)(3) are met. This emergencydefense provision is in addition to any emergency or upset provision contained in any applicable requirement.(Authority for term: OAC rule 3745-77-07(G))

16. Off-Permit ChangesThe owner or operator of a Title V source may make any change in its operations or emissions at the source thatis not specifically addressed or prohibited in the Title V permit, without obtaining an amendment or modificationof the permit, provided that the following conditions are met:

a. The change does not result in conditions that violate any applicable requirements or that violate anyexisting federally enforceable permit term or condition.

b. The permittee provides contemporaneous written notice of the change to the Director and theAdministrator of the U.S. EPA. Such written notice shall describe each such change, the date of suchchange, any change in emissions or pollutants emitted, and any federally applicable requirement thatwould apply as a result of the change.

c. The change shall not qualify for the permit shield under OAC rule 3745-77-07(F).

d. The permittee shall keep a record describing all changes made at the source that result in emissions of aregulated air pollutant subject to an applicable requirement, but not otherwise regulated under the permit,and the emissions resulting from those changes.

e. The change is not subject to any applicable requirement under Title IV of the Act or is not a modificationunder any provision of Title I of the Act.

Paragraph (I) of rule 3745-77-07 of the Administrative Code applies only to modification or amendment of thepermittee's Title V permit. The change made may require a permit to install under Chapter 3745-31 of theAdministrative Code if the change constitutes a modification as defined in that Chapter. Nothing in paragraph (I)of rule 3745-77-07 of the Administrative Code shall affect any applicable obligation under Chapter 3745-31 ofthe Administrative Code.(Authority for term: OAC rule 3745-77-07(I))

17. Compliance Method RequirementsNothing in this permit shall alter or affect the ability of any person to establish compliance with, or a violation of,any applicable requirement through the use of credible evidence to the extent authorized by law. Nothing in thispermit shall be construed to waive any defenses otherwise available to the permittee, including but not limited to,any challenge to the Credible Evidence Rule (see 62 Fed. Reg. 8314, Feb. 24, 1997), in the context of any futureproceeding.(This term is provided for informational purposes only.)

18. Insignificant ActivitiesEach insignificant activity that has one or more applicable requirements shall comply with those applicablerequirements.(Authority for term: OAC rule 3745-77-07(A)(1))



19. Permit to Install RequirementPrior to the “installation” or “modification” of any “air contaminant source,” as those terms are defined in OACrule 3745-31-01, a permit to install must be obtained from the Ohio EPA pursuant to OAC Chapter 3745-31.(Authority for term: OAC rule 3745-77-07(A)(1))

20. Air Pollution NuisanceThe air contaminants emitted by the emissions units covered by this permit shall not cause a public nuisance, inviolation of OAC rule 3745-15-07.(Authority for term: OAC rule 3745-77-07(A)(1))

21. Permanent Shutdown of an Emissions Unit The permittee may notify Ohio EPA of any emissions unit that is permanently shut down by submitting acertification by the responsible official of the date on which the emissions unit was permanently shut down.Authorization to operate the affected part or activity of the stationary source shall cease upon the date certified bythe responsible official that the emissions unit was permanently shut down.

If an emissions unit is permanently shut down (i.e., that has been physically removed from service or has beenaltered in such a way that it can no longer operate without a subsequent “modification” or “installation” asdefined in OAC Chapter 3745-31 and therefore ceases to meet the definition of an “emissions unit” as defined inOAC rule 3745-77-01(O)), rendering existing permit terms and conditions irrelevant, the permittee shall not berequired, after the date of the certification and submission to Ohio EPA, to meet any monitoring, record keeping,reporting, or testing requirements, applicable to that emissions unit, except for any residual requirements, such asthe quarterly deviation reports, semi-annual deviation reports and annual compliance certification covering theperiod during which the emissions unit last operated. All records relating to the shutdown emissions unit,generated while the emissions unit was in operation, must be maintained in accordance with law.

No emissions unit certified by the responsible official as being permanently shut down may resume operationwithout first applying for and obtaining a permit to install pursuant to OAC Chapter 3745-31.



B. State Only Enforceable Section

1. Reporting Requirements Related to Monitoring and Record Keeping Requirements

The permittee shall submit required reports in the following manner:

a. Reports of any required monitoring and/or record keeping information shall be submitted to theappropriate Ohio EPA District Office or local air agency.

b. Except as otherwise may be provided in the terms and conditions for a specific emissions unit, quarterlywritten reports of (i) any deviations (excursions) from emission limitations, operational restrictions, andcontrol device operating parameter limitations that have been detected by the testing, monitoring, andrecord keeping requirements specified in this permit, (ii) the probable cause of such deviations, and (iii)any corrective actions or preventive measures which have been or will be taken, shall be submitted to theappropriate Ohio EPA District Office or local air agency. In identifying each deviation, the permitteeshall specify the applicable requirement for which the deviation occurred, describe each deviation, andprovide the magnitude and duration of each deviation. If no deviations occurred during a calendarquarter, the permittee shall submit a quarterly report, which states that no deviations occurred during thatquarter. The reports shall be submitted quarterly, i.e., by January 31, April 30, July 31, and October 31of each year and shall cover the previous calendar quarters. (These quarterly reports shall excludedeviations resulting from malfunctions reported in accordance with OAC rule 3745-15-06.)

2. Records Retention RequirementsEach record of any monitoring data, testing data, and support information required pursuant to this permit shallbe 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 continuousmonitoring instrumentation, and copies of all reports required by this permit. Such records may be maintained incomputerized form.

3. Inspections and Information RequestsThe Director of the Ohio EPA, or an authorized representative of the Director, may, subject to the safetyrequirements of the permittee and without undue delay, enter upon the premises of this source at any reasonabletime for purposes of making inspections, conducting tests, examining records or reports pertaining to anyemission of air contaminants, and determining compliance with any applicable State air pollution laws andregulations and the terms and conditions of this permit. The permittee shall furnish to the Director of the OhioEPA, or an authorized representative of the Director, upon receipt of a written request and within a reasonabletime, any information that may be requested to determine whether cause exists for modifying, reopening orrevoking this permit or to determine compliance with this permit. Upon verbal or written request, the permitteeshall also furnish to the Director of the Ohio EPA, or an authorized representative of the Director, copies ofrecords required to be kept by this permit.

4. Scheduled Maintenance/Malfunction ReportingAny scheduled maintenance of air pollution control equipment shall be performed in accordance with paragraph(A) of OAC rule 3745-15-06. The malfunction of any emissions units or any associated air pollution controlsystem(s) shall be reported to the appropriate Ohio EPA District Office or local air agency in accordance withparagraph (B) of OAC rule 3745-15-06. Except as provided in that rule, any scheduled maintenance ormalfunction necessitating the shutdown or bypassing of any air pollution control system(s) shall be accompaniedby the shutdown of the emissions unit(s) that is (are) served by such control system(s).

5. Permit TransfersAny transferee of this permit shall assume the responsibilities of the prior permit holder. The appropriate OhioEPA District Office or local air agency must be notified in writing of any transfer of this permit.



6. Additional Reporting Requirements When There Are No Deviations of Federally Enforceable EmissionLimitations, Operational Restrictions, or Control Device Operating Parameter Limitations (See Section Aof This Permit)

If no emission limitation (or control requirement), operational restriction and/or control device parameterlimitation deviations occurred during a calendar quarter, the permittee shall submit a quarterly report, whichstates that no deviations occurred during that quarter. The reports shall be submitted by January 31, April 30,July 31, and October 31 of each year; and each report shall cover the previous calendar quarter.

The permittee is not required to submit a quarterly report which states that no deviations occurred during thatquarter for the following situations:

a. where an emissions unit has deviation reporting requirements for a specific emission limitation,operational restriction, or control device parameter limitation that override the deviation reportingrequirements specified in General Term and Condition A.1.c.ii;

b. where an uncontrolled emissions unit has no monitoring, record keeping, or reporting requirements andthe emissions unit’s applicable emission limitations are established at the potentials to emit; and

c. where the company’s responsible official has certified that an emissions unit has been permanently shutdown.

1 11Facility Name: AK Steel Corporation Facility ID: 14-09-01-0006

Part II - Specific Facility Terms and Conditions

A. State and Federally Enforceable Section

1. The permittee is subject to the applicable limitations(s) and/or control measures, operational restrictions,monitoring and/or record keeping requirements, reporting requirements, testing requirements and the generaland/or other requirements specified in 40 CFR Part 63, Subpart DDDDD - National Emission Standards forHazardous Air Pollutants for Subpart DDDDD, Industrial/Commercial/Institutional Boilers and ProcessHeaters, (including the Tables(s) and Appendix(ices) referenced in Subpart DDDDD, which are included inthe text of Attachment 1 hereto, and are hereby incorporated into this permit as if fully rewritten.

Ordinarily, these requirements would be incorporated into Part II of this Title V Permit; however, incorporatingSubpart DDDDD into Part II of this Title V permit was not practical due to technical incompatibilities and thelimitations of the STARS program. In addition, numerous difficulties were encountered in attempting to copyand paste the Subpart's tables and/or equations into STARS format.

The following emissions units in this permit may be subject to the aforementioned requirements:

B007B008B009B010B021B022B023B026P019P022

2. The permittee is subject to the applicable limitations(s) and/or control measures, operational restrictions,monitoring and/or record keeping requirements, reporting requirements, testing requirements and the generaland/or other requirements specified in 40 CFR Part 63, Subpart CCCCC - National Emission Standards forHazardous Air Pollutants for Coke Ovens: Pushing, Quenching, and Battery Stacks (including the Tables(s)and Appendix(ices) referenced in Subpart CCCCC, which are included in the text of Attachment 2 hereto, andare hereby incorporated into this permit as if fully rewritten.

Ordinarily, these requirements would be incorporated into Part II of this Title V Permit; however, incorporatingSubpart CCCCC into Part II of this Title V permit was not practical due to technical incompatibilities and thelimitations of the STARS program. In addition, numerous difficulties were encountered in attempting to copyand paste the Subpart's tables and/or equations into STARS format.


B918F021P043

Specific Facility Terms and ConditionsTitle V Final Permit

Page 11


A. State and Federally Enforceable Section (continued)

3. The permittee is subject to the applicable limitations(s) and/or control measures, operational restrictions,monitoring and/or record keeping requirements, reporting requirements, testing requirements and the generaland/or other requirements specified in 40 CFR Part 63, Subpart FFFFF - National Emission Standards forHazardous Air Pollutants for Integrated Iron and Steel Manufacturing Facilities (including the Tables(s) andAppendix(ices) referenced in Subpart FFFFF), which are included in the text of Attachment 3 hereto, and arehereby incorporated into this permit as if fully rewritten.

Ordinarily, these requirements would be incorporated into Part II of this Title V Permit; however, incorporatingSubpart FFFFF into Part II of this Title V permit was not practical due to technical incompatibilities and thelimitations of the STARS program. In addition, numerous difficulties were encountered in attempting to copyand paste the Subpart's tables and/or equations into STARS format.


F011F025P047P925P926P927P934P956


Page 12



4. The following insignificant emissions units are located at this facility:

P087 EP Roll Shop Shotblaster 1P088 EP Roll Shop Shotblaster 2P089 CSM Roll Shop ShotblasterP090 Shops Abrasive BlastT011 STTP HCl TanksZ012 NiCO3 Storage TankZ013 NiCO3/Elect MixerZ014 Lime SiloZ016 Roll./RP Oils TanksZ019 EGL WWTP Lime BinsZ020 STTP Limestone BinsZ021 HSM WWTP RM A BinsZ022 HSM WWTP RM B BinsZ023 HSM WWTP RM C BinsZ024 NTTP Lime BinsZ025 Chem B Lime BinsZ026 CHEM B FS BinsZ027 No. 8 Fuel Oil TankZ028 No. 5 Fuel Oil TankZ029 CSM Waste Oil TanksZ030 4CL CA Strip SprayZ031 4CL Pot Snout HeatingZ032 4CL Pot PreheaterZ033 4CL PrinterZ034 3CL Caustic Rec TankZ035 3CL BonderiteZ036 3CL Rust Prev Tank 1Z037 3CL Rust Prev Tank 2Z038 3CL H2SO4 CleaningZ044 2EG Caustic TankZ045 2EG Degreas. TankZ046 2EG Surf Act. TankZ047 2EG Rust Prev TankZ048 2EG Con Roll Zn TankZ049 2EG Con Roll ZnNi TankZ050 2EG Tank Farm


Page 13



Z051 2EG Permerate TankZ052 2EG W H2SO4 TankZ053 2EG E H2SO4 TankZ054 Diesel Tank - GarageZ055 PS MT25 Tank - 6TMZ056 PS 1 Roll Shop Cool. TankZ057 N4P ULHF46 TankZ058 N5P ULHF46 TankZ059 N4P Pickle Rinse TanksZ060 N5P Pickle Rinse TanksZ061 N4P SPL TanksZ062 N5P SPL TanksZ063 Rolling Oil Tank- Pickle HseZ064 Rust Prev Tank - Pickle HseZ065 N4P ULMP2 TankZ066 N5P ULMP2 TankZ067 CSM N3 Sys Lube Oil TankZ068 CSM UNOCAL Hyd TankZ069 CSM ULMR2 RP TankZ070 CSM Unimist 222 TankZ071 CSM Morgoil MO1 TankZ072 CSM Morgoil MO2 TankZ073 CSM DI Water TankZ074 CSM Morgoil 1200 Tank1Z075 CSM Morgoil 1200 Tank2Z076 CSM Morgoil 2450 Tank1Z077 CSM Morgoil 2450 Tank2Z078 CSM N6 Hyd Sys TankZ079 CSM N8 Hyd Sys TankZ080 CSM Roll Coolant TanksZ081 HSM Hyd 22,23,24 TankZ082 HSM Hot Rolling Oil TankZ083 HSM H-17 Sys TankZ084 HSM H-18 Sys TankZ085 HSM H-1 Sys TankZ086 HSM H-2 Sys TankZ087 HSM H-1, H-2 Sys TankZ088 HSM ULSO385 604 TankZ089 HSM ULSO385 613 TankZ090 HSM Bulk Tanks - Door 611Z091 HSM Scale Pits (3)Z092 HSM RS ULSY995 SystemZ093 HSM RS ULSY997 SystemZ094 N3BF Stockhse Hyd TankZ095 N3BF N5 Cooling Tower CellZ096 N3BF N Sludge PondZ097 N3BF S Sludge PondZ098 N2BH Nitric Acid TankZ099 N2BH Betz CPD TankZ100 N2BH Betz AL39 Tank1


Page 14



Z101 N2BH Lime Slurry TanksZ102 N2BH Betz AL39 Tank2Z103 EGLTP Caustic Tank1Z104 EGLTP Caustic Tank2Z105 EGLTP Zn/Ni Surge TanksZ106 EGLTP Zn/Ni Mix TankZ107 EGLTP Zn/Ni Used Oil TankZ108 EGLTP Nalco 9901 TanksZ109 STTP PRW Tanks (2)Z110 STTP Ashland SPL TankZ111 STTP Crown Inhib. TankZ112 STTP Oil Skim A/A TankZ113 STTP Interm Inhib TankZ114 HSMTP Betz 91946 TankZ115 HSMTP H2SO4 TankZ116 HSM Oil Holding Tanks (2)Z117 NTTP SPL TankZ118 NTTP PRW Surge Tanks (3)Z119 NTTP Caustic TankZ120 NTTP Oil Concentator PitZ121 N3BH Nalco 1720 TankZ122 N3BH Nalco 7204T TankZ123 N3BH N6 Fuel Oil TankZ124 N3BH N7 Fuel Oil TankZ125 Carp Saws(3) ExhaustZ126 Weld Weld N LatheZ127 Weld Weld M LatheZ128 Weld Weld S LatheZ129 Weld Roll PreheaterZ130 Mach Cut-Off SawZ131 Mach Caster Roll Grind.Z132 Lub Pipe Clean TankZ133 Lub Grease Tank 607Z134 Lub Grease Tanks 612Z135 Dust Suppr Tank Door 82AZ136 Dust Suppr Tank Door 600KZ137 Round House Diesel Tank 1Z138 Round House Diesel Tank 2Z139 Diesel Tank Door 351Z140 Round Hse Waste Oil TankZ141 CP H2SO4 S TanksZ142 CP H3PO4 N TankZ143 CP H3PO4 S TankZ144 CP Caustic E TankZ145 CP Caustic W TankZ146 CP Bulk Oil S TankZ147 Deskull PitZ148 BOF NALCO 8315 TZ149 BOF Quin 822-300 TZ150 BOF Betz 36073 T


Page 15



Z151 Misc Kerosene TanksZ152 Misc Cold CleanersZ154 3CL PrinterZ155 EGL PrinterZ156 Round Hse Lub Tank

Each insignificant emissions unit at this facility must comply with all applicable State and federal regulations,and well as any emission limitations and/or control requirements contained within the identified permit toinstall for the emissions unit. Insignificant emissions units listed above that are not subject to specific permit toinstall requirements are subject to one or more of the applicable requirements contained in thefederally-approved versions of OAC Chapters 3745-17, 3745-18, and/or 3745-21.

5. Nitrogen Oxides (NOx) Budget Trading Program

OAC Chapter 3745-14

5.a Facility Code - 880028

5.b The four (4) waste heat recovery boilers (P009, P010, P011 and P012) are NOx budget units, as defined inOAC rule 3745-14-01(B)(2)(eee), and are subject to the applicable requirements specified in OAC Chapter3745-14. The slab furnaces which are coupled with each of the waste heat recovery boilers are not subject tothe NOx budget program requirements specified in OAC Chapter 3745-14. The NOx allowance allocation, asdefined in OAC rule 3745-14-01(B)(2)(rr), for the four NOx budget units for the 2004-2007 control periods, asdefined in OAC rule 3745-14-01(B)(2)(r), are listed below:

NOx budget unit Annual Allowance during Control Periods 2004 through 2007

P009 66P010 66P011 66P012 66

i. By April 1, 2005, the Director shall submit to the Administrator the NOx allowance allocation for the fourNOx budget units listed above for the control periods in years 2008 through 2012.

ii. By April 1, 2010, by April 1 of 2015, and thereafter by April1 of the year that is five years after the last yearfor which NOx allowance allocations are determined, the Director shall submit to the Administrator the NOxallowance allocation for the four NOx budget units listed above.

iii. NOx allowance allocations shall be determined in accordance with OAC rule 3745-14-05(C).

5.c The emissions units identified in Section A.5.b above are NOx budget units under OAC rule3745-14-01(C)(1)(b).[OAC rule 3745-14-01(C)(1)]

5.d NOx allowances for units commencing operation on the dates specified in OAC rule 3745-14-05(C)(4) shallbe allocated from the new source set-aside in accordance with the provisions of OAC rule3745-14-05(C)(4)(d).[OAC rule 3745-14-05(C)(4)]

5.e The NOx authorized account representative, as defined in OAC rule 3745-14-01(B)(2)(xx), shall submit acomplete NOx budget permit application in accordance with the deadlines specified in paragraphs (B)(2) and(B)(3) of OAC rule 3745-14-03. The NOx authorized account representative shall also submit, in a timelymanner, any supplemental information that the Director determines is necessary in order to review a NOxbudget permit application and issue or deny a NOx budget permit.[OAC rules 3745-14-01(E)(1)(a)(i), 3745-14-01(E)(1)(a)(ii), and 3745-14-03(B)(1)]


Page 16



5.f Beginning May 31, 2004, the owners and operators of each NOx budget source and each NOx budget unit atthe source shall hold NOx allowances available for compliance deductions under paragraph (E) of OAC rule3745-14-06, as of the NOx allowance transfer deadline, in the unit's compliance account and the source'soverdraft account in an amount not less than the total NOx emissions for the control period from the unit, asdetermined in accordance with OAC rule 3745-14-08, plus any amount necessary to account for actualutilization under paragraph (C)(5) of OAC rule 3745-14-05 for the control period.[OAC rules 3745-14-01(E)(3)(a) and 3745-14-01(E)(3)(c)]

5.g NOx allowances shall be held in, deducted from, or transferred among NOx allowance tracking systemaccounts in accordance with OAC rules 3745-14-05, 3745-14-06, 3745-14-07, and 3745-14-09.[OAC rule 3745-14-01(E)(3)(d)]

5.h A NOx allowance shall not be deducted, in order to comply with the requirement under paragraph (E)(3)(a) ofOAC rule 3745-14-01, for a control period in a year prior to the year for which the NOx allowance wasallocated.[OAC rule 3745-14-01(E)(3)(e)]

5.i Each ton of NOx emitted in excess of the NOx budget emission limitation, as defined in OAC rule3745-14-01(B)(2)(yy), shall constitute a separate violation of OAC Chapter 3745-14, the Clean Air Act, andapplicable Ohio law. The owners and operators of a NOx budget unit that has excess emissions, as defined inOAC rule 3745-14-01(B)(2)(x), in any control period shall surrender the NOx allowances required fordeduction under paragraph (E)(4)(a) of OAC rule 3745-14-06 and pay any fine, penalty, or assessment orcomply with any other remedy imposed under paragraph (E)(4)(c) of OAC rule 3745-14-06.[OAC rules 3745-14-01(E)(3)(b), 3745-14-01(E)(4)(a) and 745-14-01(E)(4)(b)]

5.j When recorded by the Administrator pursuant to OAC rules 3745-14-06 and 3745-14-07, every allocation,transfer, or deduction of a NOx allowance to or from a NOx budget unit's compliance account or the overdraftaccount of the source where the unit is located is deemed to amend automatically, and become a part of, anyNOx budget permit of the NOx budget unit by operation of law without any further review.[OAC rule 3745-14-01(E)(3)(h)]

5.k Except as provided below, the Director shall revise the NOx budget permit, as necessary, in accordance withOAC rule 3745-77-08. Each NOx budget permit is deemed to incorporate automatically the definitions ofterms under paragraph (B) of OAC rule 3745-14-01 and, when recorded by the Administrator, in accordancewith OAC rules 3745-14-06 and 3745-14-07, every allocation, transfer, or deduction of a NOx allowance to orfrom the compliance accounts of the NOx budget units covered by the permit or the overdraft account of theNOx budget source covered by the permit.[OAC rules 3745-14-03(D)(2) and 3745-14-03(E)(1)]

5.l The owner or operator of a NOx budget unit shall comply with the prohibitions under OAC rule3745-14-08(A)(5).[OAC rule 3745-14-08(A)(5)]

5.m The owners and operators of the NOx budget unit shall keep on site at the source each of the followingdocuments for a period of five years from the date the document is created: (This period may be extended forcause, at any time prior to the end of five years, in writing by the Director or Administrator.)


Page 17



i. the account certificate of representation for the NOx authorized account representative for the NOx budgetunit and all documents that demonstrate the truth of the statements in the account certificate ofrepresentation, in accordance with paragraph (D) of OAC rule 3745-14-02, provided that the certificate anddocuments shall be retained on site at the source beyond such five-year period until such documents aresuperseded because of the submission of a new account certificate or representation changing the NOxauthorized account representative;

ii. all emission monitoring information, in accordance with OAC rule 3745-14-08;

iii. copies of all reports, compliance certifications, and other submissions and all records made or requiredunder the NOx budget trading program; and

iv. copies of all documents used to complete a NOx budget permit application and any other submissionunder the NOx budget trading program or to demonstrate compliance with the requirements of the NOxbudget trading program.[OAC rule 3745-14-01(E)(5)(a)(i) through (iv)]

5.n The permittee, and to the extent applicable, the NOx authorized account representative of the NOx budgetunit, shall comply with the monitoring and reporting requirements as provided in OAC rule 3745-14-08 and in40 CFR Part 75, Subpart H. For purposes of complying with such requirements the definitions in OAC rule3745-14-01(B) and in 40 CFR 72.2 shall apply, and the terms "affected unit," "designated representative," and"continuous emission monitoring system" (or "CEMS") in 40 CFR Part 75 shall be replaced by the terms "NOxbudget unit," "NOx authorized account representative," and "continuous emission monitoring system" (or"CEMS"), respectively, as defined in OAC rule 3745-14-01(B).[OAC rule 3745-14-08(A)]

5.o During each control period, the permittee shall operate and maintain equipment to continuously monitor andrecord nitrogen oxides emissions from the NOx budget units identified in Section A.5.b above. Suchcontinuous monitoring and recording equipment shall comply with the applicable requirements specified in 40CFR Part 75. The permittee's monitoring system shall comply with the alternate monitoring provisionsspecified in the permittee's petition which has been approved by the Director and the Administrator inaccordance with 40 CFR 75.66(l) and OAC rule 3745-14-08(F). This includes all systems required to monitorthe NOx emission rate and heat input. The permittee shall comply with the initial and re-certificationprocedures of 40 CFR Part 75. The permittee shall maintain on-site documentation from the USEPA or theOhio EPA that the continuous nitrogen oxides monitoring system has been certified in accordance with 40CFR Part 75. The certification documentation shall be made available to the Director upon request. For eachcontrol period, the permittee shall maintain records of the following data obtained by the continuous nitrogenoxides monitoring system: emissions of nitrogen oxides in lb/mmBtu actual heat input on an hourly averagebasis and emissions of nitrogen oxides in lbs/hr. Whenever the monitoring system fails to meet the qualityassurance or data validation requirements of 40 CFR Part 75, data shall be substituted using the applicableprocedures in Appendix D, or Appendix E of 40 CFR Part 75.[OAC rules 3745-14-01(E)(2)(a), 3745-14-01(E)(5)(a)(ii), 745-14-08(A)(2)(a) through (A)(2)(d),3745-14-08(B)(1), and 3745-14-08(C)(1)]

5.p The permittee shall comply with the monitoring plan requirements of 40 CFR Part 75.62, except that themonitoring plan is only required to include information required by 40 CFR Part 75, Subpart H.[OAC rule 3745-14-08(E)(2)(b)]

5.q The NOx authorized account representative of the NOx budget unit shall submit the reports and compliancecertifications required under the NOx budget trading program, including those under OAC rules 3745-14-04and 3745-14-08, to the Director and Administrator.[OAC rule 3745-14-01(E)(4)(b)]

5.r Each submission under the NOx budget trading program shall be submitted, signed, and certified by the NOxauthorized account representative for each NOx budget source on behalf of which the submission is made.Each such submission shall include the following certification statement by the NOx authorized accountrepresentative:


Page 18



5.s "I am authorized to make this submission on behalf of the owners and operators of the NOx budget sourcesor NOx budget units for which the submission is made. I certify under penalty of law that I have personallyexamined, and am familiar with, the statements and information submitted in this document and all itsattachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information,I certify that the statements and information are to the best of my knowledge and belief true, accurate, andcomplete. I am aware that there are significant penalties for submitting false statements and information oromitting required statements and information, including the possibility of fine or imprisonment."

5.t If the NOx authorized account representative for a NOx budget unit subject to an acid rain emission limitationwho signed and certified any submission that is made under Subpart F or G of 40 CFR Part 75 and whichincludes data and information required under OAC rule 3745-14-08 or Subpart H of 40 CFR Part 75 is not thesame person as the designated representative or the alternate designated representative for the unit under 40CFR Part 72, then the submission shall also be signed by the designated representative or the alternatedesignated representative.[OAC rules 3745-14-02(A)(5) and 3745-14-08(E)(1)(b)]

5.u The NOx authorized account representative shall submit quarterly reports covering the period May 1 throughSeptember 30 of each year and including the data described in 40 CFR Part 75.74(c)(6). The NOx authorizedaccount representative shall submit such quarterly reports, beginning with the calendar quarter covering May1 through June 30, 2003. The NOx authorized account representative shall submit each quarterly report tothe Administrator within thirty days following the end of the calendar quarter covered by the report. Quarterlyreports shall be submitted in the manner specified in 40 CFR Part 75, Subpart H.[OAC rules 3745-14-08(E)(4)(b) and 3745-14-08(E)(4)(c)(i)]The NOx authorized account representative shallsubmit to the Administrator a compliance certification in support of each quarterly report based on areasonable inquiry of those persons with primary responsibility for ensuring that all of the unit's emissions arecorrectly and fully monitored. The compliance certification shall state that:

i. the monitoring data submitted were recorded in accordance with the applicable requirements of OAC rule3745-14-08 and 40 CFR Part 75, including the quality assurance procedures and specifications; and

ii. for a unit with add-on NOx emission controls and for all hours where data are substituted in accordancewith 40 CFR Part 75.34(a)(1), the add-on emission control were operating within the range of parameterslisted in the quality assurance program under Appendix B of 40 CFR Part 75 and the substitute values do notsystematically underestimate the NOx emissions.[OAC rule 3745-14-08(E)(4)(d)(i) and (ii)]

The NOx authorized account representative for a NOx budget unit shall submit written notice of monitoringsystem certification and re-certification test dates to the Director and the Administrator in accordance with 40CFR Part 75.61. The NOx authorized account representative shall submit a certification application to theAdministrator, U.S. EPA, Region V Office, and the Director within forty-five days after completing all initial orre-certification tests required under paragraph (B) of OAC rule 3745-14-08, including the information requiredunder Subpart H of 40 CFR Part 75.[OAC rules 3745-14-08(D) and 3745-14-08(E)(3)]


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5.v For each control period in which one or more NOx budget units at a source are subject to the NOx budgetemission limitation, the NOx authorized account representative of the source shall submit to the Director andthe Administrator, by November 30 of that year, a compliance certification report for each source covering allsuch units. The NOx authorized account representative shall include the following elements in thecompliance certification report, in a format prescribed by the Administrator, concerning each unit at the sourceand subject to the NOx budget emission limitation for the control period covered by the report:

i. identification of each NOx budget unit;

ii. at the NOx authorized account representative's option, the serial numbers of the NOx allowances that areto be deducted from each unit's compliance account or overdraft account under paragraph (E) of OAC rule3745-14-06 for the control period;

iii. at the NOx authorized account representative's option, for units sharing a common stack and having NOxemissions that are not monitored separately or apportioned in accordance with OAC rule 3745-14-08, thepercentage of allowances that is to be deducted from each unit's compliance account under paragraph (E)(5)of OAC rule 3745-14-06; and

iv. the compliance certification under paragraph (A)(3) of OAC rule 3745-14-04.[OAC rules 3745-14-04(A)(1) and 3745-14-04(A)(2)]

5.w In the compliance certification report under Section A.5.v.iv above, the NOx authorized account representativeshall certify, based upon reasonable inquiry of those persons with the primary responsibility for operating thesource and the NOx budget units at the source in compliance with the NOx budget trading program, whethereach NOx budget unit for which the compliance certification is submitted was operated during the calendaryear covered by the report in compliance with the requirements of the NOx budget trading program applicableto the unit, including all the following:

i. whether the unit was operated in compliance with the NOx budget emission limitation;

ii. whether the monitoring plan that governs the unit has been maintained to reflect the actual operation andmonitoring of the unit, and contains all information necessary to attribute NOx emissions to the unit, inaccordance with OAC rule 3745-14-08;

iii. whether all the NOx emissions from the unit, or group of units (including the unit) using a common stack,were monitored or accounted for through the missing data procedures and reported in the quarterlymonitoring reports, including whether conditional data were reported in the quarterly reports in accordancewith OAC rule 3745-14-08, and if conditional data were reported, the permittee shall indicate whether thestatus of all conditional data has been resolved and all necessary quarterly report submissions have beenmade; and

iv. whether the facts that form the basis for certification under OAC rule 3745-14-08 of each monitor at theunit or group of units (including the unit) using a common stack, or for using an excepted monitoring methodor alternative monitoring method approved under OAC rule 3745-14-08, if any, have changed. If a change isrequired to be reported under Section A.1.v.iv above, specify the nature of the change, the reason for thechange, when the change occurred, and how the unit's compliance status was determined subsequent to thechange, including what method was used to determine emissions when a change mandated the need formonitor re-certification.[OAC rule 3745-14-04(A)(3)]

5.x The NOx authorized account representative shall submit a complete NOx budget permit renewal applicationfor the NOx budget source covering the NOx budget units at the source in accordance with paragraph (E) ofOAC rule 3745-77-08.[OAC rule 3745-14-03(B)(3)(a)]

5.y The emission measurements recorded and reported in accordance with OAC rule 3745-14-08 shall be usedto determine compliance by the unit with the NOx budget emission limitation under paragraph (E)(3) of OACrule 3745-14-01.[OAC rule 3745-14-01(E)(2)(b)]


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B. State Only Enforceable Section

1. The permittee shall comply with the provisions of the Consent Order and Final Judgement Entry for State ofOhio ex rel. Petro v. AK Steel Corporation, Butler County Court of Common Pleas, Case No. CV 2004 031000.


Page 21

71 Facility Name:Facility ID:

Emissions Unit: Boiler No.1,No.2 BH (B007)

AK Steel Corporation 14-09-01-0006

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a Particulate emissions shall not exceed 0.020 pound per million Btu of actual heat input except whenburning non-distillate fuel oil (No. 4 fuel oil or higher), used oil, non-distillate fuel oil, or used oil.

2.b Particulate emissions shall not exceed 0.11 pound per million Btu of actual heat input when burningnon-distillate fuel oil (No. 4 fuel oil or higher) used oil, or when co-firing non-distillate oil or used oil withany gaseous fuels. This limit was obtained from curve P-1 in Figure I of OAC rule 3745-17-10 using atotal heat input of 844 mmBtu/hr, which is the combined total heat input from emissions units B007 thruB010.

2.c Particulate emissions shall not exceed 0.040 pound per million Btu of actual heat input when burning onlyblast furnace gas or any mixture of blast furnace gas and other gaseous fuels.

II. Operational Restrictions

The quality of the coke oven gas, blast furnace gas, on-specification used oil or fuel oil and natural gasburned in this emissions unit shall have a combination of sulfur content and heat content that is sufficient tocomply with the allowable sulfur dioxide emission limitation of 0.90 pound sulfur dioxide/mmBtu of actual heatinput.

1.

The permittee shall burn only natural gas, fuel oil, on-specification used oil, blast furnace gas, and coke ovengas in this emissions unit.

2.

Boiler No.1,No.2 BH (B007)

Babcock & Wilcox Gas/Oil Industrial Boiler produces steam for consumption throughout the facility.

A.

I. Applicable Emissions Limitations and/or Control Requirements1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed inthe following table along with the applicable rules and/or requirements and with the applicableemissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable EmissionsLimitations/Control

MeasuresApplicable Rules/

RequirementsOperations, Property,

and/or Equipment

211 MMBtu/hr coke oven gas, blastfurnace gas, natural gas,on-specification used oil (as definedin OAC rule 3745-279-11), and fueloil-fired boiler

OAC rule 3745-17-07(A) Visible particulate emissions fromany stack shall not exceed 20percent opacity as a 6-minuteaverage, except as provided by therule.

50 50

OAC rule 3745-17-10(B)(1) See A.I.2.a and A.I.2.c below.50 50

OAC rule 3745-17-10(C)(1) See A.I.2.b below.50 50

OAC rule 3745-18-15(C)(1) Sulfur dioxide emissions shall notexceed 0.90 lb/mmBtu actual heatinput.

50 50

40 CFR Part 63, Subpart DDDDD See Part II - Specific Facility Termsand Conditions.

50 50

limitations, and the listed control measures shall be employed. Additional applicable emissionslimitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions UnitsPage 22Title V Final Permit




III. Monitoring and/or Record Keeping Requirements

The permittee shall maintain records of the fuel oil and on-specification used oil burned in this emissions unitin accordance the following:

1.

a. Alternative 1:

For each shipment of fuel oil or on-specification used oil received for burning in this emissions unit, thepermittee shall collect or require the oil supplier to collect a representative grab sample of oil and maintainrecords of the total quantity of oil received, the permittee's or oil supplier's analyses for sulfur content and heatcontent, and the calculated sulfur dioxide emission rate (in lbs/mmBtu). (The sulfur dioxide emission rate shallbe calculated in accordance with the formula specified in OAC rule 3745-18-04(F).) A shipment may becomprised of multiple tank truck loads from the same supplier's batch, and the quality of the oil for those loadsmay be represented by a single batch analysis from the supplier.

The permittee shall perform or require the supplier to perform the analyses for sulfur content and heat contentin accordance with 40 CFR Part 60, Appendix A, Method 19, or the appropriate ASTM methods (such as,ASTM methods D240, D4294,),or equivalent methods as approved by the Director.

b. Alternative 2:

The permittee shall collect a representative grab sample of fuel oil or on-specification used oil that is burned inthis emissions unit for each day when the emissions unit burns fuel oil or on-specification used oil. If additionaloil is added to the tank serving this emissions unit on a day when the emissions unit is in operation, thepermittee shall collect a sufficient number of grab samples to develop a composite sample representative ofthe oil burned in this emissions unit.

A representative grab sample of oil does not need to be collected on days when this emissions unit does notburn fuel oil or on-specification used oil or when this emissions unit is only operated for the purpose of testfiring. The permittee shall maintain records of the total quantity of oil burned each day, except for the purposeof test-firing, the permittee's analyses for sulfur content and heat content, and the calculated sulfur dioxideemission rate (in lbs/mmBtu). (The sulfur dioxide emission rate shall be calculated in accordance with theformula specified in OAC rule 3745-18-04(F).)

The permittee shall perform or require the supplier to perform the analyses for sulfur content and heat contentin accordance with 40 CFR Part 60, Appendix A, Method 19, or the appropriate ASTM methods (such as,ASTM methods D240, D4294), or equivalent methods as approved by the Director.





III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall collect daily grab samples of the coke oven gas burned in this emissions unit as specifiedin section A.III.3 of the terms and conditions for emissions unit P067. The following information shall becollected and recorded on a quarterly basis:

a. the total cubic feet of coke oven gas burned;

b. the average sulfur content of the samples taken, recorded in percent by weight, of the coke oven gas (thegrains of hydrogen sulfide (H2S) per 100 dry standard cubic feet of coke oven gas shall be converted to adecimal fraction of sulfur by multiplying the grains of H2S per 100 cubic feet times 1 pound H2S per 7000grains of H2S times 0.94 pound of sulfur per 1 pound of H2S, and dividing by the density of coke oven gas(0.027 pound per cubic feet));

c. The heat content of the coke oven gas, in BTU per cubic foot. (The heat content shall be determinedusing the ASTM D1826-88 Method Thermo Electron Corporation Flo-Cal Instrument continuous recordingcalorimeter in the slab furnace/waste heat boiler complex on the Coke Oven Gas supply line). The averageheat content of natural gas shall assumed to be 1000 Btu/cubic foot; and

d. the average sulfur dioxide emission rate for the coke oven gas, recorded as pounds of SO2/mmBtu actualheat input (the resulting decimal fraction of sulfur and heat content determined in (b) and (c) above shall beused as input into the equation defined in OAC rule 3745-18-04(F) to calculate the sulfur dioxide emissionrate).

The hydrogen sulfide content, heat content, and sampling procedures for the coke oven gas shall be basedon approved ASTM procedures.

2.

Monitoring and record keeping for sulfur content is not required for natural gas because the sulfur dioxideemission rate from the burning of natural gas is less than the allowable sulfur dioxide emission rate in SectionA.I.1 of these terms and conditions.

3.

Monitoring and record keeping for sulfur content is not required for blast furnace gas because the sulfurdioxide emission rate from the burning of blast furnace gas is less than the allowable sulfur dioxide emissionrate in Section A.I.1 of these terms and conditions.

4.

The permittee shall perform weekly checks, when the emissions unit is in operation and when the weatherconditions allow, for any visible particulate emissions from the stack serving this emissions unit. Thepresence or absence of any visible emissions shall be noted in an operations log. If visible emissions areobserved, the permittee shall also note the following in the operations log:

a. the color of the emissions;b. whether the emissions are representative of normal operations;c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;d. the total duration of any visible emission incident; ande. any corrective actions taken to eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have todocument the exact start and end times for the visible emission incident under item (d) above or continue thedaily check until the incident has ended. The observer may indicate that the visible emission incident wascontinuous during the observation period (or, if known, continuous during the operation of the emissions unit).With respect to the documentation of corrective actions, the observer may indicate that no corrective actionswere taken if the visible emissions were representative of normal operations, or specify the minor correctiveactions that were taken to ensure that the emissions unit continued to operate under normal conditions, orspecify the corrective actions that were taken to eliminate abnormal visible emissions.

5.

For each day during which the permittee burns a fuel other than natural gas, fuel oil, on-specification used oil,blast furnace gas, and coke oven gas, the permittee shall maintain a record of the type and quantity of fuelburned in this emissions unit.

6.





IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visibleparticulate emissions were observed from the stack serving this emissions unit and (b) describe anycorrective actions taken to eliminate the visible particulate emissions. These reports shall be submitted to theDirector (the appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each yearand shall cover the previous 6-month period.

1.

The permittee shall submit quarterly deviation (excursion) reports that identify all exceedances of theallowable sulfur dioxide emission limitation based upon the calculated sulfur dioxide emission rates fromSection A.III above.

2.

The permittee shall submit quarterly deviation (excursion) reports that identify each day when a fuel otherthan natural gas, fuel oil, on-specification used oil, blast furnace gas, and/or coke oven gas was burned in thisemissions unit.

3.

The quarterly deviation reports shall be submitted in accordance with the reporting requirements specified inPart I, Section A.1.c.ii of the General Term and Conditions.

4.

V. Testing Requirements

Compliance with the emission limitations in Section A.I.1 of these terms and conditions shall be determined inaccordance with the following methods:

1.

Emission Limitation:

Visible particulate emissions shall not exceed 20 percent opacity, as a 6-minute average, except as providedby the rule.

Applicable Compliance Method:

If required, compliance shall be determined through visible emissions observations performed in accordancewith 40 CFR Part 60, Appendix A, Method 9, and the procedures specified in OAC rule 3745-17-03(B)(1).

1.a





V. Testing Requirements (continued)


Particulate emissions shall not exceed 0.020 pound per million Btu of actual heat input except when burningnon-distillate fuel oil (No. 4 fuel oil or higher), used oil, non-distillate fuel oil or on-specification used oil.


i. To determine the actual particulate emission rate for natural gas, the following equation may be used:

E (lb/mmBtu) = (1.9 lb/10^6 scf) x (1 scf/1000 Btu) x (1,000,000 Btu/mmBtu) = 0.0019 lb/mmBtu

Where:

E = particulate emission rate from natural gas, in lb/mmBtu;

1.9 lb/10^6 scf = emission factor for filterable particulate matter from burning natural gas, from AP-42, Section1.4 Natural Gas Combustion, Table 1.4-2, 7/98;

1 scf/1000 Btu = the heat value of 1 scf of natural gas; and

1,000,000 Btu/mmBtu = conversion from Btu to mmBtu.

ii. To determine the particulate emission rate for coke oven gas, the permittee may use the emission factorof 0.012 lb particulate/mmBtu from AP-42, Section 12.5 Iron and Steel Production, Table 12.5-1, 10/86.

iii. The actual particulate emission rate when distillate oil (No 2 fuel oil or lighter) is being fired may bedetermined by multiplying the maximum fuel oil capacity of the emissions unit (gallons/hr) by the AP-42, FifthEdition, Section 1.3, Table 1.3-1 (revised 9/98) emission factor of 2.0 lbs filterable PE/1000 gallons, and thendividing by the maximum hourly heat input capacity of the emissions unit (MMBtu/hr).

iv. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with40 CFR Part 60, Appendix A, Methods 1 through 5, and the procedures specified in OAC rule3745-17-03(B)(9).

1.b


Particulate emissions shall not exceed 0.11 pound per million Btu of actual heat input when burningnon-distillate fuel oil (No. 4 fuel oil or higher) used oil, or when co-firing non-distillate oil or on-specificationused oil with any gaseous fuels.


If required, the permittee shall demonstrate compliance with this emission limitation in accordance with 40CFR Part 60, Appendix A, Methods 1 through 5, and the procedures specified in OAC rule 3745-17-03(B)(9).

1.c





V. Testing Requirements (continued)


Particulate emissions shall not exceed 0.040 pound per million Btu of actual heat input when burning onlyblast furnace gas or any mixture of blast furnace gas and other gaseous fuels.


i. To determine the actual particulate emission rate for natural gas, the following equation may be used:

E (lb/mmBtu) = (1.9 lb/10^6 scf) x (1 scf/1000 Btu) x (1,000,000 Btu/mmBtu) = 0.0019 lb/mmBtu

Where:

E = particulate emission rate from natural gas, in lb/mmBtu;

1.9 lb/10^6 scf = emission factor for filterable particulate matter from burning natural gas, from AP-42, Section1.4 Natural Gas Combustion, Table 1.4-2, 7/98;

1 scf/1000 Btu = the heat value of 1 scf of natural gas; and

1,000,000 Btu/mmBtu = conversion from Btu to mmBtu.

ii. To determine the particulate emission rate for coke oven gas, the permittee may use the emission factorof 0.012 lb particulate/mmBtu from AP-42, Section 12.5 Iron and Steel Production, Table 12.5-1, 10/86.

1.d

iii. To determine the particulate emission rate for blast furnace gas, the permittee may use the emissionfactor of 0.035 lb particulate/mmBtu from AP-42, Section 12.5 Iron and Steel Production, Table 12.5-1, 10/86.

iv.

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