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1 Facility Name: AK Steel Corporation Application Number: 14-4605 Date: Draft PTI (date will be entered upon final issuance) GENERAL PERMIT CONDITIONS TERMINATION OF PERMIT TO INSTALL Substantial construction for installation must take place within 18 months of the effective date of this permit. 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 party shows good cause for any such extension. NOTICE OF INSPECTION The Director of the Ohio Environmental Protection Agency, or his authorized representatives, may enter upon the premises of the above-named applicant during construction and operation at any reasonable time for the purpose of making inspections, conducting tests, or to examine records or reports pertaining to the construction, modification or installation of the source(s) of environmental pollutants identified within this permit. CONSTRUCTION OF NEW SOURCES The proposed source(s) shall be constructed in strict accordance with the plans and application submitted for this permit to the Director of the Ohio Environmental Protection Agency. There may be no deviation from the approved plans without the express, written approval of the Agency. Any deviations from the approved plans or the above conditions may lead to such sanctions and penalties as provided under Ohio law. Approval of these plans does not constitute an assurance that the proposed facilities will operate in compliance with all Ohio laws and regulations. Additional facilities shall be installed upon orders of the Ohio Environmental Protection Agency if the proposed sources are inadequate or cannot meet applicable standards. If the construction of the proposed source(s) has already begun or has been completed prior to the date the Director of the Environmental Protection Agency approves the permit application and plans, the approval does not constitute expressed or implied assurance that the proposed facility has been constructed in accordance with the approved plans. The action of beginning and/or completing construction prior to obtaining the Director's approval constitutes a violation of Ohio Administrative Code (OAC) Rule 3745-31-02. Furthermore, issuance of the Permit to Install does not constitute an assurance that the proposed source will operate in compliance with all Ohio laws and regulations. Approval of the plans in any case is not to be construed as

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1Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

GENERAL PERMIT CONDITIONS

TERMINATION OF PERMIT TO INSTALL

Substantial construction for installation must take place within 18 months of the effective date of this permit. 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 party shows good cause for any such extension.

NOTICE OF INSPECTION

The Director of the Ohio Environmental Protection Agency, or his authorized representatives, may enter upon the premises of the above-named applicant during construction and operation at any reasonable time for the purpose of making inspections, conducting tests, or to examine records or reports pertaining to the construction, modification or installation of the source(s) of environmental pollutants identified within this permit.

CONSTRUCTION OF NEW SOURCES

The proposed source(s) shall be constructed in strict accordance with the plans and application submitted for this permit to the Director of the Ohio Environmental Protection Agency. There may be no deviation from the approved plans without the express, written approval of the Agency. Any deviations from the approved plans or the above conditions may lead to such sanctions and penalties as provided under Ohio law. Approval of these plans does not constitute an assurance that the proposed facilities will operate in compliance with all Ohio laws and regulations. Additional facilities shall be installed upon orders of the Ohio Environmental Protection Agency if the proposed sources are inadequate or cannot meet applicable standards.

If the construction of the proposed source(s) has already begun or has been completed prior to the date the Director of the Environmental Protection Agency approves the permit application and plans, the approval does not constitute expressed or implied assurance that the proposed facility has been constructed in accordance with the approved plans. The action of beginning and/or completing construction prior to obtaining the Director's approval constitutes a violation of Ohio Administrative Code (OAC) Rule 3745-31-02. Furthermore, issuance of the Permit to Install does not constitute an assurance that the proposed source will operate in compliance with all Ohio laws and regulations. Approval of the plans in any case is not to be construed as

2Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

an approval of the facility as constructed and/or completed. Moreover, issuance of the Permit to Install 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 applicable standards.

PERMIT TO INSTALL FEE

In accordance with Ohio Revised Code 3745.11, the specified Permit to Install fee must be remitted within 30 days of the effective date of this permit to install.

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.

APPLICABILITY

This Permit to Install is applicable only to the contaminant sources identified. Separate application must be made to the Director for the installation or modification of any other contaminant sources.

3Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

BEST AVAILABLE TECHNOLOGY

As specified in OAC Rule 3745-31-05, all new sources must employ Best Available Technology (BAT). Compliance with the terms and conditions of this permit will fulfill this requirement.

PERMIT TO OPERATE APPLICATION

A Permit to Operate application must be submitted to the appropriate field office for each air contaminant source in this Permit to Install. In accordance with OAC Rule 3745-35-02, the application shall be filed no later than thirty days after commencement of operation.

SOURCE OPERATION AFTER COMPLETION OF CONSTRUCTION

This facility is permitted to operate each source described by this permit to install for a period of up to one year from the date the source commenced operation. This permission to operate is granted only if the facility complies with all requirements contained in this permit and all applicable air pollution laws and regulations.

4Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

5Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

Ohio EPA

Source Number

SourceIdentification

NumberBAT

DeterminationApplicable Federal

& OAC Rules

Permit Allowable Mass Emissions and/or Control/Usage Requirements

AIR EMISSION SUMMARY

The air contaminant emissions units listed below comprise the Permit to Install for AK Steel Corporation located in Butler County. The emissions units listed below shall not exceed the emission limits/control requirements contained in the table. This condition in no way limits the applicability of any other state or federal regulations. Additionally, this condition does not limit the applicability of additional special terms and conditions of this permit.

Ohio EPA

Source Number

B027 B028

B028Cont’d

F021

F021Cont’d

F023

P091

P091Cont’d

P092

6Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

Ohio EPA

Source Number

SourceIdentification

NumberBAT

DeterminationApplicable Federal

& OAC Rules

Permit Allowable Mass Emissions and/or Control/Usage Requirements

P092Cont’d

P093

P920

P920Cont’d

P921

P921Cont’d

P921Cont’d

P937

7Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

Ohio EPA

Source Number

SourceIdentification

NumberBAT

DeterminationApplicable Federal

& OAC Rules

Permit Allowable Mass Emissions and/or Control/Usage Requirements

Source Identification Description

695 MMBtu/hour Blast furnace gas/natural gas fired boiler

695 MMBtu/hour Blast furnace gas/natural gas fired boiler

Paved roadways and parking areas

Coal handling

Quench tower for batteries A1 and A2

Quench tower for batteries B1 and B2

Cooling tower

96 oven nonrecovery coke batteries A1 and

8Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

Ohio EPA

Source Number

SourceIdentification

NumberBAT

DeterminationApplicable Federal

& OAC Rules

Permit Allowable Mass Emissions and/or Control/Usage Requirements

A2

96 oven nonrecovery coke batteries B1 and B2

Coke handling

BATDetermination

Visible emission limitations; mass emission rate limitations; compliance with recordkeeping and reporting requirements; compliance with 40 CFR Part 60, Subpart Da.

Visible emission

9Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

Ohio EPA

Source Number

SourceIdentification

NumberBAT

DeterminationApplicable Federal

& OAC Rules

Permit Allowable Mass Emissions and/or Control/Usage Requirements

limitations; mass emission rate limitations; compliance with recordkeeping and reporting requirements; compliance with 40 CFR Part 60, Subpart Da.

Compliance with visible particulate emission limitation; flushing with water and sweeping with vacuum; compliance with recordkeeping requirements; emissions limitations

Compliance with visible particulate emission limitations; emissions limitations; enclosure of

conveyors and transfer points; and use of wet suppression system to minimize or eliminate visible emissions of fugitive dust

Use of quench water with equal to or less than 1150 mg/L total dissolved solids concentration and installation and proper maintenance of internal baffles that cover a minimum of 95 percent of the cross-sectional area of the tower

Use of quench water with equal to or less than 1150 mg/L total dissolved solids concentration and installation and proper maintenance of internal baffles that cover a minimum of 95 percent of the cross-sectional area of the tower

Visible emissions limitation and mass emissions limitation

Visible particulate emissions limitations; control requirements; compliance with 40 CFR Part 63, Subpart L; and Compliance with the Ohio EPA Air Toxic Policy

10Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

Ohio EPA

Source Number

SourceIdentification

NumberBAT

DeterminationApplicable Federal

& OAC Rules

Permit Allowable Mass Emissions and/or Control/Usage Requirements

Visible particulate emissions limitations; control requirements; compliance with 40CFR Part 63, Subpart L; and Compliance with the Ohio EPA Air Toxic Policy

Visible particulate emissions limitations; emissions

limitations; enclosures for conveyors and each transfer point; use of scrubbers with 99 percent control efficiency of particulates from coke crushing and screening

Applicable Federal &OAC Rules

3745-15-07

3745-17-07 (A)*

3745-17-10 (B)(1)*

3745-21-08 (B)*

3745-23-06 (C)(1)*

3745-31-05

40 CFR 60, Subpart Da

3745-15-07

11Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

Ohio EPA

Source Number

SourceIdentification

NumberBAT

DeterminationApplicable Federal

& OAC Rules

Permit Allowable Mass Emissions and/or Control/Usage Requirements

3745-17-07 (A)*

3745-17-10 (B)(1)*

3745-21-08 (B)*

3745-23-06 (C)(1)*

3745-31-05

40 CFR 60, Subpart Da

3745-15-07

3745-17-

07 (B)(4)*

3745-17-08(B)(7)-(9)

3745-31-05

3745-15-073745-17-07 (B)3745-17-08 (B)(3)*3745-31-05

3745-15-07

3745-17-07 (A)*

3745-17-11*

3745-31-05

3745-31-28

3745-15-07

3745-17-07 (A)*

3745-17-11*

3745-31-05

3745-31-28

3745-15-07

3745-17-07 (A)

3745-17-11*

3745-31-05

3745-15-07

3745-17-07 (A)*3745-17-07 (B)(1)***

3745-17-07(B)(2)(d)***

3745-17-07(B)(2)(e)

3745-17-08(B)(3)(b)*

3745-17-10*

3745-17-11*

3745-18-06 (E)(2)*

3745-21-08 (B)*

3745-23-06 (B)*

3745-31-05

40 CFR Part 63, Subpart L

12Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

Ohio EPA

Source Number

SourceIdentification

NumberBAT

DeterminationApplicable Federal

& OAC Rules

Permit Allowable Mass Emissions and/or Control/Usage Requirements

3745-31-28

3745-15-07

3745-17-07 (A)*

3745-17-07

(B)(1)***

3745-17-07(B)(2)(d)***

3745-17-07(B)(2)(e)

3745-17-08(B)(3)(b)*

3745-17-10*

3745-17-11*

3745-18-06 (E)(2)*

3745-21-08 (B)*

3745-23-06 (B)*

3745-31-05

40 CFR Part 63, Subpart L

3745-31-28

3745-15-073745-17-07 (A)*3745-17-07 (B)3745-17-08 (B)(3)*

3745-31-05

Permit Allowable Mass Emissions

and/or Control/UsageRequirements

See General Terms

Less stringent

Less stringent

Less stringent

Less stringent

See Section I. Terms A.1., A.2., A.3.(a)-A.3.(f)., A.4., C.7.-C.9., D.6. and D.7.

See Section I. Terms C.1.-C.6., D.1.-D.5., and E.1.-E.6., F.1., and F.2.

See General

Terms

Less stringent

Less stringent

Less stringent

Less stringent

See Section II. Terms A.1., A.2., A.3.(a)-A.3.(f)., A.4., C.7.-C.9., D.6. and D.7.

See Section II. Terms C.1.-C.6., D.1.-D.5., and E.1.-E.6., F.1., and F.2.

See General Terms

Less stringent

See Terms and Conditions

7.65 TPY PM

13Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

Ohio EPA

Source Number

SourceIdentification

NumberBAT

DeterminationApplicable Federal

& OAC Rules

Permit Allowable Mass Emissions and/or Control/Usage Requirements

3.7 TPY PM10(See Sections III. A.1.-A.3)

No visible particulate emissions except for six minutes during any sixty minute period

0.35 pound/hour PM and 0.38 TPY PM**

0.17 pound/hour PM10and 0.18 TPY PM10**

See General Terms

Less stringent

Less stringent

262.90 pounds PM/hour392.19 TPY of PM from P091 and P092, based on a rolling, 12-month limitation of PM emissions 24.27 pounds of PM10/hour36.2 TPY of PM10from P091 and P092, based on a rolling, 12-month limitation of PM10 emissions

See Section V. Terms A.1.-A.3., B.1.-B.3., C.1., D.1.

Section V. A.3., B.1., B.2., C.1., D.1.

See General Terms

Less stringent

Less stringent

262.90 pounds PM/hour392.19 TPY of PM from P091 and P092, based on a rolling, 12-month summation of PM emissions 24.27 pounds of PM10/hour36.2 TPY of PM10from P091 and P092, based on a rolling, 12-month limitation of PM10 emissions

See Section VI. Terms A.1.-A.3., B.1.-B.3., C.1., D.1.

Section VI. A.3., B.1., B.2., C.1., D.1.

See General Terms

See Section VII. Term A.1.

Less stringent

0.3 pound/hour PM/PM101.33 TPY PM/PM10See General Terms

Less stringent

See Section VIII. Term A.3.

Less stringent

Less stringent

Less stringent

Less stringent

Less stringent

Less stringent

Less stringent

Less stringent

See Section VIII. Terms A.2., A.4., A.5., A.7.-A.16., B.1.-B.3., B.5., B.14., B.15., C.1.-C.7., D.1., D.4-D.7., E.7. and F.2.

See Section VIII. Terms A.1., A.6., B.4., B.6.-B.13., C.8-C.11., D.2., D.3., and D.8-D.13.

Section VIII. A.5., A.8-A.11., A.15., A.16., B.2., B.3., B.14., C.6., D.7.

See General Terms

Less stringent

14Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

Ohio EPA

Source Number

SourceIdentification

NumberBAT

DeterminationApplicable Federal

& OAC Rules

Permit Allowable Mass Emissions and/or Control/Usage Requirements

See Section IX. Term A.3.

Less stringent

Less stringent

Less stringent

Less stringent

Less stringent

Less stringent

Less stringent

Less stringe

nt

See Section IX. Terms A.2., A.4., A.5., A.7.-A.16., B.1.-B.3., B.5., B.14., B.15., C.1.-C.7., D.1., D.4-D.7., D.10., D.11., E.7. and F.2.

See Section IX. Terms A.1., A.6., B.4., B.6.-B.11., C.8-C.11., D.2., D.3., and D.8-D.13.

Section IX. A.5., A.8-A.11., A.15., A.16.,B.2., B.3., B.14., C.6., D.7.

Emissions from coke crushing and screening scrubbers**;

0.015 gr PM/scf and 4.50 pounds PM/hour and 14.04 TPY; 0.01 gr PM10/scf and 3.00 pounds PM10/hour and 9.36 TPY PM10Fugitive emissions from coke crushing and screening**;

2.37 pounds PM/hour and 7.39 TPY PM;

1.58 pounds PM10/hour and 4.93 TPY PM10Coke convey, transfer and loadout**;0.53 pound PM/hour and 1.66 TPY PM; 0.25 pound PM10/hour and 0.78 TPY PM10

15Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

Ohio EPA

Source Number

SourceIdentification

NumberBAT

DeterminationApplicable Federal

& OAC Rules

Permit Allowable Mass Emissions and/or Control/Usage Requirements

16Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

* The emissions limitation(s)/opacity restrictions established by these rules are less stringent than those established by Ohio Administrative Code rule 3745-31-05(BAT).

** The TPY mass emission rate allowables are based on a rolling, 12-month summation.

*** The emission limitation established by this rule is less stringent than those established by 40 CFR Part 63, Subpart L.

SUMMARYTOTAL PERMIT TO INSTALL ALLOWABLE EMISSIONS

Pollutant

Organic Compound

PM

SO2

N0x

CO

PM10

Lead

Tons Per Year

221.26

843.24

922.64

1210.69

476.06

379.58

0.29

Contemp. Increase

33.58

80.83

0.15

27.01

5.59

73.18

0.0

Actual Contemp. Decrease

514.26

1252.98

962.64

1197.8

812.68

744.87

0.0

Net**** Increase

0.0

0.0

0.0

39.9

0.0

0.0

0.29

**** AK Steel elected to consume only enough emissions to make the increase 0.0 for OC, PM, SO2, CO and PM10.

REPORTING REQUIREMENTS

Unless otherwise specified, reports required by the Permit to Install need only be submitted to Hamilton County Dept. of Env. Services, 1632 Central Parkway, Cincinnati, OH 45210.

17Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

WASTE DISPOSAL

The owner/operator shall comply with any applicable state and federal requirements governing the storage, treatment, transport

and disposal of any waste material generated by the operation of the sources.

MAINTENANCE OF EQUIPMENT

This source and its associated air pollution control system(s) shall be maintained regularly in accordance with good engineering practices and the recommendations of the respective manufacturers in order to minimize air contaminant emissions.

MALFUNCTION/ABATEMENT

In accordance with OAC RULE 3745-15-06, any malfunction of the source(s) or associated air pollution control system(s) shall be reported immediately to the Hamilton County Dept. of Env. Services, 1632 Central Parkway, Cincinnati, OH 45210.

Except as provided by OAC Rule 3745-15-06(A)(3), scheduled maintenance of air pollution control equipment that requires the shutdown or bypassing of air pollution control system(s) must be accompanied by the shutdown of the associated air pollution sources.

AIR POLLUTION NUISANCES PROHIBITED

The air contaminant source(s) identified in this permit may not cause a public nuisance in violation of OAC Rule 3745-15-07.

NINETY DAY OPERATING PERIOD

The facility will be permitted to operate during a 90-day period in accordance with OAC Rule 3745-35-02(C)(4)(b). The purpose of this period of operation is to fulfill the performance tests conditions used in the determination of compliance with the provisions of this Permit to Install or other applicable Ohio EPA rules.

18Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

CONSTRUCTION COMPLIANCE CERTIFICATION

The applicant shall provide Ohio EPA with a written certification (see enclosed form) that the facility has been constructed in accordance with the Permit to Install application and the terms and conditions of the Permit to Install. The certification shall be provided to Ohio EPA upon completion of construction but prior to startup of the source.

ADDITIONAL GENERAL TERMS AND CONDITIONS

A. Applicable Emission Limitations and/or Control Requirements

1. Except as otherwise specified in the Additional Special Terms and Conditions for each emissions unit, the visible particulate emissions from any stack shall not exceed 20 percent opacity, as a six-minute average.

2. Except as otherwise specified in the Additional Special Terms and Conditions, the visible fugitive particulate emissions from any emissions unit shall not exceed 20 percent opacity, as a three-minute average.

3. The emissions of NOx from Coke Batteries A1 and A2 (emissions unit P920), Coke Batteries B1 and B2(emissions unit P921), two 695 MMBtu/Hr Blast Furnace Gas/Natural Gas Boilers (emissions units B027 and B028) and the No. 3 Blast Furnace Flare (emissions unit P925) shall not exceed 1210.69 tons per year, based upon a rolling, 12-month summation of the NOx emissions.

To ensure enforceability during the first 12 calendar months of operation following the issuance of this permit, the permittee shall not exceed the emission levels specified in the following table:

Maximum AllowableCumulative Emissions

Month(s) of NOx (Tons)

1 605.31-2 605.31-3 605.31-4 605.31-5 605.31-6 605.31-7 706.21-8 807.1

19Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

1-9 9081-10 1008.91-11 1109.81-12 1210.69

After the first 12 calendar months of operation following the issuance of this permit, compliance with the annual emission limitation for NOx shall be based upon a rolling, 12-month summation of the NOxemissions.

B. Operational Restrictions

1. Emissions units B007, B008, B009 and/or B010 shall be permanently shut down no later than thirty (30) days after startup of emissions unit B027 and/or emissions unit B028.

2. The total quantity of blast furnace gas(BFG) burned in the two 695 MMBtu/Hr Blast Furnace Gas/Natural Gas Boilers (emissions units B027 and B028) and the No. 3 Blast Furnace Flare (emissions unit P925) shall not exceed 100,039.31 million cubic feet per year (MMcf/yr) based upon a rolling, 12-month summation of the BFG usage.

To ensure enforceability during the first 12 calendar months of operation following the issuance of this permit, the permittee shall not exceed the BFG usage levels specified in the following table:

Maximum AllowableCumulative BFG Usage

Month(s) (MMcf)

1 50,019.71-2 50,019.71-3 50,019.71-4 50,019.71-5 50,019.71-6 50,019.71-7 58,356.31-8 66,692.91-9 75,029.51-10 83,366.11-11 91,702.71-12 100,039.31

After the first 12 calendar months of operation following the issuance of this permit, compliance with

20Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

the annual BFG usage limitation shall be based upon a rolling, 12-month summation of the BFG usage.

3. The permittee shall operate and maintain a flame suppression system to control the PM/PM10 emissions from emissions unit P925.

C. Monitoring and Recordkeeping Requirements

1. The permittee shall maintain monthly records of the total quantity of BFG, in MMcf/month, burned in the Blast Furnace Flare(P925)and the two 695 MMBtu/Hr Blast Furnace Gas/Natural Gas Boilers (B027 and B028).

Additionally, during the first thirty days after startup of either emissions unit B027 or B028, the permittee shall maintain records of the total quantity of BFG, in MMcf/month, burned in emissions unit B007, B008, B009, and B010.

2. Except as otherwise specified in the Additional Special Terms and Conditions, all recordkeeping requirements, as well as any supporting analyses and computations shall be retained for a period of not less than five years from the date the record was created. Support information shall include, but is not 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.

3. The permittee shall maintain separate records of the monthly emissions of NOx from the coke oven batteries(P920 and P921), blast furnace flare(P925), and boilers(B027 and B028).

Additionally, during the first 30 days after startup of either emissions unit B027 and B028, the permittee shall maintain separate records of the emissions of NOxfrom emissions units B007, B008, B009 and B010.

D. Reporting Requirements

1. The permittee shall submit, except as otherwise

21Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

specified in the Additional Special Terms and Conditions, required reports in the following manner:

a. reports of any required monitoring and/or record keeping information shall be submitted to the Hamilton County Dept. of Env. Services; and,

b. 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 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 Hamilton County Dept. of Env. Services. 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, i.e., by January 30, April 30, July 30, and October 30 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).

2. The permittee shall submit quarterly reports which identify the total quantity (in MMcf) of BFG burned in the Blast Furnace Flare and the total quantity (in MMcf) of BFG burned in each boiler for each calendar month.

3. The permittee shall submit deviation (excursion) reports which identify all exceedances of the rolling, 12-month emission limitation for NOx and, for the first 12 calendar months of operation following the issuance of this permit, all exceedances of the maximum allowable cumulative emission levels.

4. The permittee shall submit deviation (excursion) reports which identify all exceedances of the rolling, 12-month BFG usage limitation and, for the first 12 calendar months of operation following the issuance of this permit, all exceedances of the maximum allowable cumulative BFG usage levels.

22Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

E. Compliance Methods/Testing Requirements

1. Compliance with the visible emission limitation in Section A.1 of these terms and conditions shall be determined by the methods outlined in OAC rule 3745-17-03(B)(1).

2. Compliance with the visible emission limitation in Section A.2 of these terms and conditions shall be determined by the methods outlined in OAC rule 3745-17-03(B)(3).

3. Compliance with the emission limitation in additional general term and condition A.3 of this permit to install shall be determined by the following equation:

(A + B + C + D + E) < 1210.69 TPY

Where,

A = rolling, 12-month emissions of NOx from Coke Batteries A1 and A2, including pushing, charging and waste gas emissions(emissions unit P920);

B = rolling, 12-month emissions of NOx from Coke Batteries B1 and B2, including pushing, charging and waste gas emissions(emissions unit P921);

C = rolling, 12-month emissions of NOx from Boiler (emissions unit B027);

D = rolling, 12-month emissions of NOx from Boiler (emissions unit B028); and,

E = rolling, 12-month emissions of NOx from No. 3 Blast Furnace Flare(emissions unit P925).

Additionally, during the first 30 days after startup of either emissions unit B027 and B028, the permittee shall include the emissions of NOx from emissions units B007, B008, B009 and B010 for the purposes of determining compliance with additional general term and

23Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

condition A.3. The NOx emissions from emissions units B007, B008, B009 and B010 shall be determined by multiplying the lbs NOx/MMBtu, as determined by the most recent stack test, by the MMBtu heat input rate for each emissions unit.

The rolling, 12-month emissions of NOx from each operation identified above (A - E) shall be determined by the following methods:

a. the annual emissions of NOx from Coke Batteries A1 & A2 shall be determined by multiplying the emission factor for coke oven charging and pushing emissions of 0.01603 lb NOx/wet ton of coal charged by the wet tons of coal charged/month, plus the calculated lbs NOx/wet ton coal charged, as demonstrated during the most recent stack test of the coke oven battery waste gas exhaust, times the tons of coal charged per month; adding the current month’s emissions rate to the emission rate for the preceding eleven month’s;

b. the annual emissions of NOx from Coke Batteries B1 & B2 shall be determined by multiplying the emission factor for coke oven charging and pushing emissions of 0.01603 lb NOx/wet ton of coal charged by the wet tons of coal charged/month, plus the calculated lbs NOx/wet ton coal charged, as demonstrated during the most recent stack test of the coke oven battery waste gas exhaust, times the tons of coal charged per month; adding the current month’s emissions rate to the emission rate for the preceding eleven month’s;

c. the annual emissions of NOx from the boiler (B027) shall be determined by adding the NOx emissions rate for each day of the calendar month, as determined by the NOx CEM; adding the current month’s emissions rate to the preceding eleven calendar month’s;

d. the annual emissions of NOx from the boiler (B028) shall be determined by adding the NOx emissions rate for each day of the calendar month, as determined by the NOx CEM; adding the current

24Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

month’s emissions rate to the preceding eleven calendar month’s; and,

e. the annual emissions of NOx from the No. 3 Blast Furnace Flare shall be determined by multiplying the total monthly quantity of BFG burned in the No. 3 Blast Furnace Flare, in MMcf/month by 23 lbs NOx/MMcf; adding the current month’s emissions rate to the preceding eleven calendar month’s.

4. The emissions reduction for PM from the flame suppression system (emissions unit P925) shall be determined by multiplying the uncontrolled emission factor of 0.6 lb PM/ton of pig iron by (1 - flame suppression system control efficiency) then times the tons of pig iron produced per year . The flame suppression system control efficiency is 50 percent.

5. The emissions reductions for PM10 from the flame suppression system (emissions unit P925) shall be determined by multiplying the uncontrolled emission factor of 0.31 lb PM10/ton of pig iron by (1 - flame suppression system control efficiency) then times the tons of pig iron produced per year. The flame suppression system control efficiency is 50 percent.

F. Miscellaneous Requirements

1. None.

ADDITIONAL SPECIAL TERMS AND CONDITIONS

I. Emissions Unit B027 for 695 MMBtu/Hr Blast Furnace Gas/Natural Gas Fired Boiler

A. Applicable Emission Limitations and/or Control Requirements

1. Visible particulate emissions from emissions unit B027 shall not exceed 20 percent opacity, as a six-minute average, except for one 6-minute period per hour of not more than 27 percent opacity.

2. All annual emission limitations identified in the Air Emission Summary section of this permit for this emissions unit are based on a rolling, 12-month summation of the respective emissions.

25Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

3. The maximum emissions from emissions unit B027 shall not exceed the following:

a. 0.022 lb PM/MMBtu and 67.91 TPY PM;

b. 0.022 lb PM10/MMBtu and 67.91 TPY PM10;

c. 0.001 lb SO2/MMBtu and 1.77 TPY SO2;

d. 0.100 lb NOx/MMBtu and 182.52 TPY NOx;

e. 0.002 lb VOC/MMBtu and 5.03 TPY VOC; and

f. 0.045 lb CO/MMBtu and 137.0 TPY CO.

4. The emissions of Hazardous Air Pollutants (HAPs) as identified in Section 112(b) of Title III of the Clean Air Act from emissions units B027 and B028 shall not exceed 9.9 TPY for any single HAP and 24.9 TPY for any combination of HAPs. Compliance with the above limitations shall be determined based upon a rolling, 12-month summation.

B. Operational Restrictions

1. None

C. Monitoring and Recordkeeping Requirements

1. The permittee shall install, calibrate, maintain, and operate a continuous monitoring system, and record the output of the system, for measuring nitrogen oxides (NOx) and sulfur dioxides (SO2) emissions, in units of the applicable standard. Such continuous monitoring and recording equipment shall comply with the requirements specified in 40 CFR Part 60.13 and/or 40 CFR Part 75 and in accordance with 40 CFR Part 60, Section 60.47a(f) through (h).

2. The permittee shall maintain records of all data obtained by the continuous NOx and SO2 monitoring systems including, but not limited to, parts per million NOx, SO2 and O2 or CO2 on a 1-hour average basis, emissions of NOx and SO2 in units of the

26Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

applicable standard on a 30-day rolling average, results of daily zero/span calibration checks, and magnitude of manual calibration adjustments.

3. A statement of certification of the continuous N0x and S02 monitoring system shall be maintained on site and shall consist of a letter from Ohio EPA detailing the results of an agency review of the certification tests and a statement by the agency that the system is considered certified in accordance with the requirements of 40 CFR Part 60, Appendix B, Performance Specification 6. Proof of certification shall be made available to the Director (the Hamilton County Dept. of Env. Services) upon request.

4. Within 180 days of the effective date of this permit, the permittee shall develop a written quality assurance/quality control plan for the continuous NOxSO2 and O2 or CO2 monitoring systems designed to ensure continuous valid and representative readings of NOx, SO2 and O2 or CO2 emissions in units of the applicable standard. The plan shall follow the requirements of 40 CFR Part 60, Appendix F and/or 40 CFR Part 75, Appendix B. The quality assurance/quality control plan and a logbook dedicated to the continuous NOx, SO2 and O2 or CO2 monitoring systems must be kept on site and available for inspection during regular office hours.

5. The permittee shall install, calibrate, maintain, and operate a continuous monitoring system, and record the output of the system, for measuring the oxygen or carbon dioxide content of the flue gases, in percent O2or percent CO2, at each location where nitrogen oxide or sulfur dioxide emissions are monitored. Such continuous monitoring and recording equipment shall comply with the requirements specified in 40 CFR Part 60.13 and/or 40 CFR Part 75 and in accordance with 40 CFR Part 60, Section 60.47a(f) through (h).

27Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

6. Each continuous monitoring system shall be operated and data recorded during all periods of operation of the emissions unit including periods of startup, shutdown, malfunction or emergency conditions, except for continuous monitoring system breakdowns, repairs, calibration checks, and zero and span adjustments.

7. The permittee shall use methods and procedures in paragraph (i) of §60.47a to conduct monitoring system performance evaluations under §60.13(c) and calibration checks under §60.13(d).

8. The permittee shall obtain, or have obtained, monthly representative samples of the blast furnace gas and natural gas used for fuel in this emissions unit. Each sample shall be analyzed for actual heat content, in Btu/scf.

Copies of the monthly analyses of heat content for natural gas and/or blast furnace gas may be obtained by the fuel supplier, provided the supplier obtains representative samples for heat content analysis.

Existing methods for analyzing blast furnace gas and heat value calculations may be employed for the purposes of compliance with this term and condition.

9. The permittee shall maintain monthly records for emissions unit B027 of the quantity of each fuel burned, in Mmcf/month.

10. The permittee shall collect and record the following information each month for emissions units B027 and B028:

a. the Hazardous Air Pollutant (HAP) emissions shall be calculated from factors determined from the sampling and analysis of each fuel burned. A factor shall be determined for each HAP in each fuel on a pounds per cubic foot of fuel basis. The sampling and analysis of each fuel shall be completed within 60 days after the startup of the emissions unit;

b. the total combined HAP content of each fuel in

28Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

pounds of combined HAP’s per cubic foot of fuel;

c. the total cubic feet of fuel burned;

29Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

d. the total individual HAP emissions for each HAP from all fuels burned in pounds or tons per month[ for each HAP the sum of (a) times (c)];

e. the total combined HAP emissions from all fuels burned in pounds or tons per month [ the sum of (b) times (c)];

f. the updated rolling, 12-month summation for each individual HAP emissions, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months. For the first twelve calendar months of operation following issuance of the permit, this shall be a cumulative total for all months since the issuance of the PTI; and,

g. the updated rolling, 12-month summation for the total combined HAP emissions, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months. For the first twelve calendar months of operation following issuance of the permit, this shall be a cumulative total for all months since the issuance of the PTI.

D. Reporting Requirements

1. The permittee shall submit a signed statement indicating whether:

a. the required continuous monitoring system calibration, span, and drift checks or other periodic audits have or have not been performed as specified;

b. the data used to show compliance was or was not obtained in accordance with approved methods and procedures of 40 CFR Part 60 and is representative of plant performance;

c. the minimum data requirements have or have not been met; or, the minimum data requirements have not been met for errors that were unavoidable;

30Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

and,

d. compliance with the standards has or has not been achieved during the reporting period.

31Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

2. Certification

a. Prior to the installation of the continuous NOxand SO2 monitoring systems, the permittee shall submit information detailing the proposed location of the sampling site in accordance with the siting requirements in 40 CFR Part 60, Appendix B, Performance Specification 2 for approval by the Ohio EPA, Central Office; and,

b. Prior to the installation of the continuous O2 or CO2 monitoring system, the permittee shall submit information detailing the proposed location of the sampling site in accordance with the siting requirements in 40 CFR Part 60, Appendix B, Performance Specification 3 for approval by the Ohio EPA, Central Office.

3. Pursuant to OAC rules 3745-15-04, 3745-35-02, and ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts 60.7 and 60.13(h), the permittee shall submit reports within 30 days following the end of each calendar quarter to the Hamilton County Dept. of Env. Services documenting the date, commencement and completion times, duration, magnitude, reason (if known), and corrective actions taken (if any), of all instances of NOx and/or SO2 values in excess of the applicable limits specified in 40 CFR Part 60, Subpart Da, 40 CFR Part 76 or any limitations specified in the terms and conditions or Air Emission Summary section of this permit. These reports shall also contain the total Nox and SO2 emissions for the calendar quarter (in tons).

The permittee shall submit reports within 30 days following the end of each calendar quarter to the Hamilton County Dept. of Env. Services documenting any continuous NOx and/or SO2 monitoring system downtime while the emissions unit was on line (date, time, duration and reason) along with any corrective action(s) taken.

32Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

The permittee shall provide the emissions unit operating time during the reporting period and the date, time, reason and corrective action(s) taken for each time period of emissions unit and control equipment malfunctions.

The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement to that effect along with the emissions unit operating time during the reporting period and the date, time, reason, and corrective action(s) taken for each time period of emissions unit, control equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line also shall be included in the quarterly report. These quarterly excess emission reports shall be submitted by January 30, April 30, July 30, and October 30 of each year and shall address the data obtained during the previous calendar quarter.

4. Pursuant to 40 CFR Parts 60.7 and 60.13(h), the permittee shall submit reports within 30 days following the end of each calendar quarter to the Hamilton County Dept. of Env. Services documenting all instances of continuous O2 or CO2 monitoring system downtime while the emissions unit was on line (date, time, duration and reason) along with any corrective action(s) taken.

The permittee shall provide the emissions unit operating time during the reporting period and the date, time, reason and corrective action(s) taken for each time period of emissions unit malfunctions. The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line shall be included in the quarterly report.

These quarterly reports shall be submitted by January 30, April 30, July 30, and October 30 of each year and

33Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

shall address the data obtained during the previous calendar quarter.

5. The permittee shall submit all applicable reports in accordance with the requirements of 40 CFR Part 60, Section 60.49a(b), (c) and (d).

6. The permittee shall submit monthly summaries of the actual heat content (Btu/cf) for natural gas and blast furnace gas and the total quantity (MMcf) of each fuel burned for each calendar quarter.

7. The permittee shall notify the Hamilton County Department of Environmental Services of any exceedance of the HAP emissions limitations set forth in term A.4. The permittee shall submit annual reports which identify all exceedances of these limitations, as well as the corrective actions that were taken to achieve compliance. These reports shall be submitted by January 31 of each year. If no exceedances occurred during the reporting period then a report is required stating so.

8. The permittee shall submit annual reports of emissions. The permittee may elect to submit Title V emissions fee reports in lieu of annual reports for those emissions required by the Title V emissions fee regulation. These reports shall be submitted by January 31 of each year.

E. Compliance Methods/Testing Requirements

Compliance with the emission limitation(s) in the Air Emission Summary section of this permit shall be determined in accordance with the following method(s):

1. The permittee shall conduct, or have conducted, an initial performance emission test for this emissions unit in accordance with the following requirements:

a. the emission testing shall be conducted in accordance with the requirements of 40 CFR Part 60, Section 60.8 and 40 CFR Part 60, Section 60.48a, if applicable.

2. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rates for particulate matter, SO2, Nox and CO.

3. The following test method(s) shall be employed to demonstrate compliance with the allowable mass emission rate(s): for particulate, Method 5 of 40 CFR Part 60, Appendix A, or as provided in 40 CFR Part 60, Section

34Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

60.48a; for NOx, Method 7 of 40 CFR Part 60, Appendix A, or as provided in 40 CFR Part 60, Section 60.48a; for SO2, Method 6 of 40 CFR Part 60, Appendix A; for CO, Method 10 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.

4. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, burning a mixture of natural gas and blast furnace gas, as proposed in Permit To Install application 14-4605, unless otherwise specified or approved by the Hamilton County Dept. of Env. Services.

5. Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test" notification to the Hamilton County Dept. of Env. Services. 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 Hamilton County Dept. of Env. Services refusal to accept the results of the emission test(s).

Personnel from the Hamilton County Dept. of Env. Services 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 Hamilton County Dept. of Env. Services 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

35Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

prior approval from the Hamilton County Dept. of Env. Services.

6. Within 60 days of startup of this emissions unit, the permittee shall conduct certification tests of the continuous SO2, NOx and O2 or CO2 monitoring systems pursuant to ORC section 3704.03(I) and 40 CFR Part 60, Appendix B, Performance Specification 2 and 3, where applicable, and/or 40 CFR Part 75. Personnel from the Hamilton County Dept. of Env. Services shall be notified 30 days prior to initiation of the applicable tests and shall be permitted to examine equipment and witness the certification tests.

In accordance with OAC rule 3745-15-04, all copies of the test results shall be submitted to the Hamilton County Dept. of Env. Services within 30 days after the test is completed. Copies of the test results shall be sent to the Hamilton County Dept. of Env. Services and the Ohio EPA, Central Office. Certification of the continuous NOx, SO2 and O2 or CO2 monitoring systems shall be granted upon determination by the Ohio EPA, Central Office that the systems meets all requirements of ORC section 3704.03(I) and 40 CFR Part 60, Appendix B, Performance Specification 2 and 3, respectively, and/or 40 CFR Part 75.

7. Compliance with the lbs NOx/MMBtu emissions limitation constitutes compliance with the percent reduction requirements under 40 CFR Part 60, Section 60.44a(a)(2). Compliance with this NOx emission limitation shall be determined by the requirements of 40 CFR Part 60, Section 60.48a(d) [CEM].

8. Compliance with the lbs PM/MMBtu emissions limitation constitutes compliance with the percent reduction requirements under 40 CFR Part 60, Section 60.42a(a)(2) and (3). Compliance with this PM emission limitation shall be determined by the requirements of 40 CFR Part 60, Section 60.48a(b).

9. Except as otherwise specified in 40 CFR Part 60, Subpart Da, compliance with the lbs/MMBtu emissions limitations for SO2 shall be determined by the SO2continuous emission monitor or approved alternative monitoring methods determined under 40 CFR Part 60, Section 60.13(i).

10. Compliance with the TPY emissions limitations for particulates, CO and VOC shall be determined by multiplying the emission factors, in lb/MMcf, found in

36Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

the Agency’s emission calculations for this emissions unit, in Permit to Install(PTI) 14-4605, by the monthly volume of fuel burned, for each fuel; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

11. Compliance with the SO2 TPY emissions limitation shall be determined by adding the SO2 emissions rate for each day of the calendar month as determined by the SO2 CEM or approved alternative methods; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

12. Compliance with the NOx TPY emissions limitation shall be determined by adding the NOx emissions rate for each day of the calendar month, as determined by the NOxCEM; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

37Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

13. Compliance with the visible particulate emissions limitation in A.1 of this permit, for this emissions unit, shall be determined by 40 CFR Part 60, Method 9, Appendix A and the procedures in 40 CFR Part 60, Section 60.11.

14. Compliance with the HAP emission limitations in A.4 shall be determined by the recordkeeping in C.9.

F. Miscellaneous Requirements

1. The PM and NOx emissions limitations in A.3 of this permit, for this emissions unit, apply at all times except during periods of startup, shutdown, or malfunction.

2. The SO2 emissions limitations in A.3 of this permit, for this emissions unit, apply at all times except during periods of startup, shutdown, or when both emergency conditions exist and the procedures under 40 CFR Part 60, Section 60.46a(d) are implemented.

3. The lb/MMBtu emission limitation(s) outlined are based upon the emissions unit’s PTE. Therefore, no lb/MMBturecords are required to demonstrate compliance with these limits, except as otherwise specified in E.7 through E.9 of this permit, for this emissions unit.

4. In accordance with 40 CFR Part 60, Section 60.13(i), the permittee may submit to the Administrator for approval a written application specifying an alternative to any CEM procedures or requirements.

II. Emissions Unit B028 - For 695 MMBtu/Hr Blast Furnace Gas/Natural Gas Fired Boiler

A. Applicable Emission Limitations and/or Control Requirements

1. Visible particulate emissions from emissions unit B027 shall not exceed 20 percent opacity, as a six-minute average, except for one 6-minute period per hour of not more than 27 percent opacity.

2. All annual emission limitations identified in the Air Emission Summary section of this permit for this

38Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

emissions unit are based on a rolling, 12-month summation of the respective emissions.

3. The maximum emissions from emissions unit B027 shall not exceed the following:

a. 0.022 lb PM/MMBtu and 67.91 TPY PM;

b. 0.022 lb PM10/MMBtu and 67.91 TPY PM10;

c. 0.001 lb SO2/MMBtu and 1.77 TPY SO2;

d. 0.100 lb NOx/MMBtu and 182.52 TPY NOx;

e. 0.002 lb VOC/MMBtu and 5.03 TPY VOC; and

f. 0.045 lb CO/MMBtu and 137.0 TPY CO.

4. The emissions of Hazardous Air Pollutants (HAPs) as identified in Section 112(b) of Title III of the Clean Air Act from emissions units B027 and B028 shall not exceed 9.9 TPY for any single HAP and 24.9 TPY for any combination of HAPs. Compliance with the above limitations shall be determined based upon a rolling, 12-month summation.

B. Operational Restrictions

1. None

C. Monitoring and Recordkeeping Requirements

1. The permittee shall install, calibrate, maintain, and operate a continuous monitoring system, and record the output of the system, for measuring nitrogen oxides (NOx) and sulfur dioxides (SO2) emissions, in units of the applicable standard. Such continuous monitoring and recording equipment shall comply with the requirements specified in 40 CFR Part 60.13 and/or 40 CFR Part 75 and in accordance with 40 CFR Part 60, Section 60.47a(f) through (h).

2. The permittee shall maintain records of all data obtained by the continuous NOx and SO2 monitoring systems including, but not limited to, parts per million NOx, SO2 and O2 or CO2 on a 1-hour average basis, emissions of NOx and SO2 in units of the applicable standard on a 30-day rolling average, results of daily zero/span calibration checks, and magnitude of manual calibration adjustments.

39Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

3. A statement of certification of the continuous N0x and S02 monitoring system shall be maintained on site and shall consist of a letter from Ohio EPA detailing the results of an agency review of the certification tests and a statement by the agency that the system is considered certified in accordance with the requirements of 40 CFR Part 60, Appendix B, Performance Specification 6. Proof of certification shall be made available to the Director (the Hamilton County Dept. of Env. Services) upon request.

4. Within 180 days of the effective date of this permit, the permittee shall develop a written quality assurance/quality control plan for the continuous NOxSO2 and O2 or CO2 monitoring systems designed to ensure continuous valid and representative readings of NOx, SO2 and O2 or CO2 emissions in units of the applicable standard. The plan shall follow the requirements of 40 CFR Part 60, Appendix F and/or 40 CFR Part 75, Appendix B. The quality assurance/quality control plan and a logbook dedicated to the continuous NOx, SO2 and O2 or CO2 monitoring systems must be kept on site and available for inspection during regular office hours.

5. The permittee shall install, calibrate, maintain, and operate a continuous monitoring system, and record the output of the system, for measuring the oxygen or carbon dioxide content of the flue gases, in percent O2or percent CO2, at each location where nitrogen oxide or sulfur dioxide emissions are monitored. Such continuous monitoring and recording equipment shall comply with the requirements specified in 40 CFR Part 60.13 and/or 40 CFR Part 75 and in accordance with 40 CFR Part 60, Section 60.47a(f) through (h).

6. Each continuous monitoring system shall be operated and data recorded during all periods of operation of the emissions unit including periods of startup, shutdown, malfunction or emergency conditions, except for continuous monitoring system breakdowns, repairs, calibration checks, and zero and span adjustments.

7. The permittee shall use methods and procedures in paragraph (i) of §60.47a to conduct monitoring system

40Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

performance evaluations under §60.13(c) and calibration checks under §60.13(d).

8. The permittee shall obtain, or have obtained, monthly representative samples of the blast furnace gas and natural gas used for fuel in this emissions unit. Each sample shall be analyzed for actual heat content, in Btu/scf.

Copies of the monthly analyses of heat content for natural gas and/or blast furnace gas may be obtained by

the fuel supplier, provided the supplier obtains representative samples for heat content analysis.

Existing methods for analyzing blast furnace gas and heat value calculations may be employed for the purposes of compliance with this term and condition.

9. The permittee shall maintain monthly records for emissions unit B027 of the quantity of each fuel burned, in Mmcf/month.

10. The permittee shall collect and record the following information each month for emissions units B027 and B028:

a. the Hazardous Air Pollutant (HAP) emissions shall be calculated from factors determined from the sampling and analysis of each fuel burned. A factor shall be determined for each HAP in each fuel on a pounds per cubic foot of fuel basis. The sampling and analysis of each fuel shall be completed within 60 days after the startup of the emissions unit;

b. the total combined HAP content of each fuel in pounds of combined HAP’s per cubic foot of fuel;

c. the total cubic feet of fuel burned;

d. the total individual HAP emissions for each HAP from all fuels burned in pounds or tons per month[ for each HAP the sum of (a) times (c)];

e. the total combined HAP emissions from all fuels burned in pounds or tons per month [ the sum of (b) times (c)];

f. the updated rolling, 12-month summation for each individual HAP emissions, in pounds or tons. This

41Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

shall include the information for the current month and the preceding eleven calendar months. For the first twelve calendar months of operation following issuance of the permit, this shall be a cumulative total for all months since the issuance of the PTI; and,

g. the updated rolling, 12-month summation for the total combined HAP emissions, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months. For the first twelve calendar months of operation following issuance of the permit, this shall be a cumulative total for all months since the issuance of the PTI.

D. Reporting Requirements

1. The permittee shall submit a signed statement indicating whether:

a. the required continuous monitoring system calibration, span, and drift checks or other periodic audits have or have not been performed as specified;

b. the data used to show compliance was or was not obtained in accordance with approved methods and procedures of 40 CFR Part 60 and is representative of plant performance;

c. the minimum data requirements have or have not been met; or, the minimum data requirements have not been met for errors that were unavoidable; and,

d. compliance with the standards has or has not been achieved during the reporting period.

2. Certification

a. Prior to the installation of the continuous NOxand SO2 monitoring systems, the permittee shall submit information detailing the proposed location of the sampling site in accordance with the siting

42Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

requirements in 40 CFR Part 60, Appendix B, Performance Specification 2 for approval by the Ohio EPA, Central Office; and,

b. Prior to the installation of the continuous O2 or CO2 monitoring system, the permittee shall submit information detailing the proposed location of the sampling site in accordance with the siting requirements in 40 CFR Part 60, Appendix B, Performance Specification 3 for approval by the Ohio EPA, Central Office.

3. Pursuant to OAC rules 3745-15-04, 3745-35-02, and ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts 60.7 and 60.13(h), the permittee shall submit reports within 30 days following the end of each calendar quarter to the Hamilton County Dept. of Env. Services documenting the date, commencement and completion times, duration, magnitude, reason (if known), and corrective actions taken (if any), of all instances of NOx and/or SO2 values in excess of the applicable limits specified in 40 CFR Part 60, Subpart Da, 40 CFR Part 76 or any limitations specified in the terms and conditions or Air Emission Summary section of this permit. These reports shall also contain the total Nox and SO2 emissions for the calendar quarter (in tons).

The permittee shall submit reports within 30 days following the end of each calendar quarter to the Hamilton County Dept. of Env. Services documenting any continuous NOx and/or SO2 monitoring system downtime while the emissions unit was on line (date, time, duration and reason) along with any corrective action(s) taken.

The permittee shall provide the emissions unit operating time during the reporting period and the date, time, reason and corrective action(s) taken for each time period of emissions unit and control equipment malfunctions.

The total operating time of the emissions unit and the

43Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

total operating time of the analyzer while the emissions

unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement to that effect along with the emissions unit operating time during the reporting period and the date, time, reason, and corrective action(s) taken for each time period of emissions unit, control equipment, and/or monitoring system malfunctions. The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line also shall be included in the quarterly report. These quarterly excess emission reports shall be submitted by January 30, April 30, July 30, and October 30 of each year and shall address the data obtained during the previous calendar quarter.

4. Pursuant to 40 CFR Parts 60.7 and 60.13(h), the permittee shall submit reports within 30 days following the end of each calendar quarter to the Hamilton County Dept. of Env. Services documenting all instances of continuous O2 or CO2 monitoring system downtime while the emissions

unit was on line (date, time, duration and reason) along with any corrective action(s) taken.

The permittee shall provide the emissions unit operating time during the reporting period and the date, time, reason and corrective action(s) taken for each time period of emissions unit malfunctions. The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line shall be included in the quarterly report.

These quarterly reports shall be submitted by January 30, April 30, July 30, and October 30 of each year and shall address the data obtained during the previous calendar quarter.

5. The permittee shall submit all applicable reports in accordance with the requirements of 40 CFR Part 60, Section 60.49a(b), (c) and (d).

6. The permittee shall submit monthly summaries of the actual heat content (Btu/cf) for natural gas and blast

44Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

furnace gas and the total quantity (MMcf) of each fuel burned for each calendar quarter.

7. The permittee shall notify the Hamilton County Department of Environmental Services of any exceedance of the HAP emissions limitations set forth in term A.4. The permittee shall submit annual reports which identify all exceedances of these limitations, as well as the corrective actions that were taken to achieve compliance. These reports shall be submitted by January 31 of each year. If no exceedances occurred during the reporting period then a report is required stating so.

8. The permittee shall submit annual reports of emissions. The permittee may elect to submit Title V emissions fee reports in lieu of annual reports for those emissions required by the Title V emissions fee regulation. These reports shall be submitted by January 31 of each year.

E. Compliance Methods/Testing Requirements

Compliance with the emission limitation(s) in the Air Emission Summary section of this permit shall be determined in accordance with the following method(s):

1. The permittee shall conduct, or have conducted, an initial performance emission test for this emissions unit in accordance with the following requirements:

a. The emission testing shall be conducted in accordance with the requirements of 40 CFR Part 60, Section 60.8 and 40 CFR Part 60, Section 60.48a, if applicable.

2. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rates for particulate matter, SO2, Nox and CO.

3. The following test method(s) shall be employed to demonstrate compliance with the allowable mass emission rate(s): for particulate, Method 5 of 40 CFR Part 60, Appendix A, or as provided in 40 CFR Part 60, Section 60.48a; for NOx, Method 7 of 40 CFR Part 60, Appendix A, or as provided in 40 CFR Part 60, Section 60.48a; for SO2, Method 6 of 40 CFR Part 60, Appendix A; for

45Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

CO, Method 10 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.

4. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, burning a mixture of natural gas and blast furnace gas, as proposed in Permit To Install application 14-4605, unless otherwise specified or approved by the Hamilton County Dept. of Env. Services.

5. Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test" notification to the Hamilton County Dept. of Env. Services. 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 Hamilton County Dept. of Env. Services refusal to accept the results of the emission test(s).

Personnel from the Hamilton County Dept. of Env. Services 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 Hamilton County Dept. of Env. Services 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 Hamilton County Dept. of Env. Services.

6. Within 60 days of startup of this emissions unit, the permittee shall conduct certification tests of the continuous SO2, NOx and O2 or CO2 monitoring systems pursuant to ORC section 3704.03(I) and 40 CFR Part 60, Appendix B, Performance Specification 2 and 3, where

46Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

applicable, and/or 40 CFR Part 75. Personnel from the Hamilton County Dept. of Env. Services shall be notified 30 days prior to initiation of the applicable tests and shall be permitted to examine equipment and witness the certification tests.

In accordance with OAC rule 3745-15-04, all copies of the test results shall be submitted to the Hamilton County Dept. of Env. Services within 30 days after the test is completed. Copies of the test results shall be sent to the Hamilton County Dept. of Env. Services and the Ohio EPA, Central Office. Certification of the continuous NOx, SO2 and O2 or CO2 monitoring systems shall be granted upon determination by the Ohio EPA, Central Office that the systems meets all requirements of ORC section 3704.03(I) and 40 CFR Part 60, Appendix B, Performance Specification 2 and 3, respectively, and/or 40 CFR Part 75.

7. Compliance with the lbs NOx/MMBtu emissions limitation constitutes compliance with the percent reduction requirements under 40 CFR Part 60, Section 60.44a(a)(2). Compliance with this NOx emission limitation shall be determined by the requirements of 40 CFR Part 60, Section 60.48a(d) [CEM].

8. Compliance with the lbs PM/MMBtu emissions limitation constitutes compliance with the percent reduction requirements under 40 CFR Part 60, Section 60.42a(a)(2) and (3). Compliance with this PM emission limitation shall be determined by the requirements of 40 CFR Part 60, Section 60.48a(b).

9. Except as otherwise specified in 40 CFR Part 60, Subpart Da, compliance with the lbs/MMBtu emissions limitations for SO2 shall be determined by the SO2continuous emission monitor or approved alternative monitoring methods determined under 40 CFR Part 60, Section 60.13(i).

10. Compliance with the TPY emissions limitations for particulates, CO and VOC shall be determined by multiplying the emission factors, in lb/MMcf, found in the Agency’s emission calculations for this emissions unit, in Permit to Install(PTI) 14-4605, by the monthly

47Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

volume of fuel burned, for each fuel; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

11. Compliance with the SO2 TPY emissions limitation shall be determined by adding the SO2 emissions rate for each day of the calendar month as determined by the SO2 CEM or approved alternative methods; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

12. Compliance with the NOx TPY emissions limitation shall be determined by adding the NOx emissions rate for each day of the calendar month, as determined by the NOxCEM; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

13. Compliance with the visible particulate emissions limitation in A.1 of this permit, for this emissions unit, shall be determined by 40 CFR Part 60, Method 9, Appendix A and the procedures in 40 CFR Part 60, Section 60.11.

14. Compliance with the HAP emission limitations in A.4 shall be determined by the recordkeeping in C.9.

F. Miscellaneous Requirements

1. The PM and NOx emissions limitations in A.3 of this permit, for this emissions unit, apply at all times except during periods of startup, shutdown, or malfunction.

2. The SO2 emissions limitations in A.3 of this permit, for this emissions unit, apply at all times except during periods of startup, shutdown, or when both emergency conditions exist and the procedures under 40 CFR Part 60, Section 60.46a(d) are implemented.

3. The lb/MMBtu emission limitation(s) outlined are based upon the emissions unit’s PTE. Therefore, no lb/MMBturecords are required to demonstrate compliance with these limits, except as otherwise specified in E.7 through E.9 of this permit, for this emissions unit.

4. In accordance with 40 CFR Part 60, Section 60.13(i), the permittee may submit to the Administrator for approval a written application specifying an alternative to any CEM procedures or requirements.

48Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

III. Emissions Unit F021 - For Paved Roadways and Parking Areas

A. Applicable Emission Limitations and/or Control Requirements

1. The paved road segments and parking areas which are covered by this permit and which are subject to the requirements of PTI 14-4605 are listed in the sections below:

Paved parking areas and associated paved road segments:

approximate, one-way mileageidentification of road segment

Batteries A1, A2, B1 & B2 2.00Road

Batteries A1, A2, B1 & B2 0.10Parking Areas

2. 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 and sweeping with vacuum at sufficient treatment frequencies to ensure compliance. Nothing in this paragraph shall prohibit the permittee from employing other control measures to ensure compliance.

3. 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 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.

49Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

4. 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.

5. 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.

B. Operational Restrictions

1. None

C. Monitoring and/or Recordkeeping Requirements

1. Except as otherwise provided in this section, the permittee shall perform inspections of the paved roadways and parking areas in accordance with the following frequencies:

paved roadways minimum inspection frequency

Batteries A1, A2, B1 & B2 dailyRoad

paved parking areas minimum inspection frequency

Batteries A1, A2, B1 & B2 daily Parking

2. The purpose of the inspections is to determine the need for implementing the above-mentioned control measures specified in T&C A.2. 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 practical thereafter.

The permittee may, upon receipt of written approval from the Hamilton County Dept. of Env. Services, modify the above-mentioned inspection frequencies if operating experience indicates that less frequent inspections

50Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

would be sufficient to ensure compliance with the previous-mentioned applicable requirements.

3. The permittee shall maintain records of the following information:

a. 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;

b. the date of each inspection where it was determined by the permittee that it was necessary to implement the control measures;

c. the dates the control measures were implemented; and,

d. 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, or when the roadways and/or parking areas were sufficiently clean and not require control measures.

The information required in C.3.d. shall be updated on a calendar quarter basis within 30 days after the end of each calendar quarter.

D. Reporting Requirements

1. The permittee shall submit deviation reports that identify any of the following occurrences:

a. 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,

b. each instance when a control measure, that was to be implemented as a result of an inspection, was not implemented.

51Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

E. Testing Requirements

1. 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.

F. Miscellaneous Requirements

1. None

IV. Emissions Unit F023 - For Coal Handling

A. Applicable Emission Limitations and/or Control Requirements

1. Visible particulate emissions from this emissions unit shall not exceed 20% percent opacity, as a three-minute average.

2. The emissions limitations for this emissions unit are identified in the Air Emissions Summary page of this permit.

B. Operational Restrictions

1. The maximum annual wet coal usage rate for this emissions unit shall not exceed 1,723,900 tons per year, based upon a rolling, 12-month summation of the wet coal usage rates.

To ensure enforceability during the first 12 calendar months of operation following the issuance of this permit, the permittee shall not exceed the wet coal usage levels specified in the following table:

Maximum AllowableMonth Cumulative Wet Coal Usage (Tons)

1 861,950

52Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

1-2 861,9501-3 861,9501-4 861,9501-5 861,9501-6 861,9501-7 1,005,6081-8 1,149,2671-9 1,292,9251-10 1,436,5831-11 1,580,2411-12 1,723,900

After the first 12 calendar months of operation following the issuance of this permit, compliance with the annual wet coal usage rate limitation shall be based upon a rolling, 12-month summation of the wet coal usage rates.

2. In accordance with the requirements of paragraph (B) of Ohio Administrative Code (OAC) rule 3745-17-08, OAC rule 3745-17-07 and paragraph (A)(3) of OAC rule 3745-31-05, the permittee shall operate and maintain, or have operated and maintained, a wet suppression system in order to minimize or eliminate visible emissions of fugitive dust into the ambient air.

3. In accordance with the requirements of paragraph (B) of Ohio Administrative Code (OAC) rule 3745-17-08, OAC rule 3745-17-07 and paragraph (A)(3) of OAC rule 3745-31-05, the permittee shall employ and maintain total enclosure of each conveyor transfer point and, at a minimum, partial enclosure of each conveyor, in order to minimize or eliminate visible emissions of fugitive dust into the ambient air.

C. Monitoring and Recordkeeping Requirements

1. The permittee shall maintain monthly records of the following information:

a. the wet coal usage rate for each month, in tons; and,

b. beginning after the first 12 calendar months of operation following the issuance of this permit, the rolling, 12-month summation of the wet coal usage rates.

Also, during the first 12 calendar months of operation following issuance of this permit, the permittee shall record the cumulative wet coal usage rate, in tons, for

53Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

each calendar month.

D. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify all exceedances of the rolling, 12-month coal usage rate limitation and, for the first 12 calendar months of operation following the issuance of this permit, all exceedances of the maximum allowable cumulative coal usage levels.

E. Compliance Methods/Testing Requirements

1. Compliance with the visible emissions limitation in Term A.1 shall be determined by the methods outlined in Ohio Administrative Code (OAC) rule 3745-17-03(B)(3).

2. Compliance with the emission limitations in the Air Emission Summary page of PTI 14-4605 shall be determined in accordance with the following method(s):

a. compliance with the lbs/hr emissions limitation for PM shall be determined by multiplying the uncontrolled emission factor of 0.00176 lb PM/ton of wet coal transferred by the tons of wet coal transferred/hour multiplied by (1 - wet suppression control efficiency) times (1 -enclosure control efficiency), for each emissions point;

b. compliance with the lbs/hr emissions limitation for PM10 shall be determined by multiplying the uncontrolled emission factor of 0.000831 lb PM10/ton of wet coal transferred by the tons of wet coal transferred/hour multiplied by (1 - wet suppression control efficiency) times (1 -enclosure control efficiency), for each emissions point;

c. compliance with the TPY emissions limitation for PM shall be determined by multiplying the uncontrolled emission factor of 0.00176 lb PM/ton of wet coal transferred by the tons of wet coal transferred/year multiplied by (1 - wet suppression control efficiency) times (1 -

54Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

enclosure control efficiency), for each emissions point; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months; and,

d. compliance with the TPY emissions limitation for PM10 shall be determined by multiplying the uncontrolled emission factor of 0.000831 lb PM10/ton of wet coal transferred by the tons of wet coal transferred/year multiplied by (1 - wet suppression control efficiency) times (1 -enclosure control efficiency), for each emissions point; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

F. Miscellaneous Requirements

1. The hourly emission limitations outlined are based upon the emissions unit’s PTE. Therefore, no hourly records are required to demonstrate compliance with these limits.

V. Emissions Unit P091 - For Quench Tower for Batteries A1 and A2

A. Applicable Emission Limitations and/or Control Requirements

1. Visible particulate emissions from this emissions unit shall not exceed 20% percent opacity, as a six-minute average.

2. For lbs/hr and TPY emissions limitations for this emissions unit, see the Air Emissions Summary page of this permit.

3. The concentration of total dissolved solids of the water employed to quench coke in this emissions unit shall not exceed 1150 mg/L of water.

B. Operational Restrictions

1. The permittee shall operate and maintain an interior baffle system for this emissions unit. The interior

55Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

baffle systems shall be designed and maintained in accordance with good engineering practice and which provides coverage of not less than ninety-five per cent of the cross-sectional area of the tower.

2. The permittee shall employ clean quench water with a total dissolved solids concentration of equal to or less than 1150 mg/L of water during the coke quenching operation.

3. The permittee shall not employ direct by-product contact water in the quench tower.

C. Monitoring and Recordkeeping Requirements

1. The permittee shall collect a monthly sample of the water employed in this emissions unit which shall be analyzed for concentration of total dissolved solids, in mg/L.

D. Reporting Requirements

1. The permittee shall notify the Director (Hamilton County Dept. of Env. Services) in writing of any monthly record showing that the total dissolved solids concentration exceeds the applicable limitation. The notification shall include a copy of such record and shall be sent to the Director (Hamilton County Dept. of Env. Services) within 30 days after the exceedance occurs.

2. The permittee shall submit annual reports of emissions. The permittee may elect to submit Title V emissions fee reports in lieu of annual reports for those emissions required by the Title V emissions fee regulation. These reports shall be submitted by January 31 of each year.

E. Compliance Methods/Testing Requirements

1. Compliance with the visible emissions limitations shall be determined by the methods outlined in Ohio Administrative Code (OAC) rule 3745-17-03(B)(1).

2. Compliance with the emission limitations in the Air Emission Summary section of PTI 14-4605 shall be determined in accordance with the following method(s):

a. compliance with the lbs/hr emissions limitations for PM and PM10 shall be determined by multiplying the emission factor equation found in the Agency’s

56Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

PTI 14-4605 emission calculations, by the tons of wet coal charged per hour; and,

b. compliance with the TPY emissions limitations for PM and PM10 shall be determined by multiplying the emission factor equation found in the Agency’s PTI 14-4605 emission calculations, by the combined tons of wet coal charged per month at emissions units P920 and P921; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

3. Compliance with the total dissolved solids concentration limitation shall be determined by the methods outlined in OAC rule 3745-17-03(B)(10)(c).

F. Miscellaneous Requirements

1. The hourly emission limitation(s) outlined are based upon the emissions unit’s PTE. Therefore, no hourly records are required to demonstrate compliance with these limits.

57Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

VI. Emissions Unit P092 - For Quench Tower for Batteries B1 and B2

A. Applicable Emission Limitations and/or Control Requirements

1. Visible particulate emissions from this emissions unit shall not exceed 20% percent opacity, as a six-minute average.

2. For lbs/hr and TPY emissions limitations for this emissions unit, see the Air Emissions Summary page of this permit.

3. The concentration of total dissolved solids of the water employed to quench coke in this emissions unit shall not exceed 1150 mg/L of water.

B. Operational Restrictions

1. The permittee shall operate and maintain an interior baffle system for this emissions unit. The interior baffle systems shall be designed and maintained in accordance with good engineering practice and which provides coverage of not less than ninety-five per cent of the cross-sectional area of the tower.

2. The permittee shall employ clean quench water with a total dissolved solids concentration of equal to or less than 1150 mg/L of water during the coke quenching operation.

3. The permittee shall not employ direct by-product contact water in the quench tower.

C. Monitoring and Recordkeeping Requirements

1. The permittee shall collect a monthly sample of the water employed in this emissions unit which shall be analyzed for concentration of total dissolved solids, in mg/L.

D. Reporting Requirements

1. The permittee shall notify the Director (Hamilton County Dept. of Env. Services) in writing of any

58Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

monthly record showing that the total dissolved solids concentration exceeds the applicable limitation. The notification shall include a copy of such record and shall be sent to the Director (Hamilton County Dept. of Env. Services) within 30 days after the exceedance occurs.

59Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

2. The permittee shall submit annual reports of emissions. The permittee may elect to submit Title V emissions fee reports in lieu of annual reports for those emissions required by the Title V emissions fee regulation. These reports shall be submitted by January 31 of each year.

E. Compliance Methods/Testing Requirements

1. Compliance with the visible emissions limitations shall be determined by the methods outlined in Ohio Administrative Code (OAC) rule 3745-17-03(B)(1).

2. Compliance with the emission limitations in the Air Emission Summary section of PTI 14-4605 shall be determined in accordance with the following method(s):

a. compliance with the lbs/hr emissions limitations for PM and PM10 shall be determined by multiplying the emission factor equation found in the Agency’s PTI 14-4605 emission calculations, by the tons of wet coal charged per hour; and,

b. compliance with the TPY emissions limitations for PM and PM10 shall be determined by multiplying the emission factor equation found in the Agency’s PTI 14-4605 emission calculations, by the combined tons of wet coal charged per month at emissions units P920 and P921; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

3. Compliance with the total dissolved solids concentration limitation shall be determined by the methods outlined in OAC rule 3745-17-03(B)(10)(c).

F. Miscellaneous Requirements

1. The hourly emission limitation(s) outlined are based upon the emissions unit’s PTE. Therefore, no hourly records are required to demonstrate compliance with these limits.

VII. Emissions Unit P093 - For Cooling Tower

A. Applicable Emission Limitations and/or Control Requirements

60Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

1. Visible particulate emissions from this emissions unit shall not exceed 20% percent opacity, as a six-minute average.

2. For lbs/hr and TPY emissions limitations for this emissions unit, see the Air Emissions Summary page of this permit.

B. Operational Restrictions

1. None.

C. Monitoring and Recordkeeping Requirements

1. None.

D. Reporting Requirements

1. The permittee shall submit annual reports of emissions. The permittee may elect to submit Title V emissions fee reports in lieu of annual reports for those emissions required by the Title V emissions fee regulation. These reports shall be submitted by January 31 of each year.

E. Compliance Methods/Testing Requirements

1. Compliance with the visible emissions limitations shall be determined by the methods outlined in Ohio Administrative Code (OAC) rule 3745-17-03(B)(1).

2. Compliance with the emission limitations in the Air Emission Summary section of PTI 14-4605 shall be determined in accordance with the following method(s):

a. compliance with the lbs/hr emissions limitations for PM and PM10 shall be determined by multiplying the emission factor found in the Agency’s PTI 14-4605 emission calculations, by the gallons of water to the cooling tower per hour; and,

b. compliance with the TPY emissions limitations for PM and PM10 shall be determined by multiplying the

61Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

emission factor found in the Agency’s PTI 14-4605 emission calculations, by the gallons of water to the cooling tower per year.

F. Miscellaneous Requirements

1. The hourly emission limitation(s) outlined are based upon the emissions unit’s PTE. Therefore, no hourly records are required to demonstrate compliance with these limits.

VIII. Emissions Unit P920 - For 96 Oven Nonrecovery Coke Batteries A1 and A2

A. Applicable Emission Limitations and/or Control Requirements

1. Each oven or the common duct tunnel shall be continuously operated under negative pressure, as determined by term and condition C.6.

2. No visible emissions shall be permitted from the waste gas common duct or its associated piping.

3. Except as otherwise provided in these terms and conditions, visible particulate emissions of fugitive dust from this emissions unit shall not exceed 20% percent opacity, as a three-minute average.

4. Except as otherwise provided in these terms and conditions, visible particulate emissions from any stack shall not exceed 20% percent opacity, as a six-minute average.

5. Visible particulate emissions from the waste gas exhaust stack(s) shall not exceed 10% percent opacity, as a six-minute average.

6. The visible emissions from the topside port lids and the offtake systems, if applicable, shall not exceed 0.0 percent.

7. There shall be no visible particulate emissions from any charging operation except for a period of time not to exceed 11 seconds per charge. Visible particulate emissions captured by the control system shall not be counted towards the 11 second limit.

8. Visible particulate emissions from any pushing

62Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

operation shall not exceed an average of 20 percent opacity read above the battery top. For purposes of this paragraph, the duration of a pushing operation shall commence with the moving (or pushing) of the coke mass from an oven and shall conclude once all of the coke is in the quench car.

9. Visible particulate emissions from the quench car travel shall not exceed 10 percent opacity read above the battery top. For purposes of this paragraph, the quench car travel will begin with the movement of the car and end once the quench car reaches the quench tower.

63Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

10. The emissions of PM from emissions units P920 and P921 shall not exceed the following mass emission rate allowables:

a. the emissions of PM from the coke oven pushing operation shall not exceed 33.22 lbs PM/hr per emissions unit. The combined emissions of PM from emissions units P920 and P921 shall not exceed 49.56 TPY of PM, based on a rolling, 12-month summation of the PM emissions;

b. the fugitive emissions of PM from the coke oven charging operation shall not exceed 12.02 lbs PM/hr per emissions unit. The combined fugitive emissions of PM from emissions units P920 and P921 shall not exceed 17.92 TPY of PM, based on a rolling, 12-month summation of the PM emissions;

c. the individual emissions of PM from the baghouse employed for the control of PM emissions from the coke oven battery waste gas exhaust for emissions units P920 and P921 shall not exceed 0.015 gr PM/dscf, 23.17 lbs PM/hr per emissions unit. The combined emissions of PM from emissions units P920 and P921 shall not exceed 202.30 TPY of PM, based on a rolling, 12-month summation of the PM emissions; and,

d. the emissions of PM from the baghouse employed for the control of PM emissions from the coke oven charging operation shall not exceed 0.005 gr PM/dscf and 0.86 lb PM/hr per emissions unit. The combined emissions of PM from emissions units P920 and P921 shall not exceed 3.76 TPY of PM, based on a rolling, 12-month summation of the PM emissions.

11. The emissions of PM10 from emissions units P920 and P921 shall not exceed the following mass emission rate allowables:

a. the emissions of PM10 from the coke oven pushing operation shall not exceed 14.45 lbs PM10/hr per emissions unit. The combined emissions of PM10from emissions units P920 and P921 shall not exceed 21.56 TPY of PM10, based on a rolling,

64Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

12-month summation of the PM10 emissions;

b. the fugitive emissions of PM10 from the coke oven charging operation shall not exceed 12.02 lbs PM10/hr per emissions unit. The combined fugitive emissions of PM10 from emissions units P920 and P921 shall not exceed 17.92 TPY of PM10, based on a rolling, 12-month summation of the PM10emissions;

c. the individual emissions of PM10 from the baghouse employed for the control of PM10 emissions from the coke oven battery waste gas exhaust for emissions units P920 and P921 shall not exceed 0.01 gr PM10/dscf, 15.44 lbs PM10/hr per emissions unit. The combined fugitive emissions of PM from emissions units P920 and P921 shall not exceed 134.8 TPY of PM10, based on a rolling, 12-month summation of the PM10 emissions; and,

d. the emissions of PM10 from the baghouse employed for the control of PM10 emissions from the coke charging operation shall not exceed 0.005 gr PM10/dscf and 0.86 lb PM10/hr per emissions unit. The combined fugitive emissions of PM from emissions units P920 and P921 shall not exceed 3.76 TPY of PM10, based on a rolling, 12-month summation of the PM emissions.

12. The emissions of SO2 from emissions units P920 and P921 shall not exceed the following mass emission rate allowables:

a. the emissions of SO2 from the coke oven pushing operation shall not exceed 38.13 lbs SO2/hr per emissions unit. The combined emissions of SO2 from emissions units P920 and P921 shall not exceed 56.88 TPY of SO2, based on a rolling, 12-month summation of the SO2 emissions;

b. the emissions of SO2 from the coke oven charging operation shall not exceed 0.17 lb SO2/hr per emissions unit. The combined emissions of SO2 from emissions units P920 and P921 shall not exceed 0.26 TPY of SO2, based on a rolling, 12-month summation of the SO2 emissions;

65Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

c. the maximum combined annual SO2 emission rate from the coke oven battery waste gas exhaust for emissions units P920 and P921 shall not exceed 861.96 TPY, based upon a rolling, 12-month summation of the SO2 emissions.

To ensure enforceability during the first 12 calendar months of operation, following the startup of the lime spray dryer, the permittee shall not

exceed the annual SO2 emission rate limitation specified in the following table:

Maximum AllowableMonth SO2 Emission Rate (tons)

1 4311-2 4311-3 4311-4 4311-5 4311-6 4311-7 502.811-8 574.641-9 646.471-10 718.301-11 790.131-12 861.96

After the first 12 calendar months of operation following the startup of the lime spray dryer, compliance with the annual SO2 emission rate limitation shall be based upon a rolling, 12-month summation of the SO2 emission rates; and,

d. the individual emissions of SO2 from the lime spray dryer employed for the control of SO2emissions from the coke oven battery waste gas exhaust for emissions units P920 and P921 shall not exceed 577.8 lbs SO2/hr.

13. The emissions of NOx from emissions units P920 and P921 shall not exceed the following mass emission rate

66Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

allowables:

a. the emissions of NOx from the coke oven pushing operation shall not exceed 9.24 lbs NOx/hr per emissions unit. The combined emissions of NOx from emissions units P920 and P921 shall not exceed 13.8 TPY of NOx, based on a rolling, 12-month summation of the NOx emissions;

b. the emissions of NOx from the coke oven charging operation shall not exceed 0.017 lb NOx/hr per emissions unit. The combined emissions of NOx from emissions units P920 and P921 shall not exceed 0.026 TPY of NOx, based on a rolling, 12-month summation of the NOx emissions; and,

c. the individual emissions of NOx from the coke oven battery waste gas exhaust for emissions units P920 and P921 shall not exceed 254.23 lbs NOx/hr per emissions unit. The combined emissions of NOx from emissions units P920 and P921 shall not exceed 758.52 TPY of NOx, based on a rolling, 12-month summation of the NOx emissions.

14. The emissions of CO from emissions units P920 and P921 shall not exceed the following mass emission rate allowables:

a. the emissions of CO from the coke oven pushing operation shall not exceed 10.23 lbs CO/hr per emissions unit. The combined emissions of CO from emissions units P920 and P921 shall not exceed 15.26 TPY of CO, based on a rolling, 12-month summation of the CO emissions;

b. the emissions of CO from the coke oven charging operation shall not exceed 0.14 lb CO/hr per emissions unit. The combined emissions of CO from emissions units P920 and P921 shall not exceed 0.22 TPY of CO, based on a rolling, 12-month summation of the CO emissions; and,

c. the individual emissions of CO from the coke oven battery waste gas exhaust for emissions units P920

67Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

and P921 shall not exceed 47.9 lbs CO/hr per emissions unit. The combined emissions of CO from emissions units P920 and P921 shall not exceed 142.92 TPY of CO, based on a rolling, 12-month summation of the CO emissions.

15. The emissions of VOC from emissions units P920 and P921 shall not exceed the following mass emission rate allowables:

a. the emissions of VOC from the coke oven pushing operation shall not exceed 115.56 lbs VOC/hr per emissions unit. The combined emissions of VOC from emissions units P920 and P921 shall not exceed 172.4 TPY of VOC, based on a rolling, 12-month summation of the VOC emissions;

b. the emissions of VOC from the coke oven charging operation shall not exceed 1.04 lbs VOC/hr per emissions unit. The combined emissions of VOC from

emissions units P920 and P921 shall not exceed 1.56 TPY of VOC, based on a rolling, 12-month summation of the VOC emissions; and,

c. the individual emissions of VOC from the coke oven battery waste gas exhaust for emissions units P920 and P921 shall not exceed 12.48 lbs VOC/hr per emissions unit. The combined emissions of VOC from emissions units P920 and P921 shall not exceed 37.24 TPY of VOC, based on a rolling, 12-month summation of the VOC emissions.

16. The individual emissions of lead from the coke oven battery waste gas exhaust for emissions units P920 and P921 shall not exceed 0.10 lb lead/hr per emissions unit. The combined emissions of lead from emissions units P920 and P921 shall not exceed 0.29 TPY of lead.

B. Operational Restrictions

1. The maximum annual wet coal usage rate for emissions units P920 and P921, combined shall not exceed 1,723,900 tons per year, based upon a rolling, 12-month summation of the wet coal usage rates.

To ensure enforceability during the first 12 calendar months of operation following the issuance of this permit, the permittee shall not exceed the wet coal usage levels specified in the following table:

68Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

Maximum AllowableMonth Cumulative Wet Coal Usage (Tons)

1 861,9501-2 861,9501-3 861,9501-4 861,9501-5 861,9501-6 861,9501-7 1,005,6081-8 1,149,2671-9 1,292,9251-10 1,436,5831-11 1,580,2411-12 1,723,900

After the first 12 calendar months of operation following the issuance of this permit, compliance with the annual wet coal usage rate limitation shall be based upon a rolling, 12-month summation of the wet coal usage rates.

2. The permittee shall install, operate and maintain a removable cover on the coke receiving quench car for the collection of emissions in a manner consistent with good air pollution control practices for minimizing emissions from the pushing operation. The removable cover shall be in a position which completely covers the top of the coke receiving quench car, in a manner consistent with good engineering practices, prior to the coke pushing operation.

3. The permittee shall install, operate and maintain a baghouse for the control of particulate matter emissions from the coke oven battery waste gas exhaust for emissions units P920 and P921. The pressure drop across the baghouse employed to control emissions from the coke oven battery waste gas exhaust shall be maintained within the range established during the most recent emission test that demonstrated compliance, in inches of water, at all times during operation of the emissions units, except as otherwise specified in term and condition B.13.

69Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

4. The permittee shall install, operate and maintain a collection system vented to a baghouse for minimizing emissions from the charging operation or an alternative emission standard as promulgated by the United States Environmental Protection Agency.

The pressure drop across the baghouse employed to control charging emissions shall be maintained within the range specified and/or recommended by the manufacturer, in inches of water, at all times during operation of the emissions unit.

5. The permittee shall operate and maintain equipment to continuously monitor and record SO2 emissions from the lime spray dryer in units of ppm. Such continuous monitoring and recording equipment shall comply with the requirements specified in 40 CFR Part 60, Section 60.13.

6. The permittee shall prepare and submit to the Administrator a written emissions control work practice plan for each coke oven battery, in accordance with 40 CFR Part 63, Subpart L, §63.306.

7. During any period of time that the permittee is required to implement the provisions of a plan for a particular emission point, the failure to implement one or more obligations under the plan and/or any record keeping requirements under §63.311(f)(4) for the emission point during a particular day is a single violation.

8. The permittee shall implement the provisions of the coke oven emission control work practice plan in accordance with §63.306(c).

9. Revisions to the work practice emission control plan are governed by the provisions of §63.306(a)(2) and §63.306(d).

10. At all times including periods of startup, shutdown, and malfunction, the permittee shall operate and maintain the coke oven battery and its pollution control equipment required under 40 CFR Part 63, Subpart L, in a manner consistent with good air pollution control practices for minimizing emissions to the levels required by any applicable performance standards under 40 CFR Part 63, Subpart L. Failure to adhere to the requirement of this paragraph shall not constitute a separate violation if a violation of an applicable performance or work practice standard has

70Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

also occurred.

11. The permittee of a coke oven battery shall develop and implement a written startup, shutdown, and malfunction plan, in accordance with §63.310(b)and §63.310(g).

12. The Administrator may require reasonable revisions to a startup, shutdown, and malfunction plan, in accordance with the provisions in §63.310(h).

13. If the owner or operator demonstrates to the satisfaction of the Administrator that a startup, shutdown, or malfunction has occurred, then an observation occurring during such startup, shutdown, or malfunction shall not:

a. constitute a violation of relevant requirements of 40 CFR Part 63, Subpart L;

b. be used in any compliance determination under §63.309; or,

c. be considered for purposes of §63.306, until the Administrator has resolved the claim that a startup, shutdown, or malfunction has occurred. If the Administrator determines that a startup, shutdown, or malfunction has not occurred, such observations may be used for purposes of §63.306, regardless of whether the permittee further contests such determination. The permittee’s receipt of written notification from the Administrator that a startup, shutdown, or malfunction has not occurred will serve, where applicable under §63.306, as written notification from the certified observer that an exceedance has occurred.

14. In order to ensure emission limits for the waste gas exhaust are not exceeded, the permittee shall operate and maintain common duct temperatures in a range established during the most recent performance test which demonstrated compliance.

The permittee shall also operate and maintain the common battery tunnel ducts under a negative pressure.

71Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

The instrument used for determining the pressure shall be subject to approval by the Ohio EPA and shall be calibrated at least once every six (6) months.

15. The lime spray dryer and baghouse associated with the battery waste gas exhaust shall begin operation within forty (40) days after start-up of the first coke battery.

C. Monitoring and Recordkeeping Requirements

1. The permittee shall maintain monthly records for emissions unit P920 and P921 of the following information:

a. the total combined wet coal usage rate, in tons, for each month; and,

b. beginning after the first 12 calendar months of operation following the issuance of this permit, the rolling, 12-month summation of the total combined wet coal usage rates.

Also, during the first 12 calendar months of operation following issuance of this permit, the permittee shall record the cumulative wet coal usage rate, in tons, for each calendar month.

2. The permittee shall maintain records of the emissions from the lime spray dryer for emissions unit P920 and P921 of the following information:

a. the hourly SO2 emission rate;

b. the total monthly SO2 emission rate for each month;

c. beginning after the first 12 calendar months of operation, following the startup of the lime spray

dryer, the rolling, 12-month summation of the SO2emission rates; and,

d. also, during the first 12 calendar months of

72Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

operation following issuance of this permit, the permittee shall record the cumulative SO2 emission rate, in tons, for each calendar month.

3. The permittee shall maintain records of all data obtained by the continuous SO2 monitoring system including, but not limited to, parts per million SO2 on a 1-hour basis, results of daily zero/span calibration checks, and magnitude of manual calibration adjustments.

4. Within 180 days of the effective date of this permit, the permittee shall develop a written quality assurance/quality control plan for the continuous SO2monitoring system designed to ensure continuous valid and representative readings of SO2.

The plan shall follow the requirements of 40 CFR Part 60, Appendix F. The quality assurance/quality control plan and a logbook dedicated to the continuous SO2monitoring system must be kept on site and available for inspection during regular office hours.

5. The permittee shall monitor and record the temperature of the common duct tunnel on a once per shift basis.

6. The permittee shall properly install, operate, and maintain equipment to monitor the pressure drop across the coke oven battery waste gas exhaust baghouse, at all times during operation of this emissions unit.

The monitoring equipment shall be installed, calibrated, operated, and maintained in accordance with the manufacturer’s recommendations, instructions, and operating manual(s). The permittee shall record the pressure drop across the coke oven battery waste gas exhaust baghouse on a once per shift basis.

7. The permittee shall properly install, operate, and maintain equipment to monitor the pressure drop across the coke oven charging baghouse, at all times during operation of this emissions unit.

The monitoring equipment shall be installed, calibrated, operated, and maintained in accordance with the manufacturer’s recommendations, instructions, and operating manual(s). The permittee shall record the pressure drop across the coke oven charging baghouse on a once per shift basis.

8. The permittee shall monitor and record, once per day

73Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

for each day of operation, the pressure in each oven or in a common battery tunnel to ensure that the ovens are operated under a negative pressure.

The permittee shall maintain a log which includes the date of each oven or common battery tunnel duct pressure instrument calibration and the name of the personnel and company responsible for calibrating the instrumentation.

9. The permittee shall maintain files of all required information in a permanent form suitable for inspection at an onsite location for at least 1 year and must thereafter be accessible within 3 working days to the Administrator for a period of at least five years from the date of the monitoring sample, measurement, report or application.

Copies of the work practice plan developed under §63.306 and the startup, shutdown, and malfunction plan developed under §63.310 shall be kept onsite at all times. The permittee shall maintain the following information:

a. records of daily pressure monitoring, according to §63.303(b)(1)(ii);

b. records demonstrating the performance of work practice requirements according to §63.306(b)(7);

c. design characteristics of each emission control system for the capture and collection of charging emissions, as required by §63.303(b)(2);

d. a copy of the work practice plan required by §63.306 and any revision to the plan; and,

e. records required to be maintained and reports required to be filed with the Administrator under 40 CFR Part 63, Subpart L shall be made available in accordance with the requirements of this paragraph by the permittee to the authorized collective bargaining representative of the employees at a coke oven battery, for inspection and copying.

74Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

i. requests under this term and condition shall be submitted in writing, and shall identify the records or reports that are subject to the request with reasonable specificity;

ii. the permittee shall produce the reports for inspection and copying within a reasonable period of time, not to exceed 30 days. A reasonable fee may be charged for copying (except for the first copy of any document), which shall not exceed the copying fee charged by the Administrator under part 2 of the CFR, chapter 40;

iii. nothing in this term and condition shall require the production for inspection or copying of any portion of a document that contains trade secrets or confidential business information that the Administrator would be prohibited from disclosing to the public under part 2 of the CFR, chapter 40; and,

iv. the inspection or copying of a document under this term and condition shall not in any way affect any property right of the permittee in such document under laws for the protection of intellectual property, including the copyright laws.

10. The permittee shall maintain a record of internal reports which form the basis of each malfunction notification under Additional Special Term and Condition D.2.

11. To satisfy the requirements of §63.310 to develop a startup, shutdown, and malfunction plan, the permittee may use the standard operating procedures manual for the battery, provided the manual meets all the requirements for §63.310 and is made available for inspection at reasonable times when requested by the Administrator.

D. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify all exceedances of the rolling, 12-month coal usage rate limitation and, for the first 12 calendar months of operation following the issuance of this permit, all exceedances of the maximum allowable cumulative coal usage levels.

2. In order for the provisions of Additional Special Term

75Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

and Condition B.13 to apply with respect to the observation (or set of observations) for a particular day, notification of a startup, shutdown, or a malfunction shall be made by the owner or operator:

a. if practicable, to the certified observer if the observer is at the facility during the occurrence; or,

b. to the enforcement agency, in writing, within 24 hours of the occurrence first being documented by a company employee, and if the notification under term and condition D.2.(a) was not made, an explanation of why no such notification was made.

3. Within 14 days of the notification made under Additional Special Term and Condition D.2, or after a startup or shutdown, the permittee shall submit a written report to the applicable permitting authority that:

a. describes the time and circumstances of the startup, shutdown, or malfunction; and,

b. describes actions taken that might be considered inconsistent with the startup, shutdown, or malfunction plan.

4. The permittee shall submit annual reports that identify the actual monthly wet coal usage rates for each calendar month and the updated rolling, 12-month summation. These reports shall be submitted by January 30 of each year and shall cover the previous calendar year.

5. Pursuant to OAC rules 3745-15-04, 3745-35-02, and ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts 60.7 and 60.13(h), the permittee shall submit reports within 30 days following the end of each calendar quarter to the Hamilton County Dept. of Env. Services documenting the date, commencement and completion times, duration, magnitude, reason (if known), and corrective actions taken (if any), of all instances of SO2 values in excess of the applicable limits specified in OAC Chapter 3745-18, the monthly and/or annual SO2 emission

76Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

rate. These reports shall also contain the total SO2emissions for the calendar quarter (in tons).

The permittee shall submit reports within 30 days following the end of each calendar quarter to the Hamilton County Dept. of Env. Services documenting any continuous SO2 monitoring system downtime while the emissions unit was on line (date, time, duration and reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit operating time during the reporting period and the date, time, reason and corrective action(s) taken for each time period of emissions unit and control equipment malfunctions. The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line shall also be included in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement to that effect along with the emissions unit operating time during the reporting period and the date, time, reason, and corrective action(s) taken for each time period of emissions unit, control equipment, and/or monitoring system malfunctions.

The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line also shall be included in the quarterly report. These quarterly excess emission reports shall be submitted by January 30, April 30, July 30, and October 30 of each year and shall address the data obtained during the previous calendar quarter.

6. Pursuant to OAC rules 3745-15-04, 3745-35-02, and ORC sections 3704.03(I) and 3704.031, the permittee shall submit a summary of the excess emission report pursuant to 40 CFR Part 60.7. The summary shall be submitted to the Hamilton County Dept. of Env. Services within 30 days following the end of each calendar quarter in a manner prescribed by the Director.

7. The permittee shall submit pressure drop deviation (excursion) reports that identify that all periods of time during which the pressure drop across the coke

77Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

oven battery waste gas exhaust baghouse did not comply with the allowable range specified above.

8. The permittee shall submit pressure drop deviation (excursion) reports that identify that all periods of time during which the pressure drop across the coke oven charging baghouse did not comply with the allowable range specified above.

9. The permittee shall provide a written statement(s) to certify compliance to the Administrator within 45 days of the applicable compliance date for the emission limitations or requirements in 40 CFR Part 63, Subpart L. The permittee shall include the following information in the initial compliance certification:

a. statement, signed by the permittee, certifying that a written startup, shutdown, and malfunction plan has been prepared as required in §63.310.

10. The permittee shall provide written notification(s) to the Administrator of:

a. intention to construct a new coke oven battery (including reconstruction of an existing coke oven battery and construction of a greenfield coke oven battery), a brownfield coke oven battery, or a padup rebuild coke oven battery, including the anticipated date of startup.

11. The permittee shall include the following information

in the semiannual compliance certification:

a. certification, signed by the permittee, that a startup, shutdown, or malfunction event did not occur for a coke oven battery during the reporting period or that a startup, shutdown, and malfunction event did occur and a report was submitted according to the requirements in §63.310(e); and,

b. certification, signed by the permittee, that work practices were implemented if applicable under §63.306.

12. The permittee shall submit common tunnel duct temperature deviation (excursion) reports that identify all periods of time during which the temperature in the common tunnel duct fell out of the range determined during the first 60 days of maximum production and demonstrated by the most recent performance test which demonstrated compliance with the waste gas exhaust emission limitations. These reports shall include the

78Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

time of the temperature deviation, the duration of the exceedance and the corrective action taken.

13. The permittee shall submit oven pressure deviation(excursion) reports that identify all periods of time during which the oven pressure or the pressure in the common battery tunnel duct is no longer negative.

These reports shall include the time of the pressure deviation, the duration of the exceedance and the corrective action taken.

14. The permittee shall submit annual reports of emissions. The permittee may elect to submit Title V emissions fee reports in lieu of annual reports for those emissions required by the Title V emissions fee regulation. These reports shall be submitted by January 31 of each year.

E. Compliance Methods/Testing Requirements

1. Compliance with term and condition A.6 shall be determined by the procedures and requirements of Method 303 or 303A in appendix A of 40 CFR Part 63 and in accordance with §63.309(d)(1). For the purposes of determining compliance the visible emission reader does not have to be certified in Method 303.

2. Compliance with the fugitive visible particulate emissions limitations in Additional Special Term and Condition A.3 shall be determined by the methods outlined in the Ohio Administrative Code (OAC)rule 3745-17-03(B)(3).

3. Compliance with the visible particulate emissions limitations in A.4 and A.5 shall be determined by the methods outlined in OAC rule 3745-17-03(B)(1).

4. Compliance with visible particulate emission limitation in A.7 shall be determined by procedures 3.3 to 3.6 contained in Method 303 of 40 CFR Part 63, Appendix A. For the purposes of determining compliance the visible emission reader does not have to be certified in Method 303.

79Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

5. Compliance with the visible particulate emissions limitations in A.8 shall be determined by Method 9 of 40 CFR Part 60, Appendix A. The average opacity shall be determined by summing the opacity readings and dividing this sum by the number of observations during that pushing operation.

6. Compliance with the visible particulate emissions limitations in A.9 shall be determined by Method 9 of 40 CFR Part 60, Appendix A. The average opacity shall be determined by summing the opacity readings and dividing this sum by the number of observations during that quench car travel.

7. The permittee shall conduct, or have conducted, emission testing for the coke oven battery waste gas exhaust associated with this emissions unit in accordance with the following requirements:

a. the emission testing shall be conducted within 6 months after startup of this emissions unit;

b. the emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate for sulfur dioxide, nitrogen oxides, particulate, volatile organic compounds (VOC), carbon monoxide and lead;

c. the following test method(s) shall be employed to demonstrate compliance with the allowable mass emission rate(s): for sulfur dioxide, Method 6 of 40 CFR Part 60, Appendix A; for nitrogen oxides, Method 7 of 40 CFR Part 60, Appendix A; for particulate, Method 5 of 40 CFR Part 60, Appendix A; for VOC, Method 18 or Method 25/25A of 40 CFR Part 60, Appendix A (whichever is applicable); for carbon monoxide, Method 10 of 40 CFR Part 60, Appendix A; and for lead, Methods 12 or 29 of 40 CFR Part 60, Appendix A (whichever is applicable);. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA; and,

d. the test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless otherwise specified or approved by the Hamilton County Dept. of Env. Services.

Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test" notification to the Hamilton County Dept. of Env.

80Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

Services. 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 Hamilton County Dept. of Env. Services refusal to accept the results of the emission test(s).

Personnel from the Hamilton County Dept. of Env. Services 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 Hamilton County Dept. of Env. Services 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 Hamilton County Dept. of Env. Services.

8. Compliance with the lbs/hr emissions limitations for PM, PM10, SO2, NOx, CO, and VOC for the pushing operation shall be determined by multiplying the emission factor in lbs of pollutant/wet ton coal charged, as found in the Agency’s emissions calculations in PTI 14-4605 for this emissions unit, by the wet tons of coal charged per hour.

9. Compliance with the TPY emissions limitations for PM, PM10, SO2, NOx, CO, and VOC for the pushing operation shall be determined by multiplying the emission factor in lbs of pollutant/wet ton coal charged, as found in the Agency’s emissions calculations in PTI 14-4605 for this emissions unit, by the tons of wet coal charged per month; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar

81Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

months.

10. Compliance with the lbs/hr emissions limitations for PM, PM10, SO2, NOx, CO, and VOC for the charging operation shall be determined by multiplying the emission factor in lbs of pollutant/wet ton coal charged, as found in the Agency’s emissions calculations in PTI 14-4605 for this emissions unit, by the wet tons of coal charged per hour.

11. Compliance with the TPY emissions limitations for PM, PM10, SO2, NOx, CO, and VOC for the charging operation shall be determined by multiplying the emission factor in lbs of pollutant/wet ton coal charged, as found in the Agency’s emissions calculations in PTI 14-4605 for this emissions unit, by the wet tons of coal charged per month; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

12. Compliance with the TPY emissions limitations for PM,NOx, CO, VOC and lead for the coke oven battery waste gas exhaust shall be determined by multiplying the lbs of pollutant/wet ton coal charged, calculated from the results of the most recent performance test which demonstrated compliance, by the amount of wet tons of coal charged per month; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

13. Compliance with the TPY PM10 emissions limitation for the coke oven battery waste gas exhaust shall be determined by multiplying the PM emission rate as determined by Additional Special Term and Condition E.10 times 66.67 percent; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

14. Compliance with the lbs/hr emissions limitations for NOx, CO, VOC and lead for the coke oven battery waste gas exhaust shall be determined by multiplying the lbs of pollutant/wet ton coal charged, calculated from the results of the most recent performance test which demonstrated compliance, by the wet tons of coal charged/hr.

15. Compliance with the lbs/hr emissions limitations for PMfor the coke oven battery waste gas exhaust shall be determined by the results of the most recent performance test.

82Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

16. Compliance with the lbs/hr emissions limitations forPM10 for the coke oven battery waste gas exhaust shall be determined by multiplying the lbs/hr PM emission rate as determined by Additional Special Term and Condition E.10 times 66.67 percent.

17. Compliance with the lbs/hr emissions limitation for SO2for the coke oven battery waste gas exhaust shall be determined by converting the average hourly SO2 ppm concentration obtained from the SO2 CEM into units of lbs/hr.

18. Compliance with SO2 TPY emissions limitation shall be determined by adding the SO2 emissions rate for each day of the calendar month, as measured by the SO2 CEM; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

F. Miscellaneous Requirements

1. The hourly emission limitation(s) outlined are based upon the emissions unit’s PTE. Therefore, no hourly records are required to demonstrate compliance with these limits.

2. If the permittee fails to comply with the visible particulate emission limitation in A.8. via the use of the cover on the quench car, then the permittee shall install a capture and control system to achieve compliance with the visible particulate emission limitation.

IX. Emissions Unit P921 - For 96 Oven Nonrecovery Coke Batteries B1 and B2

A. Applicable Emission Limitations and/or Control Requirements

1. Each oven or the common duct tunnel shall be continuously operated under negative pressure, as determined by Additional Special Term and Condition C.6.

2. No visible emissions shall be permitted from the waste

83Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

gas common duct or its associated piping.

3. Except as otherwise provided in these terms and conditions, visible particulate emissions of fugitive dust from this emissions unit shall not exceed 20% percent opacity, as a three-minute average.

4. Except as otherwise provided in these terms and conditions, visible particulate emissions from any stack shall not exceed 20% percent opacity, as a six-minute average.

5. Visible particulate emissions from the waste gas exhaust stack(s) shall not exceed 10% percent opacity, as a six-minute average.

6. The visible emissions from the topside port lids and the offtake systems, if applicable, shall not exceed 0.0 percent.

7. There shall be no visible particulate emissions from any charging operation except for a period of time not to exceed 11 seconds per charge. Visible particulate emissions captured by the control system shall not be counted towards the 11 second limit.

8. Visible particulate emissions from any pushing operation shall not exceed an average of 20 percent opacity read above the battery top. For purposes of this paragraph, the duration of a pushing operation shall commence with the moving (or pushing) of the coke mass from an oven and shall conclude once all of the coke is in the quench car.

9. Visible particulate emissions from the quench car travel shall not exceed 10 percent opacity read above the battery top. For purposes of this paragraph, the quench car travel will begin with the movement of the car and end once the quench car reaches the quench tower.

10. The emissions of PM from emissions units P920 and P921 shall not exceed the following mass emission rate allowables:

a. the emissions of PM from the coke oven pushing operation shall not exceed 33.22 lbs PM/hr per emissions unit. The combined emissions of PM from emissions units P920 and P921 shall not exceed 49.56 TPY of PM, based on a rolling, 12-month

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summation of the PM emissions;

b. the fugitive emissions of PM from the coke oven charging operation shall not exceed 12.02 lbs PM/hr per emissions unit. The combined fugitive emissions of PM from emissions units P920 and P921 shall not exceed 17.92 TPY of PM, based on a rolling, 12-month summation of the PM emissions;

c. the individual emissions of PM from the baghouse employed for the control of PM emissions from the coke oven battery waste gas exhaust for emissions units P920 and P921 shall not exceed 0.015 gr PM/dscf, 23.17 lbs PM/hr per emissions unit. The combined emissions of PM from emissions units P920 and P921 shall not exceed 202.30 TPY of PM, based on a rolling, 12-month summation of the PM emissions; and,

d. the emissions of PM from the baghouse employed for the control of PM emissions from the coke oven charging operation shall not exceed 0.005 gr PM/dscf and 0.86 lb PM/hr per emissions unit. The combined emissions of PM from emissions units P920 and P921 shall not exceed 3.76 TPY of PM, based on a rolling, 12-month summation of the PM emissions.

11. The emissions of PM10 from emissions units P920 and P921 shall not exceed the following mass emission rate allowables:

a. the emissions of PM10 from the coke oven pushing operation shall not exceed 14.45 lbs PM10/hr per emissions unit. The combined emissions of PM10from emissions units P920 and P921 shall not exceed 21.56 TPY of PM10, based on a rolling, 12-month summation of the PM10 emissions;

b. the fugitive emissions of PM10 from the coke oven charging operation shall not exceed 12.02 lbs PM10/hr per emissions unit. The combined fugitive emissions of PM10 from emissions units P920 and P921 shall not exceed 17.92 TPY of PM10, based on a rolling, 12-month summation of the PM10

85Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

emissions;

c. the individual emissions of PM10 from the baghouse employed for the control of PM10 emissions from the coke oven battery waste gas exhaust for emissions units P920 and P921 shall not exceed 0.01 gr PM10/dscf, 15.44 lbs PM10/hr per emissions unit. The combined emissions of PM10 from emissions units P920 and P921 shall not exceed 134.8 TPY of PM10, based on a rolling, 12-month summation of the PM10 emissions; and,

d. the emissions of PM10 from the baghouse employed for the control of PM10 emissions from the coke charging operation shall not exceed 0.005 gr PM10/dscf and 0.86 lb PM10/hr per emissions unit. The combined emissions of PM10 from emissions units P920 and P921 shall not exceed 3.76 TPY of PM10, based on a rolling, 12-month summation of the PM emissions.

12. The emissions of SO2 from emissions units P920 and P921 shall not exceed the following mass emission rate allowables:

a. the emissions of SO2 from the coke oven pushing operation shall not exceed 38.13 lbs SO2/hr per emissions unit. The combined emissions of SO2 from emissions units P920 and P921 shall not exceed 56.88 TPY of SO2, based on a rolling, 12-month summation of the SO2 emissions;

b. the emissions of SO2 from the coke oven charging operation shall not exceed 0.17 lb SO2/hr per emissions unit. The combined emissions of SO2 from emissions units P920 and P921 shall not exceed 0.26 TPY of SO2, based on a rolling, 12-month summation of the SO2 emissions;

c. the maximum combined annual SO2 emission rate from the coke oven battery waste gas exhaust for emissions units P920 and P921 shall not exceed 861.96 TPY, based upon a rolling, 12-month summation of the SO2 emissions.

To ensure enforceability during the first 12 calendar months of operation, following the startup of the lime spray dryer, the permittee

86Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

shall not

exceed the annual SO2 emission rate limitation specified in the following table:

Maximum AllowableMonth SO2 Emission Rate (tons)

1 4311-2 4311-3 4311-4 4311-5 4311-6 4311-7 502.811-8 574.641-9 646.471-10 718.301-11 790.131-12 861.96

After the first 12 calendar months of operation following the startup of the lime spray dryer, compliance with the annual SO2 emission rate limitation shall be based upon a rolling, 12-month summation of the SO2 emission rates; and,

d. the individual emissions of SO2 from the lime spray dryer employed for the control of SO2emissions from the coke oven battery waste gas exhaust for emissions units P920 and P921 shall not exceed 577.8 lbs SO2/hr.

13. The emissions of NOx from emissions units P920 and P921 shall not exceed the following mass emission rate allowables:

a. the emissions of NOx from the coke oven pushing operation shall not exceed 9.24 lbs NOx/hr per emissions unit. The combined emissions of NOx from emissions units P920 and P921 shall not exceed 13.8 TPY of NOx, based on a rolling, 12-month summation of the NOx emissions;

87Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

b. the emissions of NOx from the coke oven charging operation shall not exceed 0.017 lb NOx/hr per emissions unit. The combined emissions of NOx from emissions units P920 and P921 shall not exceed 0.026 TPY of NOx, based on a rolling, 12-month summation of the NOx emissions; and,

88Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

c. the individual emissions of NOx from the coke oven battery waste gas exhaust for emissions units P920 and P921 shall not exceed 254.23 lbs NOx/hr per emissions unit. The combined emissions of NOx from emissions units P920 and P921 shall not exceed 758.52 TPY of NOx, based on a rolling, 12-month summation of the NOx emissions.

14. The emissions of CO from emissions units P920 and P921 shall not exceed the following mass emission rate allowables:

a. the emissions of CO from the coke oven pushing operation shall not exceed 10.23 lbs CO/hr per emissions unit. The combined emissions of CO from emissions units P920 and P921 shall not exceed 15.26 TPY of CO, based on a rolling, 12-month summation of the CO emissions;

b. the emissions of CO from the coke oven charging operation shall not exceed 0.14 lb CO/hr per emissions unit. The combined emissions of CO from emissions units P920 and P921 shall not exceed 0.22 TPY of CO, based on a rolling, 12-month summation of the CO emissions; and,

c. the individual emissions of CO from the coke oven battery waste gas exhaust for emissions units P920 and P921 shall not exceed 47.9 lbs CO/hr per emissions unit. The combined emissions of CO from emissions units P920 and P921 shall not exceed 142.92 TPY of CO, based on a rolling, 12-month summation of the CO emissions.

15. The emissions of VOC from emissions units P920 and P921 shall not exceed the following mass emission rate allowables:

a. the emissions of VOC from the coke oven pushing operation shall not exceed 115.56 lbs VOC/hr per emissions unit. The combined emissions of VOC from emissions units P920 and P921 shall not exceed 172.4 TPY of VOC, based on a rolling, 12-month summation of the VOC emissions;

89Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

b. the emissions of VOC from the coke oven charging operation shall not exceed 1.04 lbs VOC/hr per emissions unit. The combined emissions of VOC from emissions units P920 and P921 shall not exceed 1.56

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TPY of VOC, based on a rolling, 12-month summation of the VOC emissions; and,

c. the individual emissions of VOC from the coke oven battery waste gas exhaust for emissions units P920 and P921 shall not exceed 12.48 lbs VOC/hr per emissions unit. The combined emissions of VOC from emissions units P920 and P921 shall not exceed 37.24 TPY of VOC, based on a rolling, 12-month summation of the VOC emissions.

16. The individual emissions of lead from the coke oven battery waste gas exhaust for emissions units P920 and P921 shall not exceed 0.10 lb lead/hr per emissions unit. The combined emissions of VOC from emissions units P920 and P921 shall not exceed 0.29 TPY of lead.

B. Operational Restrictions

1. The maximum annual wet coal usage rate for emissions units P920 and P921, combined shall not exceed 1,723,900 tons per year, based upon a rolling, 12-month summation of the wet coal usage rates.

To ensure enforceability during the first 12 calendar months of operation following the issuance of this permit, the permittee shall not exceed the wet coal usage levels specified in the following table:

Maximum AllowableMonth Cumulative Wet Coal Usage (Tons)

1 861,9501-2 861,9501-3 861,9501-4 861,9501-5 861,9501-6 861,9501-7 1,005,6081-8 1,149,2671-9 1,292,9251-10 1,436,5831-11 1,580,2411-12 1,723,900

91Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

After the first 12 calendar months of operation following the issuance of this permit, compliance with the annual wet coal usage rate limitation shall be based upon a rolling, 12-month summation of the wet coal usage rates.

2. The permittee shall install, operate and maintain a removable cover on the coke receiving quench car for the collection of emissions in a manner consistent with good air pollution control practices for minimizing emissions from the pushing operation. The removable cover shall be in a position which completely covers the top of the coke receiving quench car, in a manner consistent with good engineering practices, prior to the coke pushing operation.

3. The permittee shall install, operate and maintain a baghouse for the control of particulate matter emissions from the coke oven battery waste gas exhaust for emissions units P920 and P921. The pressure drop across the baghouse employed to control emissions from the coke oven battery waste gas exhaust shall be maintained within the range established during the most recent emission test that demonstrated compliance, in inches of water, at all times during operation of the emissions units, except as otherwise specified in Additional Special Term and Condition B.13.

4. The permittee shall install, operate and maintain a collection system vented to a baghouse for minimizing emissions from the charging operation or an alternative emission standard as promulgated by the United States Environmental Protection Agency.

The pressure drop across the baghouse employed to control charging emissions shall be maintained within the range specified and/or recommended by the manufacturer, in inches of water, at all times during operation of the emissions unit.

5. The permittee shall operate and maintain equipment to continuously monitor and record SO2 emissions from the lime spray dryer in units of ppm. Such continuous monitoring and recording equipment shall comply with the requirements specified in 40 CFR Part 60, Section

92Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

60.13.

6. The permittee shall prepare and submit to the Administrator a written emissions control work practice plan for each coke oven battery, in accordance with 40 CFR Part 63, Subpart L, §63.306.

7. During any period of time that the permittee is required to implement the provisions of a plan for a particular emission point, the failure to implement one or more obligations under the plan and/or any recordkeeping

requirements under §63.311(f)(4) for the emission point during a particular day is a single violation.

8. The permittee shall implement the provisions of the coke oven emission control work practice plan in accordance with §63.306(c).

9. Revisions to the work practice emission control plan are governed by the provisions of §63.306(a)(2) and §63.306(d).

10. At all times including periods of startup, shutdown, and malfunction, the permittee shall operate and maintain the coke oven battery and its pollution control equipment required under 40 CFR Part 63, Subpart L, in a manner consistent with good air pollution control practices for minimizing emissions to the levels required by any applicable performance standards under 40 CFR Part 63, Subpart L. Failure to adhere to the requirement of this paragraph shall not constitute a separate violation if a violation of an applicable performance or work practice standard has also occurred.

11. The permittee of a coke oven battery shall develop and implement a written startup, shutdown, and malfunction plan, in accordance with §63.310(b)and §63.310(g).

12. The Administrator may require reasonable revisions to a startup, shutdown, and malfunction plan, in accordance with the provisions in §63.310(h).

13. If the owner or operator demonstrates to the satisfaction of the Administrator that a startup, shutdown, or malfunction has occurred, then an observation occurring during such startup, shutdown, or malfunction shall not:

93Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

a. constitute a violation of relevant requirements of 40 CFR Part 63, Subpart L;

b. be used in any compliance determination under §63.309; or,

c. be considered for purposes of §63.306, until the Administrator has resolved the claim that a startup, shutdown, or malfunction has occurred. If the Administrator determines that a startup, shutdown, or malfunction has not occurred, such observations may be used for purposes of §63.306, regardless of whether the permittee further contests such determination. The permittee’s receipt of written notification from the Administrator that a startup, shutdown, or malfunction has not occurred will serve, where applicable under §63.306, as written notification from the certified observer that an exceedance has occurred.

14. In order to ensure emission limits for the waste gas exhaust are not exceeded, the permittee shall operate and maintain common duct temperatures in a range established during the most recent performance test which demonstrated compliance.

The permittee shall also operate and maintain the common battery tunnel ducts under a negative pressure. The instrument used for determining the pressure shall be subject to approval by the Ohio EPA and shall be calibrated at least once every six (6) months.

15. The lime spray dryer and baghouse associated with the battery waste gas exhaust shall begin operation within forty (40) days after start-up of the first coke battery.

C. Monitoring and Recordkeeping Requirements

1. The permittee shall maintain monthly records for emissions unit P920 and P921 of the following information:

a. the total combined wet coal usage rate, in tons,

94Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

for each month; and,

b. beginning after the first 12 calendar months of operation following the issuance of this permit, the rolling, 12-month summation of the total combined wet coal usage rates.

Also, during the first 12 calendar months of operation following issuance of this permit, the permittee shall record the cumulative wet coal usage rate, in tons, for each calendar month.

2. The permittee shall maintain records of the emissions from the lime spray dryer for emissions unit P920 and P921 of the following information:

a. the hourly SO2 emission rate;

b. the total monthly SO2 emission rate for each month;

c. beginning after the first 12 calendar months of operation, following the startup of the lime spray dryer, the rolling, 12-month summation of the SO2 emission rates; and,

d. also, during the first 12 calendar months of operation following issuance of this permit, the permittee shall record the cumulative SO2 emission rate, in tons, for each calendar month.

3. The permittee shall maintain records of all data obtained by the continuous SO2 monitoring system including, but not limited to, parts per million SO2 on a 1-hour basis, results of daily zero/span calibration checks, and magnitude of manual calibration adjustments.

4. Within 180 days of the effective date of this permit, the permittee shall develop a written quality assurance/quality control plan for the continuous SO2monitoring system designed to ensure continuous valid and representative readings of SO2.

The plan shall follow the requirements of 40 CFR Part 60, Appendix F. The quality assurance/quality control plan and a logbook dedicated to the continuous SO2monitoring system must be kept on site and available for inspection during regular office hours.

95Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

5. The permittee shall monitor and record the temperature of the common duct tunnel on a once per shift basis.

6. The permittee shall properly install, operate, and maintain equipment to monitor the pressure drop across the coke oven battery waste gas exhaust baghouse, at all times during operation of this emissions unit.

The monitoring equipment shall be installed, calibrated, operated, and maintained in accordance with the manufacturer’s recommendations, instructions, and operating manual(s). The permittee shall record the pressure drop across the coke oven battery waste gas exhaust baghouse on a once per shift basis.

7. The permittee shall properly install, operate, and maintain equipment to monitor the pressure drop across the coke oven charging baghouse, at all times during operation of this emissions unit.

The monitoring equipment shall be installed, calibrated, operated, and maintained in accordance with the manufacturer’s recommendations, instructions, and operating manual(s). The permittee shall record the pressure drop across the coke oven charging baghouse on a once per shift basis.

8. The permittee shall monitor and record, once per day for each day of operation, the pressure in each oven or in a common battery tunnel to ensure that the ovens are operated under a negative pressure.

The permittee shall maintain a log which includes the date of each oven or common battery tunnel duct pressure instrument calibration and the name of the personnel and company responsible for calibrating the instrumentation.

9. The permittee shall maintain files of all required information in a permanent form suitable for inspection at an onsite location for at least 1 year and must thereafter be accessible within 3 working days to the Administrator for a period of at least five years from the date of the monitoring sample, measurement, report or application.

96Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

Copies of the work practice plan developed under §63.306 and the startup, shutdown, and malfunction plan developed under §63.310 shall be kept onsite at all times. The permittee shall maintain the following information:

a. records of daily pressure monitoring, according to §63.303(b)(1)(ii);

b. records demonstrating the performance of work practice requirements according to §63.306(b)(7);

c. design characteristics of each emission control system for the capture and collection of charging emissions, as required by §63.303(b)(2);

d. a copy of the work practice plan required by §63.306 and any revision to the plan; and,

e. records required to be maintained and reports required to be filed with the Administrator under 40 CFR Part 63, Subpart L shall be made available in accordance with the requirements of this paragraph by the permittee to the authorized collective bargaining representative of the employees at a coke oven battery, for inspection and copying.

i. requests under this term and condition shall be submitted in writing, and shall identify the records or reports that are subject to the request with reasonable specificity;

ii. the permittee shall produce the reports for inspection and copying within a reasonable period of time, not to exceed 30 days. A reasonable fee may be charged for copying (except for the first copy of any document), which shall not exceed the copying fee charged by the Administrator under part 2 of the CFR, chapter 40;

iii. nothing in this term and condition shall require the production for inspection or copying of any

97Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

portion of a document that contains trade secrets or confidential business information that the Administrator would be prohibited from disclosing to the public under part 2 of the CFR, chapter 40; and,

iv. the inspection or copying of a document under this term and condition shall not in any way affect any property right of the permittee in such document under laws for the protection of intellectual property, including the copyright laws.

10. The permittee shall maintain a record of internal reports which form the basis of each malfunction notification under Additional Special Term and Condition D.2.

11. To satisfy the requirements of §63.310 to develop a startup, shutdown, and malfunction plan, the permittee may use the standard operating procedures manual for the battery, provided the manual meets all the requirements for §63.310 and is made available for inspection at reasonable times when requested by the Administrator.

D. Reporting Requirements

1. The permittee shall submit deviation (excursion) reports that identify all exceedances of the rolling, 12-month coal usage rate limitation and, for the first 12 calendar months of operation following the issuance of this permit, all exceedances of the maximum allowable cumulative coal usage levels.

2. In order for the provisions of term and condition B.13 to apply with respect to the observation (or set of observations) for a particular day, notification of a startup, shutdown, or a malfunction shall be made by the owner or operator:

a. if practicable, to the certified observer if the observer is at the facility during the occurrence; or,

b. to the enforcement agency, in writing, within 24 hours of the occurrence first being documented by a company employee, and if the notification under Additional Special Term and Condition D.2.(a) was not made, an explanation of why no such notification was made.

98Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

3. Within 14 days of the notification made under term and condition D.2, or after a startup or shutdown, the permittee shall submit a written report to the applicable permitting authority that:

a. describes the time and circumstances of the startup, shutdown, or malfunction; and,

b. describes actions taken that might be considered inconsistent with the startup, shutdown, or malfunction plan.

4. The permittee shall submit annual reports that identify the actual monthly wet coal usage rates for each calendar month and the updated rolling, 12-month summation. These reports shall be submitted by January 30 of each year and shall cover the previous calendar year.

5. Pursuant to OAC rules 3745-15-04, 3745-35-02, and ORC sections 3704.03(I) and 3704.031 and 40 CFR Parts 60.7 and 60.13(h), the permittee shall submit reports within 30 days following the end of each calendar quarter to the Hamilton County Dept. of Env. Services documenting the date, commencement and completion times, duration, magnitude, reason (if known), and corrective actions taken (if any), of all instances of SO2 values in excess of the applicable limits specified in OAC Chapter 3745-18, the monthly and/or annual SO2 emission rate. These reports shall also contain the total SO2emissions for the calendar quarter (in tons).

The permittee shall submit reports within 30 days following the end of each calendar quarter to the Hamilton County Dept. of Env. Services documenting any continuous SO2 monitoring system downtime while the emissions unit was on line (date, time, duration and reason) along with any corrective action(s) taken. The permittee shall provide the emissions unit operating time during the reporting period and the date, time, reason and corrective action(s) taken for each time period of emissions unit and control equipment malfunctions. The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line shall also be included

99Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

in the quarterly report.

If there are no excess emissions during the calendar quarter, the permittee shall submit a statement to that effect along with the emissions unit operating time during the reporting period and the date, time, reason, and corrective action(s) taken for each time period of emissions unit, control equipment, and/or monitoring system malfunctions.

The total operating time of the emissions unit and the total operating time of the analyzer while the emissions unit was on line also shall be included in the quarterly report. These quarterly excess emission reports shall be submitted by January 30, April 30, July 30, and October 30 of each year and shall address the data obtained during the previous calendar quarter.

6. Pursuant to OAC rules 3745-15-04, 3745-35-02, and ORC sections 3704.03(I) and 3704.031, the permittee shall submit a summary of the excess emission report pursuant to 40 CFR Part 60.7. The summary shall be submitted to the Hamilton County Dept. of Env. Services within 30 days following the end of each calendar quarter in a manner prescribed by the Director.

7. The permittee shall submit pressure drop deviation (excursion) reports that identify that all periods of time during which the pressure drop across the coke oven battery waste gas exhaust baghouse did not comply with the allowable range specified above.

8. The permittee shall submit pressure drop deviation (excursion) reports that identify that all periods of time during which the pressure drop across the coke oven charging baghouse did not comply with the allowable range specified above.

100Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

9. The permittee shall provide a written statement(s) to certify compliance to the Administrator within 45 days of the applicable compliance date for the emission limitations or requirements in 40 CFR Part 63, Subpart L. The permittee shall include the following information in the initial compliance certification:

a. statement, signed by the permittee, certifying that a written startup, shutdown, and malfunction plan has been prepared as required in §63.310.

10. The permittee shall provide written notification(s) to the Administrator of:

a. intention to construct a new coke oven battery (including reconstruction of an existing coke oven battery and construction of a greenfield coke oven battery), a brownfield coke oven battery, or a padup rebuild coke oven battery, including the anticipated date of startup.

11. The permittee shall include the following information in the semiannual compliance certification:

a. certification, signed by the permittee, that a startup, shutdown, or malfunction event did not occur for a coke oven battery during the reporting period or that a startup, shutdown, and malfunction event did occur and a report was submitted according to the requirements in §63.310(e); and,

b. certification, signed by the permittee, that work practices were implemented if applicable under §63.306.

12. The permittee shall submit common tunnel duct temperature deviation (excursion) reports that identify all periods of time during which the temperature in the common tunnel duct fell out of the range determined during the first 60 days of maximum production and demonstrated by the most recent performance test which demonstrated compliance with the waste gas exhaust emission limitations. These reports shall include the time of the temperature deviation, the duration of the exceedance and the corrective action taken.

101Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

13. The permittee shall submit oven pressure deviation(excursion) reports that identify all periods of time during which the oven pressure or the pressure in the common battery tunnel duct is no longer negative.

These reports shall include the time of the pressure deviation, the duration of the exceedance and the corrective action taken.

14. The permittee shall submit annual reports of emissions. The permittee may elect to submit Title V emissions fee reports in lieu of annual reports for those emissions required by the Title V emissions fee regulation. These reports shall be submitted by January 31 of each year.

E. Compliance Methods/Testing Requirements

1. Compliance with Additional Special Term and Condition A.6 shall be determined by the procedures and requirements of Method 303 or 303A in appendix A of 40 CFR Part 63 and in accordance with §63.309(d)(1). For the purposes of determining compliance the visible emission reader does not have to be certified in Method 303.

2. Compliance with the fugitive visible particulate emissions limitations in Additional Special Term and Condition A.3 shall be determined by the methods outlined in the Ohio Administrative Code (OAC)rule 3745-17-03(B)(3).

3. Compliance with the visible particulate emissions limitations in A.4 and A.5 shall be determined by the methods outlined in OAC rule 3745-17-03(B)(1).

4. Compliance with visible particulate emission limitation in A.7 shall be determined by procedures 3.3 to 3.6 contained in Method 303 of 40 CFR Part 63, Appendix A. For the purposes of determining compliance the visible emission reader does not have to be certified in Method 303.

5. Compliance with the visible particulate emissions limitations in A.8 shall be determined by Method 9 of 40 CFR Part 60, Appendix A. The average opacity shall be determined by summing the opacity readings and dividing this sum by the number of observations during that pushing operation.

6. Compliance with the visible particulate emissions

102Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

limitations in A.9 shall be determined by Method 9 of 40 CFR Part 60, Appendix A. The average opacity shall be determined by summing the opacity readings and dividing this sum by the number of observations during that quench car travel.

7. The permittee shall conduct, or have conducted, emission testing for the coke oven battery waste gas exhaust associated with this emissions unit in accordance with the following requirements:

a. the emission testing shall be conducted within 6 months after startup of this emissions unit;

b. the emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate for sulfur dioxide, nitrogen oxides, particulate, volatile organic compounds (VOC), carbon monoxide and lead;

c. the following test method(s) shall be employed to demonstrate compliance with the allowable mass emission rate(s): for sulfur dioxide, Method 6 of 40 CFR Part 60, Appendix A; for nitrogen oxides, Method 7 of 40 CFR Part 60, Appendix A; for particulate, Method 5 of 40 CFR Part 60, Appendix A; for VOC, Method 18 or Method 25/25A of 40 CFR Part 60, Appendix A (whichever is applicable); for carbon monoxide, Method 10 of 40 CFR Part 60, Appendix A; and for lead, Methods 12 or 29 of 40 CFR Part 60, Appendix A (whichever is applicable);. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA; and,

d. the test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless otherwise specified or approved by the Hamilton County Dept. of Env. Services.

Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test" notification to the Hamilton County Dept. of Env. Services. The "Intent to Test" notification shall describe in detail the proposed test methods and

103Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

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 Hamilton County Dept. of Env. Services refusal to accept the results of the emission test(s).

Personnel from the Hamilton County Dept. of Env. Services 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 Hamilton County Dept. of Env. Services 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 Hamilton County Dept. of Env. Services.

8. Compliance with the lbs/hr emissions limitations for PM, PM10, SO2, NOx, CO, and VOC for the pushing operation shall be determined by multiplying the emission factor in lbs of pollutant/wet ton coal charged, as found in the Agency’s emissions calculations in PTI 14-4605 for this emissions unit, by the wet tons of coal charged per hour.

9. Compliance with the TPY emissions limitations for PM, PM10, SO2, NOx, CO, and VOC for the pushing operation shall be determined by multiplying the emission factor in lbs of pollutant/wet ton coal charged, as found in the Agency’s emissions calculations in PTI 14-4605 for this emissions unit, by the tons of wet coal charged per month; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

104Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

10. Compliance with the lbs/hr emissions limitations for PM, PM10, SO2, NOx, CO, and VOC for the charging operation shall be determined by multiplying the emission factor in lbs of pollutant/wet ton coal charged, as found in the Agency’s emissions calculations in PTI 14-4605 for this emissions unit, by the wet tons of coal charged per hour.

11. Compliance with the TPY emissions limitations for PM, PM10, SO2, NOx, CO, and VOC for the charging operation shall be determined by multiplying the emission factor in lbs of pollutant/wet ton coal charged, as found in the Agency’s emissions calculations in PTI 14-4605 for this emissions unit, by the wet tons of coal charged per month; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

12. Compliance with the TPY emissions limitations for PM,NOx, CO, VOC and lead for the coke oven battery waste gas exhaust shall be determined by multiplying the lbs of pollutant/wet ton coal charged, calculated from the results of the most recent performance test which demonstrated compliance, by the amount of wet tons of coal charged per month; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

13. Compliance with the TPY PM10 emissions limitation for the coke oven battery waste gas exhaust shall be determined by multiplying the PM emission rate as determined by term and condition E.10 times 66.67 percent; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

14. Compliance with the lbs/hr emissions limitations for NOx, CO, VOC and lead for the coke oven battery waste gas exhaust shall be determined by multiplying the lbs of pollutant/wet ton coal charged, calculated from the results of the most recent performance test which demonstrated compliance, by the wet tons of coal charged/hr.

15. Compliance with the lbs/hr emissions limitations for PMfor the coke oven battery waste gas exhaust shall be determined by the results of the most recent performance test.

16. Compliance with the lbs/hr emissions limitations for

105Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

PM10 for the coke oven battery waste gas exhaust shall be determined by multiplying the lbs/hr PM emission rate as determined by Additional Special Term and Condition E.10 times 66.67 percent.

17. Compliance with the lbs/hr emissions limitation for SO2for the coke oven battery waste gas exhaust shall be determined by converting the average hourly SO2 ppm concentration obtained from the SO2 CEM into units of lbs/hr.

18. Compliance with SO2 TPY emissions limitation shall be determined by adding the SO2 emissions rate for each day of the calendar month, as measured by the SO2 CEM; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

F. Miscellaneous Requirements

1. The hourly emission limitation(s) outlined are based upon the emissions unit’s PTE. Therefore, no hourly records are required to demonstrate compliance with these limits.

2. If the permittee fails to comply with the visible particulate emission limitation in A.8. via the use of the cover on the quench car, then the permittee shall install a capture and control system to achieve compliance with the visible particulate emission limitation.

X. Emissions Unit P937 - For Coke Handling

A. Applicable Emission Limitations and/or Control Requirements

1. Visible fugitive particulate emissions from this emissions unit shall not exceed 20% percent opacity, as a three-minute average.

2. Visible particulate emissions from any stack associated with this emissions unit shall not exceed 20% percent opacity, as a six-minute average.

3. The emissions limitations for this emissions unit are

106Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

identified in the Air Emissions Summary page of this permit.

B. Operational Restrictions

1. The permittee shall employ and maintain enclosures of each coke conveyor and each coke conveyor transfer point in order to minimize or eliminate visible emissions of fugitive dust into the ambient air.

2. Scrubber Operational Restrictions

The permittee shall properly install, operate and maintain two scrubbers for the control of PM and PM10emissions from the coke crushing and screening processes. The scrubber water supply pressure shall be continuously maintained within the range recommended by the manufacturer, while the crushing and screening processes are in operation.

The scrubber water flow rate shall be continuously maintained within the range recommended by the manufacturer while the crushing and screening processes are in operation.

107Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

C. Monitoring and Record keeping Requirements

1. Scrubber Pressure Drop Monitoring and Recordkeeping Requirements

The permittee shall properly install, operate, and maintain equipment to monitor the pressure drop across each scrubber and the water flow rate of each scrubber while the coke crushing and screening processes are in operation. The monitoring equipment shall be installed, calibrated, operated, and maintained in accordance with the manufacturer’s recommendations, instructions, and operating manual(s).

The permittee shall collect and record the following information each day:

a. the water supply pressure, in psig, on a once/day basis;

b. the water flow rate, in gpm, on a once/day basis; and,

c. a log or record of operating time for the capture (collection) system, control device, monitoring equipment, and the associated emissions unit.

D. Reporting Requirements

1. Scrubber Reporting Requirements

The permittee shall submit deviation (excursion) reports that identify all periods of time during which the following scrubber parameters were not maintained at or above the required levels:

a. the water supply pressure; and,

b. the scrubber water flow rate.

E. Compliance Methods/Testing Requirements

1. The permittee shall conduct, or have conducted, emission testing for each scrubber, which serves the coke crushing and screening processes, in accordance

108Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

with the following requirements:

a. the emission testing shall be conducted within 6 months after startup of the coke crushing and screening processes;

b. the emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate(s) of particulates;

c. the following test method(s) shall be employed to demonstrate compliance with the allowable mass emission rate(s):for particulates, Method 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA; and,

d. the test(s) shall be conducted while the coke crushing and screening processes are operating at or near its maximum capacity, unless otherwise specified or approved by the Hamilton County Dept. of Env. Services.

Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test" notification to the Hamilton County Dept. of Env. Services. The "Intent to Test" notification shall describe in detail the proposed test methods and procedures, the coke crushing and screening process 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 Hamilton County Dept. of Env. Services refusal to accept the results of the emission test(s).

Personnel from the Hamilton County Dept. of Env. Services 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 coke crushing and screening processes and the testing procedures provide a valid characterization of the emissions from the coke crushing and screening processes

109Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

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 Hamilton County Dept. of Env. Services 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 Hamilton County Dept. of Env. Services.

2. Compliance with the fugitive visible emissions limitation in A.1 shall be determined by the methods outlined in Ohio Administrative Code (OAC) rule 3745-17-03(B)(3).

3. Compliance with the visible emissions limitation in A.2 shall be determined by the methods outlined in Ohio Administrative Code (OAC) rule 3745-17-03(B)(1).

4. Compliance with the lbs/hr and TPY PM emission limitations in the Air Emission Summary page of PTI 14-4605 for the coke crushing and screening processes shall be determined in accordance with the following method(s):

a. compliance with the lbs/hr emissions limitations for PM shall be determined by multiplying the combined, calculated lbs PM/wet ton coal processed, as demonstrated during the most recent stack test of both scrubbers, by the wet tons of coal processed/hr, times the control efficiency of the building enclosure, if applicable, for each emissions point;

b. compliance with the TPY emissions limitation for PM shall be determined by multiplying the combined, calculated lbs PM/wet ton coal processed, as demonstrated during the most recent stack test of both scrubbers, by the wet tons of coal processed/month, times the control efficiency of the building enclosure, if applicable, for each emissions point, divided by 2000 lbs/ton; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months;

c. compliance with the lbs/hr emissions limitation

110Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

for PM10 shall be determined by the emissions calculation equation found in the Agency’s PTI 14-4605 emissions calculations; and,

d. compliance with the TPY emissions limitation for PM10 shall be determined by the emissions calculation equation found in the Agency’s PTI 14-4605 emissions calculations; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

5. Compliance with the lbs/hr PM and PM10 emissions limitations for the coke transfer, conveying and loadout station operations shall be determined by the emissions calculation equation found in the Agency’s PTI 14-4605 emissions calculations.

6. Compliance with the TPY PM and PM10 emissions limitations for the coke transfer, conveying and loadout station operations shall be determined by the emissions calculation equation found in the Agency’s PTI 14-4605 emissions calculations; adding the current month’s emissions rate to the emission rate for the preceding eleven calendar months.

F. Miscellaneous Requirements

1. The hourly emission limitation(s) outlined are based upon the emissions unit’s PTE. Therefore, no hourly records are required to demonstrate compliance with these limits.

111Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)

ADDITIONAL NETTING SPECIAL TERMS AND CONDITIONS

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113Facility Name: AK Steel CorporationApplication Number: 14-4605Date: Draft PTI (date will be entered upon final issuance)