notice of 30-day period for public commentpermits.air.idem.in.gov/41472d.pdf · (b) one (1)...

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT We Protect Hoosiers and Our Environment.

100 N. Senate Avenue • Indianapolis, IN 46204

(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov

Eric J. Holcomb Bruno L. Pigott Governor Commissioner

An Equal Opportunity Employer

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NOTICE OF 30-DAY PERIOD

FOR PUBLIC COMMENT

Preliminary Findings Regarding a New Source Review and Minor Source Operating Permit (MSOP)

for Sims Metal Management in Lake County

MSOP No.: M089-41472-00608

The Indiana Department of Environmental Management (IDEM) has received an application from Sims Metal Management, located at 425 West 152nd Street, East Chicago, IN 46312, for a new source review and MSOP. If approved by IDEM’s Office of Air Quality (OAQ), this proposed permit would allow Sims Metal Management to construct and operate new emisison units and to continue to operate its existing source. Sims Metal Management has applied to transition from a Registration to a MSOP. The applicant intends to construct and operate new equipment that will emit air pollutants; therefore, the permit contains new or different permit conditions. In addition, some conditions from previously issued permits/approvals have been corrected, changed, or removed. These corrections, changes, and removals may include Title I changes (e.g. changes that add or modify synthetic minor emission limits). IDEM has reviewed this application and has developed preliminary findings, consisting of a draft permit and several supporting documents, which would allow the applicant to make this change. A copy of the permit application and IDEM’s preliminary findings are available at:

East Chicago Public Library 2401 East Columbus Drive East Chicago, IN 46312 and IDEM Northwest Regional Office 330 W. US Highway 30, Suites E & F Valparaiso, IN 46385

A copy of the preliminary findings is available on the Internet at: http://www.in.gov/ai/appfiles/idem-caats/. A copy of the preliminary findings is also available via IDEM’s Virtual File Cabinet (VFC.) Please go to: http://www.in.gov/idem/ and enter VFC in the search box. You will then have the option to search for permit documents using a variety of criteria. How can you participate in this process? The date that this notice is posted on IDEM’s website (https://www.in.gov/idem/5474.htm) marks the beginning of a 30-day public comment period. If the 30th day of the comment period falls on a day when IDEM offices are closed for business, all comments must be postmarked or delivered in person on the next business day that IDEM is open. You may request that IDEM hold a public hearing about this draft permit. If adverse comments concerning the air pollution impact of this draft permit are received, with a request for a public hearing, IDEM will decide whether or not to hold a public hearing. IDEM could also decide to hold a public meeting instead of, or in addition to, a public hearing. If a public hearing or meeting is held, IDEM will

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(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov



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DRAFT Minor Source Operating Permit

OFFICE OF AIR QUALITY

Sims Metal Management 425 West 152nd Street

East Chicago, Indiana 46312

(herein known as the Permittee) is hereby authorized to operate subject to the conditions contained herein, the source described in Section A (Source Summary) of this permit. This permit is issued to the above mentioned company under the provisions of 326 IAC 2-1.1, 326 IAC 2-6.1 and 40 CFR 52.780, with conditions listed on the attached pages. Indiana statutes from IC 13 and rules from 326 IAC, quoted in conditions in this permit, are those applicable at the time the permit was issued. The issuance or possession of this permit shall not alone constitute a defense against an alleged violation of any law, regulation or standard, except for the requirement to obtain a MSOP under 326 IAC 2-6.1. Operation Permit No.: M089-41472-00608 Master Agency Interest ID: 13541

Issued by: Heath Hartley, Section Chief Permits Branch Office of Air Quality

Issuance Date: Expiration Date:

Sims Metal Management Page 2 of 24 East Chicago, Indiana M089-41472-00608 Permit Reviewer: Kendra Sutherland

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SECTION A SOURCE SUMMARY ......................................................................................................... 4

A.1 General Information [326 IAC 2-5.1-3(c)][326 IAC 2-6.1-4(a)] A.2 Emission Units and Pollution Control Equipment Summary

SECTION B GENERAL CONDITIONS ................................................................................................... 6

B.1 Definitions [326 IAC 2-1.1-1] B.2 Permit Term [326 IAC 2-6.1-7(a)][326 IAC 2-1.1-9.5][IC 13-15-3-6(a)] B.3 Term of Conditions [326 IAC 2-1.1-9.5] B.4 Enforceability B.5 Severability B.6 Property Rights or Exclusive Privilege B.7 Duty to Provide Information B.8 Annual Notification [326 IAC 2-6.1-5(a)(5)] B.9 Preventive Maintenance Plan [326 IAC 1-6-3] B.10 Prior Permits Superseded [326 IAC 2-1.1-9.5] B.11 Termination of Right to Operate [326 IAC 2-6.1-7(a)] B.12 Permit Renewal [326 IAC 2-6.1-7] B.13 Permit Amendment or Revision [326 IAC 2-5.1-3(e)(3)][326 IAC 2-6.1-6] B.14 Source Modification Requirement B.15 Inspection and Entry

[326 IAC 2-5.1-3(e)(4)(B)][326 IAC 2-6.1-5(a)(4)][IC 13-14-2-2][IC 13-17-3-2][IC 13-30-3-1]

B.16 Transfer of Ownership or Operational Control [326 IAC 2-6.1-6] B.17 Annual Fee Payment [326 IAC 2-1.1-7] B.18 Credible Evidence [326 IAC 1-1-6]

SECTION C SOURCE OPERATION CONDITIONS ............................................................................. 11

Emission Limitations and Standards [326 IAC 2-6.1-5(a)(1)] .................................................. 11 C.1 Permit Revocation [326 IAC 2-1.1-9] C.2 Opacity [326 IAC 5-1] C.3 Open Burning [326 IAC 4-1] [IC 13-17-9] C.4 Incineration [326 IAC 4-2] [326 IAC 9-1-2] C.5 Fugitive Dust Emissions [326 IAC 6-4] C.6 Fugitive Particulate Matter Emissions [326 IAC 6.8-10-3] C.7 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61, Subpart M]

Testing Requirements [326 IAC 2-6.1-5(a)(2)] .......................................................................... 14 C.8 Performance Testing [326 IAC 3-6]

Compliance Requirements [326 IAC 2-1.1-11] ......................................................................... 14 C.9 Compliance Requirements [326 IAC 2-1.1-11]

Compliance Monitoring Requirements [326 IAC 2-6.1-5(a)(2)] ............................................... 15 C.10 Compliance Monitoring [326 IAC 2-1.1-11] C.11 Instrument Specifications [326 IAC 2-1.1-11]

Corrective Actions and Response Steps................................................................................... 15 C.12 Response to Excursions or Exceedances C.13 Actions Related to Noncompliance Demonstrated by a Stack Test

Record Keeping and Reporting Requirements [326 IAC 2-6.1-5(a)(2)] .................................. 16 C.14 Malfunctions Report [326 IAC 1-6-2] C.15 Emission Statement [326 IAC 2-6] C.16 General Record Keeping Requirements [326 IAC 2-6.1-5] C.17 General Reporting Requirements [326 IAC 2-1.1-11] [326 IAC 2-6.1-2]

[IC 13-14-1-13]


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SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS .............................................................. 18

Emission Limitations and Standards [326 IAC 2-6.1-5(a)(1)] ................................................... 18 D.1.1 Volatile Organic Compounds (VOC) BACT Limits [326 IAC 8-1-6] D.1.3 Preventive Maintenance Plan [326 IAC 1-6-3]

Compliance Determination Requirements [326 IAC 2-6.1-5(a)(2)] .......................................... 19 D.1.4 Particulate Matter D.1.5 Testing Requirements [326 IAC 2-1.1-11]

Compliance Monitoring Requirements [326 IAC 2-6.1-5(a)(2)] ................................................ 19 D.1.6 Water Spray System Failure Detection

Record Keeping and Reporting Requirements [326 IAC 2-6.1-5(a)(2)] ................................... 20 D.1.7 Record Keeping Requirement D.1.8 Reporting Requirements

Quarterly Report ........................................................................................................................................ 21

ANNUAL NOTIFICATION .......................................................................................................................... 22

MALFUNCTION REPORT .......................................................................................................................... 23

Attachment A- Fugitive Dust Control Plan


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SECTION A SOURCE SUMMARY

This permit is based on information requested by the Indiana Department of Environmental Management (IDEM), Office of Air Quality (OAQ). The information describing the source contained in conditions A.1 and A.2 is descriptive information and does not constitute enforceable conditions. However, the Permittee should be aware that a physical change or a change in the method of operation that may render this descriptive information obsolete or inaccurate may trigger requirements for the Permittee to obtain additional permits or seek modification of this permit pursuant to 326 IAC 2, or change other applicable requirements presented in the permit application. A.1 General Information [326 IAC 2-5.1-3(c)][326 IAC 2-6.1-4(a)]

The Permittee owns and operates a stationary scrap metal recycling facility.

Source Address: 425 West 152nd Street, East Chicago, Indiana 46312 General Source Phone Number: (773) 650-6495 SIC Code: 5093 (Scrap and Waste Materials) County Location: Lake Source Location Status: Nonattainment for 8-hour ozone standard

Attainment for all other criteria pollutants Source Status: Minor Source Operating Permit Program Minor Source, under PSD and Emission Offset Rules

Minor Source, Section 112 of the Clean Air Act Not 1 of 28 Source Categories

A.2 Emission Units and Pollution Control Equipment Summary

This stationary source consists of the following emission units and pollution control devices:

The following is a list of the existing emission units and pollution control devices:

(a) One (1) scrap metal shredder, approved in 2019 for construction, with a maximum capacity of 112 tons per hour, using an integral smart water injection system as fire/explosion suppression and particulate control, and exhausting to the atmosphere.

(b) One (1) Z-box/cyclone system, approved in 2019 for construction, with a maximum

capacity of 112 tons per hour of metal scrap separating heavy materials from light materials using a counter-flow forced air stream cascade system, equipped with a cyclone particle separator with cyclone exhaust recirculated internally within the Z-box separator and reused for the forced air stream cascade system.

(c) One (1) conveying system, consisting of twelve drop points, approved in 2019 for

construction, with a maximum capacity of 112 tons per hour, using no control, and exhausting to the atmosphere.

(d) One (1) granulator for insulated copper wire, constructed in 2018, with a maximum capacity of one (1) ton per hour, using no controls, and exhausting indoors.

(e) One (1) hand-held torch cutting station, constructed prior to 2000, with a maximum capacity of 3.5 tons per hour, using no controls, and exhausting outdoors.

(f) One (1) shear, constructed prior to 2000, with a maximum capacity of 25 tons per hour, using no controls, and exhausting outdoors.

(g) One (1) baler, constructed prior to 2000, with a maximum capacity of 500 tons per month,

using no controls, and exhausting outdoors.


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(h) Two (2) diesel storage tanks, identified as Tanks #1 and #2, constructed prior to 2000,

each with a maximum capacity of 10,000 gallons, each using no controls, and each exhausting outdoors.

(i) One (1) natural gas-fired hot water heater, with a maximum heat input capacity of 0.038

MMBtu per hour, using no controls, and exhausting to the atmosphere. (j) Paved and unpaved roads


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SECTION B GENERAL CONDITIONS

B.1 Definitions [326 IAC 2-1.1-1] Terms in this permit shall have the definition assigned to such terms in the referenced regulation. In the absence of definitions in the referenced regulation, the applicable definitions found in the statutes or regulations (IC 13-11, 326 IAC 1-2 and 326 IAC 2-1.1-1) shall prevail.

B.2 Permit Term [326 IAC 2-6.1-7(a)][326 IAC 2-1.1-9.5][IC 13-15-3-6(a)]

(a) This permit, M089-41472-00608, is issued for a fixed term of five (5) years from the issuance date of this permit, as determined in accordance with IC 4-21.5-3-5(f) and IC 13-15-5-3. Subsequent revisions, modifications, or amendments of this permit do not affect the expiration date of this permit.

(b) If IDEM, OAQ, upon receiving a timely and complete renewal permit application, fails to

issue or deny the permit renewal prior to the expiration date of this permit, this existing permit shall not expire and all terms and conditions shall continue in effect, until the renewal permit has been issued or denied.

B.3 Term of Conditions [326 IAC 2-1.1-9.5]

Notwithstanding the permit term of a permit to construct, a permit to operate, or a permit modification, any condition established in a permit issued pursuant to a permitting program approved in the state implementation plan shall remain in effect until:

(a) the condition is modified in a subsequent permit action pursuant to Title I of the Clean Air

Act; or (b) the emission unit to which the condition pertains permanently ceases operation.

B.4 Enforceability Unless otherwise stated, all terms and conditions in this permit, including any provisions designed to limit the source's potential to emit, are enforceable by IDEM, the United States Environmental Protection Agency (U.S. EPA) and by citizens in accordance with the Clean Air Act.

B.5 Severability The provisions of this permit are severable; a determination that any portion of this permit is invalid shall not affect the validity of the remainder of the permit.

B.6 Property Rights or Exclusive Privilege

This permit does not convey any property rights of any sort or any exclusive privilege. B.7 Duty to Provide Information

(a) The Permittee shall furnish to IDEM, OAQ, within a reasonable time, any information that IDEM, OAQ may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit. Upon request, the Permittee shall also furnish to IDEM, OAQ copies of records required to be kept by this permit.

(b) For information furnished by the Permittee to IDEM, OAQ, the Permittee may include a claim of confidentiality in accordance with 326 IAC 17.1. When furnishing copies of requested records directly to U. S. EPA, the Permittee may assert a claim of confidentiality in accordance with 40 CFR 2, Subpart B.


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B.8 Annual Notification [326 IAC 2-6.1-5(a)(5)]

(a) An annual notification shall be submitted by an authorized individual to the Office of Air Quality stating whether or not the source is in operation and in compliance with the terms and conditions contained in this permit.

(b) The annual notice shall be submitted in the format attached no later than March 1 of each

year to:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

(c) The notification shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAQ on or before the date it is due.

B.9 Preventive Maintenance Plan [326 IAC 1-6-3]

(a) If required by specific condition(s) in Section D of this permit, the Permittee shall prepare and maintain Preventive Maintenance Plans (PMPs) no later than ninety (90) days after issuance of this permit or ninety (90) days after initial start-up, whichever is later, including the following information on each facility:

(1) Identification of the individual(s) responsible for inspecting, maintaining, and

repairing emission control devices; (2) A description of the items or conditions that will be inspected and the inspection

schedule for said items or conditions; and (3) Identification and quantification of the replacement parts that will be maintained

in inventory for quick replacement. If, due to circumstances beyond the Permittee’s control, the PMPs cannot be prepared and maintained within the above time frame, the Permittee may extend the date an additional ninety (90) days provided the Permittee notifies: Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 The Permittee shall implement the PMPs.

(b) A copy of the PMPs shall be submitted to IDEM, OAQ upon request and within a reasonable time, and shall be subject to review and approval by IDEM, OAQ. IDEM, OAQ may require the Permittee to revise its PMPs whenever lack of proper maintenance causes or is the primary contributor to an exceedance of any limitation on emissions.

(c) To the extent the Permittee is required by 40 CFR Part 60/63 to have an Operation Maintenance, and Monitoring (OMM) Plan for a unit, such Plan is deemed to satisfy the PMP requirements of 326 IAC 1-6-3 for that unit.


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B.10 Prior Permits Superseded [326 IAC 2-1.1-9.5]

(a) All terms and conditions of permits established prior to M089-41472-00608 and issued pursuant to permitting programs approved into the state implementation plan have been either: (1) incorporated as originally stated, (2) revised, or (3) deleted.

(b) All previous registrations and permits are superseded by this permit.

B.11 Termination of Right to Operate [326 IAC 2-6.1-7(a)] The Permittee's right to operate this source terminates with the expiration of this permit unless a timely and complete renewal application is submitted at least one hundred twenty (120) days prior to the date of expiration of the source’s existing permit, consistent with 326 IAC 2-6.1-7.

B.12 Permit Renewal [326 IAC 2-6.1-7]

(a) The application for renewal shall be submitted using the application form or forms prescribed by IDEM, OAQ and shall include the information specified in 326 IAC 2-6.1-7. Such information shall be included in the application for each emission unit at this source. The renewal application does require an affirmation that the statements in the application are true and complete by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

Request for renewal shall be submitted to: Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

(b) A timely renewal application is one that is:

(1) Submitted at least one hundred twenty (120) days prior to the date of the

expiration of this permit; and (2) If the date postmarked on the envelope or certified mail receipt, or affixed by the

shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAQ on or before the date it is due.

(c) If the Permittee submits a timely and complete application for renewal of this permit, the

source’s failure to have a permit is not a violation of 326 IAC 2-6.1 until IDEM, OAQ takes final action on the renewal application, except that this protection shall cease to apply if, subsequent to the completeness determination, the Permittee fails to submit by the deadline specified, pursuant to 326 IAC 2-6.1-4(b), in writing by IDEM, OAQ any additional information identified as being needed to process the application.

B.13 Permit Amendment or Revision [326 IAC 2-5.1-3(e)(3)][326 IAC 2-6.1-6] (a) Permit amendments and revisions are governed by the requirements of 326 IAC 2-6.1-6

whenever the Permittee seeks to amend or modify this permit.


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(b) Any application requesting an amendment or modification of this permit shall be

submitted to: Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

(c) The Permittee shall notify the OAQ no later than thirty (30) calendar days of

implementing a notice-only change. [326 IAC 2-6.1-6(d)] B.14 Source Modification Requirement

A modification, construction, or reconstruction is governed by the requirements of 326 IAC 2.

B.15 Inspection and Entry [326 IAC 2-5.1-3(e)(4)(B)][326 IAC 2-6.1-5(a)(4)][IC 13-14-2-2][IC 13-17-3-2][IC 13-30-3-1] Upon presentation of proper identification cards, credentials, and other documents as may be required by law, and subject to the Permittee’s right under all applicable laws and regulations to assert that the information collected by the agency is confidential and entitled to be treated as such, the Permittee shall allow IDEM, OAQ, U.S. EPA, or an authorized representative to perform the following:

(a) Enter upon the Permittee's premises where a permitted source is located, or emissions

related activity is conducted, or where records must be kept under the conditions of this permit;

(b) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit;

(c) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, inspect, at reasonable times, any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit;

(d) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, sample or monitor, at reasonable times, substances or parameters for the purpose of assuring compliance with this permit or applicable requirements; and

(e) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, utilize any photographic, recording, testing, monitoring, or other equipment for the purpose of assuring compliance with this permit or applicable requirements.

B.16 Transfer of Ownership or Operational Control [326 IAC 2-6.1-6]

(a) The Permittee must comply with the requirements of 326 IAC 2-6.1-6 whenever the Permittee seeks to change the ownership or operational control of the source and no other change in the permit is necessary.

(b) Any application requesting a change in the ownership or operational control of the source shall contain a written agreement containing a specific date for transfer of permit responsibility, coverage and liability between the current and new Permittee. The application shall be submitted to:


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Indiana Department of Environmental Management Permit Administration and Support Section, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 The application which shall be submitted by the Permittee does require an affirmation that the statements in the application are true and complete by an "authorized individual" as defined by 326 IAC 2-1.1-1(1).

(c) The Permittee may implement notice-only changes addressed in the request for a notice-

only change immediately upon submittal of the request. [326 IAC 2-6.1-6(d)(3)] B.17 Annual Fee Payment [326 IAC 2-1.1-7]

(a) The Permittee shall pay annual fees due no later than thirty (30) calendar days of receipt of a bill from IDEM, OAQ,.

(b) The Permittee may call the following telephone numbers: 1-800-451-6027 or

317-233-4230 (ask for OAQ, Billing, Licensing, and Training Section), to determine the appropriate permit fee.

B.18 Credible Evidence [326 IAC 1-1-6]

For the purpose of submitting compliance certifications or establishing whether or not the Permittee has violated or is in violation of any condition of this permit, nothing in this permit shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether the Permittee would have been in compliance with the condition of this permit if the appropriate performance or compliance test or procedure had been performed.


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SECTION C SOURCE OPERATION CONDITIONS

Entire Source

Emission Limitations and Standards [326 IAC 2-6.1-5(a)(1)]

C.1 Permit Revocation [326 IAC 2-1.1-9] Pursuant to 326 IAC 2-1.1-9 (Revocation of Permits), this permit to operate may be revoked for any of the following causes:

(a) Violation of any conditions of this permit.

(b) Failure to disclose all the relevant facts, or misrepresentation in obtaining this permit.

(c) Changes in regulatory requirements that mandate either a temporary or permanent

reduction of discharge of contaminants. However, the amendment of appropriate sections of this permit shall not require revocation of this permit.

(d) Noncompliance with orders issued pursuant to 326 IAC 1-5 (Episode Alert Levels) to

reduce emissions during an air pollution episode.

(e) For any cause which establishes in the judgment of IDEM, the fact that continuance of this permit is not consistent with purposes of this article.

C.2 Opacity [326 IAC 5-1]

Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-1 (Applicability) and 326 IAC 5-1-3 (Temporary Alternative Opacity Limitations), opacity shall meet the following, unless otherwise stated in this permit:

(a) Opacity shall not exceed an average of twenty percent (20%) in any one (1) six (6)

minute averaging period as determined in 326 IAC 5-1-4.

(b) Opacity shall not exceed sixty percent (60%) for more than a cumulative total of fifteen (15) minutes (sixty (60) readings as measured according to 40 CFR 60, Appendix A, Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a continuous opacity monitor) in a six (6) hour period.

C.3 Open Burning [326 IAC 4-1] [IC 13-17-9] The Permittee shall not open burn any material except as provided in 326 IAC 4-1-3, 326 IAC 4-1-4 or 326 IAC 4-1-6. The previous sentence notwithstanding, the Permittee may open burn in accordance with an open burning approval issued by the Commissioner under 326 IAC 4-1-4.1.

C.4 Incineration [326 IAC 4-2] [326 IAC 9-1-2]

The Permittee shall not operate an incinerator except as provided in 326 IAC 4-2 or in this permit. The Permittee shall not operate a refuse incinerator or refuse burning equipment except as provided in 326 IAC 9-1-2 or in this permit.

C.5 Fugitive Dust Emissions [326 IAC 6-4]

The Permittee shall not allow fugitive dust to escape beyond the property line or boundaries of the property, right-of-way, or easement on which the source is located, in a manner that would violate 326 IAC 6-4 (Fugitive Dust Emissions).


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C.6 Fugitive Particulate Matter Emissions [326 IAC 6.8-10-3]

Pursuant to 326 IAC 6.8-10-3 (formerly 326 IAC 6-1-11.1) (Lake County Fugitive Particulate Matter Control Requirements), the particulate matter emissions from source wide activities shall meet the following requirements:

(a) The average instantaneous opacity of fugitive particulate emissions from a paved road

shall not exceed ten percent (10%).

(b) The average instantaneous opacity of fugitive particulate emissions from an unpaved road shall not exceed ten percent (10%).

(c) The opacity of fugitive particulate emissions from exposed areas shall not exceed ten percent (10%) on a six (6) minute average.

(d) The opacity of fugitive particulate emissions from continuous transfer of material onto and out of storage piles shall not exceed ten percent (10%) on a three (3) minute average.

(e) The opacity of fugitive particulate emissions from storage piles shall not exceed ten percent (10%) on a six (6) minute average.

(f) There shall be a zero (0) percent frequency of visible emission observations of a material during the inplant transportation of material by truck or rail at any time.

(g) The opacity of fugitive particulate emissions from the inplant transportation of material by front end loaders and skip hoists shall not exceed ten percent (10%).

(h) Material processing facilities shall include the following:

(1) There shall be a zero (0) percent frequency of visible emission observations from a building enclosing all or part of the material processing equipment, except from a vent in the building.

(2) The PM10 emissions from building vents shall not exceed twenty-two thousandths

(0.022) grains per dry standard cubic foot and ten percent (10%) opacity.

(3) The PM10 stack emissions from a material processing facility shall not exceed twenty-two thousandths (0.022) grains per dry standard cubic foot and ten percent (10%) opacity.

(4) The opacity of fugitive particulate emissions from the material processing

facilities, except a crusher at which a capture system is not used, shall not exceed ten percent (10%) opacity.

(5) The opacity of fugitive particulate emissions from a crusher at which a capture

system is not used shall not exceed fifteen percent (15%).

(i) The opacity of particulate emissions from dust handling equipment shall not exceed ten percent (10%).

(j) Material transfer limits shall be as follows:

(1) The average instantaneous opacity of fugitive particulate emissions from batch transfer shall not exceed ten percent (10%).


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(2) Where adequate wetting of the material for fugitive particulate emissions control

is prohibitive to further processing or reuse of the material, the opacity shall not exceed ten percent (10%), three (3) minute average.

(3) Slag and kish handling activities at integrated iron and steel plants shall comply

with the following particulate emissions limits:

(A) The opacity of fugitive particulate emissions from transfer from pots and trucks into pits shall not exceed twenty percent (20%) on a six (6) minute average.

(B) The opacity of fugitive particulate emissions from transfer from pits into front end loaders and from transfer from front end loaders into trucks shall comply with the fugitive particulate emission limits in 326 IAC 6.8-10-3(9).

(k) Any facility or operation not specified in 326 IAC 6.8-10-3 shall meet a twenty percent

(20%), three (3) minute average opacity standard.

The Permittee shall achieve these limits by controlling fugitive particulate matter emissions according to the attached Fugitive Dust Control Plan.

C.7 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61, Subpart M]

(a) Notification requirements apply to each owner or operator. If the combined amount of regulated asbestos containing material (RACM) to be stripped, removed or disturbed is at least 260 linear feet on pipes or 160 square feet on other facility components, or at least thirty-five (35) cubic feet on all facility components, then the notification requirements of 326 IAC 14-10-3 are mandatory. All demolition projects require notification whether or not asbestos is present.

(b) The Permittee shall ensure that a written notification is sent on a form provided by the Commissioner at least ten (10) working days before asbestos stripping or removal work or before demolition begins, per 326 IAC 14-10-3, and shall update such notice as necessary, including, but not limited to the following: (1) When the amount of affected asbestos containing material increases or

decreases by at least twenty percent (20%); or (2) If there is a change in the following:

(A) Asbestos removal or demolition start date;

(B) Removal or demolition contractor; or

(C) Waste disposal site.

(c) The Permittee shall ensure that the notice is postmarked or delivered according to the guidelines set forth in 326 IAC 14-10-3(2).

(d) The notice to be submitted shall include the information enumerated in 326 IAC 14-10-3(3). All required notifications shall be submitted to:


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Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 The notice shall include a signed certification from the owner or operator that the information provided in this notification is correct and that only Indiana licensed workers and project supervisors will be used to implement the asbestos removal project.

(e) Procedures for Asbestos Emission Control The Permittee shall comply with the applicable emission control procedures in 326 IAC 14-10-4 and 40 CFR 61.145(c). Per 326 IAC 14-10-1, emission control requirements are applicable for any removal or disturbance of RACM greater than three (3) linear feet on pipes or three (3) square feet on any other facility components or a total of at least 0.75 cubic feet on all facility components.

(f) Demolition and Renovation The Permittee shall thoroughly inspect the affected facility or part of the facility where the demolition or renovation will occur for the presence of asbestos pursuant to 40 CFR 61.145(a).

(g) Indiana Licensed Asbestos Inspector The Permittee shall comply with 326 IAC 14-10-1(a) that requires the owner or operator, prior to a renovation/demolition, to use an Indiana Licensed Asbestos Inspector to thoroughly inspect the affected portion of the facility for the presence of asbestos. The requirement to use an Indiana Licensed Asbestos inspector is not federally enforceable.

Testing Requirements [326 IAC 2-6.1-5(a)(2)]

C.8 Performance Testing [326 IAC 3-6] (a) For performance testing required by this permit, a test protocol, except as provided

elsewhere in this permit, shall be submitted to:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251 no later than thirty-five (35) days prior to the intended test date.

(b) The Permittee shall notify IDEM, OAQ of the actual test date at least fourteen (14) days prior to the actual test date.

(c) Pursuant to 326 IAC 3-6-4(b), all test reports must be received by IDEM, OAQ not later than forty-five (45) days after the completion of the testing. An extension may be granted by IDEM, OAQ if the Permittee submits to IDEM, OAQ a reasonable written explanation not later than five (5) days prior to the end of the initial forty-five (45) day period.

Compliance Requirements [326 IAC 2-1.1-11]

C.9 Compliance Requirements [326 IAC 2-1.1-11] The commissioner may require stack testing, monitoring, or reporting at any time to assure compliance with all applicable requirements by issuing an order under 326 IAC 2-1.1-11. Any


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monitoring or testing shall be performed in accordance with 326 IAC 3 or other methods approved by the commissioner or the U. S. EPA.

Compliance Monitoring Requirements [326 IAC 2-6.1-5(a)(2)]

C.10 Compliance Monitoring [326 IAC 2-1.1-11] Compliance with applicable requirements shall be documented as required by this permit. The Permittee shall be responsible for installing any necessary equipment and initiating any required monitoring related to that equipment. All monitoring and record keeping requirements not already legally required shall be implemented when operation begins.

C.11 Instrument Specifications [326 IAC 2-1.1-11]

(a) When required by any condition of this permit, an analog instrument used to measure a parameter related to the operation of an air pollution control device shall have a scale such that the expected maximum reading for the normal range shall be no less than twenty percent (20%) of full scale. The analog instrument shall be capable of measuring values outside of the normal range.

(b) The Permittee may request that the IDEM, OAQ approve the use of an instrument that

does not meet the above specifications provided the Permittee can demonstrate that an alternative instrument specification will adequately ensure compliance with permit conditions requiring the measurement of the parameters.

Corrective Actions and Response Steps

C.12 Response to Excursions or Exceedances Upon detecting an excursion where a response step is required by the D Section or an exceedance of a limitation in this permit: (a) The Permittee shall take reasonable response steps to restore operation of the emissions

unit (including any control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing excess emissions.

(b) The response shall include minimizing the period of any startup, shutdown or

malfunction. The response may include, but is not limited to, the following: (1) initial inspection and evaluation; (2) recording that operations returned or are returning to normal without operator

action (such as through response by a computerized distribution control system); or

(3) any necessary follow-up actions to return operation to normal or usual manner of

operation. (c) A determination of whether the Permittee has used acceptable procedures in response to

an excursion or exceedance will be based on information available, which may include, but is not limited to, the following: (1) monitoring results; (2) review of operation and maintenance procedures and records; and/or


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(3) inspection of the control device, associated capture system, and the process.

(d) Failure to take reasonable response steps shall be considered a deviation from the

permit. (e) The Permittee shall record the reasonable response steps taken.

C.13 Actions Related to Noncompliance Demonstrated by a Stack Test

(a) When the results of a stack test performed in conformance with Section C - Performance Testing, of this permit exceed the level specified in any condition of this permit, the Permittee shall submit a description of its response actions to IDEM, OAQ, no later than seventy-five (75) days after the date of the test.

(b) A retest to demonstrate compliance shall be performed no later than one hundred eighty (180) days after the date of the test. Should the Permittee demonstrate to IDEM, OAQ that retesting in one hundred eighty (180) days is not practicable, IDEM, OAQ may extend the retesting deadline

(c) IDEM, OAQ reserves the authority to take any actions allowed under law in response to noncompliant stack tests.

Record Keeping and Reporting Requirements [326 IAC 2-6.1-5(a)(2)]

C.14 Malfunctions Report [326 IAC 1-6-2] Pursuant to 326 IAC 1-6-2 (Records; Notice of Malfunction):

(a) A record of all malfunctions, startups or shutdowns of any emission unit or emission

control equipment, that results in violations of applicable air pollution control regulations or applicable emission limitations must be kept and retained for a period of three (3) years and be made available to the Indiana Department of Environmental Management (IDEM), Office of Air Quality (OAQ) or appointed representative upon request.

(b) When a malfunction of any emission unit or emission control equipment occurs that lasts

more than one (1) hour, the condition shall be reported to OAQ, using the Malfunction Report Forms (2 pages). Notification must be made by telephone or other electronic means, as soon as practicable, but in no event later than four (4) daytime business hours after the beginning of the occurrence.

(c) Failure to report a malfunction of any emission unit or emission control equipment shall

constitute a violation of 326 IAC 1-6, and any other applicable rules. Information on the scope and expected duration of the malfunction must be provided, including the items specified in 326 IAC 1-6-2(c)(3)(A) through (E).

(d) Malfunction is defined as any sudden, unavoidable failure of any air pollution control

equipment, process, or combustion or process equipment to operate in a normal and usual manner. [326 IAC 1-2-39]

C.15 Emission Statement [326 IAC 2-6]

Pursuant to 326 IAC 2-6-3(a)(1), the Permittee shall submit an emission statement by July 1 following a calendar year when the source emits oxides of nitrogen or volatile organic compounds into the ambient air equal to or greater than twenty-five (25) tons. The emission statement shall contain, at a minimum, the information specified in 326 IAC 2-6-4. The statement must be submitted to:


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Indiana Department of Environmental Management Technical Support and Modeling Section, Office of Air Quality 100 North Senate Avenue MC 61-50 IGCN 1003 Indianapolis, Indiana 46204-2251

C.16 General Record Keeping Requirements [326 IAC 2-6.1-5]

(a) Records of all required monitoring data, reports and support information required by this permit shall be retained for a period of at least five (5) years from the date of monitoring sample, measurement, report, or application. These records shall be physically present or electronically accessible at the source location for a minimum of three (3) years. The records may be stored elsewhere for the remaining two (2) years as long as they are available upon request. If the Commissioner makes a request for records to the Permittee, the Permittee shall furnish the records to the Commissioner within a reasonable time.

(b) Unless otherwise specified in this permit, for all record keeping requirements not already legally required, the Permittee shall be allowed up to ninety (90) days from the date of permit issuance or the date of initial start-up, whichever is later, to begin such record keeping.

C.17 General Reporting Requirements [326 IAC 2-1.1-11] [326 IAC 2-6.1-2] [IC 13-14-1-13] (a) Reports required by conditions in Section D of this permit shall be submitted to:

Indiana Department of Environmental Management Compliance and Enforcement Branch, Office of Air Quality 100 North Senate Avenue MC 61-53 IGCN 1003 Indianapolis, Indiana 46204-2251

(b) Unless otherwise specified in this permit, any notice, report, or other submission required by this permit shall be considered timely if the date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or before the date it is due. If the document is submitted by any other means, it shall be considered timely if received by IDEM, OAQ on or before the date it is due.

(c) The first report shall cover the period commencing on the date of issuance of this permit

or the date of initial start-up, whichever is later, and ending on the last day of the reporting period. Reporting periods are based on calendar years, unless otherwise specified in this permit. For the purpose of this permit, “calendar year” means the twelve (12) month period from January 1 to December 31 inclusive.


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SECTION D.1 EMISSIONS UNIT OPERATION CONDITIONS

Emissions Unit Description:

(a) One (1) scrap metal shredder, approved in 2019 for construction, with a maximum capacity of 112 tons per hour, using an integral smart water injection system as fire/explosion suppression and particulate control, and exhausting to the atmosphere.

(b) One (1) Z-box/cyclone system, approved in 2019 for construction, with a maximum

capacity of 112 tons per hour of metal scrap separating heavy materials from light materials using a counter-flow forced air stream cascade system, equipped with a cyclone particle separator with cyclone exhaust recirculated internally within the Z-box separator and reused for the forced air stream cascade system.

(c) One (1) conveying system, consisting of twelve drop points, approved in 2019 for

construction, with a maximum capacity of 112 tons per hour, using no control, and exhausting to the atmosphere.

(d) One (1) granulator for insulated copper wire, constructed in 2018, with a maximum capacity of one (1) ton per hour, using no controls, and exhausting indoors.

(e) One (1) hand-held torch cutting station, constructed prior to 2000, with a maximum capacity of 3.5 tons per hour, using no controls, and exhausting outdoors.

(f) One (1) shear, constructed prior to 2000, with a maximum capacity of 25 tons per hour, using no controls, and exhausting outdoors.

(i) One (1) natural gas-fired hot water heater, with a maximum heat input capacity of

0.038 MMBtu per hour, using no controls, and exhausting to the atmosphere. (The information describing the process contained in this emissions unit description box is descriptive information and does not constitute enforceable conditions.)

Emission Limitations and Standards [326 IAC 2-6.1-5(a)(1)]

D.1.1 Volatile Organic Compounds (VOC) BACT Limits [326 IAC 8-1-6] In order to render the requirements 326 IAC 8-1-6 not applicable, the Permittee shall comply with the following: (a) The material throughput to the scrap metal shredder shall not exceed 330,000 tons per

twelve (12) consecutive month period with compliance determined at the end of each month.

(b) VOC emissions from the scrap metal shredder shall not exceed 0.117 lbs/ton of material

throughput. (c) The Permittee shall drain and remove (to the extent possible) VOC and VHAP containing

fluids from vehicles, appliances, industrial machinery, and other metal scrap received by the Permittee prior to shredding; or the Permittee shall document that inspections have been performed to confirm the non-existence of VOC and VHAP containing fluids. Fluids shall include, but are not limited to, gasoline, motor oil, antifreeze, transmission oil, brake oil, power steering fluid, hydraulic fluid, and differential fluid.

Compliance with this limit shall limit the VOC emissions from the scrap metal shredder to less


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than twenty-five (25) tons per twelve (12) consecutive month period and shall render the requirements of 326 IAC 8-1-6 (New facilities; general reduction requirements) not applicable.

D.1.2 Particulate Matter Emission Limits [326 IAC 6.8] Pursuant to 326 IAC 6.8-1-2(a) (Particulate Matter Limitations for Lake County), particulate matter (PM) emissions from the facilities listed in the table below, shall not exceed seven hundredths (0.07) gram per dry standard cubic meter (g/dscm) (three hundredths (0.03) grain per dry standard cubic foot (dscf).

Emission Unit Description Scrap Metal Shredder Z-box System Granulator Torch Cutting Station Shear Conveyors Natural Gas-fired Water Heater

D.1.3 Preventive Maintenance Plan [326 IAC 1-6-3]

A Preventive Maintenance Plan is required for these facilities and any control devices. Section B - Preventive Maintenance Plan contains the Permittee's obligation with regard to the preventive maintenance plan required by this condition.

Compliance Determination Requirements [326 IAC 2-6.1-5(a)(2)]

D.1.4 Particulate Matter In order to ensure compliance with Condition D.1.2, the integral smart water injection system shall be in operation and control emissions from the scrap metal shredder at all times that the scrap metal shredder is in operation.

D.1.5 Testing Requirements [326 IAC 2-1.1-11]

In order to demonstrate compliance with 326 IAC 2-6.1 (Minor Source Operating Permit (MSOP)), not later than 180 days after the startup of the scrap metal shredder, the Permittee shall perform VOC testing (before controls) of the scrap metal shredder to verify the VOC emission factor, utilizing methods approved by the commissioner. Testing shall be conducted in accordance with the provisions of 326 IAC 3-6 (Source Sampling Procedures). Section C – Performance Testing contains the Permittee’s obligation with regard to the performance testing required by this condition. Note: Sims may perform testing at the Paulina shredder in lieu of testing the shredder at the East Chicago location.

Compliance Monitoring Requirements [326 IAC 2-6.1-5(a)(2)]

D.1.6 Smart Water Injection System Failure Detection In the event that a malfunction of the integral smart water injection system has been observed: Failed units and the associated process will be shut down immediately until the failed units have been repaired or replaced. The emissions unit shall be shut down no later than the completion of the processing of the material in the emission unit. Operations may continue only if the event qualifies as an emergency and the Permittee satisfies the requirements of the emergency provisions of this permit (Section B - Emergency Provisions).


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Record Keeping and Reporting Requirements [326 IAC 2-6.1-5(a)(2)]

D.1.7 Record Keeping Requirement a) To document the compliance status with Condition D.1.1, the Permittee shall maintain the

following records:

(1) The material throughput to the scrap metal shredder each month and each compliance period;

(2) Records that VOC and VHAP containing fluids have been drained and removed

(to the extent practicable) from vehicles, appliances, industrial machinery, and other scrap metal received by the Permittee prior to shredding; and

(3) If the Permittee did not drain and remove VOC and VHAP containing fluids

onsite, records of the inspections performed to confirm the non-existence of VOC and VHAP containing fluids in vehicles, appliances, industrial machinery, and other metal scrap received by the Permittee prior to shredding.

(b) Section C - General Record Keeping Requirements of this permit contains the

Permittee’s obligations with regard to the records required by this condition. D.1.8 Reporting Requirements A quarterly summary of the information to document the compliance status with D.1.1 shall be

submitted not later than thirty (30) days after the end of the quarter being reported. Section C - General Reporting contains the Permittee’s obligation with regard to the reporting required by this condition


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Indiana Department of Environmental Management Office of Air Quality

Compliance and Enforcement Branch

Quarterly Report

Source Name: Sims Metal Management Source Address: 425 West 152nd Street, East Chicago, Indiana 46312 MSOP Permit No.: M089-41472-00608 Source: Scrap Metal Shredder Pollutant: Material Throughput Limit: The material throughput to the scrap metal shredder shall not exceed 330,000 tons per twelve (12) consecutive month period with compliance determined at the end of each month

QUARTER : YEAR:_____________________

Month

Material Throughput

(tons) Column 1

Material Throughput

(tons) Column 2

Material Throughput

(tons) Column 1 + Column 2

This Month

Previous 11 Months

12 Month Total

Form Completed by: Title / Position: Date:

Phone:


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OFFICE OF AIR QUALITY

COMPLIANCE AND ENFORCEMENT BRANCH

MINOR SOURCE OPERATING PERMIT ANNUAL NOTIFICATION

This form should be used to comply with the notification requirements under 326 IAC 2-6.1-5(a)(5).

Company Name: Sims Metal Management

Address: 425 West 152nd Street

City: East Chicago, Indiana 46312

Phone #: (773) 650-6495

MSOP #: M089-41472-00608

I hereby certify that Sims Metal Management is : still in operation. no longer in operation. I hereby certify that Sims Metal Management is : in compliance with the requirements of

MSOP M089-41472-00608. not in compliance with the requirements of

MSOP M089-41472-00608.

Authorized Individual (typed):

Title:

Signature:

Date:

If there are any conditions or requirements for which the source is not in compliance, provide a narrative description of how the source did or will achieve compliance and the date compliance was, or will be achieved.

Noncompliance:


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MALFUNCTION REPORT

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY COMPLIANCE AND ENFORCEMENT BRANCH

FAX NUMBER: (317) 233-6865

This form should only be used to report malfunctions applicable to Rule 326 IAC 1-6

and to qualify for the exemption under 326 IAC 1-6-4.

THIS FACILITY MEETS THE APPLICABILITY REQUIREMENTS BECAUSE IT HAS POTENTIAL TO EMIT 25 TONS/YEAR PARTICULATE MATTER ?_____, 25 TONS/YEAR SULFUR DIOXIDE ?_____, 25 TONS/YEAR NITROGEN OXIDES?_____, 25 TONS/YEAR VOC ?_____, 25 TONS/YEAR HYDROGEN SULFIDE ?_____, 25 TONS/YEAR TOTAL REDUCED SULFUR ?_____, 25 TONS/YEAR REDUCED SULFUR COMPOUNDS ?_____, 25 TONS/YEAR FLUORIDES ?_____, 100 TONS/YEAR CARBON MONOXIDE ?_____, 10 TONS/YEAR ANY SINGLE HAZARDOUS AIR POLLUTANT ?_____, 25 TONS/YEAR ANY COMBINATION HAZARDOUS AIR POLLUTANT ?_____, 1 TON/YEAR LEAD OR LEAD COMPOUNDS MEASURED AS ELEMENTAL LEAD ?_____, OR IS A SOURCE LISTED UNDER 326 IAC 2-5.1-3(2) ?_____. EMISSIONS FROM MALFUNCTIONING CONTROL EQUIPMENT OR PROCESS EQUIPMENT CAUSED EMISSIONS IN EXCESS OF APPLICABLE LIMITATION ________. THIS MALFUNCTION RESULTED IN A VIOLATION OF: 326 IAC _______ OR, PERMIT CONDITION # _______ AND/OR PERMIT LIMIT OF _______________ THIS INCIDENT MEETS THE DEFINITION OF “MALFUNCTION” AS LISTED ON REVERSE SIDE ? Y N THIS MALFUNCTION IS OR WILL BE LONGER THAN THE ONE (1) HOUR REPORTING REQUIREMENT ? Y N

COMPANY:_________________________________________________________PHONE NO. ( )___________________ LOCATION: (CITY AND COUNTY)_________________________________________________________________________ PERMIT NO. ________________ AFS PLANT ID: ________________ AFS POINT ID: ________________ INSP:__________ CONTROL/PROCESS DEVICE WHICH MALFUNCTIONED AND REASON:________________________________________ _____________________________________________________________________________________________________ DATE/TIME MALFUNCTION STARTED: _____/_____/ 20____ _________________________________________ AM / PM ESTIMATED HOURS OF OPERATION WITH MALFUNCTION CONDITION: _______________________________________

DATE/TIME CONTROL EQUIPMENT BACK-IN SERVICE______/______/ 20____ _______________ AM/PM

TYPE OF POLLUTANTS EMITTED: TSP, PM-10, SO2, VOC, OTHER:________________________________________ ESTIMATED AMOUNT OF POLLUTANT EMITTED DURING MALFUNCTION: _______________________________________ ______________________________________________________________________________________________________ MEASURES TAKEN TO MINIMIZE EMISSIONS:______________________________________________________________ ___________________________________________________________________________________________________ REASONS WHY FACILITY CANNOT BE SHUTDOWN DURING REPAIRS: CONTINUED OPERATION REQUIRED TO PROVIDE ESSENTIAL* SERVICES:_____________________________________ CONTINUED OPERATION NECESSARY TO PREVENT INJURY TO PERSONS:_____________________________________ CONTINUED OPERATION NECESSARY TO PREVENT SEVERE DAMAGE TO EQUIPMENT:__________________________ INTERIM CONTROL MEASURES: (IF APPLICABLE)____________________________________________________________ _____________________________________________________________________________________________________ _____________________________________________________________________________________________________ MALFUNCTION REPORTED BY:__________________________________TITLE:___________________________ (SIGNATURE IF FAXED) MALFUNCTION RECORDED BY:_______________________DATE:__________________TIME:__________________ *SEE PAGE 2

PAGE 1 OF 2


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Please note - This form should only be used to report malfunctions

applicable to Rule 326 IAC 1-6 and to qualify for the exemption under 326 IAC 1-6-4.

326 IAC 1-6-1 Applicability of rule Sec. 1. This rule applies to the owner or operator of any facility required to obtain a permit under 326 IAC 2-5.1 or 326 IAC 2-6.1. 326 IAC 1-2-39 “Malfunction” definition Sec. 39. Any sudden, unavoidable failure of any air pollution control equipment, process, or combustion or process equipment to operate in a normal and usual manner. *Essential services are interpreted to mean those operations, such as, the providing of electricity by power plants. Continued operation solely for the economic benefit of the owner or operator shall not be sufficient reason why a facility cannot be shutdown during a control equipment shutdown. If this item is checked on the front, please explain rationale: ________________________________________________________________________ ________________________________________________________________________

PAGE 2 OF 2

Attachment A:

FUGITIVE PARTICULATE MATTER EMISSIONS CONTROL PLAN

SIMS METAL MANAGEMENT 425 West 152nd Street

East Chicago, IN 46312

Scrap Metal Recycling Facility

Operation Permit No.: 089-41472-00608

Fugitive Particulate Matter Emissions Control Plan Page 2 of 5 Attachment A MSOP No. 089-41472-00608 1. Introduction: Keeping potential fugitive dust problems under control is an everyday job. Planning ahead and developing a dust prevention and control plan will assist this site in controlling this issue. This plan will address the following items: (1) A description of the operation at this facility. (2) Understanding where potential fugitive emission points are as outlined in a site map. (3) A description of:

(a) vehicle routes in and out of the facility, (b) how dust will be minimized during transport, (c) measures taken to minimize fugitive dust, i.e., continual maintenance, etc., (d) how vehicles are cleaned of loose material before they leave the facility.

(4) A map showing the path for the water truck and the scheduled times the water truck must be operated.

(5) A description of how the water truck will be used during times of increased fugitive dust. (6) A description of how the facility will suppress fugitive dust when the water truck is inoperable

(including periods of inclement weather and equipment malfunction). (7) A sample and description of the record keeping system, including the employees and supervisors

assigned to each task, which will include:

(a) An outline for the use of the water truck, in combination with water spray system; (b) An outline for the water truck during times of increased fugitive dust (in addition to the

minimum required); (c) An outline for routine inspections of the facility to ensure there is no visible fugitive dust

crossing the property line.

2. Potential Fugitive Emission Points The Sims Metal Management facility is a scrap metal recycling operation that purchases, sorts, processes, and ships recyclable ferrous metal products. Areas that pose the potential for fugitive emissions are:

• Paved and unpaved roadways

See Site Map. 2.1 Vehicle Routes in and out of the facility: Daily vehicle traffic patterns are denoted on the site map 2.2 Dust Minimization: Three methods will be immediately employed to minimize dust at the facility: (1) Roadways:

Fugitive Particulate Matter Emissions Control Plan Page 3 of 5 Attachment A MSOP No. 089-41472-00608

(a) Use of the Water Truck

(i) Routine Areas:

(A) The water truck will make daily rounds in areas identified as routine traffic areas by the source.

(ii) If the water truck experiences mechanical issues the bucket of the loader will be

used to disperse water on the roadways.

(2) Sweeping:

(a) Sweeping of improved surfaces, with attachment on skid steer will occur every other day or as needed. Roadways must be watered prior to use of the sweeper.

Records of watering and sweeping shall be maintained. 2.3 Vehicle Cleaning Station: A track‐out control device (rumble strips) is installed at end of the outbound truck scale requiring all large vehicles that leave the facility to travel over these strips. These rumble strips are installed in an effort to knock off any potential buildup of dirt from tires on vehicles. 3. Water Truck Path and Schedule As described in section 2.2, the water truck will make daily rounds of areas marked as identified as routine traffic areas by the source. A record will be maintained documenting this daily activity. It should be noted that when temperatures approach 32 degrees, adding water to ground surfaces will cause a serious safety hazard to employees, truck drivers and visitors to the site. Therefore the application of water to roadways will need to be curtailed. 4. Times of Increased Fugitive Emissions At times weather conditions or site activities may cause an increase in potential fugitive emissions. To ensure that these conditions are identified and addressed as soon as possible, the following steps will be taken: (1) The site supervisor, or designee, will make a minimum of three trips throughout the day around

the facility to see if any areas need to be addressed with water. These visual inspections will be documented.

(a) One of these inspections will be performed as part of the supervisor’s daily plant

inspection. (b) Site management will perform these walk around inspections during the times the water

truck is not operating.

(2) A Tool Box Talk will be provided to all employees reviewing the importance of immediately reporting to site management areas of the facility they see as needing additional suppressant. Site management will document this notification on the Fugitive Dust – Visual Site Inspection form along with actions taken.

5. Alternatives to Water Truck

Fugitive Particulate Matter Emissions Control Plan Page 4 of 5 Attachment A MSOP No. 089-41472-00608 In the event that the water truck is compromised, the bucket of the loader will be filled with water and dispersed through the facility. 6. Recordkeeping

(1) A log for the times the water truck, in combination with water spray system, must be operated,

(2) A log for the water truck in combination with water spray system, which will be used during times of increased fugitive dust (in addition to the minimum required),

(3) A log for routine inspections of the facility to ensure there is no visible fugitive dust crossing the property line.

Fugitive Particulate Matter Emissions Control Plan Page 5 of 5 Attachment A MSOP No. 089-41472-00608

Indiana Department of Environmental Management Office of Air Quality

Technical Support Document (TSD) for a Registration Transitioning to a

Minor Source Operating Permit (MSOP) and New Source Review

Source Description and Location

Source Name: Sims Metal Management Source Location: 425 West 152nd Street, East Chicago, IN 46312 County: Lake SIC Code: 5093 (Scrap and Waste Materials) Operation Permit No.: M089-41472-00608 Permit Reviewer: Kendra Sutherland On May 21, 2019, the Office of Air Quality (OAQ) received an application from Sims Metal Management, related to the construction and operation of new emission units at an existing stationary scrap metal recycling facility and a transition from a Registration to a MSOP.

Existing Approvals

The source has been operating under Registration No. R089-39762-00608, issued on May 11, 2018. There have been no subsequent approvals issued. Due to this application, the source is transitioning from a Registration to a MSOP.

County Attainment Status

The source is located in Lake County.

(a) Ozone Standards

U.S. EPA, in the Federal Register Notice 77 FR 34228 dated June 11, 2012, designated Lake County as nonattainment for the 2008 8-hour ozone standard. On August 1, 2012, the air pollution control board issued an emergency rule adopting the U.S. EPA’s designation. This rule became effective August 9, 2012. IDEM does not agree with U.S. EPA’s designation of nonattainment. IDEM filed a suit against U.S. EPA in the U.S. Court of Appeals for the DC Circuit

Pollutant Designation SO2 Better than national standards. CO Attainment effective February 18, 2000, for the part of the city of East Chicago bounded by Columbus Drive on

the north; the Indiana Harbor Canal on the west; 148th Street, if extended, on the south; and Euclid Avenue on the east. Unclassifiable or attainment effective November 15, 1990, for the remainder of East Chicago and Lake County.

O3 On June 11, 2012, the U.S. EPA designated Lake County nonattainment, for the 8-hour ozone standard. 1 2 PM2.5 Unclassifiable or attainment effective February 6, 2012, for the annual PM2.5 standard. PM2.5 Unclassifiable or attainment effective December 13, 2009, for the 24-hour PM2.5 standard. PM10 Attainment effective March 11, 2003, for the cities of East Chicago, Hammond, Whiting, and Gary.

Unclassifiable effective November 15, 1990, for the remainder of Lake County. NO2 Cannot be classified or better than national standards. Pb Unclassifiable or attainment effective December 31, 2011.

1The U. S. EPA has acknowledged in both the proposed and final rulemaking for this redesignation that the anti-backsliding provisions for the 1-hour ozone standard no longer apply as a result of the redesignation under the 8-hour ozone standard. Therefore, permits in Lake County are no longer subject to review pursuant to Emission Offset, 326 IAC 2-3 for the 1-hour standard.

2 The department has filed a legal challenge to U.S. EPA's designation in 77 FR 34228.

Sims Metal Management Page 2 of 12 East Chicago, Indiana TSD for New Source Review and MSOP No. M089-41472-00608 Permit Reviewer: Kendra Sutherland

on July 19, 2012. However, in order to assure that sources are not potentially liable for a violation of the Clean Air Act, the OAQ is following the U.S. EPA’s designation. Volatile organic compounds (VOC) and Nitrogen Oxides (NOx) are regulated under the Clean Air Act (CAA) for the purposes of attaining and maintaining the National Ambient Air Quality Standards (NAAQS) for ozone. Therefore, VOC and NOx emissions are considered when evaluating the rule applicability relating to ozone. Therefore, VOC and NOx emissions were evaluated pursuant to the requirements of Emission Offset, 326 IAC 2-3.

(b) PM2.5

Lake County has been classified as attainment for PM2.5. Therefore, direct PM2.5, SO2, and NOx emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

(c) Other Criteria Pollutants

Lake County has been classified as attainment or unclassifiable in Indiana for all the other criteria pollutants. Therefore, these emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

Fugitive Emissions

Since this type of operation is not one (1) of the twenty-eight (28) listed source categories under 326 IAC 2-2-1(ff)(1), 326 IAC 2-3-2(g), or 326 IAC 2-7-1(22)(B), and there is no applicable New Source Performance Standard or National Emission Standard for Hazardous Air Pollutants that was in effect on August 7, 1980, fugitive emissions are not counted toward the determination of PSD, Emission Offset, and Part 70 Permit applicability. The fugitive emissions of hazardous air pollutants (HAP) are counted toward the determination of Part 70 Permit applicability and source status under Section 112 of the Clean Air Act (CAA).

Greenhouse Gas (GHG) Emissions

On June 23, 2014, in the case of Utility Air Regulatory Group v. EPA, cause no. 12-1146, (available at http://www.supremecourt.gov/opinions/13pdf/12-1146_4g18.pdf) the United States Supreme Court ruled that the U.S. EPA does not have the authority to treat greenhouse gases (GHGs) as an air pollutant for the purpose of determining operating permit applicability or PSD Major source status. On July 24, 2014, the U.S. EPA issued a memorandum to the Regional Administrators outlining next steps in permitting decisions in light of the Supreme Court’s decision. U.S. EPA’s guidance states that U.S. EPA will no longer require PSD or Title V permits for sources “previously classified as ‘Major’ based solely on greenhouse gas emissions.” The Indiana Environmental Rules Board adopted the GHG regulations required by U.S. EPA at 326 IAC 2-2-1(zz), pursuant to Ind. Code § 13-14-9-8(h) (Section 8 rulemaking). A rule, or part of a rule, adopted under Section 8 is automatically invalidated when the corresponding federal rule, or part of the rule, is invalidated. Due to the United States Supreme Court Ruling, IDEM, OAQ cannot consider GHG emissions to determine operating permit applicability or PSD applicability to a source or modification.

Background and Description of Emission Units and Pollution Control Equipment

The Office of Air Quality (OAQ) has reviewed an application, submitted by Sims Metal Management on May 21, 2019, relating to the construction and operation of new emission units at an existing stationary scrap metal recycling facility and transition from a Registration to a MSOP. The following is a list of the new emission units: (a) One (1) scrap metal shredder, approved in 2019 for construction, with a maximum capacity of

112 tons per hour, using an integral smart water injection system as fire/explosion suppression and particulate control, and exhausting to the atmosphere.

http://www.supremecourt.gov/opinions/13pdf/12-1146_4g18.pdf

Sims Metal Management Page 3 of 12 East Chicago, Indiana TSD for New Source Review and MSOP No. M089-41472-00608 Permit Reviewer: Kendra Sutherland (b) One (1) Z-box/cyclone system, approved in 2019 for construction, with a maximum capacity of

112 tons per hour of metal scrap separating heavy materials from light materials using a counter-flow forced air stream cascade system, equipped with a cyclone particle separator with cyclone exhaust recirculated internally within the Z-box separator and reused for the forced air stream cascade system.

(c) One (1) conveying system, consisting of twelve drop points, approved in 2019 for construction,

with a maximum capacity of 112 tons per hour, using no control, and exhausting to the atmosphere.

The following is a list of the existing emission units and pollution control devices: (a) One (1) granulator for insulated copper wire, constructed in 2018, with a maximum capacity of

one (1) ton per hour, using no controls, and exhausting indoors. (b) One (1) hand-held torch cutting station, constructed prior to 2000, with a maximum capacity of 3.5

tons per hour, using no controls, and exhausting outdoors. (c) One (1) shear, constructed prior to 2000, with a maximum capacity of 25 tons per hour, using no

controls, and exhausting outdoors. (d) One (1) baler, constructed prior to 2000, with a maximum capacity of 500 tons per month, using

no controls, and exhausting outdoors. (e) Two (2) diesel storage tanks, identified as Tanks #1 and #2, constructed prior to 2000, each with

a maximum capacity of 10,000 gallons, each using no controls, and each exhausting outdoors. (f) One (1) natural gas-fired hot water heater, with a maximum heat input capacity of 0.038 MMBtu

per hour, using no controls, and exhausting to the atmosphere. (e) Paved and unpaved roads

“Integral Part of the Process” Determination

Sims Metal Management, has submitted the following justifications for considering the smart water injection system on the scrap metal shredder as an integral part of the metal shredding process and metal separation process, respectively: The materials input to the scrap metal shredder consist of vehicle bodies and other types of metals. Automobile bodies typically contain residual flammable liquids and flammable solids. The high speed shearing action of the shedder creates high instantaneous temperatures and sparks in the shredder. The simultaneous presence of flammable materials and ignition sources may result in fires and explosions within in shredder. In order to prevent fires and explosions, the smart water/foam injection system will be utilized at the shredder’s material input chute and rotary hammermills to thoroughly wet the material before and during shredding. This wetting process both prevents explosions within the shredder and extinguishes any materials that ignite. The smart water injection system is integral to the process because: 1. The smart water injection system serves a primary purpose other than pollution control. The

smart water injection system is necessary to prevent fires and explosions within the shredder and is designed with an interlock to operate at all times the shredder is in operation. Any fire or explosion within the shredder would cause equipment damage it and, therefore, must be prevented. Also, any solid materials that caught fire would be transported via the automatic conveyor system to downline processes, with the possibility of damaging other equipment. Because of the interlock, the shredder will automatically shut down if the water/foam spray


system were to fail. The smart water injection system has the secondary benefit of reducing fugitive dust emissions.

2. The smart water injection system has an overall positive net economic effect. The constant

operation of the smart water injection system while the shredder is in operation prevents explosions and fires which could result in damage to the shredding and conveying equipment and unplanned shutdowns of the process. Damage to the machinery would result in repair and replacement costs. Process shutdowns would result in loss of revenue. Either of these results would have substantial negative financial impacts on the company.

IDEM, OAQ have evaluated the justifications and agree that the smart water injection system for the scrap metal shredder will be considered as an integral part of the metal shredding process. For the scrap metal shredder, the potential to emit will be determined after the use of the smart water injection system. Operating conditions in the permit will specify that the smart water injection system shall be operated and control particulate emissions from the scrap metal shredder at all times that the scrap metal shredder is in operation, and the Permittee shall operate the smart water injection system in accordance with manufacturer’s specifications.

Enforcement Issues

There are no pending enforcement actions related to this source.

Emission Calculations

See Appendix A of this Technical Support Document for detailed emission calculations.

Permit Level Determination – MSOP Significant Permit Revision

Pursuant to 326 IAC 2-1.1-1(12), Potential to Emit is defined as “the maximum capacity of a stationary source or emission unit to emit any air pollutant under its physical and operational design. Any physical or operational limitation on the capacity of a source to emit an air pollutant, including air pollution control equipment and restrictions on hours of operation or type or amount of material combusted, stored, or processed shall be treated as part of its design if the limitation is enforceable by the U. S. EPA, IDEM, or the appropriate local air pollution control agency.” The following table is used to determine the appropriate permit level under 326 IAC 2-6.1-6. This table reflects the PTE before controls of the proposed revision. If the control equipment has been determined to be integral, the table reflects the potential to emit (PTE) after consideration of the integral control device.

PTE Before Controls of the New Emission Units (ton/year)

Process / Emission Unit PM PM10 PM2.51 SO2 NOX VOC CO Single

HAP2 Total HAPs

Shredder* 19.77 19.77 19.77 -- -- 57.38 -- 4.07 15.75 Conveyors 0.56 0.19 0.05 -- -- -- -- -- -- Z-box** negl. negl. negl. -- -- -- -- -- --

Total PTE Before Controls of the New Emission Units:

20.33 19.96 19.82 -- -- 57.38 -- 4.07 15.75

1PM2.5 listed is direct PM2.5. 2Single highest HAP. *The shredder uses an integral water spray injection system to minimize explosion and fire hazards. **The Z-box separator is a closed-loop system with no external exhaust point. Therefore emission are expected to be negligible.

Sims Metal Management Page 5 of 12 East Chicago, Indiana TSD for New Source Review and MSOP No. M089-41472-00608 Permit Reviewer: Kendra Sutherland Appendix A of this TSD reflects the detailed potential emissions of the proposed revision. Pursuant to 326 IAC 2-6.1-6(i)(1)(E), this MSOP is revised through a Significant Permit Revision because the proposed revision is not an Administrative Amendment or Minor Permit Revision and the proposed revision involves the construction of new emission units with potential to emit greater than or equal to twenty-five (25) tons per year of the following pollutants: Volatile Organic Compounds (VOC). This SPR will be incorporated into this MSOPwith NSR.

Permit Level Determination – MSOP

This table reflects the unrestricted potential emissions of the source. If the control equipment has been determined to be integral, the table reflects the potential to emit (PTE) after consideration of the integral control device.

Unrestricted Source-Wide Emissions (ton/year)

PM1 PM101 PM2.51, 2 SO2 NOX VOC CO Single HAP3

Total HAPs

Total PTE of Entire Source Excluding Fugitives*

21.65 21.59 21.54 0.00 0.02 57.38 0.01 15.75 4.07

Title V Major Source Thresholds NA 100 100 100 100 100 100 10 25

PSD Major Source Thresholds 250 250 250 250 250 250 250 -- --

Emission Offset Major Source Thresholds --- NA NA NA 100 100 NA --- ---

1Under the Part 70 Permit program (40 CFR 70), PM10 and PM2.5, not particulate matter (PM), are each considered as a "regulated air pollutant.” 2PM2.5 listed is direct PM2.5. 3Single highest source-wide HAP. *Fugitive HAP emissions are always included in the source-wide emissions. *The shredder uses an integral water spray injection system to minimize explosion and fire hazards. **The Z-box separator is a closed-loop system with no external exhaust point. Therefore emission sare expected to be negligible. ***HAPs calculated using worst case operations from the shredder

Appendix A of this TSD reflects the detailed unrestricted potential emissions of the source. (a) The potential to emit (as defined in 326 IAC 2-1.1-1) of VOC is less than one hundred (100) tons

per year, but greater than or equal to twenty-five (25) tons per year. The potential to emit of all other criteria pollutants is less than twenty-five (25) tons per year. Therefore, the source is subject to the provisions of 326 IAC 2-6.1. The source will be issued an Minor Source Operating Permit (MSOP).

(b) The potential to emit (as defined in 326 IAC 2-1.1-1) of any single HAP is less than ten (10) tons

per year and the potential to emit (as defined in 326 IAC 2-1.1-1) of a combination of HAPs is less than twenty-five (25) tons per year. Therefore, this source is an area source under Section 112 of the Clean Air Act (CAA) and not subject to the provisions of 326 IAC 2-7. The source will be issued an Minor Source Operating Permit (MSOP).


Federal Rule Applicability Determination

Federal rule applicability for this source has been reviewed as follows: New Source Performance Standards (NSPS): (a) The requirements of the New Source Performance Standard for Metallic Mineral Processing

Plants, 40 CFR 60, Subpart LL, are not included in the permit since the source does not meet the definition of a metallic mineral processing plant, as defined in 40 CFR 60.381. The source operates a scrap metal recycling facility and does not produce metallic mineral concentrates from ore.

(b) The requirements of the New Source Performance Standard for Volatile Organic Liquid Storage

Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984, 40 CFR 60, Subpart Kb (326 IAC 12), are not included in the permit, since the two (2) diesel tanks each have a storage capacity less than 75 cubic meters (19,813 gallons). Each of the two (2) diesel tanks have storage capacity of 10,000 gallons.

(c) There are no New Source Performance Standards (NSPS) (326 IAC 12 and 40 CFR Part 60)

included in the permit. National Emission Standards for Hazardous Air Pollutants (NESHAP): (a) The requirements of the National Emission Standards for Hazardous Air Pollutants (NESHAPs)

for Industrial, Commercial, and Institutional Boilers Area Sources, 40 CFR 63.11193, Subpart JJJJJJ (6J), are not included in the permit, since hot water heaters are exempt under 40 CFR 63.11195(f).

(b) The requirements of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for

Primary Nonferrous Metals Area Sources- Zinc, Cadmium and Beryllium, 40 CFR 63, Subpart GGGGGG are not included in the permit since the source is not a primary zinc production facility or primary beryllium production facility. The source is a scrap metal recycling facility.

(c) The requirements of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for

Secondary Nonferrous Metals Processing Area Sources, 40 CFR 63, Subpart TTTTTT are not included in the permit since the source does not engage in secondary nonferrous metals processing as defined in 40 CFR 63.11472.

(d) The requirements of the National Emission Standards for Hazardous Air Pollutants (NESHAPs)

for Nine Metal Fabrication and Finishing Source Categories, 40 CFR 63, Subpart XXXXXX, are not included in the permit since the source is not primarily engaged in operations which are classified in one of the nine source categories listed in 40 CFR 63.11514(a)(1) through (9).

(e) The requirements of the National Emission Standards for Hazardous Air Pollutants (NESHAPs)

from Off-Site Waste and Recovery Operations, 40 CFR 63, Subpart DD, are not included in the permit, since this source is not located or part of a major source of HAPs.

(f) There are no National Emission Standards for Hazardous Air Pollutants under 40 CFR 63, 326

IAC 14 and 326 IAC 20 included in the permit. Compliance Assurance Monitoring (CAM): (a) Pursuant to 40 CFR 64.2, Compliance Assurance Monitoring (CAM) is not included in the permit,

because the unlimited potential to emit of the source is less than the Title V major source thresholds and the source is not required to obtain a Part 70 or Part 71 permit.


State Rule Applicability - Entire Source

State rule applicability for this source has been reviewed as follows: 326 IAC 2-4.1 (Major Sources of Hazardous Air Pollutants (HAP)) The operation of this source will emit less than ten (10) tons per year for a single HAP and less than twenty-five (25) tons per year for a combination of HAPs. Therefore, 326 IAC 2-4.1 does not apply. 326 IAC 2-6 (Emission Reporting) Pursuant to 326 IAC 2-6-3(a)(1), the Permittee shall submit an emission statement by July 1 following a calendar year when the source emits oxides of nitrogen or volatile organic compounds into the ambient air equal to or greater than twenty-five (25) tons. The emission statement shall contain, at a minimum, the information specified in 326 IAC 2-6-4. 326 IAC 5-1 (Opacity Limitations) Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-3 (Temporary Alternative Opacity Limitations), opacity shall meet the following, unless otherwise stated in this permit: (1) Opacity shall not exceed an average of twenty percent (20%) in any one (1) six (6) minute

averaging period as determined in 326 IAC 5-1-4.

(2) Opacity shall not exceed sixty percent (60%) for more than a cumulative total of fifteen (15) minutes (sixty (60) readings as measured according to 40 CFR 60, Appendix A, Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a continuous opacity monitor) in a six (6) hour period.

326 IAC 6-4 (Fugitive Dust Emissions Limitations) The source is subject to the requirements of 326 IAC 6-4, because the fugitive sources have the potential to emit fugitive particulate emissions. Pursuant to 326 IAC 6-4 (Fugitive Dust Emissions Limitations), the source shall not allow fugitive dust to escape beyond the property line or boundaries of the property, right-of-way, or easement on which the source is located, in a manner that would violate 326 IAC 6-4. 326 IAC 6-5 (Fugitive Particulate Matter Emission Limitations) This source is not subject to the requirements of 326 IAC 6-5, because the source has potential fugitive particulate emissions of less than twenty-five (25) tons per year. 326 IAC 6.5 (Particulate Matter Limitations Except Lake County) Pursuant to 326 IAC 6.5-1-1(a), this source (located in Lake County) is not subject to the requirements of 326 IAC 6.5 because it is not located in one of the following counties: Clark, Dearborn, Dubois, Howard, Marion, St. Joseph, Vanderburgh, Vigo or Wayne. 326 IAC 6.8 (Particulate Matter Limitations for Lake County) This source (located in Lake County) is not one of the sources specifically listed in 326 IAC 6.8-4, 326 IAC 6.8-5, or 326 IAC 6.8-8 through 326 IAC 6.8-11. The source-wide PTE of PM is 10 tons per year or more. Therefore, this source is subject to the requirements of 326 IAC 6.8-1-2 because the source-wide actual emissions of PM can be 10 tons per year or more. 326 IAC 6.8 (Lake County: Fugitive Particulate Matter) This source (located in Lake County) is not one of the sources specifically listed in 326 IAC 6.8-10-1(2)(A) through (V). The source-wide unlimited PTE of fugitive PM and PM10 is 5 tons per year or more. Therefore, this source is subject to the requirements of 326 IAC 6.8-10. (a) Pursuant to 326 IAC 6.8-10-3, the particulate matter emissions from source wide activities shall

meet the following requirements:

(1) The average instantaneous opacity of fugitive particulate emissions from a paved road shall not exceed ten percent (10%).


(2) The average instantaneous opacity of fugitive particulate emissions from an unpaved road shall not exceed ten percent (10%).

(3) The opacity of fugitive particulate emissions from exposed areas shall not exceed ten

percent (10%) on a six (6) minute average.

(4) The opacity of fugitive particulate emissions from continuous transfer of material onto and out of storage piles shall not exceed ten percent (10%) on a three (3) minute average.

(5) The opacity of fugitive particulate emissions from storage piles shall not exceed ten

percent (10%) on a six (6) minute average.

(6) There shall be a zero (0) percent frequency of visible emission observations of a material during the inplant transportation of material by truck or rail at any time.

(7) The opacity of fugitive particulate emissions from the inplant transportation of material by

front end loaders and skip hoists shall not exceed ten percent (10%).

(8) Material processing facilities shall include the following:

(A) There shall be a zero (0) percent frequency of visible emission observations from a building enclosing all or part of the material processing equipment, except from a vent in the building.

(B) The PM10 emissions from building vents shall not exceed twenty-two

thousandths (0.022) grains per dry standard cubic foot and ten percent (10%) opacity.

(C) The PM10 stack emissions from a material processing facility shall not exceed

twenty-two thousandths (0.022) grains per dry standard cubic foot and ten percent (10%) opacity.

(D) The opacity of fugitive particulate emissions from the material processing

facilities, except a crusher at which a capture system is not used, shall not exceed ten percent (10%) opacity.

(E) The opacity of fugitive particulate emissions from a crusher at which a capture

system is not used shall not exceed fifteen percent (15%).

(9) The opacity of particulate emissions from dust handling equipment shall not exceed ten percent (10%).

(10) Material transfer limits shall be as follows:

(A) The average instantaneous opacity of fugitive particulate emissions from batch

transfer shall not exceed ten percent (10%).

(B) Where adequate wetting of the material for fugitive particulate emissions control is prohibitive to further processing or reuse of the material, the opacity shall not exceed ten percent (10%), three (3) minute average.

(C) Slag and kish handling activities at integrated iron and steel plants shall comply

with the following particulate emissions limits:


(i) The opacity of fugitive particulate emissions from transfer from pots and trucks into pits shall not exceed twenty percent (20%) on a six (6) minute average.

(ii) The opacity of fugitive particulate emissions from transfer from pits into

front end loaders and from transfer from front end loaders into trucks shall comply with the fugitive particulate emission limits in 326 IAC 6.8-10-3(9).

(11) Any facility or operation not specified in 326 IAC 6.8-10-3 shall meet a twenty percent

(20%), three (3) minute average opacity standard.

The Permittee shall achieve these limits by controlling fugitive particulate matter emissions according to the Fugitive Dust Control Plan, which is included as Attachment A to the permit.

326 IAC 6.8-8 (Lake County: Continuous Compliance Plan) The requirements of 326 IAC 6.8-8 are not applicable to the source, since it is not specifically listed in 326 IAC 6.8-8-1(1) through 326 IAC 6.8-8-1(17) and the source does not qualify under 326 IAC 6.8-8-1(18), since it does not have boilers equal to or greater than twenty-five million British thermal units per hour, does not perform manufacturing operations inside a building, and the uncontrolled PM10 or TSP emissions are not greater than 100 tons per year.

State Rule Applicability – Individual Facilities

State rule applicability for this source has been reviewed as follows: Shredder 326 IAC 6.8 (Particulate Matter Limitations for Lake County) Pursuant to 326 IAC 6.8-1-2(a), the particulate emissions from the scrap metal shredder shall not exceed seven-hundredths (0.07) gram per dry standard cubic meter (g/dscm) (three-hundredths (0.03) grain per dry standard cubic foot (dscf)). 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes) Pursuant to 326 IAC 6-3-1(c)(3), the shredding operation is not subject to the requirements of 326 IAC 6-3, since the shredding operation is subject to a more stringent PM limit under 326 IAC 6.8 (Particulate Matter Limitations for Lake County). 326 IAC 8-1-6 (VOC Rules: General Reduction Requirements for New Facilities) This scrap metal shredder was constructed after January 1, 1980, and its unlimited VOC potential emissions are equal to or greater than twenty-five (25) tons per year and the scrap metal shredder is not regulated by other rules in 326 IAC 8. The source has opted to limit the potential to emit VOC from the scrap metal shredder to less than twenty-five (25) tons per twelve (12) consecutive month period in order to render the requirements of 326 IAC 8-1-6 not applicable. Therefore, the scrap metal shredder is not subject to the requirements of 326 IAC 8-1-6. In order to render the requirements of 326 IAC 8-1-6 not applicable, Permittee shall comply with the following: (a) The material throughput to the scrap metal shredder shall not exceed 330,000 tons per twelve

(12) consecutive month period with compliance determined at the end of each month. (b) VOC emissions from the scrap metal shredder shall not exceed 0.117 lbs/ton of material

throughput. (c) The Permittee shall drain and remove (to the extent possible) VOC and VHAP containing fluids

from vehicles, appliances, industrial machinery, and other metal scrap received by the Permittee


prior to shredding; or the Permittee shall document that inspections have been performed to confirm the non-existence of VOC and VHAP containing fluids. Fluids shall include, but are not limited to, gasoline, motor oil, antifreeze, transmission oil, brake oil, power steering fluid, hydraulic fluid, and differential fluid.

Compliance with these limits shall limit the potential to emit VOC from the scrap metal shredder to less than twenty five (25) tons per twelve (12) consecutive month period, and shall render the requirements of 326 IAC 8-1-6 (New Facilities: General Reduction Requirements) not applicable.

Conveyors 326 IAC 6.8 (Particulate Matter Limitations for Lake County) Pursuant to 326 IAC 6.8-1-2(a), the particulate emissions the conveyor system shall not exceed seven-hundredths (0.07) gram per dry standard cubic meter (g/dscm) (three-hundredths (0.03) grain per dry standard cubic foot (dscf)). 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes) Pursuant to 326 IAC 6-3-1(c)(3), the conveyor system is not subject to the requirements of 326 IAC 6-3, since the conveyor is subject to a more stringent PM limit under 326 IAC 6.8 (Particulate Matter Limitations for Lake County). Torch Cutting, Granulator and Shear 326 IAC 6.8 (Particulate Matter Limitations for Lake County) Pursuant to 326 IAC 6.8-1-2(a), the particulate emissions from the granulator, torch cutting and shear shall each not exceed seven-hundredths (0.07) gram per dry standard cubic meter (g/dscm) (three-hundredths (0.03) grain per dry standard cubic foot (dscf)). 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes) Pursuant to 326 IAC 6-3-1(c)(3), the granulator, torch cutting and shear are not subject to the requirements of 326 IAC 6-3, since these units are subject to a more stringent PM limit under 326 IAC 6.8 (Particulate Matter Limitations for Lake County). Z-box 326 IAC 6.8 (Particulate Matter Limitations for Lake County) Pursuant to 326 IAC 6.8-1-2(a), the particulate emissions from the Z-box shall not exceed seven-hundredths (0.07) gram per dry standard cubic meter (g/dscm) (three-hundredths (0.03) grain per dry standard cubic foot (dscf)). 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes) Pursuant to 326 IAC 6-3-1(c)(3), the z-box is not subject to the requirements of 326 IAC 6-3, since the z-box is subject to a more stringent PM limit under 326 IAC 6.8 (Particulate Matter Limitations for Lake County). Hot Water Heater 326 IAC 6-2-4 (Particulate Matter Emission Limitations for Sources of Indirect Heating) The hot water heater is not subject to the requirements of 326 IAC 6-2-4, since hot water heater does not use combustion for indirect heating, as defined at 326 IAC 1-2-19. 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes) Pursuant to 326 IAC 1-2-59, the requirements of 326 IAC 6-3-2 are not applicable to the hot water heater, since liquid and gaseous fuels and combustion air are not considered as part of the process weight. 326 IAC 6.8 (Particulate Matter Limitations for Lake County)

Sims Metal Management Page 11 of 12 East Chicago, Indiana TSD for New Source Review and MSOP No. M089-41472-00608 Permit Reviewer: Kendra Sutherland Pursuant to 326 IAC 6.8-1-2(a), the particulate emissions the hot water heater shall not exceed seven-hundredths (0.07) gram per dry standard cubic meter (g/dscm) (three-hundredths (0.03) grain per dry standard cubic foot (dscf)).

Compliance Determination and Monitoring Requirements

Permits issued under 326 IAC 2-8 are required to assure that sources can demonstrate compliance with all applicable state and federal rules on a continuous basis. All state and federal rules contain compliance provisions, however, these provisions do not always fulfill the requirement for a continuous demonstration. When this occurs, IDEM, OAQ, in conjunction with the source, must develop specific conditions to satisfy 326 IAC 2-8-4. As a result, Compliance Determination Requirements are included in the permit. The Compliance Determination Requirements in Section D of the permit are those conditions that are found directly within state and federal rules and the violation of which serves as grounds for enforcement action. If the Compliance Determination Requirements are not sufficient to demonstrate continuous compliance, they will be supplemented with Compliance Monitoring Requirements, also in Section D of the permit. Unlike Compliance Determination Requirements, failure to meet Compliance Monitoring conditions would serve as a trigger for corrective actions and not grounds for enforcement action. However, a violation in relation to a compliance monitoring condition will arise through a source's failure to take the appropriate corrective actions within a specific time period. (a) The Compliance Determination Requirements applicable to this source are as follows:

(1) The integral water spray injection system shall be in operation and control emissions from the scrap metal shredder at all times that the scrap metal shredder is in operation

Testing Requirements:

Summary of Testing Requirements Emission Unit Timeframe for Testing or

Date of Initial Valid Demonstration)

Pollutant/ Parameter

Frequency of Testing

Scrap Metal Shredder*

Not later than 180 days after the startup

VOC One Time Testing*

*The VOC emission factor used in potential to emit calulations is the average from the Sims Metal Management Johnston, Rhode Island Facility stack tests performed on September 15, 18, and 20, 2017 for a 50/50 mix of auto and white goods. The East Chicago location will be using the same the mix of material (50/50 mix of auto and white goods). The material that will be processed at the Sims East Chicago shredder will also be comparable with the infeed material at the existing Sims Paulina shredder, located in Chicago, Illinois. Due to the expense of creating a test setup at East Chicago, and because of the similar mix of material being shredded, IDEM OAQ has approved using the upcoming stack test results of the Paulina shredder in lieu of testing the shredder at the East Chicago location. If the East Chicago shredder ever changes the type of material mix fed to the shredder, testing at the source's shredder may be required.

Testing is necessary in order to verify the VOC emission factor and to comply with 326 IAC 8-1-6 (BACT) avoidance limts.


Conclusion and Recommendation

Unless otherwise stated, information used in this review was derived from the application and additional information submitted by the applicant. An application for the purposes of this review was received on May 21, 2019. The construction and operation of this source shall be subject to the conditions of the attached proposed New Source Review and MSOP No. M089-41472-00608. The staff recommends to the Commissioner that the New Source Review and MSOP be approved.

IDEM Contact

(a) If you have any questions regarding this permit, please contact Kendra Sutherland, Indiana Department Environmental Management, Office of Air Quality, Permits Branch, 100 North Senate Avenue, MC 61-53 IGCN 1003, Indianapolis, Indiana 46204-2251, or by telephone at (317) 234-5401 or (800) 451-6027, and ask for Kendra Sutherland or (317) 234-5401.

(b) A copy of the findings is available on the Internet at: http://www.in.gov/ai/appfiles/idem-caats/ (c) For additional information about air permits and how the public and interested parties can

participate, refer to the IDEM Air Permits page on the Internet at: http://www.in.gov/idem/airquality/2356.htm; and the Citizens' Guide to IDEM on the Internet at: http://www.in.gov/idem/6900.htm.

http://www.in.gov/ai/appfiles/idem-caats/

http://www.in.gov/idem/airquality/2356.htm

http://www.in.gov/idem/6900.htm

P age 1 of 13, T S D App. A

Appendix A: Emission CalculationsPTE Summary

Company Name: Sims Metal ManagementSource Address: 425 W. 152nd Street, East Chicago, IN 46312Permit Number: M089-41472-00608

Reviewer: Kendra Sutherland

Emission Unit PM PM10 PM2.5 1 SO2 NOx VOC CO Total HAPsHighest Single

HAP4

Granulator 1.88 1.82 1.77 -- -- -- -- -- --Diesel Tanks -- -- -- -- -- 2.82E-03 -- 3.70E-04 6.50E-05Hot Water Heater 3.10E-04 1.24E-03 1.24E-03 9.79E-05 1.63E-02 8.97E-04 1.37E-02 3.08E-04 5.548E-07Shredder5 19.77 19.77 19.77 -- -- 57.38 -- 15.75 4.07Z-box2 negl. negl. negl. -- -- -- -- -- --Baler3 negl. negl. negl.Total 21.65 21.59 21.54 0.00 0.02 57.38 0.01 15.75 4.07Fugitive Emissions --Torch Cutting 0.26 0.26 0.26 -- -- -- -- -- --Shear 0.33 0.12 0.12 -- -- -- -- -- --Conveyors 0.56 0.19 0.05 -- -- -- -- -- --Paved Roads 2.57 0.51 0.13 -- -- -- -- -- --Unpaved Roads 10.85 2.89 0.29 -- -- -- -- -- --Fugitive Total 14.58 3.97 0.85 -- -- -- -- -- --Total Including Fugitives 36.22 25.56 22.39 9.79E-05 0.02 57.38 0.01 15.75 4.07(1) PM2.5 listed is direct PM2.5(2) The Z-box separator is a closed-loop system with no external exhaust point. Therefore emission sare expected to be negligible. (3) The baler takes the metal scrap and compresses it into large cubes or bales of material. The process produces negligible emissions.(4) Highest single source-wide HAP is toluene(5) HAPs calculated using worst case operations from the shredder

Uncontrolled Potential to Emit (tons/yr)


Appendix A: Emission CalculationsSignificant Permit Revision



Emission Unit PM PM10 PM2.5 * SO2 NOx VOC CO Total HAPs

Highest Single HAP**

Shredder 19.77 19.77 19.77 - - 57.38 - 15.75 4.07Conveyors 0.56 0.19 0.05 - - - - - -Z-box** negl. negl. negl. - - - - - -Total 20.33 19.96 19.82 - - 57.38 - 15.75 4.07*The Z-box separator is a closed-loop system with no external exhaust point. Therefore emission sare expected to be negligible. **Highest HAP is toluene

Uncontrolled Potential to Emit (tons/yr)


Appendix A: Emissions CalculationsICW Granulator



Calculations provided by source and approved by IDEM.

Hourly Emissions EstimateThroughput

(ton/hr) PM PM10 PM2.5 PM PM10 PM2.5 PM PM10 PM2.5

Insulated Copper Wire (ICW) to Pre-Cutting Material Transfer ICW 1 3.31E-03 1.56E-03 2.37E-04 3.31E-03 1.56E-03 2.37E-04 1.45E-02 6.85E-03 1.04E-03

Wire Cutting ICW 1 0.40 0.40 0.40 0.40 0.40 0.40 1.77 1.77 1.77

Wire Insulation Waste Drop Point Waste Material 1 2.54E-02 1.20E-02 1.82E-03 2.54E-02 1.20E-02 1.82E-03 1.11E-01 5.25E-02 7.95E-03Total: 0.43 0.41 0.40 1.88 1.82 1.77

Notes:2 ICW moisture content ranges from 3% to 10% based on Sims MM experience. Using low end for conservative estimate.

Methodology:Hourly Emission Rate (lb/hr) = Throughput (ton/hr) * Emission Factor (lb/ton)Potential to Emit (ton/yr) = Hourly Emission Rate (lb/hr) * 8760 hours / 2000 lbs

Material Drop Equations (AP-42,Section 13.2.4.3)

M1 = 3 % for ICW - Based on information from Sims MM - & moisture varies from 3% to 10%M2 = 0.7 % for Light Materials - (AP-42, Table 13.2.4-1 for crushed limestone - conservative)

U = 10.00

k = 0.74 PM - (AP-42, Section 13.2.4, for Particle Size < 30 um)0.35 PM10 - (AP-42, Section 13.2.4, for Particle Size < 10 um)0.053 PM2.5 - (AP-42, Section 13.2.4, for Particle Size < 2.5 um)

mph - (average annual wind speed for Gary, IN) https://www.timeanddate.com/weather/usa/gary/climate

Emission Point Material (lb/ton of throughput) (lb/hr)Potential to Emit

(ton/yr)

*Wire Cutting Emission factor from Institute of Scrap Recycling Industries, Inc. "Title V Applicability Workbook" App. D Table D-10.E. The emission factor was derived by back calculating from the after control value given in the document and divided by the control efficiency of 90%.

Emission Factor * Hourly Emission Rate

( )( )1.4

1.3

M/2U/5 (0.0032)k E =


Appendix A: Emissions CalculationsHand-held Torch Cutting Station



Calculations provided by source and approved by IDEM.Emission Unit Number of Max. Op. PM/PM10/PM2.5 PM/PM10/PM2.5 PM/PM10/PM2.5

Stations Hours Emission Factor1,2 Emissions Emissions(hrs/yr) (lb/hr) (lb/yr) (ton/yr)

Hand-Held Torch Cutting 1 8,760 0.06 525.6 0.26

Notes1 Emission factor published in 1996 Versar Report for Institute of Scrap Recycling Industries, Inc. "Title V Applicability Workbook"Table D-52 Assume PM10 = PM2.5


Appendix A: Emissions CalculationsShear Particulate Emissions



Number of drop points: 1

Calculations provided by source and approved by IDEM.

Process Description Throughput1 PM Emission Factor

PM10/PM2.5 Emission Factor

Uncontrolled PM Emissions

Uncontrolled PM10/PM2.5 Emissions

Uncontrolled PM Emissions

Uncontrolled PM10/PM2.5 Emissions

(ton/hr) (lb/ton) (lb/ton) (lb/hr) (lb/hr) (tpy) (tpy)Shear 25.0 0.003 0.0011 0.08 0.0275 0.33 0.12045

Notes1 Provided by facilityDue to the nature of the emission process the emission factors are a conservative estimate. MethodologyUncontrolled PTE of PM/PM10/PM2.5 (tons/yr) = Throughput (ton/hr) x Emission Factor (lb/ton) / 2,000 lbs/ton x 8,760 hrs/yearUncontrolled PTE of PM/PM10/PM2.5 (lbs/hr) = Uncontrolled PTE of PM/PM10/PM2.5 (tons/yr) * 8,760 hrs/year / 2,000 lbs/ton


Appendix A: Emissions CalculationsDiesel Tanks



Calculations provided by source and approved by IDEM.Emissions from Product Storage Tanks

Tank ID Tank Contents Tank Volume Total VOC Emissions Total VOC Emissions(lbs/yr) (tpy)

Tank #1 Diesel 10,000 2.61 1.31E-03Tank #2 Diesel 10,000 3.02 1.51E-03

Total: 2.82E-03HAP Emissions

HAPTank #1 HAP

Emissions(lb/yr)

Tank #2 HAP Emissions

(lb/yr)Total Single HAP

(ton/yr)Benzene 0.01 0.01 1.00E-05Xylene 0.15 0.18 1.65E-04

n-Hexane <0.01 <0.01 0.00E+00Toluene 0.06 0.07 6.50E-05

1,2,4-Trimethylbenzene 0.11 0.13 1.20E-04

Ethylbenzene 0.01 0.01 1.00E-05TOTAL HAPs (tpy): 1.70E-04 2.00E-04

Notes1 Emissions calculated using Tanks 4.0.9d


Appendix A: Emissions CalculationsNatural Gas Combustion Only

MM BTU/HR <100



HHVHeat Input Capacity mmBtu Potential Throughput

MMBtu/hr mmscf MMCF/yr0.038 1020 0.3

Pollutant PM* PM10* direct PM2.5* SO2 NOx VOC COEmission Factor in lb/MMCF 1.9 7.6 7.6 0.6 100 5.5 84

**see belowPotential Emission in tons/yr 3.10E-04 1.24E-03 1.24E-03 9.79E-05 1.63E-02 8.97E-04 1.37E-02*PM emission factor is filterable PM only. PM10 emission factor is filterable and condensable PM10 combined.PM2.5 emission factor is filterable and condensable PM2.5 combined.**Emission Factors for NOx: Uncontrolled = 100, Low NOx Burner = 50, Low NOx Burners/Flue gas recirculation = 32

MethodologyAll emission factors are based on normal firing.MMBtu = 1,000,000 BtuMMCF = 1,000,000 Cubic Feet of GasEmission Factors are from AP 42, Chapter 1.4, Tables 1.4-1, 1.4-2, 1.4-3, SCC #1-02-006-02, 1-01-006-02, 1-03-006-02, and 1-03-006-03Potential Throughput (MMCF) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1 MMCF/1,020 MMBtuEmission (tons/yr) = Throughput (MMCF/yr) x Emission Factor (lb/MMCF)/2,000 lb/ton

Hazardous Air Pollutants (HAPs)

Benzene Dichlorobenzene Formaldehyde Hexane Toluene Total - OrganicsEmission Factor in lb/MMcf 2.1E-03 1.2E-03 7.5E-02 1.8E+00 3.4E-03Potential Emission in tons/yr 3.4E-07 2.0E-07 1.2E-05 2.94E-04 5.5E-07 3.07E-04

Lead Cadmium Chromium Manganese Nickel Total - MetalsEmission Factor in lb/MMcf 5.0E-04 1.1E-03 1.4E-03 3.8E-04 2.1E-03Potential Emission in tons/yr 8.2E-08 1.8E-07 2.3E-07 6.2E-08 3.4E-07 8.9E-07Methodology is the same as above. Total HAPs 3.08E-04The five highest organic and metal HAPs emission factors are provided above. Worst HAP 2.94E-04Additional HAPs emission factors are available in AP-42, Chapter 1.4.

HAPs - Organics

HAPs - Metals

of 13, TSD App. A

Prepared by Trinity Consultants

Appendix A: Emissions CalculationsShredder



Particulate Emissions

Maximum Feed Capacity

Annual Potential Capacity

After Control Particulate Emission

Factor*(tons/hr) (tons/yr) (lbs/ton feed) (lb/hr) (tons/yr)

Shredder 112 981,120 0.0403 4.51 19.77

Note:*Material is treated with an integral water spray injection system to minimize explosion and fire hazards.The particulate emission factor for the shredder is from the Institute of Scrap Recycling Industries, Inc. "Title V Applicability Workbook" Appendix D, Table D-10.E for 80% Auto & 20% Scrap throughput mixture.The ISRI, Inc's "Title V Applicability Workbook" Appendix D, Table D-10.E emission factor is higher than the factor determined through the stack testing performed at Capital City Metals, LLC in Indianapolis on February 8, 2005, where the vehicle/metal shredder at that facility was utilizing a Smart Water Injection system.Assumed PM = PM10 = PM2.5

Methodology:PTE of PM/PM10/PM2.5 (lb/hr) = Maximum Capacity (tons/hr) * Emission Factor (lbs/ton feed)PTE of PM/PM10/PM2.5 (tons/yr) = Maximum Capacity (tons/hr) * Emission Factor (lbs/ton feed) * 8760 hrs/yr / 2000 lbs/ton

Controlled PTE of PM/PM10/PM2.5

*Process Description


Appendix A: Emission CalculationsShredder Limited



VOC EmissionsMaximum

Feed Capacity

Annual Potential Capacity

Limited Annual

ThroughputVOC Emission

Factor(tons/hr) (tons/yr) (tons/yr) (lbs/ton feed) (lb/hr) (tons/yr)

Shredder 112 981,120 330,000 0.117 13.10 57.38

Note:

*8-1-6 BACT avoidance limitMethodology:PTE of VOC (lb/hr) = Maximum Capacity (tons/hr) * Emission Factor (lbs/ton feed)PTE of VOC (tons/yr) = Maximum Capacity (tons/hr) * Emission Factor (lbs/ton feed) * 8760 hrs/yr / 2000 lbs/tonLimited PTE of VOC (tons/yr) = Limited Annual Throughput (tons/hr) * Emission Factor (lbs/ton feed) / 2000 lbs/ton

VOC emission factor is the average from the Sims Metal Management Johnston, Rhode Island Facility stack tests performed on September 15, 18, and 20, 2017 for a 50/50 mix of auto and white goods.

Process DescriptionPTE of VOC Limited

PTE of VOC*

(tons/yr)19.30


Appendix A: Emission CalculationsShredder HAPs



HAP Emissions (Auto Shredding)

Process Description

Maximum Feed

CapacityAnnual Potential

Capacity Hexane Benzene MIBK richloroethen Toluene Ethylbenzenem,p-Xylenes Styrene(tons/hr) (tons/yr) (lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed)

112 981,120 0.0037 0.0019 0.0002 0.0002 0.0083 0.0019 0.0068 0.0009

Hexane Benzene MIBK richloroethen Toluene Ethylbenzenem,p-Xylenes Styrene(tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr)

1.82 0.93 0.10 0.10 4.07 0.93 3.34 0.44

HAP Emissions (Auto Shredding - Continued)

Process Description

Maximum Feed


Capacity o-Xylene Cumene Napthalene Isooctane Cadmium Chromium Lead PCB's(tons/hr) (tons/yr) (lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed)

112 981,120 0.0025 0.0002 0.0001 0.00531 1.16E-06 1.28E-06 7.89E-06 8.73E-05

o-Xylene Cumene Napthalene Isooctane Cadmium Chromium Lead PCB's(tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr)

1.23 0.10 0.05 2.60 5.69E-04 6.28E-04 3.87E-03 4.28E-02

Combined HAPS (Auto Shredding): 15.75

HAP Emissions (Sheet Shredding)

Process Description

Maximum Feed


Capacity hloromethan,3 Butadien Acrolein Dichloroethen Hexane Benzene richloroethan

Methyl Methacryla

te MIBK(tons/hr) (tons/yr) (lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed)

112 981,120 0.00002 0.00002 0.00002 0.00005 0.00076 0.00024 0.00003 0.00006 0.00056

Chloromethan,3 Butadien Acrolein Dichloroethen Hexane Benzene richloroethan

Methyl Methacryla

te MIBK(tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr)9.81E-03 9.81E-03 9.81E-03 2.45E-02 3.73E-01 1.18E-01 1.47E-02 2.94E-02 2.75E-01

Process Description

Maximum Feed


Capacity Toluene Ethylbenzenem,p-Xylenes Styrene o-Xylene Cumene DichlorobenzNapthalene(tons/hr) (tons/yr) (lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed(lbs/ton feed)

112 981,120 0.0024 0.00074 0.00263 0.00039 0.00104 0.0001 0.00002 0.00020

Toluene Ethylbenzenem,p-Xylenes Styrene o-Xylene Cumene DichlorobenzNapthalene(tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr)

1.18 0.36 1.29 0.19 0.51 0.05 0.01 0.10

Combined HAPS (Sheet Shredding): 4.55

Note:Organic HAP Emission Factors determined from the April 2010 TO-15 stack test performed at the Jackson, Michigan OmniSource Corporation facility. Emission Factors are averages of three test runs.The Organic HAP PTE is based on the worst-case assumption that 100% auto scrap is being processed.Metal HAP and PCB emission factors from the Institute of Scrap Recycling Industries, Inc. "Title V Applicability Workbook" Appendix D, Table D-11.F

Methodology:HAP Emissions (tons/yr) = Maximum Capacity (tons/hr) * HAP (lbs/ton feed) * 8760 hrs/yr / 2000 lbs/ton

Shredder

Organic HAPS

Organic HAPS

Metal HAPS

Shredder

Organic HAPs

Shredder

HAP Emissions (Sheet Shredding Organic HAPs

Shredder

P age 11 of 13, TS D App. A

Appendix A: Emission CalculationsConveyors



Particulate Matter Emissions

PM PM10 PM2.5 (lb/hr) (tons/yr) (lb/hr) (tons/yr) (lb/hr) (tons/yr)3TEK Infeed Conveyor 1.40E-04 4.60E-05 1.30E-05 112 1.57E-02 6.87E-02 5.15E-03 2.26E-02 1.46E-03 6.38E-033TEK 7400 Shredder/Feed Chute/DFR 1.40E-04 4.60E-05 1.30E-05 112 1.57E-02 6.87E-02 5.15E-03 2.26E-02 1.46E-03 6.38E-03General Kinematic Undermill Oscillator 1.40E-04 4.60E-05 1.30E-05 112 1.57E-02 6.87E-02 5.15E-03 2.26E-02 1.46E-03 6.38E-03Shredded Product Elevating Conveyor 1.40E-04 4.60E-05 1.30E-05 112 1.57E-02 6.87E-02 5.15E-03 2.26E-02 1.46E-03 6.38E-03Magnet Separation System with 2 pcs 1.40E-04 4.60E-05 1.30E-05 112 1.57E-02 6.87E-02 5.15E-03 2.26E-02 1.46E-03 6.38E-03Ferrous Transfer Conveyor to Z-Box 1.40E-04 4.60E-05 1.30E-05 87 1.22E-02 5.36E-02 4.02E-03 1.76E-02 1.14E-03 4.97E-03Dual Picking Conveyors 1.40E-04 4.60E-05 1.30E-05 78 1.10E-02 4.81E-02 3.61E-03 1.58E-02 1.02E-03 4.46E-03Ferrous Collection Conveyor with Belt Scale 1.40E-04 4.60E-05 1.30E-05 78 1.10E-02 4.81E-02 3.61E-03 1.58E-02 1.02E-03 4.46E-03Ferrous Radial Stacking Conveyor 1.40E-04 4.60E-05 1.30E-05 78 1.10E-02 4.81E-02 3.61E-03 1.58E-02 1.02E-03 4.46E-03Non Ferrous Stockpile Conveyor 1.40E-04 4.60E-05 1.30E-05 4 6.27E-04 2.75E-03 2.06E-04 9.03E-04 5.82E-05 2.55E-04Tramp Ferrous Recovery Conveyor with Head Pu 1.40E-04 4.60E-05 1.30E-05 20 2.82E-03 1.24E-02 9.27E-04 4.06E-03 2.62E-04 1.15E-03Cyclone Discharge Conveyor 1.40E-04 4.60E-05 1.30E-05 13 1.88E-03 8.24E-03 6.18E-04 2.71E-03 1.75E-04 7.65E-04

Potential Emissions: 0.56 0.19 0.05

Notes:1 Emissions from conveying of auto shredder residue are calculated using emission factors for crushed stone conveyor transfer points and screening from AP-42, Chapter 11.19, Table 11.19.2-2 (SCC 3-05-020-06

and 3-05-020-02, 03) (8/04).

Methodology:Unlimited PTE of PM/PM10/PM2.5 (tpy) = Throughput (tons/hr) x Emission Factor (lbs/ton) x 8760 (hrs/year) x 1 ton/2000 lbs

All conveyers are after the shredder. The water injection system on the vehicle/metal shredder is considered integral to the process. This system leaves the items in the downstream conveyors damp. Therefore controlled emission factors are used for these conveyor transfer points. The conveyor transfer point is a damp process.

Unlimited PTE of PM2.5

Process DescriptionEmission Factor (lbs/ton)1

Maximum Capacity (tons/hr)

Unlimited PTE of PM Unlimited PTE of PM10


Appendix A: Emissions CalculationsPaved Roads Emission Calculations



Paved Roads at Industrial SiteThe following calculations determine the amount of emissions created by paved roads, based on 8,760 hours of use and AP-42, Ch 13.2.1 (1/2011).

Vehicle Information (provided by source)

Type

Maximum number of

vehicles per day

Number of one-way trips per day

per vehicleMaximum trips

per day (trip/day)

Maximum Weight

(tons/trip)

Total Weight driven per day

(ton/day)

Maximum one-way distance

(feet/trip)


(mi/trip)

Maximum one-way miles (miles/day)

Maximum one-way miles (miles/yr)

Material Delivery (empty) 20.0 1 20.0 17.5 350.7 510 0.097 1.9 705.9Material Delivery (full) 20.0 1 20.0 40.0 801.5 359 0.068 1.4 497.1Material Loadout (empty) 15.0 1 15.0 17.5 262.5 359 0.068 1.0 372.1Material Loadout (full) 15.0 1 15.0 40.0 600.0 510 0.097 1.4 528.4

Totals 70.1 2,014.7 5.8 2,103.5

Average Vehicle Weight Per Trip = 28.8 tons/tripAverage Miles Per Trip = 0.08 miles/trip

Unmitigated Emission Factor, Ef = [k * (sL)^0.91 * (W)^1.02] (Equation 1 from AP-42 13.2.1)

PM PM10 PM2.5where k = 0.011 0.0022 0.00054 lb/VMT = particle size multiplier (AP-42 Table 13.2.1-1)

W = 28.8 28.8 28.8 tons = average vehicle weight (provided by source)sL = 9.7 9.7 9.7 g/m^2 = mean silt loading value for paved roads (AP-42 Table 13.2.1-3, Iron and steel production)

Taking natural mitigation due to precipitation into consideration, Mitigated Emission Factor, Eext = E * [1 - (p/4N)] (Equation 2 from AP-42 13.2.1) Mitigated Emission Factor, Eext = Ef * [1 - (p/4N)]

where p = 125 days of rain greater than or equal to 0.01 inches (see Fig. 13.2.1-2)N = 365 days per year

PM PM10 PM2.5Unmitigated Emission Factor, Ef = 2.674 0.535 0.1313 lb/mileMitigated Emission Factor, Eext = 2.445 0.489 0.1200 lb/mile

Process

Mitigated PTE of PM

(tons/yr)Mitigated PTE of PM10 (tons/yr)

Mitigated PTE of PM2.5 (tons/yr)

Material Delivery (empty) 0.86 0.17 0.04Material Delivery (full) 0.61 0.12 0.03Material Loadout (empty) 0.45 0.09 0.02Material Loadout (full) 0.65 0.13 0.03

Totals 2.57 0.51 0.13

MethodologyTotal Weight driven per day (ton/day) = [Maximum Weight Loaded (tons/trip)] * [Maximum trips per day (trip/day)]Maximum one-way distance (mi/trip) = [Maximum one-way distance (feet/trip) / [5280 ft/mile]Maximum one-way miles (miles/day) = [Maximum trips per year (trip/day)] * [Maximum one-way distance (mi/trip)]Average Vehicle Weight Per Trip (ton/trip) = SUM[Total Weight driven per day (ton/day)] / SUM[Maximum trips per day (trip/day)]Average Miles Per Trip (miles/trip) = SUM[Maximum one-way miles (miles/day)] / SUM[Maximum trips per year (trip/day)]Unmitigated PTE (tons/yr) = [Maximum one-way miles (miles/yr)] * [Unmitigated Emission Factor (lb/mile)] * (ton/2000 lbs)Mitigated PTE (tons/yr) = [Maximum one-way miles (miles/yr)] * [Mitigated Emission Factor (lb/mile)] * (ton/2000 lbs)Controlled PTE (tons/yr) = [Mitigated PTE (tons/yr)] * [1 - Dust Control Efficiency]

AbbreviationsPM = Particulate MatterPM10 = Particulate Matter (<10 um)PM2.5 = Particle Matter (<2.5 um)PTE = Potential to Emit


Appendix A: Emissions CalculationsUnpaved Roads Emission Calculations



Unpaved Roads at Industrial SiteThe following calculations determine the amount of emissions created by unpaved roads, based on 8,760 hours of use and AP-42, Ch 13.2.2 (1/2011).

Vehicle Information (provided by source)

Type

Maximum number of

vehicles per day

Number of one-way trips per day

per vehicleMaximum trips

per day (trip/day)

Maximum Weight

(tons/trip)

Total Weight driven per day

(ton/day)


(feet/trip)


(mi/trip)

Maximum one-way miles (miles/day)

Maximum one-way miles (miles/yr)

Material Delivery on Primary Route (empty) 17.0 1 17.0 17.5 298.1 381 0.072 1.2 449.1Material Delivery on Primary Route (full) 17.0 1 17.0 40.0 681.3 855 0.162 2.8 1,006.3Material Loadout on Primary Route (empty) 12.8 1 12.8 17.5 224.0 855 0.162 2.1 756.2Material Loadout on Primary Route (full) 12.8 1 12.8 40.0 512.0 381 0.072 0.9 337.5Material Delivery on Secondary Route (empty) 3.0 1 3.0 17.5 52.6 2,150 0.407 1.2 446.7Material Delivery on Secondary Route (full) 3.0 1 3.0 40.0 120.2 1,690 0.320 1.0 351.1Material Loadout on Secondary Route (empty) 2.3 1 2.3 17.5 40.3 1,690 0.320 0.7 268.6Material Loadout on Secondary Route (full) 2.3 1 2.3 40.0 92.0 2,150 0.407 0.9 341.8

Totals 70.3 2,020.5 10.8 3,957.3

Average Vehicle Weight Per Trip = 28.8 tons/tripAverage Miles Per Trip = 0.24 miles/trip

Unmitigated Emission Factor, Ef = k*[(s/12)^a]*[(W/3)^b] (Equation 1a from AP-42 13.2.2)

PM PM10 PM2.5where k = 4.9 1.5 0.15 lb/mi = particle size multiplier (AP-42 Table 13.2.2-2 for Industrial Roads)

s = 6 6 6 % = mean % silt content of unpaved roads (AP-42 Table 13.2.2-1 Iron and Steel Production)a = 0.7 0.9 0.9 = constant (AP-42 Table 13.2.2-2 for Industrial Roads)

W = 28.8 28.8 28.8 tons = average vehicle weight (provided by source)b = 0.45 0.45 0.45 = constant (AP-42 Table 13.2.2-2 for Industrial Roads)

Taking natural mitigation due to precipitation into consideration, Mitigated Emission Factor, Eext = E * [(365 - P)/365] (Equation 2 from AP-42 13.2.2)Mitigated Emission Factor, Eext = E * [(365 - P)/365]

where p = 125 days of rain greater than or equal to 0.01 inches (see Fig. 13.2.1-2)

PM PM10 PM2.5Unmitigated Emission Factor, Ef = 8.34 2.22 0.22 lb/mileMitigated Emission Factor, Eext = 5.48 1.46 0.15 lb/mile

Process

Mitigated PTE of PM

(tons/yr)Mitigated PTE of PM10 (tons/yr)

Mitigated PTE of PM2.5 (tons/yr)

Material Delivery on Primary Route (empty) 1.23 0.33 0.03Material Delivery on Primary Route (full) 2.76 0.74 0.07Material Loadout on Primary Route (empty) 2.07 0.55 0.06Material Loadout on Primary Route (full) 0.93 0.25 0.02Material Delivery on Secondary Route (empty) 1.22 0.33 0.03Material Delivery on Secondary Route (full) 0.96 0.26 0.03Material Loadout on Secondary Route (empty) 0.74 0.20 0.02Material Loadout on Secondary Route (full) 0.94 0.25 0.02

Totals 10.85 2.89 0.29

MethodologyTotal Weight driven per day (ton/day) = [Maximum Weight Loaded (tons/trip)] * [Maximum trips per day (trip/day)]Maximum one-way distance (mi/trip) = [Maximum one-way distance (feet/trip) / [5280 ft/mile]Maximum one-way miles (miles/day) = [Maximum trips per year (trip/day)] * [Maximum one-way distance (mi/trip)]Average Vehicle Weight Per Trip (ton/trip) = SUM[Total Weight driven per day (ton/day)] / SUM[Maximum trips per day (trip/day)]Average Miles Per Trip (miles/trip) = SUM[Maximum one-way miles (miles/day)] / SUM[Maximum trips per year (trip/day)]Unmitigated PTE (tons/yr) = [Maximum one-way miles (miles/yr)] * [Unmitigated Emission Factor (lb/mile)] * (ton/2000 lbs)Mitigated PTE (tons/yr) = [Maximum one-way miles (miles/yr)] * [Mitigated Emission Factor (lb/mile)] * (ton/2000 lbs)Controlled PTE (tons/yr) = [Mitigated PTE (tons/yr)] * [1 - Dust Control Efficiency]

AbbreviationsPM = Particulate MatterPM10 = Particulate Matter (<10 um)PM2.5 = Particle Matter (<2.5 um)PTE = Potential to Emit



(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov



Recycled Paper

July 3, 2019 Ms. Debbie Hays Sims Metal Management 2500 South Paulina Street Chicago, IL 60608 Re: Public Notice Sims Metal Management Permit Level: New Source Review and Minor Source Operating Permit (MSOP) Permit Number: 089-41472-00608 Dear Ms. Hays: Enclosed is a copy of your draft New Source Review and Minor Source Operating Permit (MSOP), Technical Support Document, emission calculations, and the Public Notice. The Public Notice period will begin the date the Notice is published on the IDEM Official Public Notice website. Publication has been requested and is expected within 2-3 business days. You may check the exact Public Notice begins and ends date here: https://www.in.gov/idem/5474.htm Please note that as of April 17, 2019, IDEM is no longer required to publish the notice in a newspaper. OAQ has submitted the draft permit package to the East Chicago Public Library, 2401 East Columbus Drive in East Chicago, Indiana. As a reminder, you are obligated by 326 IAC 2-1.1-6(c) to place a copy of the complete permit application at this library no later than ten (10) days after submittal of the application or additional information to our department. We highly recommend that even if you have already placed these materials at the library, that you confirm with the library that these materials are available for review and request that the library keep the materials available for review during the entire permitting process. Please review the enclosed documents carefully. This is your opportunity to comment on the draft permit and notify the OAQ of any corrections that are needed before the final decision. Questions or comments about the enclosed documents should be directed to Kendra Sutherland, Indiana Department of Environmental Management, Office of Air Quality, 100 N. Senate Avenue, Indianapolis, Indiana, 46204 or call (800) 451-6027, and ask for extension (317) 234-5401 or dial (317) 234-5401. Sincerely, Vivian Haun Vivian Haun Permits Branch Office of Air Quality

Enclosures PN Applicant Cover Letter 4/12/19




(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov



Recycled Paper

July 3, 2019 To: East Chicago Public Library From: Jenny Acker, Branch Chief Permits Branch Office of Air Quality Subject: Important Information to Display Regarding a Public Notice for an Air Permit

Applicant Name: Sims Metal Management Permit Number: 089-41472-00608 Enclosed is a copy of important information to make available to the public. This proposed project is regarding a source that may have the potential to significantly impact air quality. Librarians are encouraged to educate the public to make them aware of the availability of this information. The following information is enclosed for public reference at your library: • Notice of a 30-day Period for Public Comment • Draft Permit and Technical Support Document You will not be responsible for collecting any comments from the citizens. Please refer all questions and request for the copies of any pertinent information to the person named below. Members of your community could be very concerned in how these projects might affect them and their families. Please make this information readily available until you receive a copy of the final package. If you have any questions concerning this public review process, please contact Joanne Smiddie-Brush, OAQ Permits Administration Section at 1-800-451-6027, extension 3-0185. Questions pertaining to the permit itself should be directed to the contact listed on the notice.

Enclosures PN Library updated 4/2019



(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov



Recycled Paper

Notice of Public Comment July 3, 2019 Sims Metal Management 089-41472-00608 Dear Concerned Citizen(s): You have been identified as someone who could potentially be affected by this proposed air permit. The Indiana Department of Environmental Management, in our ongoing efforts to better communicate with concerned citizens, invites your comment on the draft permit. Enclosed is a Notice of Public Comment, which has posted on IDEM’s Public Notice website at https://www.in.gov/idem/5474.htm. The application and supporting documentation for this proposed permit have been placed at the library indicated in the Notice. These documents more fully describe the project, the applicable air pollution control requirements and how the applicant will comply with these requirements. If you would like to comment on this draft permit, please contact the person named in the enclosed Public Notice. Thank you for your interest in the Indiana’s Air Permitting Program. Please Note: If you feel you have received this Notice in error, or would like to be removed from the Air Permits mailing list, please contact Patricia Pear with the Air Permits Administration Section at 1-800-451-6027, ext. 3-6875 or via e-mail at [email protected]. If you have recently moved and this Notice has been forwarded to you, please notify us of your new address and if you wish to remain on the mailing list. Mail that is returned to IDEM by the Post Office with a forwarding address in a different county will be removed from our list unless otherwise requested.

Enclosure PN AAA Cover Letter 4/12/2019


FACSIMILIE OF PS Form 3877

Mail Code 61-53

IDEM Staff VHAUN 7/3/2019 Sims Metal Management 089-41472-00608 DRAFT Page 1 of 2

AFFIX STAMP HERE IF USED AS CERTIFICATE OF MAILING

Name and address of Sender ►

Indiana Department of Environmental Management Office of Air Quality – Permits Branch 100 N. Senate Indianapolis, IN 46204

Type of Mail:

CERTIFICATE OF MAILING ONLY

Line Article

Number Name, Address, Street and Post Office Address Postage Handing

Charges Act. Value (If Registered)

Insured Value

Due Send if COD

R.R. Fee

S.D. Fee S.H. Fee

Rest. Del. Fee Remarks

1 Debbie Hays Sims Metal Management 2500 S Paulina St Chicago IL 60608 (Source RM) 2 George Malamis General Manager Sims Metal Management 2500 S Paulina St Chicago IL 60608 (RO RM) 3 East Chicago Public Library - Main Library 2401 E Columbus Dr East Chicago IN 46312-2998 (Library) 4 Lake County Health Department-Gary 1145 W. 5th Ave Gary IN 46402-1795 (Health Department) 5 WJOB / WZVN Radio 6405 Olcott Ave Hammond IN 46320 (Affected Party) 6 Lowell Town Council and Town Manager PO Box 157, 501 East Main Street Lowell IN 46356 (Local Official) 7 Craig Hogarth 7901 West Morris Street Indianapolis IN 46231 (Affected Party) 8 Lake County Commissioners 2293 N. Main St, Building A 3rd Floor Crown Point IN 46307 (Local Official) 9 Anthony Copeland 2006 E. 140th Street East Chicago IN 46312 (Affected Party) 10 Barbara G. Perez 506 Lilac Street East Chicago IN 46312 (Affected Party) 11 Mr. Robert Garcia 3733 Parrish Avenue East Chicago IN 46312 (Affected Party) 12 Ms. Karen Kroczek 8212 Madison Ave Munster IN 46321-1627 (Affected Party) 13 Joseph Hero 11723 S Oakridge Drive St. John IN 46373 (Affected Party) 14 Mr. Larry Davis 268 South, 600 West Hebron IN 46341 (Affected Party) 15 Tony Schroeder Trinity Consultants 8910 Purdue Road, Suite 670 Indianapolis IN 46268 (Consultant)

Total number of pieces Listed by Sender

15 Total number of Pieces Received at Post Office

Postmaster, Per (Name of Receiving employee)

The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnegotiable documents under Express Mail document reconstructing insurance is $50,000 per piece subject to a limit of $50, 000 per occurrence. The maximum indemnity payable on Express mil merchandise insurance is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and S921 for limitations of coverage on inured and COD mail. See International Mail Manual for limitations o coverage on international mail. Special handling charges apply only to Standard Mail (A) and Standard Mail (B) parcels.

FACSIMILIE OF PS Form 3877

Mail Code 61-53

IDEM Staff VHAUN 7/3/2019 Sims Metal Management 089-41472-00608 DRAFT Page 2 of 2

AFFIX STAMP HERE IF USED AS CERTIFICATE OF MAILING

Name and address of Sender ►

Indiana Department of Environmental Management Office of Air Quality – Permits Branch 100 N. Senate Indianapolis, IN 46204

Type of Mail:

CERTIFICATE OF MAILING ONLY

Line Article

Number Name, Address, Street and Post Office Address Postage Handing

Charges Act. Value (If Registered)

Insured Value

Due Send if COD

R.R. Fee

S.D. Fee S.H. Fee

Rest. Del. Fee Remarks

1 Mark Coleman PO Box 85 Beverly Shores IN 46301-0085 (Affected Party) 2 Jeff Mayes News-Dispatch 422 Franklin St Michigan City IN 46360 (Affected Party) 3 4 5 6 7 8 9 10 11 12 13 14 15

Total number of pieces Listed by Sender

2 Total number of Pieces Received at Post Office

Postmaster, Per (Name of Receiving employee)

The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable for the reconstruction of nonnegotiable documents under Express Mail document reconstructing insurance is $50,000 per piece subject to a limit of $50, 000 per occurrence. The maximum indemnity payable on Express mil merchandise insurance is $500. The maximum indemnity payable is $25,000 for registered mail, sent with optional postal insurance. See Domestic Mail Manual R900, S913, and S921 for limitations of coverage on inured and COD mail. See International Mail Manual for limitations o coverage on international mail. Special handling charges apply only to Standard Mail (A) and Standard Mail (B) parcels.

notice of 30-day period for public commentpermits.air.idem.in.gov/41472d.pdf · (b) one (1)...

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