United States of America v. Maynard Steel Casting Company

Filing 11

CONSENT DECREE signed by Magistrate Judge William E Duffin on 5/30/2017. Within 30 days after the Effective Date of this Consent Decree, Defendant shall pay the first of 5 consecutive monthly sums of $5,000 each, as a civil penalty, together wit h interest accruing from the date on which this Consent Decree is lodged with the Court, at the rate specified in 28 USC § 1961 as of the date of lodging. The parties shall bear their own costs, including attorneys' fees, except that the Uni ted States shall be entitled to collect the costs (including attorneys' fees) incurred in any action necessary to collect any portion of the civil penalty or any stipulated penalties due but not paid by Defendant. The Court shall retain jurisdic tion over this case until termination of this Consent Decree. This Consent Decree shall constitute a final judgment of the Court. See Consent Decree for additional details. (Attachments: # 1 Appendix A - EAF Fume Collection System Study, # 2 Ap pendix B - Maynard Steel Casting Company Operation & Maintenance Plan and Malfunction Prevention & Abatement Plan, # 3 Appendix C - Electric Arc Furnace - Outdoor Fugitive Emissions Opacity Monitoring Protocol, # 4 Appendix D - Maynard Steel Documents Used for Civil Penalty Ability-to-Pay Analysis, # 5 Appendix E - Diagram of RCRA Containment Structure) (cc: all counsel)(lz)

Consent Decree in
United States of America v.
Maynard Steel Casting Co. (E.D. Wis.)
Appendix A
EAF Fume Collection System Study

Consent Decree in
United States of America v. Maynard Steel Casting Co. (E.D. Wis.)
Appendix A
EAF Fume Collection System Study

1.0

Purpose

The purpose of this Fume Collection System (FCS) study (the Study) is to generate
sufficient data to evaluate the capacity of the FCS on each of Maynard’s electric arc
furnaces (EAF) to capture and control the maximum emissions of particulate matter
(PM) that could reasonably be generated during a single heat. Maynard Steel Casting
Company (Maynard Steel) will be conducting this Study in accordance with the terms of
a Consent Decree between the United States and Maynard Steel.
1.1

Metal Melting and Oxygen Lancing Emissions

During the initial stages of a heat, the electrical arcing that takes place between the
electrodes and the scrap metal heats the air inside the furnace. The heated air creates
buoyant forces beneath the furnace cover, which causes hot air containing particulate
matter to escape the furnace through the annular spaces between the electrodes and
the furnace cover. The volume of hot exhaust during the initial stages of a heat depends
on the duration and magnitude of electrical arcing, which varies heat to heat.
Later in the heat, oxygen lancing is typically employed to melt down bridging of scrap
and to assist in drawing all of the scrap into the molten bath. The compressed oxygen
used during oxygen lancing substantially expands as oxygen forcefully contacts hot
metal scrap and the furnace walls, which increases both the air temperature inside the
furnace and the thermal-driven exhaust rate through the annular openings in the
furnace cover. Again, the volume of exhaust gases, and the mass and concentration of
particulate matter, among other pollutants, depends on the duration and intensity of the
oxygen pressure, which varies from heat to heat.
Once the scrap has become molten, the metal bath is typically refined. This entails
employing oxygen lancing at a pressure higher than is used during the melt down
activity discussed above. This high pressure oxygen lancing (i.e., refining) creates a
boiling effect and promotes chemical reactions within the molten metal. This condition
typically creates the highest buildup rate of thermal energy in the furnace air
environment throughout the entire heat and, consequently, is expected to result in the
highest instantaneous exhaust rate (i.e., volume of air per unit of time) from the furnace.
Because the duration of oxygen lancing during refining varies from heat to heat, the
instantaneous exhaust rate of gases and also the PM mass and concentration in the
gases also varies from heat to heat.

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Each of the side-draft hoods on EAF Nos. 5, 6, and 7 function similar to one another.
Because of its own thermal buoyancy, the furnace exhaust with entrained emissions
rises within the furnace up through the annular spaces between the electrodes and the
furnace cover. There, continuous suction created by a fan draws the furnace exhaust
into the ventilation system using a side-draft hood. Suction is maintained during furnace
tiling via a telescoping duct. A strong suction is needed to turn the thermally rising air
from vertical to horizontal and to direct the plume into the local exhaust ventilation
system. The air leaving the furnace is replaced primarily by air drawn in through the
open slag door and pour spout.
Because the ventilation system is operated at a single fan speed setting, exhaust must
be continuously applied throughout the entire heat at the minimum airflow rate that is
capable of effectively capturing the maximum emissions generated during the refining
phase.
The FCS associated with EAF No. 4 utilizes direct draw above the melting surface of
the furnace at the annular spaces between the three melting electrodes and the roof on
EAF No. 4 (the delta section), and routes emissions to a baghouse. There is currently
no telescoping duct associated with the EAF No. 4, and EAF No.4 is currently not in
operation. Maynard will repair the existing FCS prior to restarting EAF 4 operations as
provided under the Consent Decree. Within one year of exceeding 12-heats on EAF
No. 4 in a rolling 12-month period, Maynard will install a telescoping duct similar to
those in place at EAF Nos. 5, 6 and 7 and will conduct this Study at EAF No. 4.
1.2

Ventilation Control and Monitoring of Melting Emissions

Each of the exhaust systems, except as otherwise noted above for EAF No. 4, is
essentially a single source system - i.e., there is only one exhaust hood, one trunk duct
(with articulation to assure continuous attachment to the capture hood during furnace
tilting), one air filtering chamber (baghouse), one suction fan, and one discharge stack.
Maynard’s exhaust fans are not constant airflow rate devices; rather the fans’ airflow
rates reduce as the need for suction draw (i.e., fan static pressure) increases. Thus,
exhaust rate and fan static pressure are inversely related. These suction fans operate
at a single speed setting, drawing airflow at a static pressure that is dictated by both the
configuration (and the extent to which the ducts are maintained in proper repair and
cleanliness) of the ventilation system and the total differential pressure across the filters
(baghouse).
This Study will evaluate the system configuration’s effect on static pressure. The filter
total differential pressure increases as collected material builds up on the filter media
surfaces. Without adequately removing collected particulate matter from the filters (as
by filter shaking), the filter total differential pressure will eventually build up such that the
exhaust rate diminishes until emissions are no longer adequately captured by the local
exhaust hood.

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In accordance with Maynard’s Operation & Maintenance / Malfunction Prevention &
Abatement Plan (O&M Plan) (Consent Decree Appendix B), prior to commencing a
heat, each baghouse will be cleaned to a starting filter total differential pressure that will
be established by this Study for each baghouse. When necessary, this cleaning is
accomplished by mechanically shaking the filter bags so that the collected particulate
matter drops into a hopper. This type of bag cleaning will be performed offline. Cleaning is terminated at a target starting filter total differential pressure that will
be set to assure sufficient filter thickness for efficient filtration (i.e., to achieve sufficient
filter “cake”).
The O&M Plan also requires that Maynard perform a second type of filter cleaning,
terms on-line modular cleaning, to prevent rapid rise of filter total differential pressure
during a heat. The filtering system for each furnace is constructed as a series of
modules. In a filter cleaning sequence repeated continuously throughout the melting
shift, each of the modules is sequentially dampered off-line and shaken to remove
collected particulate matter, while the balance of the modules continue to operate with
the fan on.
The total differential pressure across the baghouse will increase during the melting shift
as a cumulative effect of the emissions loading from the various heats. Such an
increase in the total differential pressure will reduce the exhaust airflow rate at the local
exhaust hood. To ensure adequate suction is continuously applied to the exhaust hood
throughout the melting shift, the hood static pressure will be continuously measured.
The hood static pressure serves as a surrogate indicator for the exhaust rate
measurement. Hood static pressure has a direct, although non-linear, relationship to
exhaust rate. Hood static pressure represents the suction level that the fan exerts in the
ductwork at the transition from the capture hood (i.e., side-draft hood) to the ductwork
system. Hood static pressure is created by two suction levels that are needed to create
airflow into the hood: 1) the suction energy to accelerate room air to duct velocity; and
2) the suction energy to overcome the turbulence losses of air as it enters the hood and
proceeds into the duct transition. Although the relationship of hood static pressure to
hood exhaust rate is non-linear, it is direct and can be accurately calibrated as a
surrogate for measuring hood exhaust flow rate. Maynard Steel will use monitoring
instruments to continuously monitor the hood static pressure and the baghouse filter
total differential pressure. Maynard Steel will employ preventative maintenance of the
entire ventilation system to assure proper filtration performance of each baghouse per
the O&M Plan.

2.0

Basis for EAF FCS Assessment

This section of the Study identifies the specific measures that Maynard will implement to
evaluate the capacity of its emissions capture system. This Study is targeted to assess
each EAF’s local capture system. This local capture system extends from the collection
hood at the furnace and corresponding duct to the exhaust stack of each baghouse.

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There are two critical components to this assessment: 1) maintaining adequate draw to
capture the maximum emission rate from an EAF throughout a heat; and 2) effectively
controlling the captured emissions to limit emissions released to the atmosphere. This
Study is a performance-based assessment targeted to determine if the capture system
(as defined above) has sufficient capacity to capture the emissions during the melting
and refining phases. For this Study, there are three principal elements for determining
capacity in the collection systems:
1. Minimum Required Draw and the Low-Low Set Point: The minimum required
draw is the point at which EAF emissions begin to escape capture by the exhaust
hood. Such challenges to the system are associated with increases in the
volumetric rate of air emanating through the annular spaces around the
electrodes that occur during oxygen lancing, as discussed in Section 1.1 of this
Study. When oxygen is introduced, there is an increase in the volume of gas
(due to the injection of oxygen) within an EAF that also increases the
temperature of the atmosphere within the EAF above that which is associated
with standard melting. The increase in temperature has an associated increase
in thermal energy in the furnace air environment that, when combined with the
added volume of oxygen, results in the highest instantaneous exhaust rate (i.e.,
volume of air per unit of time) from the furnace. Coincidentally, the maximum
emission rate is expected to correspond to that which is experienced during
oxygen lancing.
The rate of oxygen introduction is highest when refining, which is typically
performed at a higher pressure (100 pounds per square inch [PSI]) than at other
times that oxygen lancing is performed (e.g., to assist in the melt down of metal
bridging within a furnace). Consequently, the Low-Low Set Point corresponds to
the minimum draw needed to effectively capture emissions while refining.
Maintaining a minimum draw that corresponds to the Low-Low Set Point
effectively provides capture for the lower emission rates that are expected
throughout a heat outside of refining. Maynard shall determine the minimum
required draw and the Low-Low Set Point based on hood static pressure
measurements by decreasing the hood flow rate during one or more test heats
and visually observing the hood static pressure at the point at which emissions
begin to escape capture while refining at a minimum oxygen pressure of 100
pounds per square inch (PSI). Visual observation and video recordings will be
used to document conditions that coincide with the Low-Low Set Point.
Operation at or above this set point throughout an entire heat demonstrates that
the system has the capacity to capture the maximum emissions. Visual and
audible alarms will be programmed to sound on parametric monitoring panels
serving each EAF baghouse to directly alert the operator, and e-mail alerts will
be sent to key designated individuals alerting them that the Low-Low Set Point
has been tripped so that appropriate actions can be implemented.

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2. Minimum Required Draw and the High-Low Set Point: As the heat
progresses, the pressure drop across the baghouse tends to incrementally
increase, which results in a corresponding decrease in hood static pressure. The
operating span for the hood static pressure is the difference between the hood
static pressure under optimal conditions (i.e., when the bags have been shaken
to the extent practicable) prior to the start of a heat, minus the Low-Low Set Point
that corresponds to the minimum hood static pressure required to maintain no
visual emissions escaping capture from the start to the end of the test heats, as
confirmed by both visual observation and video recordings. The High-Low Set
Point is the hood static pressure at which the heat ends during normal operating
conditions. A hood static pressure that drops below the High-Low Set Point will
trigger an alarm. The difference between the High-Low and Low-Low Set Points
may be considered a safety margin above minimum required draw as illustrated
in Figure 1, below on page 5.
3. Minimal Initial Margin and the Low-High Set Point: Before emissions from the
melting phase of a heat are generated, the FCS will be checked to ensure it has
the capability to capture and collect all emissions generated during the heat. The
hood static pressure before the heat should be high enough such that it does not
drop below the High-Low Set Point during the heat. The pre-melt minimum
target hood static pressure is the Low-High Set Point. The difference between
the Low-High and High-Low Set Points is the “minimal initial margin,” as
illustrated in Figure 1, below.
4. Maximum Emission Rate – Oxygen Lancing: Maynard shall maximize the
oxygen lancing operating pressure and duration to the extent practicable during
refining phase for all test heats, which should generate the maximum emission
rate during that heat from that EAF.
5. Baghouse Performance - Effective Control of Captured Emissions: Prior to
dampering the flow to determine the Low-Low Set Point for each FCS, Maynard
shall do the following: 1) collect information to calculate the predicted fan
performance for each FCS; 2) collect ventilation performance measurements
(e.g., static pressure, airflow traverses, temperature and baghouse total
differential pressure) to verify predicted fan performance; and then 3) compare
the FCS’s predicted fan performance curve to that FCS’s actual fan performance.

A-5

FIGURE 1. HOOD STATIC PRESSURE SET POINTS (IN-H2O)
Low-High: Target for start of heat

Initial Margin

Adequate Margin

3.0

High-Low: Target end point of heat.
ALARM Condition - Implement appropriate actions to
ensure that hood static does not drop below Low-Low set
point.
Low-Low: No further melting except in accordance with O&M Plan.
ALARM Condition - Implement appropriate actions to
return hood static pressure above Low-Low set point.

Protocol to Evaluate the EAF FCS

The evaluation of the actual performance of each FCS during typical operations will be
conducted in three phases:
Phase 1 – Specification and Installation of Parametric Monitoring Systems
Phase 2 – Evaluating Exhaust System Capability and Establishing Ventilation
Performance Limits
Phase 3 – Monitoring Ongoing Fume Control Performance During Production
Melting Heats
The following identifies the particulars for each of the three phases.
Phase 1 – Specification and Installation of Continuous Parametric Monitoring
Systems
Maynard will develop and implement the following continuous parametric monitoring
systems (CPMS) for the emissions capture system for both this Study and compliance

A-6

with the Consent Decree:
Parameter
Hood Static Pressure
Pressure Drop (by module)
Total Pressure Drop

Range
Note 1
1 to 8 in-H2O (permitted)
1 to 8 in-H2O (permitted)

Frequency of Measurement
Method
Continuously
Pressure transducer
Note 2
Magnehelic Gauge
Continuously
Diff. Pressure transducer

Recorded
Electronically
Note 2
Electronically

Notes
1. The low end of the range is planned to be es tablis hed for each EAF FCS by modulating the air flow and vis ually as s es s ing ca pture.
2. The pres s ure drop acros s each module will be us ed, as needed, for trouble-s hooting purpos es .

During Phase 1 of this Study, these CPMS must be installed, calibrated, commissioned
and operating continuously during a heat on each EAF before Phases 2.b and 3 can be
undertaken at that EAF.
The CPMS is required to implement specific phases of this Study to determine the
exhaust system capability of each FCS and to establish performance limits for these
ventilation systems. Preliminary specifications for these systems include (in part):
Display panel and continuous data logging for each furnace will include:
o Display of instantaneous hood static pressure and baghouse total
differential pressure
o Low-Low and High-Low visible and audible alarms for hood static
pressure
o High-High and Low-Low visible and audible alarms for total pressure
drop across the baghouse. These Set Points indicate possible problems
with the baghouse, including bag clogging, broken bags, etc.
o Low-High and High-Low visible alarms for total pressure drop across the
baghouse to allow operators to take appropriate actions before the
pressure drop further approaches either the Low-Low or High-High Set
Points
Maynard Steel may elect to conduct additional parametric monitoring at various points
along the FCS (elbows, duct expansions/reductions, etc.) to evaluate FCS performance
during the course of this Study. These additional parametric monitors, however, are not
intended to be permanent or be included as part of the CPMS requirements under the
Consent Decree.
Phase 2 – Confirming Exhaust System Capability and Establishing Ventilation
Performance Limits
Phase 1 must be completed before Phase 2 can be initiated. Phase 2 is divided into two
parts, Phase 2A and Phase 2B. Note that the canopy hood associated with EAF No. 4
shall not operate during Phase 2B for EAF Nos. 5 and 6.

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A. Confirming Exhaust System Capability – Cold Work
Phase 2A is called Cold Work because it is work that will be completed when the EAFs
are not in use and the bag houses are shaken in preparation for a melting shift using
off-line shaking and with on-line shaking shut-off (as described in Section 1.2). In
Phase 2A, Maynard shall complete the following:
1. If not currently available, obtain from the manufacturers fan curves for baghouse
fans associated with each FCS.
2. Develop AutoCAD line drawing schematics of each FCS, showing the furnace
capture hood, all of the ductwork sections, transitions and fittings, baghouse, fan,
control damper and stack; and provide dimensional data by way of diameters,
lengths, and fitting angles.
3. With each FCS in its starting mode (i.e., after completing at least one complete
off-line shaking cycle), gather the following data:
a. Flow Rates: Using standard pitot tubes compensated for temperature and
Magnehelic gauges calibrated against manometers, air flow readings shall be
obtained at each of the following locations:
In the trunk duct on the roof
In the downcomer duct between the baghouse and the fan
In the stack
b. Static Pressure: Using Magnehelic gauges calibrated against manometers,
the static pressure readings shall be obtained at each of the following
locations:
Upstream and downstream of the: 1) duct separation on the furnace; 2)
telescoping duct; and 3) baghouse at the points where filter total
differential pressure will be monitored
Fan inlet and outlet (fan outlet on both sides of the control damper)
The starting mode is when the FCS is operating optimally. This means that the
baghouse has been thoroughly shaken down and the entire system is otherwise
clean and operational.
4. Compare the measured fan airflow rate and differential static pressure to that
predicted by the fan curve. Where there is variance, identify the reasons for any
variance.
5. Use the design parameters of the Industrial Ventilation Manual of Recommended
Practice of the American Conference of Governmental Industrial Hygienists
(ACGIH) to predict the pressure drops of the ductwork and fittings. Where there

A-8

is variance between the measured and the predicted static pressures, identify the
reasons for any variance.
6. After completing evaluations in the ventilation system starting mode in Steps 3-5
with the damper set in its normal position, damper back the fan to a minimum of
ten (10) additional settings. At each of these ten (10) settings, measure fan static
pressure and fan exhaust flow rate and temperature. Plot these actual points of
operation on a fan performance graph to demonstrate that the relationship
between flow rate and fan static pressure is always inverse, signifying that the
fan performance in this zone is predictable.
7. Within 30 days of completing Phase 2A, prepare and submit to EPA a report
detailing the findings and conclusions, together with supporting documentation,
about Maynard’s ventilation system capacity.
B. Establishing Ventilation Performance Limits – Hot Work
Prior to conducting Phase 2B, first the hood static pressure and filter total differential
pressure monitors described in Phase 1 must be installed, calibrated and
commissioned, and operating continuously on EAF Nos. 5, 6 and 7 (Phase 1).
Phase 2B will include data collection on a minimum of three (3) heats per EAF as
described below.
During Phase 2B, Maynard shall complete the following:
1. Maynard shall: (1) within 30 days of commencing test heats and no later than 30
days after completing a shift during which the test heats were performed, conduct
bag leak testing using fluorescent dye, as set forth in either paragraph 9 of the
“Periodic Inspection Guide – EAF Shaker Baghouse” contained in the O&M Plan,
or a comparable procedure from an outside contractor; and (2) conduct a visual
clean-side inspection of the baghouse associated with the EAF for which Phase
2B is being conducted no more than 48 hours before commencing and within 48
hours of the end of the shift in which the test heat(s) were completed. The cleanside inspection shall be conducted during daylight hours and consist of the
following activities:
a. Ensuring that the baghouse ventilation system is turned off.
b. Observing the condition of the baghouse access door for faulty gaskets,
warping and proper alignment. Air leakage into the clean air plenum from
outdoors via improper seals around the access door has the potential to
alter dust settling conditions inside the clean air plenum – if such
conditions are encountered, then they must be corrected.
c. Opening the access door to the baghouse.

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d. Without physically entering the baghouse, visually verifying that the floor
of the clean air plenum is free of any readily visible dust layer. This may
necessitate the use of supplemental artificial lighting to visibly assess the
condition of the floor of the clean air plenum.
e. Noting whether or not any dust is observed on the floor of the clean air
plenum. If dust is observed, then investigate and correct the cause
thereof (e.g., repair access door gaskets, etc.) consistent with the O&M
Plan, and remove the dust from the floor of the clean air plenum in
accordance with applicable requirements (e.g., confined space entry).
f. Securely closing access to the baghouse.
The results of these inspections shall be documented and provided to EPA as
part of the Final FCS Report, described in Phase 3, item 5 below.
2. Begin a melting heat with the FCS in its starting mode as described in Phase 2A,
item 3 above. Operate the FCS to collect and capture all PM emissions from the
EAF for the duration of the heat, unless otherwise specifically noted. Leave the
on-line shaking protocol (as described in Section 1.2) on, as usual, and the fan
control damper in its normal position. The hood static pressure in the starting
mode prior to powering on the EAF will be a candidate Low-High Set Point.
3. Record on a Microsoft Excel spreadsheet pertinent process information for this
heat, including: 1) mass of total metal charged; 2) start time; 3) power on / off
time; 4) oxygen lancing start / end time(s) and associated pressure settings; 5)
refining – start / end time(s) and associated pressure settings; 6) tapping start
time; 7) type of metal(s) charged; and 8) type and mass of each additive.
4. Visually observe and document emissions capture at the electrodes throughout
the heat via video recording. Qualitatively confirm that emission capture at the
inlet of the local exhaust hood is essentially complete throughout the heat.
5. From the continuously monitored data, establish the reduction in hood static
pressure, and the rise in total filter differential pressure across the baghouse that
occurred throughout the heat.
6. Repeat steps 2-5 on a second heat, except that during the high-pressure oxygen
lancing phase of the heat (refining, specifically), reduce the hood flow rate via fan
dampering to a flow rate such that capture of emissions during refining is
substantially complete and visually marginal (e.g., capture may be less direct and
small puffs may start to move away, only to be drawn back by the suction of the
fan).
The hood static pressure associated with that suction level will represent a
candidate Low-Low Set Point below which melting and refining should not
continue, or should continue only in accordance with procedures established in

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the O&M Plan, which are intended to raise hood static pressure and flow rate to
sufficient levels to allow the heat to continue.
7. Complete the heat under normal conditions after Step 6. The hood static
pressure at the completion of the heat will be a candidate High-Low Set Point.
8. During the course of completing evaluations in Steps 2-5, at a minimum,
measure fan static pressure and fan exhaust flow rate and temperature at the
following points during the furnace heat:
a. at the start of the heat
b. at the beginning and end of low pressure oxygen lancing (melting)
c. at the beginning and end of high pressure oxygen lancing (refining)
d. at the end of the heat
9. Evaluate the circumstances around any instances where hood static pressure fell
below the High-Low, and/or the Low-Low Set Point, and detail the steps that
were taken to remedy those conditions.
10. During the course of completing evaluations in Steps 6 and 7 in subsequent
furnace test heats and in the following order, at a minimum, measure fan exhaust
flow rate, fan static pressure and temperature at the following points:
a. at the start of the heat
b. at the beginning and end of low pressure oxygen lancing (melting)
c. at the start of high pressure oxygen lancing (refining)
d. after reducing the exhaust rate to the point that defines the Low-Low Set
Point during refining
e. as time allows given the relatively short duration of refining operations,
following airflow adjustments to one or more airflow rates between points c
and d, above
f. at the end of the heat
Phase 3 – Fume Capture Performance during Subsequent Production Melting
Heats
Phase 3 is intended to use the monitoring Set Points established in Phase 2B to assess
capture performance during three (3) additional heats on each EAF. During Phase 3,
Maynard will complete the following:
1. Begin a melting heat with each FCS in its starting mode as described in Phase
2A, item 3 above. Operate the FCS to collect and capture all PM emissions from
the EAF for the duration of the heat, unless otherwise specifically noted. The
hood static pressure in the starting mode shall be a candidate Low-High Set
Point.
2. Using the parametric monitoring equipment (Phase 2B), monitor the hood static
pressure and total filter differential pressure, and respond to any limit settings

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reached during the three (3) additional heats on each furnace by taking
corrective steps as detailed in the O&M Plan.
3. Record pertinent process information for each heat on a Microsoft Excel
spreadsheet (see Phase 2B, Step 2).
4. Use a single stationary video camera to record emissions capture where the
electrodes penetrate the furnace cover, coordinated with the parametric
monitoring of the hood static pressure, and total baghouse differential pressure.
5. Prepare a Final FCS Report detailing the steps taken and results of Phase 2B
and Phase 3. Submit the Final FCS Report to EPA for review and approval
within 60 days of completing Phase 3.

Phase 4 – Performance Testing
Phase 4 is the final phase of the Study. Maynard shall conduct stack performance tests
on the baghouse associated with each operational EAF. These performance tests will
be conducted in accordance with the requirements detailed in Section VI (Compliance
Requirements) of the Consent Decree.
4.0

Modification of Study

This Study may be modified as a non-material change by written agreement between
Maynard Steel and the USEPA, as provided under Paragraph 129 of the Consent
Decree.

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