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 B
Maynard Steel Casting Company
Operation & Maintenance Plan and Malfunction
Prevention & Abatement Plan
Operation & Maintenance Plan
and
Malfunction Prevention & Abatement Plan
Maynard Steel Casting Company
Milwaukee, Wisconsin
September 2015
Operation & Maintenance Plan
and
Malfunction Prevention & Abatement Plan
Maynard Steel Casting Company
Milwaukee, Wisconsin
September 2015
Maynard Steel Casting Company
Final Copy
© 2011 RMT, Inc.
All Rights Reserved
Table of Contents
1.
Overview ....................................................................................................................................... 1-1
1.1
1.2
1.3
1.4
2.
Process Overview ........................................................................................................................ 2-1
2.1
2.2
3.
Process Description ............................................................................................................ 2-1
Discussion of Emissions .................................................................................................... 2-2
2.2.1 Primary Capture .................................................................................................... 2-2
2.2.2 Secondary Capture ................................................................................................ 2-3
2.2.3 Furnace Cover & Furnace Interface .................................................................... 2-4
2.2.4 Slag Door Deflectors ............................................................................................. 2-4
2.2.5 Slag Pit .................................................................................................................... 2-5
Startup, Shutdown & Operating Procedures ............................................................................ 3-1
3.1
3.2
3.3
3.4
3.5
4.
Pollution Prevention Management Practices ................................................................. 1-1
Malfunction Prevention & Abatement Plan Requirement ........................................... 1-2
Functional Organization of Plan ...................................................................................... 1-2
Plan Modification ............................................................................................................... 1-3
Purpose ................................................................................................................................ 3-1
Startup Procedures............................................................................................................. 3-1
Shutdown Procedures ....................................................................................................... 3-1
3.3.1 EAF .......................................................................................................................... 3-2
3.3.2 EAF Ventilation Systems ...................................................................................... 3-2
Operating Parameters and Response Actions ................................................................ 3-2
Recordkeeping & Reporting ............................................................................................. 3-4
Malfunction Prevention & Abatement Plan ............................................................................. 4-1
4.1
4.2
4.3
4.4
4.5
4.6
Purpose ................................................................................................................................ 4-1
Scope .................................................................................................................................... 4-2
Individuals Responsible for Inspection, Maintenance, and Repair ............................ 4-2
Inspections .......................................................................................................................... 4-3
4.4.1 Routine Inspections............................................................................................... 4-3
4.4.2 Periodic Inspection of Overall System ............................................................... 4-4
4.4.3 Periodic Inspection of Bags .................................................................................. 4-5
Calibration Schedule .......................................................................................................... 4-5
Spare Parts Inventory ........................................................................................................ 4-5
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4.7
4.8
4.9
4.10
5.
Corrective Action Procedure ............................................................................................ 4-6
Records Retention & Periodic Review ............................................................................ 4-7
Reporting ............................................................................................................................. 4-7
Conformance with MPAP ................................................................................................. 4-8
Reporting Requirements .............................................................................................................. 5-1
5.1
5.2
Reporting Requirements ................................................................................................... 5-1
Compliance Monitoring & Certification ......................................................................... 5-2
List of Tables
Table 3-1
Table 3-2
Table 4-1
Table 4-2
Operating Conditions & Monitored Parameters for EAF Operations
Response Actions
Maximum Intervals for Routine Inspections
Items or Conditions Checked During Routine Inspections
List of Figures
Figure 2-1
Electric Arc Furnace
List of Appendices
Appendix A
Appendix B
Appendix C
Appendix D
Calibration Records
Routine Inspection Checklists
- Maynard Steel Pollution Control Device Daily Inspection Record
- Maynard Steel Pollution Control Device Weekly Inspection Record
- Baghouse Dust Collector Monthly Prevention Maintenance Record
- Parametric Monitoring Device Measurement Logs & Calibration Record
Assessment
Periodic Inspection of EAF Systems
- Periodic Inspection Guide – EAF Shaker Baghouse
- EAF Shaker Baghouse Inspection Checklist [alt. used if performed by 3rd party]
- EAF Shaker Baghouse – Bag Condition [alt. used if performed by 3rd party]
MPAP Review Forms
- MPAP Semiannual Compliance Review
- MPAP 5-year Review
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Appendix E
Appendix F
Appendix G
EAF Emission Control System Checklists & Operating Parameters
- EAF Emissions Control – Parametric Operating Limits
- EAF Emissions Control Checklist – Maintenance Pre-Operation
- EAF Emissions Control Checklist – Melt Department Operation
- EAF Emissions Control Checklist – Re-bagging
Malfunction Occurrence Log
MPAP Spare Parts Inventory
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Section 1
Overview
Maynard Steel Casting Company (Maynard Steel) operates a steel foundry that is located in
Milwaukee County at 2856 South 27th Street in Milwaukee, Wisconsin. The Wisconsin
Department of Natural Resources (WDNR) facility identification number for this facility is
241005710. A facility-wide air operating permit was issued to the facility on November 26, 2004,
under WDNR Permit No. 241005710-P01, which was renewed on November 24, 2014, as WDNR
Permit No. 241005710-P20.
This document has been prepared as a combined Operation & Maintenance (O&M) and Startup,
Shutdown and Malfunction (SSM) plan, as required in accordance with conditions established
under a 2015 Consent Decree (CD). Due to the overlapping nature of similar state-specific
requirements, this plan also serves to consolidate into this plan, Malfunction, Prevention and
Abatement Plant (MPAP) requirements codified under s. NR 439.11, Wis. Adm. Code. An
overview of the pollution prevention management practices required under the Consent Decree
are discussed in Section 1.1, while discussion of the MPAP requirements is presented in Section
1.2. The functional organization of this consolidated plan is summarized in Section 1.3.
1.1
Pollution Prevention Management Practices
The primay pollution prevention management practices required to be implemented in
accordance with the CD and associated schedules specified therein, include the following:
1. Operate and maintain for each electric arc furnace (EAF) a capture and fume collection
system (i.e., air pollution control equipment) that meets accepted engineering standards
(e.g., American Conference of Governmental Industrial Hygienists [ACGIH]);
2. Install and operate continuous parametric monitoring systems (CPMS) on each
operating EAF to measure the pressure drop across each baghouse, and the hood static
pressure for the local exhaust hood;
3. For each operating EAF, install, maintain and operate a bag leak detection system
(BLDS) in accordance with a BLDS Monitoring Plan, which senses and records relative
particulate loading, and is equipped with an audible alarm;
4. Prepare and operate all EAF particulate control devices in accordance with an O&M
Plan that includes, in part, monthly inspection of equipment (e.g., pressure sensors,
dampers, etc.) related to performance of the total capture system, which is also referred
to as the fume collection system (FCS); and
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5. Prepare and operate according to a Startup, Shutdown and Malfunction (SSM) plan [See
Section 3].
1.2
Malfunction Prevention & Abatement Plan Requirement
Pursuant to s. NR 439.11(1), Wis. Adm. Code, a source that may emit hazardous substances, or
that emits more than 15 pounds in any day or 3 pounds in any hour of any air contaminant for
which emission limits have been adopted is required to prepare a written MPAP. The purpose
of a MPAP is to detail actions and procedures that are intended to prevent, detect and correct
malfunctions or equipment failures that may cause any applicable emission limitation to be
violated or which may cause air pollution. This requirement is specifically included in
Maynard Steel’s air operating permit under Condition I.ZZZ.7. Although this requirement
applies to sources in addition to the EAF, the MPAP has been incorporated in its entirety into
Section 4 of this consolidated plan.
1.3
Functional Organization of Plan
This document has been developed to consolidate elements of Maynard Steel’s operation,
maintenance, and malfunction prevention & abatement procedures related to its EAF
operations into single document to increase efficiencies and clarity, maintain consistency, and
minimize redundancy. To this end, this consolidated plan is organized as follows:
Section 2 – Process Overview: This section provides a general overview of the EAF
operations, the associated emissions and the overall system intended to manage such
emissions, including the capture and control thereof.
Section 3 – Startup, Shutdown & Operating Procedures: This section presents
information regarding procedures related to operating and maintaining the EAFs,
including during periods of SSM. Information regarding the controls and operating
practices employed to manage emissions (e.g., capture, control, reduce) is discussed
along with corresponding parameters that are monitored to ensure that such controls
and operating practices are effectively implemented. Response actions are also detailed
for instances where an operating condition or monitored parameter may be outside of
appropriate ranges or set points.
Section 4 – Malfunction Prevention & Abatement Plan: The MPAP contained herein is
intended to serve as a stand-alone document that addresses applicable requirements
under s. NR 439.11 for all covered sources; however, it has been incorporated into this
consolidated document for the reasons noted above.
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The combination of elements under Sections 3 and 4 are intended to address operation and
maintenance, as well as startup and shutdown procedures particularly related to the EAF
operations, while also presenting Maynard’s program that is targeted to preventing
malfunctions and, where necessary, implementing appropriate response actions.
1.4
Plan Modification
This plan may be modified via operating permit revision procedures codified under ss. NR
407.11 through 407.13, Wis. Adm. Code, and/or in accordance with applicable construction
permitting requirements codified under chapters NR 405, 406, or 408, Wis. Adm. Code.
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Section 2
Process Overview
2.1
Process Description
Maynard Steel uses four EAFs designated as EAF Nos. 4, 5, 6, and 7 to produce its castings.
These EAFs were installed between 1940 and 1982. In general, an EAF is a refractory-lined steel
pot, fitted with a refractory-lined cover through which three vertical graphite electrodes are
inserted, as shown in Figure 2-1.
The interface between the sidewalls of the pot and the cover is comprised of layer of sand that is
used to reduce gaps that may otherwise allow fugitive emissions to escape or excess air to enter.
The metal charge is melted with static electrical arcs generated by electrical current flowing
among the electrodes and through the charge.
Figure 2-1. Electric Arc Furnace
[Source: USEPA, AP-42, 5th ed., Section 12.13, page 12.13-3]
An EAF heat cycle (a.k.a. “heat”) generally commences with charging of an EAF, and concludes
with tapping into a pouring ladle. Interim stages can include melting, oxygen lancing, backcharging, refining, testing and slagging. The EAF is vertically oriented when charging and
when melting commences, but it may be necessary to tilt the EAFs at different stages of the heat
(e.g., for oxygen lancing, refining, slagging and tapping). The frequency and degree of tilting
during a heat is variable depending on a variety of production requirements and operating
needs. For example, if scrap adheres to a side of the EAF or forms a bridge such that it cannot
be adequately accessed by lancing through the slag door with the EAF in the fully vertical
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position, then it may be necessary to tilt the EAF to achieve the necessary access and/or position
to release the scrap.
2.2
Discussion of Emissions
In brief, the points of emission from the EAF operations prior to tapping include the following
after the EAF is powered on:
1.
Vertical discharge of hot gases while melting, which emanate from the annular spaces
in the furnace cover around the three electrodes which penetrate the cover.
2.
Emissions out of the interface between the furnace and furnace cover.
3.
Buildup of hot gases inside the EAF can result in puffing out the slag door, especially
when the air lance is used to clear scrap from the slag door and when the EAF is tilted
forward during refining activities.
4.
As slag is poured and dragged out of the slag door, it collects in the slag hopper
outside of the EAF, from which emissions may continue as the slag cools.
The vast majority of emissions (on a total mass basis) are anticipated to be attributed to the first
of these points, with the balance contributing significantly less emissions. Tapping, including
the associated additions of de-oxidants, generates additional emissions. Brief discussions of
these sources are presented in the following subsections.
2.2.1
Primary Capture
EAFs 5, 6, and 7 are each equipped with a sidedraft hood that is connected to a
telescoping duct to direct emissions to a dedicated shaker baghouse that is, in turn,
exhausted to the ambient atmosphere. The sidedraft hood is configured to capture the
majority of the emissions from the annular spaces in the EAF cover around the
electrodes, while the telescoping duct allows for continuous draw at these points even
when the EAF is tilted.
As the scrap melts down, back-charging may be necessary to add more scrap to the EAF,
in which case the EAF roof (cover) is temporarily opened (along with the electrodes) so
that additional charge can be loaded into the EAF. At such times, the EAF roof is
temporarily removed, thereby disengaging the sidedraft hood, to allow the charge
bucket to introduce additional scrap into the EAF. Once added, the EAF roof is returned
to position and melting can continue as the electrodes are re-inserted into the EAF.
The ventilation configuration for EAF 4 currently differs from that which is employed on
EAF’s 5, 6, and 7, and includes a combination: 1) local capture via an enclosing hood; 2)
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room exhaust ventilation via an overhead hood; and 3) the use of an engineered air
curtain to contain emissions in the west end of the melt shop.
An enclosing hood is capable of directly capturing the majority of emissions when a
furnace is vertically oriented and the EAF cover is in place; however, its capture
efficiency when so oriented can be challenged due to changes in furnace pressure (e.g.,
due to melt reactions, refining, and oxygen lancing) that can cause fumes to escape
through the annular spaces around the electrodes. Consequently, the enclosing hood is
the first component of an integrated ventilation system that relies on other established
ventilation techniques to assist in the containment and secondary capture of emissions
that are not initially captured by the enclosing hood.
Containment of the emissions in the west end of the melt department – where EAFs 4, 5,
and 6 are located in line, respectively, from west to east - is effected by the use of an
engineered air curtain (based on ACGIH engineering design calculations) that is located
immediately east of EAF 6. This air curtain was designed to span the melt bay from
north to south, and restrict emissions from migrating beyond (i.e., to the east) of the air
curtain. Significant openings in the roof (e.g., windows, seams) are sealed or otherwise
closed to reduce the potential for emissions restrained in this area to leave the building
by means other than by powered exhaust ventilation systems serving the west end – in
particular, including: 1) a roof canopy exhaust hood situated between EAFs 4 & 5; 2) the
enclosing hood on EAF 4; and 3) the sidedraft hoods on EAFs 5 & 6. The roof canopy
exhaust is strategically positioned to capture a significant portion of the emissions (not
otherwise captured by the enclosing hood) that thermally rise from EAF 4. The canopy
hood, enclosing hood on EAF 4, and operating sidedraft hoods on EAFs 5 and/or 6
further assist in providing secondary capture of emissions that are retained in the west
end by the air curtain (e.g., emissions occurring when the EAF roof is removed for backcharging, or when EAF 4 is otherwise not vertically oriented). With the building being
reasonably sealed and under negative pressure, the only means for emissions to
evacuate the building are via powered ventilation systems in this area.
2.2.2
Secondary Capture
Although the sidedraft hoods are not explicitly designed to capture emissions from the
interface between the EAF and the EAF roof (cover), or emissions that may emanate
from the slag door or slag pit, there is a zone of influence established by the sidedraft
hood whereby emissions in the vicinity of the EAF are drawn to the inlet of the sidedraft
hood due to relative negative pressurization. This effect is one example of secondary
capture, whereby emissions that are not directly vented via a dedicated local exhaust
system are secondarily drawn into such systems along with inplant air. Secondary
capture of at least part of the emissions that are not directly captured by the sidedraft
hoods on EAFs 5, 6, and 7, and the enclosing hood on EAF 4 is expected as a result of the
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negative pressurization of the melt department, which is predominantly attributed to
the effect of the local exhaust systems that serve these EAFs.
Understanding that the supply air that enters the local exhaust system is inplant air that
is drawn from the vicinity of the EAF, if emissions that are not directly captured by a
local exhaust system are retained within the area or zone from which the supply air is
drawn, then there is an increased possibility to expedite the secondary capture such
emissions while reducing effective age of air. To this end, Maynard Steel uses an air
curtain, as discussed in Section 2.2.1 to retain emissions within vicinity of the EAF’s to
promote the more expeditious secondary capture of emissions by the powered exhaust
systems and associated exhaust hoods (e.g., sidedraft hoods, enclosing hood, canopy
hood).
2.2.3
Furnace Cover & Furnace Interface
In general, in cases involving an EAF with a continuous and uninterrupted sand layer,
the majority of the air emissions over the course of a heat are expected to emanate from
the annular electrode holes, while lesser amounts of emissions are anticipated from the
slag door. The interface between the sidewalls of the pot and the cover is comprised of
layer of sand that is used to reduce gaps that may otherwise allow fugitive emissions to
escape or excess air to enter.
2.2.4
Slag Door Deflectors
To enhance the secondary capture of emissions from the slag door (e.g., when slag is
dragged out and deposited in a slag hopper beside the EAF, or when the EAF it tilted as
for oxygen lancing), deflectors are employed on EAFs 5, 6, and 7 to assist in directing
such emissions toward the sidedraft hoods. Such deflectors include fabricated plates
that are installed above the slag door, and in some instances the equipment (e.g., existing
ductwork - as is the case on EAF 5) itself coincidentally is configured to effectively act as
a deflector.
The deflectors improve indoor air quality by reducing slag door emissions and the
potential for such emissions to migrate from the building. The deflectors enhance and
expedite (i.e., reduce the age of air) the secondary capture of slag door emissions.
However, given the relatively small amounts of emissions from the slag door, operation
of the EAFs does not mandate the deflectors are used. Absent the deflector plates, such
emissions are generally expected to migrate with prevailing in plant air flows to areas of
relative negative pressurization, which are predominantly established by the EAF
baghouses within the melt department that, in turn, assist with secondary capture of
such emissions via by the powered exhaust systems and associated exhaust hoods (e.g.,
sidedraft hoods, enclosing hood, canopy hood).
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2.2.5
Slag Pit
In addition to slagging activities, some off-gassing from materials in the slag pit is
expected. As with the puffs from the slag door, some of the off-gassing of materials in
the slag pit are reasonably anticipated to be drawn into the local exhaust hoods. The
total mass of emissions from materials in the slag pit can be limited by controlling the
amounts of combustible materials that enter the pit (e.g., samplers used to collect molten
metal samples for spectroscopic analysis are comprised of consumable materials). To
avoid undue combustion thereof and associated fugitive emissions from the slag pit, the
remaining portion of the samplers will either be cooled via dipping in water and placed
into dedicated containers for appropriate disposal, or placed directly into an EAF to
complete the consumption thereof so that associated emissions may be directly captured
and vented to the corresponding baghouse.
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Section 3
Startup, Shutdown & Operating Procedures
3.1
Purpose
The purpose of this section of the plan is to describe procedures for operating and maintaining
the emission sources discussed in Section 2 during periods of startup, shutdown and normal
operations to:
1. Ensure that, at all times, each affected source (as described in Section 2), including
associated air pollution control and monitoring equipment, is operated and
maintained in a manner which satisfies the general duty to minimize emissions
established by 40 CFR 63.6(e); and
2. Reduce the reporting burden associated with periods of startup and shutdown.
3. Achieve the Pollution Prevention Management Practices described in Section 1.1 of
this plan.
3.2
Startup Procedures
The startup procedure includes checking various conditions associated with the systems
described in Section 2 to ensure that they are in proper condition before initiating a heat. The
conditions that are checked are detailed on two checklists that are provided in Appendix E:
1. EAF EMISSIONS CONTROL CHECKLIST – MAINTENANCE PRE-OPERATION:
This checklist details items that are normally checked during first or second shift, or
otherwise in advance of commencing melting. Metal melting is not performed during
these daytime/afternoon shifts due to increased electrical costs. NOTE: Metal melting is
primarily conducted during non-peak hours from from 8:00 p.m. to 8:00 a.m.
2. EAF EMISSIONS CONTROL CHECKLIST – MELT DEPARTMENT OPERATION:
This checklist details items that are checked for each heat before melting commences.
Also included on this checklist are operating conditions that are checked, which are
further discussed in Section 3.4.
3.3
Shutdown Procedures
Certain shutdown activities need to be performed in a sequential manner. Specifically, after
tapping is completed for the final heat for a given period (i.e., 8:00 p.m. to 8:00 a.m.), the EAF is
first powered down before proceding with the shutdown of the balance of the emissions control
related systems.
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3.3.1
EAF
EAF shutdown is to occur before the baghouse shutdown practices are initiated. This
practice is intended to prevent excess emissions from being released from the EAFs as
part of the normal shutdown procedure. The EAFs will be shutdown as described by
standard operating procedures (SOP) internal to Maynard Steel.
3.3.2
EAF Ventilation Systems
The shutdown procedure for the EAF ventilation systems can be initiated after an EAF
has been tapped, powered off, and fugitive indoor emissions from the EAF operations
have substantially cleared. After the conclusion of the scheduled heats for a melt shift
for a particular EAF, the appropriate shutdown procedure for each baghouse is to be
followed using corresponding SOPs, which generally entail allowing one-complete
shake-down cycle to proceed after shutting off the fan. This action is to be completed
prior to the next scheduled heat.
Each baghouse is designed to allow isolation of individual cells for bag replacement or
repair. Routine maintenance of filter bags in the baghouse system is not classified as a
reportable event for purposes of this plan.
In addition to shutting down a baghouse, the blower for the air curtain (to the
immediate east of EAF 6) may be turned off after all of the west end EAFs (i.e., EAF Nos.
4, 5 or 6) have been powered down, and fugitive indoor emissions from the west end
EAF operations have substantially cleared.
3.4
Operating Parameters and Response Actions
Table 3-1 delineates the operating practices and parameters that are monitored to ensure that
the overall EAF emissions control system is functioning properly while a heat is being
performed. These elements are also incorporated into the ‘EAF EMISSIONS CONTROL
CHECKLIST – MELT DEPARTMENT OPERATION’ contained in Appendix E. Operating
limits for each operating parameter, as established during testing or as otherwise specified in
the NR 407 operating permit are summarized in Appendix E. Maynard uses a continuous
parametric monitoring systems (CPMS)1 that includes the hood static pressure for the sidedraft
hood system, the pressure drop across the baghouse, and BLDS implemented in accordance
with the CD.
A CPMS, also called parametric monitoring, measures a parameter (or multiple parameters) that is a key
indicator of system performance. The parameter is generally an operational parameter of the process or
the air pollution control device (APCD) that is known to affect the emissions levels from the process or
the control efficiency of the APCD. Examples of parametric monitoring include temperature, pressure, or
flow rate monitoring.
1
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CPMS – Hood Static Pressure: The hood static pressure is used to ensure that the
sidedraft hood is providing sufficient draw throughout the heat. Operating setpoints
are EAF-specific and are generally based on empirical information related to various
factors (e.g., hood, duct, baghouse configuration, etc.). Changes in such factors that
reduce the draw can be manifested in a decrease in the hood static pressure. For
example, an increase in the pressure drop across the baghouse will tend to result in a
reduction in the hood static pressure. Similarily, damage to ductwork can cause an
increased pressure drop across the system that contributes to a decreased hood static
pressure. A Hi-Low setpoint is established as an alert that the hood static pressure is
approaching its minimum or Low-Low setpoint; thereby allowing time for actions to be
implemented, where appropriate, to increase the hood static pressure before actually
exceeding the Low-Low setpoint. If the hood static pressure drops below the Low-Low
point, a the draw is deemed to be inadequate to provide effective capture.
CPMS – Baghouse Pressure Drop: In general, the pressure drop is used as an indicator
of the relative performance of the baghouse, and includes both a lower and upper
bound. A low pressure drop can be indicative of air bypassing or otherwise
unacceptably passing through a bag (e.g., bag break, improperly seated bags, etc.).
Conversely, an elevated pressure drop can translate into a reduction in exhaust flow and
also result in excess strain on the fibers of the bags, which can stretch the fibers and
expand the pathways through which dust can pass. The proper operating range for the
pressure drop is based on manufacturer recommendations, ventilation studies,
baghouse maintenance contractor recommendations, or other appropriate methods.
Internally, a Hi-Low and a Hi-Hi point are established within the proper operating
range to provide setpoints that serve as an alert that the parameter is approaching an
endpoint of the range; thereby allowing time for actions to be implemented, where
appropriate, to reduce the potential for the monitored parameter to actually exceed the
proper operating range. It is important to note that the proper range may change under
certain circumstances (e.g., change in bag supplier, etc.).
CPMS – BLDS: Light scattering BLDS will be installed, operated and maintained on
each EAF-baghouse in accordance with the terms and conditions established under the
CD, which include operation in accordance with a BLDS Monitoring Plan.
In the event of a deviation from an established operating limits, the corrective action procedure
in Section 4.7 is implemented. To facilitate the implementation thereof, reasonably anticipated
deviations and the corresponding response actions are identified by a unique identifier (e.g., “R01”) in right-most column of Table 3-1, which are cross-referenced to detailed response actions
that are presented in Table 3-2. In the event of a verified malfunction that necessitates the
implementation of the procedure presented in Section 4.7, a Malfunction Occurrence Log
provided in Appendix F will be completed. This log includes information regarding completion
of appropriate corrective actions to address the malfunction.
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3.5
Recordkeeping & Reporting
The checklists discussed in Section 3.2, as well as any Malfunction Occurrence Logs are to be
signed by the on duty Maintenance Supervisor, the on duty Melt Supervisor, and the
Maintenance Superintendent/Manager. Ultimately, these documents should be routed to the
Safety/Environmental Manager or his/her designee for centralized recordkeeping and will be
retained for at least five (5) years. In the event of a malfunction condition that is not identified
in Table 3-2, this plan will be modified and updated to include the newly identified malfunction
condition within 6-months of the identification thereof.
Situations under which Maynard Steel is required to report to the WDNR are discussed in
Section 5.1. In brief, such reporting includes notifications in the event of the following: 1) a
hazardous substance air spill; 2) a malfunction or other unscheduled event that causes or may
cause any emission limitation to be exceeded; 3) schedules for the planned shutdown and
startup of air pollution control equipment and the measures to be taken to minimize the down
time of the control equipment while the source is operating; and 4) any deviations from the
terms and conditions of the operating permit.
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Section 4
Malfunction Prevention & Abatement Plan
4.1
Purpose
As discussed in Section 1.2, this Malfunction Prevention and Abatement Plan (MPAP) is written
in accordance with s. NR 439.11, Wis. Adm. Code. Pursuant to this requirement, the purpose of
this MPAP is to detail actions and procedures that are intended to prevent, detect and correct
malfunctions or equipment failures that may cause any applicable emission limitation to be
violated or which may cause air pollution. To this end, the MPAP
1. Identifies positions responsible for inspecting, maintaining and repairing emission
control devices;
2. Describes items, equipment, and conditions that will be checked, and the maximum
intervals for such checks and routine maintenance;
3. Presents the calibration schedule for any device that monitors either a source or air
pollution control operational variables;
4. Provides a listing of materials and spare parts that will be maintained in inventory to
facilitate the expeditious repair of control device systems; and
5. Describes corrective action procedures that will be taken in the event of a
malfunction or failure that results in the exceedance of an applicable emission
limitation.
Pursuant to s. NR 439.11(1), Wis. Adm. Code, a source that may emit hazardous substances, or
that emits more than 15 pounds in any day or 3 pounds in any hour of any air contaminant for
which emission limits have been adopted is required to prepare a written malfunction MPAP.
This requirement is specifically included in Maynard Steel’s air operating permit under
Condition I.ZZZ.7.
In light of the overlapping nature of select O&M and SSM requirements established under
the CD, and those of the state-specific MPAP requirements, Maynard Steel has incorporated
SSM Plan elements related to malfunctions into this MPAP, as well as O&M Plan elements
related to maintenance. In both cases, such elements are exclusively related to the the entire
melt shop including the ventilation systems. These specific elements are not intended to be
addressed herein in relation to sources other than the EAFs, which are only subject to the above-
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noted MPAP requirement. Rather than maintain a separate document for sources other than
the EAFs, they are also addressed in this section.
4.2
Scope
Maynard Steel has a corporate goal of maintaining compliance with all applicable
environmental regulations. It is incumbent on all employees to follow and enforce the best
management practices outlined in this MPAP. All pollution control equipment shall be
operated and maintained in conformance with good engineering practices to minimize the
possibility for exceedance of any emission limitation.
4.3
Individuals Responsible for Inspection, Maintenance, and Repair
Personnel responsible for inspecting, maintaining, and repairing the control equipment covered
under this MPAP are listed below according to s. NR 439.11(1)(a).
Location:
2856 S. 27th Street Milwaukee, WI 53215
Main phone: 414-385-6575 (security desk) - cell during non-business hours 414-940-3894
A. Plant Manager (top executive manager in charge of operations and maintenance)
Ray Sabin
414-385-6593, radio page through security, or cell 414-940-4638
Responsible for the overall administration and financial funding of the MPAP, and
any decisions to discontinue or continue operation of a source that has a
malfunction. In the absence of the Plant Manager, such decisions are to be made by
the Night Manager / Superintendent who shall, in turn, notify the Plant Manager as
soon as possible.
B. Night Manager / Superintendent
John Wasikowski
Radio page through security
In the absence of the Plant Manager, the Night Manager / Superintendent is
responsible for any decisions to discontinue or continue operation of a source that
has a malfunction. This individual will notify the Plant Manager as soon as possible
after making such a decision. This responsibility lies with the designated or acting
Night Manager / Superintendent, if other than the individual named above.
C. Maintenance Superintendent / Manager
Ron Dosch
414-385-6588, radio through security, or cell 550-7940
Responsible for the day to day implementation of the plan, preventive maintenance
schedules, allocating manpower (including the assignment of routine inspections
and repairs to maintenance personnel, as described under Item E below), work
orders, reviewing inspections (see also Section 4.4), maintaining records, calibration
of test equipment, ordering spare parts, etc. Responsible for the prompt notification
of the Plant Manager and the Safety/Environmental Manager when there is a
malfunction or shutdown of pollution control equipment.
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D. Safety / Environmental Manager
Gene O’Kelly
414-385-6570 or cell 414-526-2719
[Alternate:
Jason Krueger 414-385-6572]
Responsible to revise and maintain this MPAP as needed, advise and assist Plant
Manager in decisions to continue operation or discontinue operation in the event of a
malfunction, audit monthly for compliance to the plan and it’s record keeping
requirements, notify top management of deficiencies in compliance, notify
Department of Natural Resources as needed according to the plan.
E. Departmental Supervisors and Superintendents / Managers
Responsible for the proper operation of the equipment in their department (e.g.,
Melt, Maintenance, etc.), turning on/off, coordinate timely emptying of hoppers if
needed, assisting maintenance of any monitoring or data recording necessary,
notifying maintenance when malfunctions or problems are noted, and reviewing
completed maintenance activities and repairs.
F. Maintenance Personnel
Various as specified by the Maintenance Superintendent / Manager
Maintenance personnel identified by the Maintenance Superintendent / Manager as
having an appropriate working knowledge of control devices and monitoring
equipment will be responsible for conducting the routine inspections described
under Section 4.4.1, and for performing select repairs, as necessary and as directed
by the Maintenance Supervisor.
4.4
Inspections
Inspections conducted as part of routine maintenance to identify potential issues that, if left
uncorrected, could lead to a malfunction. For the purpose of this MPAP, the inspections relate
to each air pollution control device that satisfies the criteria under s. NR 439.11(1), as
summarized in Section 4.1, and to each associated parametric monitoring device. The control
device is inspected to ensure that functions properly to control emissions, while the associated
monitoring device is inspected to ensure that it functions properly to provide accurate
parametric information regarding the operation of the control device – e.g., pressure drop across
a baghouse is within the permitted range that is indicative of normal performance.
The inspections required under s. NR 439 are routine inspections that are primarily performed
by Maynard Steel personnel, as discussed in Section 4.4.1. In addition to these routine
inspections, periodic inspections are to be performed of the overall systems associated with the
EAF’s, as discussed in Section 4.4.2.
4.4.1
Routine Inspections
Completion of the routine inspections discussed under this section is the responsibility
of the Maintenance Superintendent / Manager. The intent of routine inspection and
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maintenance of pollution control equipment is to keep the equipment in efficient
operating condition, and prevent malfunctions that may cause an applicable emission
limitation to be violated or which may cause air pollution. The air pollution control
equipment that is subject to routine inspections and the maximum intervals thereof are
summarized in Table 4-1. Associated parametric monitoring devices (e.g., pressure drop
gauges) are inspected and calibrated at least quarterly to ensure that they are operating
properly. Items to be checked during the routine inspections are summarized in Table
4-2.
The maximum intervals for routine control device inspections include daily and weekly
inspections which take in account operating conditions as well as manufacturer’s
recommendations. The intervals for inspection and maintenance shall never be less than
the manufacturer’s recommendations.
In addition to the daily and weekly inspections, each control device listed in Table 4-1
(to the extent it operates) receives monthly preventative maintenance, which includes an
inspection of the total capture system, including observation of the physical appearance
of the equipment (presence of holes in the ductwork or hoods, flow constrictions caused
by dents or accumulated dusts in the ductwork, and fan erosion).
All inspections must be completed and documented by personnel with the appropriate
working knowledge of the control device and monitoring equipment to be inspected.
The resulting inspection reports are to be reviewed by maintenance shift supervisors.
Repairs and any maintenance performed must likewise be performed by Maynard Steel
maintenance personnel with appropriate skills and/or training to make such repairs
and/or outside contractors when necessary. All work completed is to be reviewed by
maintenance shift supervisors. Copies of the associated inspection forms are available in
Appendix B.
The Maintenance Superintendent / Manager is responsible for ensuring that the daily,
weekly, and monthly inspections are being properly performed, and for reviewing the
inspection reports to verify that noted potential issues and repairs are addressed.
4.4.2
Periodic Inspection of Overall System
In addition to the required routine inspections (see Section 4.4.1) that are conducted on
all control devices subject to s. NR 439.11, Maynard Steel conservatively utilizes a thirdparty to conduct periodic inspections to review the condition and performance of the
EAF local ventilation system – including the sidedraft hood, telescoping duct, duct and
baghouse, as well as ancillary systems to increase the capture of emissions from EAF
tapping (e.g., air curtains). A guide outlining the conditions that should be checked
during these inspections are presented in Appendix C. Such inspections will be
Maynard Steel Casting Company
4-4
performed at least once every 12 months of operation and the results documented in
an inspection report, which will be reviewed by appropriate facility personnel including,
but not limited to, the Maintenance Supervisor, Safety/Environmental Manager, and
Plant Manager.
4.4.3
Periodic Inspection of Bags
To assess the effectiveness of the bags and to provide a relative indication as to when a
baghouse should be rebagged, two bags from opposite ends of each baghouse will be
removed (and replaced with spare bags), properly packaged and shipped to a third
party for analysis. The analysis to which the bags will be subjected are intended to:
Determine the condition of the bag (e.g., acceptable for continued use, etc.)
Estimate the approximate useful life remaining
Determine if replacement is required
Present recommendations for enhanced performance (e.g., run shaker longer /
more frequently, die test, etc.)
Such analyses are to be performed in accordancd with manufacturer recommendations,
but at least once every 12-months of operation of the baghouse. Subsequent testing
prior to replacement will be considered as recommended by the third party conducting
the analyses.
4.5
Calibration Schedule
Completion of the required calibrations discussed under this section is the responsibility of the
Maintenance Superintendent / Manager. All flow meters and pressure drop monitoring gauges for
the devices covered under this MPAP must be calibrated according to manufacturers’
directions at least annually. In the case of the pressure drop gauges for each EAF FCS, the
calibration frequency is at least quarterly. Records of the calibrations are required to be
maintained, as part of the required records discussed under Section 4.8. Copies of such
calibration records will be retained in Appendix A for at least three years, starting with
available records for the 2015 calendar year.
4.6
Spare Parts Inventory
At least one of each of the materials and spare parts listed in Appendix G are maintained in
inventory, normally in the stock room. In the event that the spare parts needed to complete
repairs on an EAF FCS are not among those normally maintained in the onsite inventory, then
depending on the nature of the parts and the type of repairs needed, Maynard Steel will secure
such parts either by: 1) directly obtaining the required parts from local vendors and/or ordering
the required parts necessary to complete the repairs in a timely manner; or 2) retaining a
ventilation repair firm to supply the necessary parts and to complete the required repairs.
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4.7
Corrective Action Procedure
In the event of a malfunction or failure that results in the exceedance of an applicable emission
limitation (e.g., parametric monitoring variable outside of a permitted range, etc.), the actions
outlined below will be taken. In the event of a malfunction with an EAF and associated
pollution control equipement, please refer to Tables 3-1 and 3-2.
1.
Verification of the Value of the Operating Parameter: Operating personnel check gauges as
required. If a monitored parameter is determined to be outside the specified ranges,
Maintenance is contacted. In turn, the Maintenance Supervisor in charge, or his/her designee,
should take a new reading to ensure the validity of the reading.
2.
Initial Correction Attempt: After verifying that the monitored parameter is outside the
operating range, the Maintenance Supervisor in charge, or his/her designee, should make
adjustment(s) or repairs, as necessary to return the parameter to within the required
operating range.
3.
Response to Unsuccessful Correction Attempts: If the Maintenance Supervisor in charge, or
his/her designee, determines, through trial and error that the operating parameter cannot
be returned to the stated range, then the operating Department Supervisor should make a
complete assessment of the situation and notify the Plant Manager and the
Safety/Environmental Manager.
4.
Secondary Correction Attempt: After notification of the situation, the Plant Manager, along
with the Maintenance Superintendent / Manager should take the following actions:
—
Assist the Maintenance Supervisor in charge, or his/her designee, in determining the
cause of the malfunction.
—
Solicit the resources necessary to verify that the readings are valid and not attributable
to instrument error.
—
Assist the Maintenance Supervisor in charge, or his/her designee, in making the
necessary adjustments or repairs.
—
Solicit the resources necessary to make the required repairs.
—
If the above efforts are unsuccessful at returning the operating parameter to the
acceptable operating range, solicit resources that are determined to be necessary to
solve the problem.
5.
The Maintenance Superintendent / Manager and/or the Maintenance Supervisor in charge will
direct repairs and inspection of the malfunctioning unit to determine the extent of damage
and estimate the amount of time required to repair the unit.
6.
The Maintenance Superintendent / Manager and/or the Maintenance Supervisor in charge will
determine the amount of time to reasonably and safely shut down the affected plant
operations.
7.
The Maintenance Superintendent / Manager and/or the Maintenance Supervisor in charge will
report the following information to the Plant Manager and Safety/Environmental Manager:
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the cause of the malfunction and the duration of the exceedance, along with the time the
malfunction started and when repairs are expected to be completed.
8.
The Safety/Environmental Manager will make an assessment as to the potential impact of the
malfunction as to whether or not it has or is likely to cause a permit limitation to be
exceeded, and based on this assessment and in consult with the Plant Manager, decide if it is
appropriate to shut down the associated operation – providing such can be done safely.
NOTE: It is possible for certain malfunctions to occur that are do not or are not likely to cause an
emission limitations to be exceeded. In such a case, the operation need not be shut down, and the
WDNR does not need to be notified. Repairs then need to be made as quickly as possible to restore
the equipment to its normal operating condition.
9.
The Safety/Environmental Manager will call the WDNR Bureau of Air Management contact
by the next business day of any such event, and inform such person that:
—
a malfunction has occurred;
—
which unit is malfunctioning;
—
the cause of the malfunction and duration of the exceedance;
—
what time the malfunction started or was discovered; and
—
when repairs are expected to be completed and the measure(s) that will be taken to
minimize emissions during that period.
10. If required, following safe shut-down of the affected equipment, the Maintenance
Superintendent / Manager and/or Maintenance Supervisor in charge will proceed with the
required corrective actions as directed by the Plant Manager.
11. The Safety/Environmental Manager, or his/her designee, will document the malfunction
occurrence (Appendix F) and send copies of such documentation to the appropriate WDNR
personnel, as necessary.
4.8
Records Retention & Periodic Review
Documented records and forms of the inspections are to be retained in the Environmental
Department for a minimum period of five (5) years (see Appendix B & C), or in another area as
specified by the Plant Manager or the Safety/Environmental Manager. This MPAP will be
reviewed and updated, if necessary, at least every 5 years. A form to facilitate the document
that such a review has been completed is provided in Appendix D.
4.9
Reporting
In relation to this MPAP, situations under which Maynard Steel is required to report to the
WDNR include: 1) a hazardous substance air spill; and 2) a malfunction or other unscheduled
event that causes or may cause any emission limitation to be exceeded. Details regarding such
reporting are presented in Section 5.1.
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4.10 Conformance with MPAP
This MPAP is an enforceable document under Maynard Steel air operating permit (Condition
I.ZZZ.7); therefore, adherence to the elements of this MPAP is required. Maynard Steel must
document conformance with this plan as part of required semiannual compliance monitoring
reports, and in a required annual compliance certification. Consequently, the Maintenance
Superintendent / Manager and the Plant Manager shall certify every six months, by signature, that:
1. The facility has operated according to this MPAP;
2. There were no deviations from the MPAP;
3. No deviations were reported to the Safety/Environmental Manager;
4. There were no known exceedances of applicable PM, HAP or fugitive emissions limits;
and
5. There were no malfunctions that were not properly and promptly notified to the
WDNR.
A form is provided in Appendix D to document this review and certification, which includes a
certification by the Safety/Environmental Manager as to whether or not he/she was informed of
any deviations.
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Section 5
Reporting Requirements
5.1
Reporting Requirements
In accordance with Condition II.D of the air operating permit, the WDNR will be notified as
follows:
1. Hazardous Substance Air Spill: In the event of any hazardous emission not in conformity
with a permit or allowed by the WDNR under chapters NR 400 to 499, the WDNR will be
notified immediately by calling 1-800-943-0003. Notice shall be given as required by s.
292.11, Wis. Stats., and ch. NR 706, Wis. Adm. Code.
2. Malfunctions & Unscheduled Events: In the event of a malfunction or other unscheduled
event that causes or may cause any emission limitation to be exceeded, the WDNR must be
notified by the next business day, unless Maynard has otherwise reported the event to the
WDNR in advance. The information to be reported includes: 1) the cause and duration of
the exceedence; 2) the period of time considered necessary for correction; and 3) measures
taken to minimize emissions during the period.
3. Deviations from Other Permit Conditions: In addition to the requirements noted above, the
WDNR is required to be notified by the next business day of deviations from any other
conditions specified in the permit. The information to be reported includes identification of
the deviation, the cause, duration, and steps taken to prevent recurrence.
4. Planned Shutdown & Startup of Air Pollution Control Equipoment: Maynard will report to
the Department, in advance, schedules for the planned shutdown and startup of air
pollution control equipment and the measures to be taken to minimize the down time of the
control equipment while the source is operating. Scheduled maintenance or any other
scheduled event, including startup, shutdown or soot blowing procedures that have been
approved by the WDNR under s. NR 436.03(2)(b), which causes an emission limit to be
exceeded shall also be reported in advance. Advance reporting pursuant to this permit
condition does not relieve any Maynard Steel from the duty to comply with any applicable
emission limitations. Emissions in excess of the limits set in chs. NR 400-499, Wis. Adm.
Code, may be allowed when the emissions are temporary and due to scheduled
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maintenance, startup or shutdown of operations carried out in accord with a plan and
schedule approved by the WDNR.
5.2
Compliance Monitoring & Certification
Semiannual compliance status reports will be provided to the WDNR within 45 days of the
end of each 6 month reporting period. Annual compliance certifications will be submitted to
the WDNR and USEPA-Region 5 within 45 days of the end of each calendar year. Compliance
certifications, excess emissions, monitoring parameter excursions and the results of any
performance test conducted during the reporting period shall be included in these reports to
satisfy the requirements associated with this plan.
Maynard Steel Casting Company
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Tables
Sand interface layer is managed to
remove scrap that may have fallen onto
the interface layer while charging. This
generally includes removal of the scrap
and adding to & leveling the sand.
Furnace cover is preliminarily set onto None expected.
the furnace to check for proper
alignment and fit with the sand interface
layer, and is adjusted as necessary (e.g.,
re-aligned, sand added/leveled).
Connection between the hood and the
duct is checked for proper alignment.
5
6
7
1 of 2
Charging the EAF
4
N/A
N/A
N/A
a. Secondary capture
b. Uncaptured emissions
N/A
b. Uncaptured emissions
a. Secondary capture
N/A
Capture¹
N/A
N/A
N/A
a. EAF Baghouse (during heat)
b. None
N/A
EAF Baghouse (during heat)
Air curtain (west end only)
Control
EAF Baghouse (pre-heat)
Connection between hood and duct is
visually checked.
Sand is added/leveled, as appropriate.
a. BH Pressure drop & bag leak detection
b. Indoor visible emissions
c. Align bucket over EAF to reduce scrap
on sand layer
Scrap is removed from sand layer.
Sand is added/leveled, as appropriate.
N/A
a. BH Pressure drop & bag leak detection
Air curtain blower ON (west end only)
b. Indoor visible emissions
a. Check for open / broken windows.
b. Verification of operating status:
- EAF Baghouse fan ON
- Air curtain blower ON (west end only)
c. CPMS operating.
d. EAF BH P w/in within permitted range.
E. EAF Hood Static w/in Low-High range.
Operating Practice /
Parameter Monitored²
R-03
N/A
N/A
R-01
R-08
N/A
R-01
R-05
R-08
R-09
R-05
R-02
R-01
R-04.1
R-08
Response Actions³
[See Table 3-2]
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None expected.
Dust entrained on scrap
may contribute to
emissions as scrap is
loaded into the EAF
None expected.
Sand is added/leveled around the
circumference of the pot before initially
charging.
3
Dust entrained on scrap
may contribute to
emissions as scrap is
loaded into the charge
bucket
None expected.
Charge bucket loading
Emissions
None expected.
2
Step
Heat Operating Activity
1 Pre-heat Ventilation Systems check
Table 3-1. Operating Practices & Monitored Parameters for EAF Operations
Oxygen Lancing, Refining, and Slagging
(performed via the slag door)
Testing / Analysis
Samplers contain combustible materials;
therefore, to avoid undue combustion
thereof and associated emissions, the
samplers are placed into a dedicated
container for appropriate disposal.
Tapping / Ladle Inoculation / Carbon
Adjustment
9
10
c. Uncaptured
b. Secondary Capture
a. Primary Capture - exhaust
hood(s)
Capture¹
Fumes (notably
particulate matter)
b. Secondary Capture
a. Primary Capture - exhaust
hood(s)
Minimal additional fumes a. Primary Capture - exhaust
as probe is withdrawn
hood(s)
from the EAF via the slag
door.
b. Secondary Capture
b. Secondary Capture
Same as Step 8, plus
a. Primary Capture - exhaust
occasional puffs from the hood(s)
slag door.
Fumes (notably
particulate matter),
primarily emanating from
the annular spaces in the
cover through which the
electrodes pass.
Emissions
a1.
a2.
a3.
b1.
b2.
c.
a1.
a2.
a3.
b1.
b2.
c.
a1.
a2.
a3.
b1.
b2.
c.
a1.
a2.
b1.
b2.
c.
Deflector Plate
Exhaust hood(s)
EAF Baghouse
EAF Baghouse (during heat)
Air curtain
None
Push nozzles (EAF 6 only)
Exhaust hood(s)
EAF Baghouse
EAF Baghouse (during heat)
Air curtain
None
Deflector Plate
Exhaust hood(s)
EAF Baghouse
EAF Baghouse (during heat)
Air curtain
None
Exhaust hood(s)
EAF Baghouse
EAF Baghouse (during heat)
Air curtain
None
Control
In place, where necessary
Hood Static Pressure
BH Pressure drop & bag leak detection
BH Pressure drop & bag leak detection
Powered on
Indoor visible emissions
Hood Static Pressure
BH Pressure drop & bag leak detection
BH Pressure drop & bag leak detection
Powered on
Indoor visible emissions
a1.
a2.
a3.
b1.
b2.
c.
Powered on (prior to tap)
Hood Static Pressure
BH Pressure drop & bag leak detection
BH Pressure drop & bag leak detection
Powered on
Indoor visible emissions
Same as Step 9, plus
Place used samplers into dedicated bin.
a1.
a2.
a3.
b1.
b2.
c.
a1.
a2.
b1.
b2.
c.
Operating Practice /
Parameter Monitored²
2 of 2
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R-07
R-04
R-01
R-01
R-05
R-08
Same as Step 9
R-10
R-06
R-04
R-01
R-01
R-05
R-08
R-04
R-01
R-01
R-05
R-08
Response Actions³
[See Table 3-2]
Notes
1. Primary capture relates to the direct capture of emissions upon release from a source as by the drawing thereof into a local exhaust hood.
Secondary capture relates to the capture of emissions released inside the building that are induced to flow toward and be drawn into powered ventilation systems inside the building.
Uncaptured relates to emissions that are neither primarily or secondarily captured by a powered exhaust ventilation system, which may settle-out inside the building and/or may otherwise leave the building.
2. Parameters are generally specific to each EAF dust collection system. If outside of specified ranges, then initiate 'Response Actions'.
The bag leak detection system (BLDS) be installed on each EAF baghouse in accordance with the schedule specified in the Consent Decree.
3. Response actions are to be initiated if parameter / condition is outside of specified ranges. Refer to Table 3-2 for response action details.
11
EAF is powered on as electrodes are
lowered into the pot through ports in
the cover.
Heat Operating Activity
8
Step
Table 3-1. Operating Practices & Monitored Parameters for EAF Operations
Outside of range
Condition
As noted in the actions
descibed below.
1 of 2
Verify gauge is working properly, to the extent such can safely be done while the heat is underway.
If not, check for & clean any obstruction in leads to gauge, if possible.
If HSP returns to acceptable range, then continue normal operation. Otherwise, proceed to Step 4.
If HSP does not return to acceptable range, then (prior to tapping) hold operation & complete full BH shakedown cycle.
If HSP returns to levels above the High-Low set point, then continue normal operation.
Otherwise initiate the catastrophic failure response action (CAT-RA).
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1.
2.
3.
4.
5.
R-04.2 HSP During Heat
At or below the High-Low
Must be maintained above the Low- set point, as determined
for each EAF
Low set point at all times.
Appropriate corrective measures
are to be implemented upon hitting
the High-Low set point.
Verify gauge is working properly.
If not, check for & clean any obstruction in leads to gauge, if possible.
If HSP returns to acceptable range, then continue normal operation. Otherwise, proceed to Step 4.
If HSP does not return to acceptable range, then (prior to starting heat) complete a full BH shakedown cycle.
If HSP returns to levels above the Low-High set point, then continue normal operation.
Otherwise repeat Step 4. If after two shakedown cycles, the HSP is within 20% of the minimum Low-High set point, then initiate
heat and implement approprirate corrective actions if HSP trips the High-Low alarm set point. Otherwise, do not proceed with heat.
Connection is appreciably 1. Investigate the cause or conditions contributing the misalignment or excessive gap.
offset or there is a
2. Make any necessary repairs or adjustments to ensure proper alignment & to resolve the gap before powering the EAF.
significant gap between
the hood and duct
1. Turn ON the CPMS.
2. If unable to activate, then with appropriate support (Supervisor), investigate the cause and attempt to correct.
3. If corrective actions are not successful in turning on the CPMS, then alert the Mt. Supervisor and/or Mt. Superintendent
to coordinate appropriate repairs.
4. Do not proceed with the heat until the CPMS is operating.
1.
2.
3.
4.
5.
Hood Connection
The sidedraft hood and duct need
to be properly aligned and joined to
ensure proper draw.
R-03
CPMS not operating
Table 3-2. Response Actions
Action
In the event of a castrophic failure - i.e., one that has a reasonable potential to result in the exceedance of an applcable emissions
limitation (e.g., hourly mass emission limit, opacity limit) - a heat will be ended as soon as is safely possible without damage to the
equipment. If the charge is not yet melted in, then shutdown shall proceed in accordance with the SSM procedure. Alternatively, if
the carge is melted in (molten), then the heat will be dumped as follows:
1. EAFs 4-6: Tap the contents of the EAF into a ladle and remake the heat in another EAF.
2. EAF 7: Tap contents into multiple ladles for remake in other EAFs, pour emergency ingot(s) or pig mold(s), or retain in EAF 7 and
shutdown the EAF 7 in accordance with the SSM procedure.
1. Verify gauge is working properly.
2. If not, check for & clean any obstruction in leads to gauge.
3. If P returns to acceptable range, then continue normal operation. Otherwise proceed to Step 4.
4. If P does not return to acceptable range, then (prior to tapping) hold operation & complete full BH shakeout cycle.
5. If P returns to acceptable range, then continue normal operations.
Otherwise initiate the catastrophic failure response action (CAT-RA).
1. Verify equipment is working properly.
2. If not, investigate & correct apparent cause in accordance with manufacturer's instructions.
3. If reading returns to level at or below setpoint, then continue normal operation. Otherwise proceed to Step 4.
4. Otherwise initiate the catastrophic failure response action (CAT-RA).
R-04.1 Pre-heat Hood Static Pressure (HSP) At or below the Low-High
set point range, as
Verify that starting hood static
pressure is within the target range determined for each EAF
(Low-High set point range).
Continuous Parametric Monitoring
System (CPMS)
Must be operating whenever the
respective EAF is operating.
Bag Leak Detection System (BLDS) Above setpoint
Continuous monitoring - may entail
cycling of monitoring equipment
common to multiple collectors.
BH Pressure Drop
Pressure drop is checked at least
once every 8-hours of operation.
R-02
R-01
No.
Operating Practice / Parameter
CAT-RA Catastrophic Response Action
EAF Baghouse Fan
Ensure that the baghouse fan is on
prior to charging.
Sampler Media
Media placed into slag pit
To avoid undue combustion of
consumable media in a slag pit, the
samplers are either placed into a
dedicated container for appropriate
disposal or into the EAF.
R-09
R-10
2 of 2
Building Openings
Windows open
Windows along the upper reaches Broken windows found
of the melt bay are to be closed
prior to charging. Broken windows
should be covered/repaired. Leave
powered exhaust on to allow
R-08
1. All personnel are to be instructed as to the appropriate operating practice - See 'Operating Practice / Parameter' column.
2. Upon discovery, the Shift Supervisor must remind the person who placed the media into the pit of the appropriate operating
practice.
3. Shift Supervisor should continue to monitor the process to ensure that appropriate operating practice is consistently implemented.
1. Turn ON the fan.
2. If unable to activate, then with appropriate support (Supervisor), investigate the cause and attempt to correct.
3. If corrective actions are not successful in turning on the blower, then alert the Mt. Supervisor and/or Mt. Superintendent
to coordinate appropriate repairs.
4. Only after the baghouse fan has been successfully turned on can a heat proceed.
5. If the fan fails during a heat, then initiate the catastrophic failure response action (CAT-RA).
1. Close any open windows prior to the night's first heat.
2. Repair or temporarily cover with appropriate materials, any broken windows.
If unable to repair in a timely manner, then employ the opacity monitoring protocol.
3. Allow operating powered exhaust ventilation systems to remain on until the visible emissions substantially clear.
\\ntapabrookfield\MLW-VOL1\DATA\PROJECTS\_RMT Archive\00-02730_00206 Maynard Steel\37 2015 Assistance 228744\Air\2015-05-12 OM SSM\MSCC Process Description - 2015-05-14
Not turned ON
Push Nozzels (EAF 6 only)
Not turned ON
Must be turned on prior to tapping.
R-07
1. Turn ON the blower if such can safety be done while tapping is underway.
2. If unable to activate, then with appropriate support (Supervisor), investigate the cause and attempt to safely correct.
3. If corrective actions are not successful in turning on the blower, then alert the Mt. Supervisor and/or Mt. Superintendent
to coordinate appriate repairs.
4. Complete the heat, refer also to R-08.
Deflector Plates
Deflector plates, where
1. Attempt to secure the deflector plate in place.
2. If not successful in securing the deflector plate, then alert the Mt. Supervisor and/or Mt. Superintendent
Where present, should be securely intended to be present,
to coordinate appropriate repairs.
mounted so as to assist in directing are not securely in place.
3. Proceed with the heat.
occasional puffs from the slag door
towards the inlet of the sidedraft
hood.
Action
1. Turn ON the blower.
2. If unable to activate, then with appropriate support (Supervisor), investigate the cause and attempt to correct.
3. If corrective actions are not successful in turning on the blower, then alert the Mt. Supervisor and/or Mt. Superintendent
to coordinate appropriate repairs.
4. Proceed with the heat and implement the opacity monitoring protocol.
5. Allow operating powered exhaust ventilation systems to remain on until the visible emissions substantially clear.
Table 3-2. Response Actions
R-06
Condition
Air Curtain Blower (West End Only) Not turned ON
Air curtain blower needs to be
turned on prior to charging of EAF
Nos. 4, 5 and 6. Leave powered
exhaust on to allow visibles to clear.
Operating Practice / Parameter
R-05
No.
Table 4-1. Maximum Intervals for Routine Inspections
Control Device
Equipment ID
#4 Furnace baghouse
4296
#5 Furnace baghouse
2158
#6 Furnace baghouse
0170
#7 Furnace baghouse
3174
#4 Wheelabrator & Swing Grind baghouse
2502
#6 Wheelabrator baghouse
2504
Slinger Large Mills wet rotoclone
0121
Slinger Shakeout wet rotoclone
1222
West Room Blast dust collector
2503
Slinger muller wet rotoclone
1217
Lg Mills Bentonite Silo dust collector
3412
Lg Mills Cereal Silo dust collector
3414
Large mills Sand system reclaim dust collector*
2747
Large core room hopper dust collector*
2894
Small core room (Oil Core) hopper dust collector
1818
100 ton silo dust collector dust collector
2655
East End sand Reclaim dust collector
4156
East End Rotoblast & Vibramill dust collector
4142
Rotoblast dust collector (2015)
TBD-1
#5 Wheelabrator baghouse
2717
Fox Line Stand Grinding & Robot / Lip Cell dust collector
2522-2328
Main Bay Welding & Scarfing Torit collector
4299
Weld/Grinding dust collectors ("New")
TBD-2
East Qualify Room cartridge collector
3106
West Qualify Room cartridge collector
3107
East shakeout rotoclone
0009
West shakeout rotoclone
1998
Pattern Shop*
4073
Bentonite dust collector-Slinger*
2950
Cereal dust collector-Slinger*
2951
Max. Interval (if operating)1, 2
Daily
Weekly
Monthly
1x on 3rd shift
1x on shift 1 or 2
1x on 3rd shift
1x on shift 1 or 2
1x on 3rd shift
1x on shift 1 or 2
1x on 3rd shift
1x on shift 1 or 2
1x on any shift
1x on any shift
1x on any shift
1x on any shift
1x on 1st shift
1x on any shift
1x on 1st shift
1x on any shift
1x on any shift
1x on any shift
1x on 1st shift
1x on any shift
1x on 1st shift
1x on any shift
1x on 1st shift
1x on any shift
1x on 1st shift
1x on any shift
1x on 1st shift
1x on any shift
1x on 1st shift
1x on any shift
1x on 1st shift
1x on any shift
1x on any shift 1x on any shift
1x on any shift 1x on any shift
1x on any shift 1x on any shift
1x on any shift 1x on any shift
1x on shift 1 or 2 1x on any shift
1x on shift 1 or 2 1x on any shift
1x on shift 1 or 2 1x on any shift
1x on shift 1 or 2 1x on any shift
1x on shift 1 or 2 1x on any shift
1x on 1st shift
1x on any shift
1x on 1st shift
1x on any shift
1x on 1st shift
1x on 1st shift
1x on 1st shift
* Vents inside the building. Though maintenance is performed, this source is only listed but is not part of this MPAP.
Notes
1. As necessary, alternative shifts may be substituted for the daily & weekly inspections.
2. All operating dust collectors receive monthly preventative maintenance.
Table 4-2. Items or Conditions Checked During Routine Inspections
Control Devices - Daily & Weekly Inspections¹
1. Visually inspect the stack outlet for opacity and evidence of emissions.
2. Monitor the cleaning cycle – check damper valves for synchronization and operation. Note any unusual noises.
Visually check rotating equipment and drives for obvious signs of jamming or leakage, broken parts, wear, etc. Make
sure all valves are seating properly, and check fan belt tension.
3. Check all moving parts on discharge system and screw conveyor bearings.
4. Wet Systems (Rotoclones):
a. Open the upper compartment, and inspect rinse pumps, cones, and nozzles. Replace as needed.
b. Empty and rinse settling tank, and transport sludge to yard for disposal.
c. Monitor water additives.
Control Devices - Monthly Inspections
1. Open baghouse and access it (confined space entry permit required)
a. Check for bag signs of excessive wear or damage, leaks, and for proper bag tension.
b. Check bag cages, valves and seals for leaks.
c. Replace worn parts, as needed.
2. Inspect all bearings, bushings, chains, shafts, and shaker parts.
Replace as needed.
3. Oil & grease all moving parts and bearings.
4. Observe motors in operation and note unusual noises or vibrations.
5. Check ducts for dust build up, and observe damper valves for proper seating.
6. Visually inspect features such as gasket seals on doors, welds, bolts.
Check for evidence of corrosion and, where necessary, prepare surface and coat with paint primer.
Monitoring Gauges - Annual Inspections & Calibration¹
1. Gauges are checked to ensure that they are not fouled in such a manner as to negatively affect the accuracy thereof
(e.g. , lines leading to/from pressure drop gauges are free of residues, obstructions, kinks, holes).
2. All instruments used for measuring air pollution control device operating parameters shall be calibrated yearly or at
a frequency based on good engineering practices as established by operational history, whichever is more frequent,
pursuant to s. NR 439.055(4), Wisconsin Administrative Code. EAF FCS pressure gauges shall be calibrated quarterly.
Note
1. In addition to routine inspections, parametric monitoring of control devices is conducted in accordance with applicable air permit
requirements, which generally includes monitoring and recording the following once every 8-hours of operation:, and in the case
of wet collectors monitoring the flow meters
a. Pressure drop across the control device via a manometer, mangehelic or photohelic gauge.
b. For wet systems, the liquor flow rate via a flow meter.
Appendix A
Calibration Records
Appendix B
Routine Inspection Checklists
- Maynard Steel Pollution Control Device Daily Inspection Record
- Maynard Steel Pollution Control Device Weekly Inspection Record
- Baghouse Dust Collector Monthly Prevention Maintenance Record
- Parametric Monitoring Device Measurement Logs & Calibration Record Assessment
MAYNARD STEEL CASTING COMPANY
POLLUTION CONTROL DEVICE DAILY INSPECTION RECORD
Week of:
ATTENTION: If equipment did not operate, indicate DNO ("Did Not Operate")
Include 2503 West Room Blast in the 'Notes' section for each day that it operates, if at all
Control Device
MONDAY
#4 Electric Arc Furnace Baghouse
#5 Electric Arc Furnace Baghouse
#6 Electric Arc Furnace Baghouse
#7 Electric Arc Furnace Baghouse
South #4 wheelabrator Dust Collector
North #6 wheelabrator Dust Collector
Clean & PM Lg Mills Rotoclone
Clean & PM Slinger shakeout Rotoclone
Notes:
Manometer
or Flow
Visual Cleaning
Equipment ID meter read Emissions Cycle
Discharge System
Duct to
Fan or
Overall baghouse Blower
Rinse
Cones & Empty Monitor
Nozzles Tank Additives
4296
3158
0170
3174
2502
2504
0121
1222
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
TUESDAY
#4 Electric Arc Furnace Baghouse
#5 Electric Arc Furnace Baghouse
#6 Electric Arc Furnace Baghouse
#7 Electric Arc Furnace Baghouse
South #4 wheelabrator Dust Collector
North #6 wheelabrator Dust Collector
Clean & PM Lg Mills Rotoclone
Clean & PM Slinger shakeout Rotoclone
Notes:
4296
3158
0170
3174
2502
2504
0121
1222
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
WEDNESDAY
#4 Electric Arc Furnace Baghouse
#5 Electric Arc Furnace Baghouse
#6 Electric Arc Furnace Baghouse
#7 Electric Arc Furnace Baghouse
South #4 wheelabrator Dust Collector
North #6 wheelabrator Dust Collector
Clean & PM Lg Mills Rotoclone
Clean & PM Slinger shakeout Rotoclone
Notes:
4296
3158
0170
3174
2502
2504
0121
1222
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
THURSDAY
#4 Electric Arc Furnace Baghouse
#5 Electric Arc Furnace Baghouse
#6 Electric Arc Furnace Baghouse
#7 Electric Arc Furnace Baghouse
South #4 wheelabrator Dust Collector
North #6 wheelabrator Dust Collector
Clean & PM Lg Mills Rotoclone
Clean & PM Slinger shakeout Rotoclone
Notes:
4296
3158
0170
3174
2502
2504
0121
1222
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
\\ntapabrookfield\MLW VOL1\DATA\PROJECTS\_RMT Archive\00 02730_00206 Maynard Steel\37 2015 Assistance 228744\Air\2015 05 12 OM SSM\MSCC Process Description 2015 11 04
MAYNARD STEEL CASTING COMPANY
POLLUTION CONTROL DEVICE DAILY INSPECTION RECORD
Week of:
ATTENTION: If equipment did not operate, indicate DNO ("Did Not Operate")
Include 2503 West Room Blast in the 'Notes' section for each day that it operates, if at all
Control Device
FRIDAY
#4 Electric Arc Furnace Baghouse
#5 Electric Arc Furnace Baghouse
#6 Electric Arc Furnace Baghouse
#7 Electric Arc Furnace Baghouse
South #4 wheelabrator Dust Collector
North #6 wheelabrator Dust Collector
Clean & PM Lg Mills Rotoclone
Clean & PM Slinger shakeout Rotoclone
Notes:
Manometer
or Flow
Visual Cleaning
Equipment ID meter read Emissions Cycle
Discharge System
Duct to
Fan or
Overall baghouse Blower
Rinse
Cones & Empty Monitor
Nozzles Tank Additives
4296
3158
0170
3174
2502
2504
0121
1222
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
SATURDAY
#4 Electric Arc Furnace Baghouse
#5 Electric Arc Furnace Baghouse
#6 Electric Arc Furnace Baghouse
#7 Electric Arc Furnace Baghouse
South #4 wheelabrator Dust Collector
North #6 wheelabrator Dust Collector
Clean & PM Lg Mills Rotoclone
Clean & PM Slinger shakeout Rotoclone
Notes:
4296
3158
0170
3174
2502
2504
0121
1222
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
SUNDAY
#4 Electric Arc Furnace Baghouse
#5 Electric Arc Furnace Baghouse
#6 Electric Arc Furnace Baghouse
#7 Electric Arc Furnace Baghouse
South #4 wheelabrator Dust Collector
North #6 wheelabrator Dust Collector
Clean & PM Lg Mills Rotoclone
Clean & PM Slinger shakeout Rotoclone
Notes:
4296
3158
0170
3174
2502
2504
0121
1222
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
SIGN OFF WHEN COMPLETE
Signature
Date Signed
Inspector:
Supervisor:
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MAYNARD STEEL CASTING COMPANY
ATTENTION: If equipment did not operate, indicate DNO ("Did Not Operate")
Control Device
Date
Equipment ID Inspected
POLLUTION CONTROL DEVICE WEEKLY INSPECTION RECORD
Week of:
Meters
Visual Cleaning Discharge
Working? Emissions Cycle
System
Rinse
Cones &
Empty Monitor
Tank Additives
Bentonite dust collector Slinger*
2950
N/A
N/A
N/A
Cereal dust collector Slinger*
2951
N/A
N/A
N/A
Lg Mills Bentonite Silo dust collector
3412
N/A
N/A
N/A
Lg Mills Cereal Silo dust collector
3414
N/A
N/A
N/A
Large mills Sand system reclaim dust collector*
2747
N/A
N/A
N/A
Large core room hopper dust collector*
2894
N/A
N/A
N/A
Small core room (Oil Core) hopper dust collector
1818
N/A
N/A
N/A
100 ton silo dust collector dust collector
2655
N/A
N/A
N/A
Fox Line Stand Grinding & Robot / Lip Cell dust collector
2328
N/A
N/A
N/A
Main Bay Welding & Scarfing Torit collector
4299
N/A
N/A
N/A
Weld/Grinding dust collectors ("New")
TBD 2
N/A
N/A
N/A
East End sand Reclaim dust collector
12126
N/A
N/A
N/A
4142
N/A
N/A
N/A
East End Rotoblast & Vibramill dust collector
Rotoblast dust collector (2015)
TBD 1
N/A
N/A
N/A
#5 Wheelabrator baghouse
2717
N/A
N/A
N/A
East Qualify Room cartridge collector
3106
N/A
N/A
N/A
West Qualify Room cartridge collector
3107
N/A
N/A
N/A
Slinger muller wet rotoclone
1217
East shakeout rotoclone
0009
N/A
N/A
N/A
0008 & 1999
N/A
N/A
N/A
N/A
N/A
N/A
West (Center) shakeout rotoclone
Pattern Shop*
4073
* Vents inside the building. Though maintenance is performed, this source is only listed but is not part of this MPAP.
Notes
SIGN OFF WHEN COMPLETE
Signature
Inspector:
Supervisor:
\\ntapabrookfield\MLW VOL1\DATA\PROJECTS\_RMT Archive\00 02730_00206 Maynard Steel\37 2015 Assistance 228744\Air\2015 05 12 OM SSM\MSCC Process Description 2015 11 04
MAYNARD STEEL CASTING COMPANY
ATTENTION: If equipment did not operate, indicate DNO ("Did Not Operate")
BAGHOUSE DUST COLLECTOR MONTHLY PREVENTION MAINTENANCE RECORD
Month of:
Manometer
Visual Cleaning
or Flow
Equipment ID meter read Emissions Cycle
Control Device
Discharge System¹
Duct to
Fan or
Overall baghouse Blower
Rinse
Cones &
Nozzles
Empty Monitor
Tank Additives
#4 Furnace baghouse
4296
N/A
N/A
N/A
#5 Furnace baghouse
3158
N/A
N/A
N/A
#6 Furnace baghouse
0170
N/A
N/A
N/A
#7 Furnace baghouse
3174
N/A
N/A
N/A
#4 Wheelabrator & Swing Grind baghouse
2502
N/A
N/A
N/A
N/A
N/A
#6 Wheelabrator baghouse
2504
N/A
N/A
N/A
N/A
N/A
Large Mills wet rotoclone
0121
N/A
N/A
N/A
N/A
N/A
Slinger Shakeout wet rotoclone
1222
N/A
N/A
West Room Blast dust collector
2503
N/A
N/A
Slinger muller wet rotoclone
1217
N/A
N/A
Bentonite dust collector Slinger*
2950
N/A
N/A
N/A
N/A
N/A
Cereal dust collector Slinger*
2951
N/A
N/A
N/A
N/A
N/A
Lg Mills Bentonite Silo dust collector
3412
N/A
N/A
N/A
N/A
N/A
Lg Mills Cereal Silo dust collector
3414
N/A
N/A
N/A
N/A
N/A
Large mills Sand system reclaim dust collector*
2747
N/A
N/A
N/A
N/A
N/A
Large core room hopper dust collector*
2894
N/A
N/A
N/A
N/A
N/A
Small core room (Oil Core) hopper dust collector
1818
N/A
N/A
N/A
N/A
N/A
100 ton silo dust collector dust collector
2655
N/A
N/A
N/A
N/A
N/A
East End sand Reclaim dust collector
12126
East End Rotoblast & Vibramill dust collector
Rotoblast dust collector (2015)
N/A
N/A
N/A
N/A
N/A
4142
N/A
N/A
N/A
N/A
N/A
TBD 1
N/A
N/A
N/A
N/A
N/A
#5 Wheelabrator baghouse
2717
N/A
N/A
N/A
N/A
N/A
Fox Line Stand Grinding & Robot / Lip Cell dust collecto
2328
N/A
N/A
N/A
N/A
N/A
Main Bay Welding & Scarfing Torit collector
4299
N/A
N/A
N/A
N/A
N/A
TBD 2
N/A
N/A
N/A
N/A
N/A
Weld/Grinding dust collectors ("New")
East Qualify Room cartridge collector
3106
N/A
N/A
N/A
N/A
N/A
West Qualify Room cartridge collector
3107
N/A
N/A
N/A
N/A
N/A
East shakeout rotoclone
0009
N/A
N/A
N/A
N/A
N/A
West (Center) shakeout rotoclone
0008 & 1999
N/A
N/A
N/A
N/A
N/A
* Vents inside the building. Though maintenance is performed, this source is only listed but is not part of this MPAP.
1. For each EAF baghouse, check for the presence of holes in the ductwork or hoods, flow constrictions caused by dents or accumulated dust in the ductwork, and fan
erosion.
Notes:
Signature
SIGN OFF WHEN COMPLETE
Date Signed
Inspector:
Supervisor:
\\ntapabrookfield\MLW VOL1\DATA\PROJECTS\_RMT Archive\00 02730_00206 Maynard Steel\37 2015 Assistance 228744\Air\2015 05 12 OM SSM\MSCC Process Description 2015 11 04
P36
P34
P39
P48
P73
P71A&B
TBD
P66
P67A&B
P51A
P51A
P68
TBD
P80
P46
P47
P60B
P60A
P42
S16
S19
S51
S20
S55
S53
TBD
S66
S67
S27
S26
S60
S61
S62
Process ID
East shakeout rotoclone
West (Center) shakeout rotoclone
Slinger Shakeout wet rotoclone
Large Mills wet rotoclone
Fox Line Stand Grinding & Robot / Lip Cell dust collector
East End sand Reclaim dust collector
East End Rotoblast & Vibramill dust collector
Rotoblast dust collector (2015)
West Room Blast dust collector
#4 Wheelabrator & Swing Grind baghouse
East Qualify Room cartridge collector
West Qualify Room cartridge collector
Main Bay Welding & Scarfing Torit collector
Weld/Grinding dust collectors ("New")
Small core room (Oil Core) hopper dust collector
Slinger muller wet rotoclone
#7 Furnace baghouse
#6 Furnace baghouse
#5 Furnace baghouse
#5 Wheelabrator baghouse
#6 Wheelabrator baghouse
#4 Furnace baghouse
SIGN OFF WHEN COMPLETE
Maintenance Superintendent / Manager
Safety/Environmental Manager
Plant Manager
EAF = Electric Arc Furnace
S68
TBD
S34
S25
Process
P17A
P65
P35
Stack
S17A
S65
S15
Gauge
1 to 8
1 to 8
1 to 8
FCS TBD
1 to 8
FCS TBD
1 to 8
FCS TBD
1 to 8
FCS TBD
1 to 8
1 to 8
1 to 8
TBD
1 to 8
1 to 8
1 to 8
1 to 8
1 to 8
TBD
1 to 8
2.0
40
2.0
40
2.0
2.0
2.0
N/A
Permit
Limit
Units
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
in H2O
gpm
in H2O
gpm
in H2O
in H2O
in H2O
gpm
Provide
copies of Annual
YTD Logs (non EAF)
Date Signed
Calibration Dates
Quarterly (EAFs Only)
Q1
Q2
Q3
Q4
Calendar Year:
Calibration
record(s)
available?
\\ntapabrookfield\MLW VOL1\DATA\PROJECTS\_RMT Archive\00 02730_00206 Maynard Steel\37 2015 Assistance 228744\Air\2015 05 12 OM SSM\MSCC Process Description 2015 11 04
Signature
2717
2504
4296
Equipment
ID
Total Pressure Drop
Total Pressure Drop
Total Pressure Drop
Hood Static Pressure
C16 (Baghouse)
3158
Total Pressure Drop
Hood Static Pressure
C19 (Baghouse)
0170
Total Pressure Drop
Hood Static Pressure
C51 (Baghouse)
3174
Total Pressure Drop
Hood Static Pressure
C20 (Baghouse)
2328
Total Pressure Drop
C55 (Baghouse)
12126
Total Pressure Drop
C53 (Baghouse)
4142
Total Pressure Drop
TBD
TBD 1
Total Pressure Drop
C66 (Baghouse)
2503
Total Pressure Drop
C67 (Baghouse)
2502
Total Pressure Drop
C27 (Cartridge)
3106
Total Pressure Drop
C28 (Cartridge)
3107
Total Pressure Drop
C68 (Torit)
4299
Total Pressure Drop
TBD
TBD 2
Total Pressure Drop
C34 (Baghouse)
1818
Total Pressure Drop
C25 (Wet rotoclone)
1217
Total Pressure Drop
Flow Rate
C25 (Wet rotoclone)
0121
Total Pressure Drop
Flow Rate
C60 (Rotoclone)
0009
Total Pressure Drop
C61 (Rotoclone)
0008 & 1999 Total Pressure Drop
C25 (Wet rotoclone)
1222
Total Pressure Drop
Flow Rate
C17 (Baghouse)
C65 (Baghouse)
C15 (Baghouse)
Control Device
MAYNARD STEEL CASTING COMPANY
Parametric Monitoring Device Measurement Logs & Calibration Record Assessment
ATTENTION: If equipment did not operate, indicate DNO ("Did Not Operate")
Appendix C
Periodic Inspection of EAF Systems
- Periodic Inspection Guide – EAF Shaker Baghouse
- EAF Shaker Baghouse Inspection Checklist [alt. used if performed by 3rd party]
- EAF Shaker Baghouse – Bag Condition [alt. used if performed by 3rd party]
PERIODIC INSPECTION GUIDE – EAF SHAKER BAGHOUSE
Each baghouse is to be inspected via the following protocol by a qualified outside contractor at least
annually [Defer to outside contractor protocol, if available]
1. Start baghouse. Record readings of pressure drop gages, motor amperage, fan speed, and air
volume on the Baghouse Checklist.
a. Before taking pressure drop gage readings check gage calibration using separate U tube, and
back flush tubing with clean, dry compressed air.
b. Take pitot tube traverse of main duct to obtain air volume.
2. With baghouse running, check the housing, access doors, discharge valves and main ductwork for
leaks.
3. Check baghouse housing, hoppers and support legs for structural Integrity, rust and condition of
paint.
4. During start up and while baghouse Is running, check for visible discharge from exhaust stack.
5. Check bag cleaning cycle.
a. Stop exhaust fan and operate shake cycle.
b. Observe operation of shaking mechanism noting any undue vibration, noise, binding, etc., that
needs correcting.
c. When shaking cycle Is complete, turn off main power and lock out electrical disconnect
switches.
d. Inspect shaker mechanism checking motor, "V" belts, sheaves, mounting bolts and belt
alignment.
e. Check frequency of shake cycle.
6. Check exhaust fan operation.
a. With exhaust fan running, check the operation of the fan bearings.
b. When bearing check Is complete turn off main power and lock out electrical disconnect
switches.
c. Check "V" belt tension, alignment, condition of sheaves, mounting bolts, vibration isolators, and
flex connections.
d. Remove fan housing inspection door and hand check fan wheel balance, gap between Inlet cone
and wheel and any material build up on wheel.
7. Shut down baghouse and check the operation of discharge valve and screw conveyors. If the
baghouse is equipped with screw conveyors, check bearing packing and cover connections for leaks.
8. Enter all data on Baghouse Check List and leave one copy with the Maintenance Superintendent /
Manager, and forward one copy to the Plant Manager for review. Review all data with plant
personnel before leaving Job site.
9. Leak check baghouse bags.
a. Close access doors, lock-out shaker disconnect switches, and start exhaust fan.
b. Introduce fluorescent tracer powder at a convenient point on suction side of baghouse. Use 1 lb.
of tracing powder per 1 ,000 square feet of baghouse bag cloth area.
c. Allow baghouse fan to run for 30-60 seconds minimum to allow tracing powder to be drawn Into
bags.
d. Stop baghouse fan, lock out disconnect switch.
e. Using a black light, individually check each bag and bag plate for leaking fluorescent powder.
f. Check bags for moisture.
g. Check bag tension (shaker baghouse).
h. Corrective Action: Replace all bags shown to be leaking.
i. Corrective Action: When leaks are discovered, the clean side of the baghouse must be cleaned
of all contamination and re-tested with a different color fluorescent powder.
j. Note any signs of daylight showing In baghouse housing and caulk them from the outside using
silicone caulking.
k. Enter all data on Baghouse Bag Condition sheet, leaving one copy with the Maintenance
Superintendent, and forward one copy to the Plant Manager for review.
l. Return all valves, doors, guards, disconnect switches, etc. to ON position.
10. Check ductwork from emission source to baghouse.
a. Check for:
i. Holes;
ii. Cracks;
iii. Rust; and,
iv. Dents.
b. As much as practicable, examine interior to ductwork for particulate matter buildup.
c. Corrective Actions:
i. Repair/replace damaged ductwork;
ii. Remove (clean) particulate matter buildup impeding flow; and/or,
iii. Straighten, enlarge or smooth-out sections of ductwork where particulate matter collects
MAYNARD STEEL CASTING COMPANY
EAF SHAKER BAGHOUSE INSPECTION CHECKLIST
Baghouse No.
Inspected By:
Date Inspected:
Condition
Item
Good
Service Repair/
able Replace
Comments & Corrective Actions (CA)
Date CA
Completed
HOPPERS
1. SIDE WALLS
2. PAINT
3. VIBRATORS
4. DISCHARGE VALVES
5. SCREW CONVEYOR
6. BEARINGS/PACKING
7. ROTARY LOCK
8. HOPPER ENCLOSURE
HOUSING
1. SIDE WALLS
2. AIR LEAKS/CAULKING
3. SUPPORT STRUCTURE
4.PAINT
5. BAG PLATE
ACCESS DOORS
1. HINGES
2. LATCHES
3. GASKET
4. FRAME
5. DOOR PANEL
6. PAINT
EXHAUST FAN
1. BELT TENSION
2. BELT ALIGNMENT
3. BELT CONDITION
4. SHEAVE CONDITION
5. MOTOR CONDITION
6. INNER BEARING
7. OUTER BEARING
8. ISOLATORS ENGAGED
9. MOUNTING BOLTS
10.1NLET FLEX CONN.
11. OUTLET FLEX CONN.
12. FAN CONE/WHEEL GAP
13. FAN CONE
14. BELT GUARD
15. BEARING SHAFT GUARD
16. HAND FAN BALANCE
17. WHEEL CLEANLINESS
18. SHAFT SEAL
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MAYNARD STEEL CASTING COMPANY
EAF SHAKER BAGHOUSE INSPECTION CHECKLIST
SHAKER CLEANING
1.MOTOR
2.SHEAVES
3. BELT TENSION
4. BELT ALIGNMENT
5. SHAKER LOGS
&.BEARINGS
7.HOOKS
SYSTEM MEASUREMENTS
FAN SHAFT TACHOMETER READING, RPM:
BEARING VIBRATION READING VELOCITY, INCHES/SECOND
INNER BEARING
OUTER BEARING
MOTOR BEARING
MAIN DUCT VOLUME CFM
POINT TRAVERSE
MOTOR AMPERAGE
NAMEPLATE
ACTUAL AMPERAGE
L1
PRESSURE DROP GAUGE READING, IN H2O
DESIGN RPM:
DESIGN CFM:
AMPS
L2
HP
L3
ADDITIONAL COMMENTS
INTERNAL REVIEW & CORRECTION ACTION COMPLETION STATUS
Reviewed By:
Name
Maintenance Superintendent / Mgr.
Safety/Environmental Manager
Plant Manager
Initial
Date
Corrective Actions Completed:
Maintenance Superintendent / Mgr.
Safety/Environmental Manager
Plant Manager
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MAYNARD STEEL CASTING COMPANY
EAF SHAKER BAGHOUSE BAG CONDITION
Baghouse No.
Inspected By:
Date Inspected:
INSTRUCTIONS
1. Draw outline of baghouse around corresponding number of bag rows.
2. Show walkways.
3. Show inlet and outlet.
4. Show bag condition by placing appropriate letter for bag condition over corresponding bags, as follows:
F
Fallen Bag
T
Bag Tied Off
L
Leaking Bag (not replaced or tied off)
R
Replaced Bag
M
Bag Hole Blocked
ROW
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
6
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
7
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
8
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
9
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
COMMENTS & CORRECTION ACTIONS
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MAYNARD STEEL CASTING COMPANY
EAF SHAKER BAGHOUSE BAG CONDITION
ROW
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
COMMENTS & CORRECTION ACTIONS
INTERNAL REVIEW & CORRECTION ACTION COMPLETION STATUS
Reviewed By:
Maintenance Superintendent / Mgr.
Safety/Environmental Manager
Plant Manager
Name
Initial
Date
Corrective Actions Completed:
Date CA Completed
Maintenance Superintendent / Mgr.
Plant Manager
Name
Initial
Date
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Appendix D
MPAP Review Forms
- MPAP Semiannual Compliance Review
- MPAP 5-year Review
MPAP SEMIANNUAL COMPLIANCE REVIEW
The facility has operated according to this MPAP;
There were no deviations from the MPAP;
There were no known exceedances of applicable PM, HAP or fugitive emissions limits; and
There were no malfunctions that were not properly and promptly notified to the DNR or accordance with Section 5.1 of the plan.
Q3-4
Q3-4
Q1-2
Q1-2
Q3-4
Q3-4
2015
2015
2016
2016
2016
2016
Plant Manager
Mt. Superintendent
/ Manager
Plant Manager
Mt. Superintendent
/ Manager
Plant Manager
Mt. Superintendent
/ Manager
Plant Manager
Yes / No
N/A - Plan Finalized September 2015
Conformance with Above-Listed Criteria
If No, explain
N/A - Plan Finalized September 2015
Name
Certification
Initial
Date
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Q1-2
2015
Review Period
Year
Q1-2 / Q3-4
Title
2015
Q1-2
Mt. Superintendent
/ Manager
Note below whether or not each of these conditions were satisfied during the corresponding semiannual period. If not, then explain. By initialling below, you are certifying to the best
of your knowlege that the information supplied after reasonable inquiry is complete, accurate and true.
1.
2.
3.
4.
This MPAP is an enforceable document under Maynard Steel air operating permit (Condition I.ZZZ.7); therefore, adherence to the elements of this MPAP is required. Maynard Steel
must document conformance with this plan as part of required semiannual compliance monitoring reports, and in a required annual compliance certification. Consequently, the
Maintenance Superintendent and the Plant Manager shall certify every six months, by signature, that:
MAYNARD STEEL CASTING COMPANY
MPAP 5 YEAR REVIEW
Name
Reviewed By
Initial
7/31/2015
7/31/2020
Date
Yes / No
Changes Needed
If yes, explain
Date Made
Next 5 yr
Review
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04
Review Period
Year
Date
Starting Date of Last Plan Review / Update:
Next Required 5 year Review:
The MPAP is required to be reviewed at least every 5 years. The following serves to document the completion of this review and to indicate if any changes are appropriate as a result of
this review. If additional reviews are conducted in the interim or if the MPAP is otherwise modified, such events can also be documented below.
MAYNARD STEEL CASTING COMPANY
Appendix E
EAF Emission Control System Checklists &
Operating Parameter
- EAF Emissions Control – Parametric Operating Limits
- EAF Emissions Control Checklist – Maintenance Pre-Operation
- EAF Emissions Control Checklist – Melt Department Operation
- EAF Emissions Control Checklist – Re-Bagging
MAYNARD STEEL CASTING COMPANY
EAF EMISSIONS CONTROL - PARAMETRIC OPERATING LIMITS
The parametric operating limits include the baghouse pressure drop, and the hood static pressure for the EAF Fume Collection Systems
(FCS).
Baghouse Total Pressure Drop: In general, the pressure drop is used as an indicator of the relative performance of the baghouse, and
includes both a lower and upper bound. A low pressure drop can be indicative of air bypassing or otherwise unacceptably passing
through a bag (e.g., bag break, improperly seated bags, etc.). Conversely, an elevated pressure drop can translate into a reduction in
exhaust flow and also result in excess strain on the fibers of the bags, which can stretch the fibers and expand the pathways through
which dust can pass.
The current permitted operating range of 1 to 8 inches of water column (in-H2O) under the air operating permit is the range outside of
which the operation of the EAF is deemed to be a deviation for the purpose of the air permit. The recommended operating range is
established per the bag manufacturer, baghouse maintenance contractor or other similarly qualified entity, and corresponds to the range
over which the baghouse is actually to be operated in practice, which is generally more restrictive than the permitted operating range. In
the unlikely event that the recommended operating range is outside the permitted operating range, then a permit modification would be
needed to ensure that operation of the baghouse is compliant with permit conditions. The end points of the recommended operating
range are defined as the Low-Low and High-High set points and are not to be exceeded while operating, except in accordance with the
O&M plan. In the event that either end point is triggered, alerts are provided both to the onsite operator (via visual and audible alarms),
and remotely (via e-mail, text, or call) to designated responsible individuals. To provide onsite warning to the operator in advance of
such a condition, Low-High and High-Low alarm set points are established within the recommended operating range to allow time for
actions to be implemented, where appropriate, to reduce the potential for the monitored parameter to actually exceed a recommended
operating range.
Hood Static Pressure: The hood static pressure is used to ensure that the sidedraft hood is providing sufficient draw throughout the heat.
Operating setpoints are EAF-specific and are generally based on empirical information related to various factors (e.g., hood, duct,
baghouse configuration, etc.). Changes in such factors that reduce the draw can be manifested in a decrease in the hood static pressure.
For example, an increase in the pressure drop across the baghouse will tend to result in a reduction in the hood static pressure.
Similarly, damage to ductwork cause an increased pressure drop across the system that contributes to a decreased hood static pressure.
A Hi-Low setpoint is established as an alert that the hood static pressure is approaching its minimum or Low-Low setpoint; thereby
allowing time for actions to be implemented, where appropriate, to increase the hood static pressure before actually exceeding the LowLow setpoint. If the hood static pressure drops below the Low-Low point, a the draw is deemed to be inadequate to provide effective
capture.
EAF
No.
4
5
6
7
Equip. ID
4296
3158
0170
3174
Baghouse Total Pressure Drop Alarm, in-H2O
Alert
Warning
Low-Low
High-High
Low-High
High-Low
TBD - Fabco
TBD - Fabco
TBD - Fabco
TBD - Fabco
TBD - Fabco
TBD - Fabco
TBD - Fabco
TBD - Fabco
TBD - Fabco
TBD - Fabco
TBD - Fabco
TBD - Fabco
TBD - Fabco
TBD - Fabco
TBD - Fabco
TBD - Fabco
Hood Static Pressure, in-H2O
Alert
Warning
Starting Target
Low-Low
High-Low
Low-High
TBD - FCS
TBD - FCS
TBD - FCS
TBD - FCS
TBD - FCS
TBD - FCS
TBD - FCS
TBD - FCS
TBD - FCS
TBD - FCS
TBD - FCS
TBD - FCS
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Corrective Action
Implemented Successfully
INSTRUCTION: This checklist is to be completed after the last heat of a shift is performed not necessarily during the same
shift. If a corrective action is needed, but could not be successfully implemented, then explain in the 'Additional Comments'
section and complete a 'Malfunction Log' sheet.
Corrective Action Needed
EAF EMISSIONS CONTROL CHECKLIST MAINTENANCE PRE OPERATION
Completed
MAYNARD STEEL CASTING COMPANY
EAF No.
Date
Completed By:
(Y/N/NA) (Y/N) (Y/N/NA)
1. Complete off line shakedown of the baghouse (with fan off) and confirm that baghouse is functioning properly (e.g.,
shakers motors operating and actuating shaker mechanism).
2. Confirm that off line shakedown has returned the total pressure drop (with fan running) to a level that is within the Low
High to High Low set point range, and that the hood static pressure (HSP) is within range of the Low High. See 'Reference
Table' at the bottom of this page for EAF specific set points.
Record Total Pressure Drop After Completing Off Line Shakedown of Baghouse: _____________ in H2O
Record HSP After Completing Off Line Shakedown of Baghouse:
_____________ in H2O
3. Visually inspect the sidedraft hood, telescoping duct and inplant ductwork for obvious signs of damage or deterioration
that may affect capture. In the case of EAF 4, visually inspect the enclosing hood and associated inplant ductwork for
obvious signs of damage or deterioration that may affect capture.
4. Check deflector plate above the slag door for obvious signs of damage or deterioration.
5. Check air curtain (west end only "Greensand Foundry") to verify that it is functioning properly (turn on / off).
6. Review the 'EAF EMISSIONS CONTROL CHECKLIST MAINTENANCE PRE OPERATION' from the last heat on this EAF and
follow up on corrective actions that may be necessary.
7. Check for open / broken windows (i.e., excluding cracks) along upper reaches of the west end of the melt department
(i.e., "Greensand Foundry").
8. On Occurrence: If the EAF refractory has been rebricked since the last heat, then check that it has been properly installed
to the appropriate level to permit the addition of adequate sand to maintain the sand interface layer.
ADDITIONAL COMMENTS
INTERNAL REVIEW & CORRECTION ACTION COMPLETION STATUS
Reviewed By:
Maintenance Shift Supervisor
Maintenance Superintendent / Manager
Melt Shop Night Manager / Superintendent
Name
Initial
Date
REFERENCE TABLE SET POINTS
Baghouse Total Pressure Drop Alarm, in H2O
Hood Static Pressure, in H2O
Alert
Warning Starting Target
EAF
Alert
Warning
No. Equip. ID Low Low
High High
Low High
High Low
Low Low
High Low
Low High*
4
4296 TBD Fabco TBD Fabco TBD Fabco TBD Fabco
TBD FCS
TBD FCS
TBD FCS
5
3158 TBD Fabco TBD Fabco TBD Fabco TBD Fabco
TBD FCS
TBD FCS
TBD FCS
6
0170 TBD Fabco TBD Fabco TBD Fabco TBD Fabco
TBD FCS
TBD FCS
TBD FCS
7
3174 TBD Fabco TBD Fabco TBD Fabco TBD Fabco
TBD FCS
TBD FCS
TBD FCS
* Starting level must be within 10% of Low High or as otherwise established via the execution of the FCS Protocol.
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Description 2015 08 04
MAYNARD STEEL CASTING COMPANY
EAF No.
Date
Completed By:
Corrective Action
Implemented Successfully
Completed
INSTRUCTION: This checklist is to be completed for each melt shift. If a
corrective action is needed, but could not be successfully implemented, then
explain in the 'Additional Comments' section and complete a 'Malfunction
Log' sheet.
Corrective Action Needed
EAF EMISSIONS CONTROL CHECKLIST MELT DEPARTMENT OPERATION
Heat Nos.
(Y/N/NA) (Y/N) (Y/N/NA)
1. Startup Conditions [Prior to Charging 1st Heat]
a. For west end operations ("Greensand Foundry"), roof level windows are closed
b. Baghouse (BH) fan for active EAF is turned ON Plus, for west end operations, at least one other EAF BH is ON
c. Total Pressure Drop across BH is within the Low High to High Low range [Starting P: __________ in H2O]
d. Hood Static Pressure (HSP) within range of Low High point see Ref. Tab[Starting HSP: __________ in H2O]
e. For west end operations ("Greensand Foundry"), air curtain blower is turned ON
f. Deflector Plate is securely mounted with proper orientation
2. Operation Conditions [During each Heat per Melt Shift]
a. Charging Bucket aligned over EAF to reduce scrap on sand layer
b. Charging Scrap that may have fallen on sand layer is removed
c. Charging Sand is added and leveled, as necessary
d. Pre Melt Cover alignment is checked / sand added & leveled as needed for proper fit
e. Pre Melt Connection between hood and duct is visually checked as OK
f. Melt Hood static pressure was at or above the High Low set point throughout heat see Ref. Table
If not, was hood static pressure at or above the Low Low set point see Ref. Table?
g. Melt Total Pressure Drop across BH was within the Low High to High Low range through heat see Ref. Table
If not, was Total Pressure Drop across the BH was within the Low Low to High High range see Ref. Table?
h. Melt Sand layer maintained throughout heat
i. Melt Sample media deposited in EAF or a dedicated bin (slag tub maintained free of consumables)
j. Melt Emissions during oxygen lancing visibly captured by the fume collection system
3. Shut down Conditions [After last heat] Until visible indoor emissions have substantially cleared:
a. Each EAF baghouse that operated during the melt shift remains ON.
b. For west end operations ("Greensand Foundry"), the air curtain remains ON.
ADDITIONAL COMMENTS
INTERNAL REVIEW & CORRECTION ACTION COMPLETION STATUS
Reviewed By:
Melt Supervisor
Night Manager / Superintendent
Name
Initial
Date
REFERENCE TABLE SET POINTS
Baghouse Total Pressure Drop Alarm, in H2O
Hood Static Pressure, in H2O
EAF
Alert
Warning
Alert
Warning
Starting Target
No. Equip. ID Low Low
High High
Low High
High Low
Low Low
High Low
Low High*
4
4296 TBD Fabco TBD Fabco TBD Fabco TBD Fabco TBD FCS
TBD FCS
TBD FCS
5
3158 TBD Fabco TBD Fabco TBD Fabco TBD Fabco TBD FCS
TBD FCS
TBD FCS
6
0170 TBD Fabco TBD Fabco TBD Fabco TBD Fabco TBD FCS
TBD FCS
TBD FCS
7
3174 TBD Fabco TBD Fabco TBD Fabco TBD Fabco TBD FCS
TBD FCS
TBD FCS
* Starting level must be within 10% of Low High or as otherwise established via the execution of the FCS Protocol
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Description 2015 08 04
Corrective Action
Implemented Successfully
INSTRUCTION: Unless comparable documentation is otherwise available (e.g., baghouse maintenance contractor service
record), this checklist is to be completed after re bagging an EAF baghouse.
Corrective Action Needed
EAF EMISSIONS CONTROL CHECKLIST RE BAGGING
Completed
MAYNARD STEEL CASTING COMPANY
EAF No.
Date
Completed By:
(Y/N/NA) (Y/N) (Y/N/NA)
1. New filter bags require a pre coating before normal operation can be resumed. Confirm that precoating procedures
developed by the manufacturer, baghouse maintenance contractor, or similarly qualified entity were followed to properly
coat new bags.
Date of Rebagging: _______________
2. After rebagging and precoating is complete, confirm that the total pressure drop (with fan running) is at a level that is within
the Low High to High Low set point range. See 'Reference Table' at the bottom of this page for EAF specific set points.
Record Total Pressure Drop After Completing Rebagging & Precoating: _____________ in H2O
ADDITIONAL COMMENTS
INTERNAL REVIEW & CORRECTION ACTION COMPLETION STATUS
Reviewed By:
Maintenance Superintendent / Manager
Name
Initial
Date
REFERENCE TABLE SET POINTS
Baghouse Total Pressure Drop Alarm, in H2O
Hood Static Pressure, in H2O
EAF
Alert
Warning
Alert
Warning Starting Target
No. Equip. ID Low Low
High High
Low High
High Low
Low Low
High Low
Low High*
4
4296
TBD Fabco TBD Fabco TBD Fabco TBD Fabco
TBD FCS
TBD FCS
TBD FCS
5
3158
TBD Fabco TBD Fabco TBD Fabco TBD Fabco
TBD FCS
TBD FCS
TBD FCS
6
0170
TBD Fabco TBD Fabco TBD Fabco TBD Fabco
TBD FCS
TBD FCS
TBD FCS
7
3174
TBD Fabco TBD Fabco TBD Fabco TBD Fabco
TBD FCS
TBD FCS
TBD FCS
* Starting level must be within 10% of Low High or as otherwise established via the execution of the FCS Protocol
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Process Description 2015 08 04
Appendix F
Maintenance Occurrence Log
MAYNARD STEEL CASTING COMPANY
MALFUNCTION OCCURRENCE LOG
Facility ID No. 241005710
Permit No.
241005710 P20
Malfunction Information
Malfunctioning Device (Include WDNR Process ID No., if applicable):
Description of Malfunction
Time / date incident discovered: ____________
Time / date incident began: ____________Time / date incident ended: ____________
Total Duration: ____________
Suspected Cause:
Response Actions
Actions taken to address the malfunction and to minimize emissions during this incident:
Has the deviation or malfunction been fully resolved?
If not, then explain:
Yes
No
Yes
No
Is this deviation or malfunction included in the O&M and MPAP Plan?
Were response actions consistent with the O&M and MPAP Plan?
If not, then explain:
Yes
Yes
No
No
If the actions taken were not consistent with the O&M and MPAP Plan, and excess
emissions occurred, has the WDNR been notified, as required (i.e., immediately in the
event of a hazardous air spill, by the next business day for other deviations)?
Yes
No
Incident Review
Were there any excess emissions during the incident?
If so, describe:
Reviewed By:
Mt. Supervisor / Night Shifts Super.
Plant Manager
Safety/Environmental Manager
Name
Initial
Date
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Appendix G
MPAP Spare Parts Inventory
MAYNARD STEEL CASTING COMPANY
MPAP Spare Parts Inventory
Maynard Steel currently maintains at least one of each of the following spare parts in
inventory:
1) Actuator motor
2) Shaker motor and shaker arm
3) Diaphragm kit
4) Belt
5) Bearing
6) Bearing flange
7) Bearing pillow
8) Bearing wood
9) Bushing
10) Connecting shaft
11) Shaft pin
12) Solenoid valve
13) Starter parts
14) Miscellaneous mechanical parts
15) Outside disposal bag
16) Magnehelic gage
17) Baghouse filter bag
One or more of these parts may be out of stock at any given time if it has been removed
from inventory for use in its designated purpose. In which case, a replacement part will
be promptly ordered to re-stock the inventory, accordingly.
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