Voestalpine Permit Amendment Request 2019

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY
EXAMPLE A
NOTICE OF APPLICATION AND PRELIMINARY DECISION

FOR AIR QUALITY PERMITS
AIR QUALITY PERMIT NUMBERS 108113, PSDTX1344M2, AND GHGPSDTX43
APPLICATION AND PRELIMINARY DECISION. voestalpine Texas LLC, 2800 Kay Bailey Hutchison Road, Portland, TX
78374-7400, has applied to the Texas Commission on Environmental Quality (TCEQ) for an amendment to State Air
Quality Permit 108113, modification to Prevention of Significant Deterioration (PSD) Air Quality Permit PSDTX1344M2,
and modification to Greenhouse Gas (GHG) PSD Air Quality Permit GHGPSDTX43 for emissions of GHGs, which would
authorize modification to the Direct Reduced Iron Hot Briquetting Facility located at 2800 Kay Bailey Hutchison Road,
Portland, San Patricio County, Texas 78374. The existing facility will emit the following air contaminants: carbon
monoxide, nitrogen oxides, hydrogen sulfide, hazardous air pollutants, organic compounds, particulate matter including
particulate matter with diameters of 10 microns or less and 2.5 microns or less, lead, sulfur dioxide, ammonia, carbon
dioxide, methane and nitrous oxide.
The De Minimis Modeling results indicated that predicted emission of, PM2.5 (increment), and PM10 (increment) are less
than the respective de minimis concentration and no further analysis was required.
This application was submitted to the TCEQ on May 30, 2019. The executive director has determined that the emissions
of air contaminants from the existing facility which are subject to PSD review will not violate any state or federal air quality
regulations and will not have any significant adverse impact on soils, vegetation, or visibility. All air contaminants have
been evaluated, and “best available control technology” will be used for the control of these contaminants.
The executive director has completed the technical review of the application and prepared a draft permit which, if
approved, would establish the conditions under which the facility must operate. The permit application, executive
director’s preliminary decision, draft permit, and the executive director’s preliminary determination summary and executive
director’s air quality analysis, will be available for viewing and copying at the TCEQ central office, the TCEQ Corpus
Christi regional office, and the Bell/Whittington Library located at 2400 Memorial Parkway, Portland, TX, beginning the first
day of publication of this notice. The facility’s compliance file, if any exists, is available for public review at the TCEQ
Corpus Christi Regional Office, NRC Bldg. Suite 1200, 6300 Ocean Drive, Unit 5839, Corpus Christi, Texas.
INFORMATION AVAILABLE ONLINE. These documents are accessible through the Commission’s Web site at
www.tceq.texas.gov/goto/cid: the executive director’s preliminary decision which includes the draft permit, the executive
director’s preliminary determination summary, air quality analysis, and, once available, the executive director’s response
to comments and the final decision on this application. Access the Commissioners’ Integrated Database (CID) using the
above link and enter the permit number for this application. The public location mentioned above provides public access
to the internet. This link to an electronic map of the site or facility's general location is provided as a public courtesy and
not part of the application or notice. For exact location, refer to application.
http://www.tceq.texas.gov/assets/public/hb610/index.html?lat=27.8886&lng=-97.27777&zoom=13&type=r.
PUBLIC COMMENT/PUBLIC MEETING. You may submit additional public comments about this application. The
purpose of a public meeting is to provide the opportunity to submit comment or to ask questions about the application.
The TCEQ will hold a public meeting if the executive director determines that there is a significant degree of public interest
in the application, if requested by an interested person, or if requested by a local legislator. A public meeting is not a
contested case hearing. You may submit additional written public comments within 30 days of the date of
newspaper publication of this notice in the manner set forth in the AGENCY CONTACTS AND INFORMATION
paragraph below.
After the deadline for public comment, the executive director will consider the comments and prepare a response to all
relevant and material or significant public comment. The response to comments, along with the executive director’s
decision on the application, will be mailed to everyone who submitted public comments or is on a mailing list for
this application. The mailing will also provide instructions for requesting a contested case hearing or
reconsideration of the executive director’s decision.
OPPORTUNITY FOR A CONTESTED CASE HEARING. You may request a contested case hearing regarding the
portions of the application for State Air Quality Permit Number 108113 and for PSD Air Quality Permit Number
PSDTX1344M2. There is no opportunity to request a contested case hearing regarding the portion of the
application for GHG PSD Air Quality Permit Number GHGPSDTX43. A contested case hearing is a legal
proceeding similar to a civil trial in a state district court. A person who may be affected by emissions of air
contaminants, other than GHGs, from the facility is entitled to request a hearing. A contested case hearing
request must include the following: (1) your name (or for a group or association, an official representative),
mailing address, daytime phone number; (2) applicant’s name and permit number; (3) the statement “I/we request
a contested case hearing;” (4) a specific description of how you would be adversely affected by the application
and air emissions from the facility in a way not common to the general public; (5) the location and distance of
your property relative to the facility; (6) a description of how you use the property which may be impacted by the
facility; and (7) a list of all disputed issues of fact that you submit during the comment period. If the request is
made by a group or association, one or more members who have standing to request a hearing must be
identified by name and physical address. The interests the group or association seeks to protect must also be
identified. You may also submit your proposed adjustments to the application/permit which would satisfy your
concerns. Requests for a contested case hearing must be submitted in writing within 30 days following this
notice to the Office of the Chief Clerk, at the address provided in the information section below.
A contested case hearing will only be granted based on disputed issues of fact or mixed questions of fact and law that are
relevant and material to the Commission’s decisions on the application. The Commission may only grant a request for a
contested case hearing on issues the requestor submitted in their timely comments that were not subsequently withdrawn.
Issues that are not submitted in public comments may not be considered during a hearing.
EXECUTIVE DIRECTOR ACTION. The executive director may issue final approval of the application for the portion of
the application for GHG PSD Air Quality Permit GHGPSDTX43. If a timely contested case hearing request is not received
or if all timely contested case hearing requests are withdrawn regarding State Air Quality Permit Number 108113 and for
PSD Air Quality Permit Number PSDTX1344M2, the executive director may issue final approval of the application. The
response to comments, along with the executive director’s decision on the application will be mailed to everyone who
submitted public comments or is on a mailing list for this application and will be posted electronically to the CID. If any
timely hearing requests are received and not withdrawn, the executive director will not issue final approval of the State Air
Quality Permit Number 108113 and for PSD Air Quality Permit Number PSDTX1344M2 and will forward the application
and requests to the Commissioners for their consideration at a scheduled commission meeting.
MAILING LIST. You may ask to be placed on a mailing list to obtain additional information on this application by sending
a request to the Office of the Chief Clerk at the address below.
AGENCY CONTACTS AND INFORMATION. Public comments and requests must be submitted either electronically at
www14.tceq.texas.gov/epic/eComment/, or in writing to the Texas Commission on Environmental Quality, Office of the
Chief Clerk, MC-105, P.O. Box 13087, Austin, Texas 78711-3087. Please be aware that any contact information you
provide, including your name, phone number, email address and physical address will become part of the agency’s public
record. For more information about this permit application or the permitting process, please call the Public Education
Program toll free at 1-800-687-4040. Si desea información en Español, puede llamar al 1-800-687-4040.
Further information may also be obtained from voestalpine Texas, LLC, at the address stated above or by calling Ms. Gail
Ridgeway, Environmental Manager at (361) 704-9000.
Notice Issuance Date: June 7, 2021

Special Conditions
Permit Numbers 108113, PSDTX1344M2 and GHGPSDTX43
Emission Limitations
1. This permit authorizes only those sources of

emissions listed in the attached table entitled
“Emission Sources - Maximum Allowable Emission
Rates,” and those sources are limited to the
emission rates and other conditions specified in
the table. In addition, this permit authorizes all
emissions from planned startup and shutdown
activities associated with facilities or groups of
facilities authorized by this permit.
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Fuel Specifications
2. Fuel shall be limited as specified and use of any

other fuel will require prior approval of the
A.
AF Executive Director of the Texas Commission on
Environmental Quality (TCEQ).
Fuel for the hot flare pilot (Emission Point No. [EPN] 38) shall be pipeline-quality natural gas;
B. Fuel for the main reformer burners and the process gas system shall be pipeline-quality
natural gas and top gas;
C. Fuel for the reformer auxiliary burners shall be pipeline-quality natural gas;
D. Fuel for the Fines Recycling Plant (FRP) Dryer burner shall be pipeline-quality sweet natural
gas; and (DRAFT)
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E. Fuel used in the emergency generator (EPN 34) and the fire pump (EPN 35) is limited to
diesel containing no more than 15 ppm by weight sulfur.
3. Upon request by the Executive Director of the

TCEQ or the TCEQ Regional Director or any local
air pollution control program having jurisdiction,
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the holder of this permit shall provide a sample

and/or an analysis of the fuels used in these
facilities or shall allow air pollution control program
representatives to obtain a sample for analysis.
Federal Applicability
4. The emergency generator and fire pump engines

shall comply with all applicable requirements of
the U.S. Environmental Protection Agency (EPA)
regulations on Standards of Performance for New
Stationary Sources in Title 40 Code of Federal
Regulations (40 CFR) Part 60, specifically the
following:
Special Conditions
Page 2
A. Subpart A - General Provisions; and
B. Subpart IIII – Stationary Compression Ignition Internal Combustion Engines.
5. The emergency generator and fire pump engines

shall comply with all applicable requirements of
the EPA Regulations on National Emission
Standards for Hazardous Air Pollutants for Source
Categories in 40 CFR Part 63, specifically the
following:
A. Subpart A - General Provisions; and

B. Subpart ZZZZ –Reciprocating Internal Combustion Engines.
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Opacity/Visible Emission Limitations
6. Opacity of particulate matter emissions from the

Oxide Unloading Transfer Fabric Filter Stack (EPN
4A), Oxide Unloading and Product Loading Fabric
AF Filter Stack (EPN 4B), Oxide Pellet Transfer (Pre-
Storage) Fabric Filter Stack (EPN 5A), Oxide
Pellet Transfer (Post-Storage) Fabric Filter Stack
(EPN 5B), Oxide Pellet Transfer (Post Storage)
Fabric Filter Stack (EPN 6), Oxide Day Bin Filling
Fabric Filter Stack (EPN 7A), Oxide Day Bin
Discharge Fabric Filter Stack (EPN 7B), Oxide
Day Bin Off Spec Fabric Filter Stack (EPN 7C),
Oxide Tower Transfer Fabric Filter Stack (EPN
7D), Furnace Charge Hopper Loading Silos Fabric
Filter Stack (EPN 16), Reformer Main Flue Ejector
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Stack (EPN 29), Fines Recycling Plant (FRP) Bag
Filter Stack (EPN BFL-1), and the FRP Bin Vent
Filters 1-3 (EPNs BVF-1, BVF-2, and BVF-3) shall
not exceed 5 percent, averaged over a six-minute
period. During MSS activities, the opacity shall
not exceed 15 percent averaged over a six-minute
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period. (DRAFT)
7. Opacity of particulate matter emissions from the

Furnace Dedusting Bottom Seal Gas (BSG) Dust
Collection Wet Scrubber Stack (EPN 8), Briquetter
Dedusting Scrubber Stack (EPN 9), HBI Cooling
Conveyor Scrubber Stack (EPN 11), and Charge
Hopper Wet Scrubber Stack (EPN 17) shall not
exceed 10 percent, averaged over a six-minute
period. (DRAFT)
8. There shall be no visible fugitive emissions leaving

the property from process buildings or fugitive
sources. Observations for visible emissions shall
be performed and recorded quarterly. (DRAFT)
Special Conditions
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Operational Limitations, Work Practices, and Plant Design
9. Plant operations and production shall be limited to

the following:
A. As represented, iron ore throughput shall not exceed 500 tons per hour (tph) and 3,197,250
tons per year (tpy) in any rolling 12-month period. (03/18)
B. Hot briquette iron (HBI) production shall be limited to 360 tph and 2,205,000 tpy.
C. Loading of the Briquette Curing Bin (EPN-DP-2) shall be limited to 28 tph and 245,280 tpy.
(DRAFT)
D. Plant wide natural gas usage shall not exceed 26,698 million standard cubic feet (MMscf) per
year. (08/15)
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10. Loading and unloading of the Solid Binder Bin (EPN BVF-1) at the Fines Recycling Plant, shall be
limited to 4 hours per day, not to exceed 1,460 hours per year. (DRAFT)
11. Fabric filter baghouses designed to meet an outlet

grain loading of not more than 0.002 grains per dry
AF standard cubic foot (gr/dscf) of exhaust each,
properly installed and in good working order, shall
control particulate matter emissions from Oxide
Unloading Transfer, Oxide Unloading and Product
Loading, Oxide Pellet Transfer (Pre-Storage),
Oxide Pellet Transfer (Post-Storage), Oxide Day
Bin Filling, Oxide Day Bin Discharge, Oxide Day
Bin Off Spec, Oxide Tower Transfer, Furnace
Charge Hopper Loading Silos when the processes
are in operation. (DRAFT)
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12. A fabric filter baghouse (EPN BFL-1) designed to
meet an outlet grain loading of not more than
0.002 grains per dry standard cubic foot (gr/dscf)
of exhaust, properly installed and in good working
order, shall control particulate matter emissions
from the following sources at the Fines Recycling
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Plant: cyclone separator, briquetting plant, dosing

bin, mixer and natural gas dryer. (DRAFT)
13. Bin vent filters designed to meet and outlet grain

loading of not more than 0.002 grains per dry
standard cubic foot (gr/dscf) of exhaust each,
properly installed and in good working order, shall
control particulate matter emissions from the Solid
Binder Bin Vent (EPN BVF-1), Dried Filter Cake
Bin Vent (EPN BVF-2), and Pellet Dust Bin Vent
(EPN BVF-3). (DRAFT)
14. A wet scrubber designed to meet an outlet grain

loading of not more than 0.0079 gr/dscf of exhaust
each properly installed and in good working order,
shall control particulate matter emissions from the
Special Conditions
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Charge Hopper, Furnace Dedusting (Bottom Seal
Gas Dust Collection) and Briquetter Dedusting
when the equipment is in operation. (DRAFT)
15. The HBI conveyors shall employ water sprays to

cool the HBI and shall be equipped with vapor
hoods to remove steam created by the process.
Additionally, a wet scrubber designed to meet an
outlet grain loading of not more than 0.0079
gr/dscf of exhaust each properly installed and in
good working order, shall control particulate matter
emissions from the HBI Cooling Conveyor when
the equipment is in operation. (08/15)
16. The reformer shall be equipped with low NOx
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burners and shall not exceed the following
emission limits: (DRAFT)
Table 1: Reformer Emission Limits

AF
Pollutant Emission Limit (mg/Nm3) Averaging Time
PM, PM10, and PM2.5 20 mg/Nm3 dry at 3% O2 1-day hourly average
CO 173 mg/Nm3 dry at 3% O2 1-day hourly average
VOC (as total hydrocarbons) 11 mg/Nm3 dry at 3% O2 1-day hourly average
NOx 110 mg/Nm3 dry at 3% O2 30-day continuous average
17. During startup and shutdown, the reduction

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reactor shall exhaust through the top gas scrubber
to a flare subject to the requirements of Special
Condition (SC) 29.
18. Dock ore unloading operations shall employ

enclosed conveyors and water sprays at conveyor
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transfer points.
19. All conveyors at the Fines Recycling Plant shall be

fully enclosed and shall not contribute to the total
emissions from the Hot Briquetting Facility.
(DRAFT)
20. The following sources shall employ hooded

conveyors and enclosed transfer stations: Oxide
Unloading Transfer, Oxide Unloading and Product
Loading, Oxide Pellet Transfer (Pre-Storage),
Oxide Pellet Transfer (Post-Storage), Oxide Day
Bin Discharge, Oxide Day Bin Off Spec, Oxide
Tower Transfer, and Product Transfer and
Screening (Station No. 2, Post Pile fully enclosed).
(08/15)
Special Conditions
Page 5
21. Emissions from the cement, burnt lime, hydrated
lime, and hydrated dolomite storage silos shall be
controlled by the fabric filter exhausting at EPN 16.
22. Iron ore shall be stored in enclosed storage.

(03/18)
23. Replaced or used fabric filter bags shall be placed

in sealed containers and disposed of in a manner
that will prevent any dust from becoming airborne.
24. All air pollution abatement equipment shall be

properly maintained and operated during the
operation of these facilities. Cleaning and
maintenance of the abatement equipment shall be
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performed as recommended by the manufacturer
and as necessary so the equipment efficiency can
be adequately maintained.
25. All hood, duct, and collection systems shall be

AF effective in capturing emissions from process
equipment and in preventing fugitive emissions
from the buildings. The hood and duct systems
shall be maintained free of holes, cracks, and
other conditions that would reduce the collection
efficiency of the emission capture system.
26. The hoods and ductwork for the emission capture

and control systems shall be inspected quarterly to
ensure they are free of holes, cracks, and other
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conditions that would reduce the collection
efficiency of the emission capture system.
27. This facility shall not create a nuisance as defined

in 30 TAC § 101.4 as adopted by the TCEQ. If
such a condition does occur, additional controls
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may be required.
28. The operations/processes listed in the table below operate per the criteria of the referenced Permit
by Rule (PBR) and are incorporated by reference only. The list is not meant to be an exhaustive
list. (DRAFT)
Table 1: Authorizations Incorporated by Reference

Operation/Process PBR No. Registration
No.
Facility Welding 106.227 N/A
Barbecue Pit 106.244 N/A
Routine Maintenance 106.263 N/A
Industrial Vacuums 106.266 N/A
Motor Vehicle Fueling 106.412 N/A
Special Conditions
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Diesel Fuel Storage 106.472 N/A
Gasoline Storage 106.473 N/A
Emergency Engines 106.511 N/A
Oil and Water Separator 106.532 N/A
Maintenance Yard 106.261 and 106.452 150444
Temporary Storage Piles and Screeners 106.261 147082
Flare
29. The flare controlling emissions from the Hot

Pressure Relief Vent (EPN 38) shall be designed
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and operated in accordance with the following
requirements:
A. The flare shall have a minimum destruction and removal efficiency (DRE) for methane, CO,
and VOC of 98%. (DRAFT)
B.
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The flare systems shall be designed such that the combined assist natural gas and waste
stream to each flare meets the 40 CFR § 60.18 specifications for minimum heating value and
maximum tip velocity under normal, upset, and maintenance flow conditions.
The heating value and velocity requirements shall be satisfied during operations authorized
by this permit. Flare testing per 40 CFR § 60.18(f) may be requested by the regional office
having jurisdiction to demonstrate compliance with these requirements.
C. The flare shall be operated with a flame present at all times and/or have a constant pilot
flame. The pilot flame shall be continuously monitored by a thermocouple or an infrared
monitor. The time, date, and duration of any loss of pilot flame shall be recorded. Infrared
monitors shall be accurate and shall be calibrated at a frequency in accordance with, the
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manufacturer’s specifications.
D. The flare shall be operated with no visible emissions except periods not to exceed a total of
five minutes during any two consecutive hours. This shall be ensured by the use of air assist
to the flare.
E. The permit holder shall install a continuous flow monitor and composition analyzer that
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provide a record of the vent stream flow and composition (total VOC or Btu content) to the
flare. The flow monitor sensor and analyzer sample points shall be installed in the vent
stream as near as possible to the flare inlet such that the total vent stream to the flare is
measured and analyzed. Readings shall be taken at least once every 15 minutes and the
average hourly values of the flow and composition shall be recorded each hour.
The monitors shall be calibrated on an annual basis to meet the following accuracy
specifications: the flow monitor shall be ±5.0%, temperature monitor shall be ±2.0% at
absolute temperature, and pressure monitor shall be ±5.0 mm Hg;
If VOC are monitored, calibration of the analyzer shall follow the procedures and
requirements of Section 10.0 of 40 CFR Part 60, Appendix B, Performance Specification 9,
as amended through October 17, 2000 (65 FR 61744), except that the multi-point calibration
procedure in Section 10.1 of Performance Specification 9 shall be performed at least once
every calendar quarter instead of once every month, and the mid-level calibration check
procedure in Section 10.2 of Performance Specification 9 shall be performed at least once
every calendar week instead of once every 24 hours. The calibration gases used for
Special Conditions
Page 7
calibration procedures shall be in accordance with Section 7.1 of Performance Specification
9. Net heating value of the gas combusted in the flare shall be calculated according to the
equation given in 40 CFR §60.18(f)(3) as amended through October 17, 2000 (65 FR 61744).
If a calorimeter is used, the calorimeter shall be calibrated, installed, operated, and
maintained, in accordance with manufacturer recommendations, to continuously measure
and record the net heating value of the gas sent to the flare, in British thermal units/standard
cubic foot of the gas.
The monitors and analyzers shall operate as required by this section at least 95% of the time
when the flare is operational, averaged over a rolling 12-month period. Flared gas net
heating value and actual exit velocity determined in accordance with 40 CFR §60.18(f)(4)
shall be recorded at least once every 15 minutes.
If a VOC monitor is used, hourly mass emission rates shall be determined and recorded
using the above readings and the emission factors used in the permit application PI-1 dated
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February 4, 2013.
Cooling Tower
30. The cooling water used by the cooling tower

AF exhausting at EPN 33 shall use sea water and
shall be equipped with drift eliminators having a
design drift rate not greater than 0.0005%.
A. Cooling water shall be sampled once a week for concentrations of total dissolved solids
(TDS). 3% of the dissolved solids in the cooling water drift are considered to be emitted as
PM10 and 3% of the dissolved solids are considered to be emitted as PM2.5. The analysis
method for TDS shall be EPA Method 160.1, ASTM D5907, and SM 2540 C [SM - 19th
edition of Standard Methods for Examination of Water].
Cooling water shall either be sampled once a day for conductivity and analyzed using ASTM
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D1125-95A and SM 2510B [SA – 19th edition of Standard Methods for Examination of Water]
or shall be continuously monitored for conductivity. Use of an alternative sampling method
shall be approved by the TCEQ Regional Director prior to its implementation. Quality-
assured (or valid) data must be generated when the cooling tower is operating except during
the performance of a daily zero check. Loss of valid data due to periods of monitor
breakdown, out-of-control operation (producing inaccurate data), repair, maintenance, or
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calibration may be exempted provided the total data loss period does not exceed 5 percent of
the time (in hours) that the cooling tower operated over the previous rolling 12 month period.
The measurements missed shall be estimated using engineering judgment and the methods
used recorded.
The TDS and conductivity data shall result from sampling or monitoring the cooling tower
return stream (i.e., water stream routed to the tower for cooling), and represent the water
being cooled in the tower. Water samples should be capped upon collection and transferred
to a laboratory area for analysis.
B. The permit holder may reduce the frequency of TDS sampling required by paragraph B of
this condition by establishing a valid correlation between TDS and conductivity for the cooling
tower as follows:
(1) The sampling and analysis required by paragraph B of this condition (i.e., frequency of
sampling for TDS and conductivity) shall be conducted as specified until a valid
correlation is established between TDS and conductivity.
Special Conditions
Page 8
(2) For a minimum period of six months, the cooling water shall be sampled at least
weekly for analysis of TDS and conductivity. The data from the TDS and conductivity
measurements shall be plotted, with a total range of two standard deviations (plus and
minus one standard deviation) applied to the resulting plot. A report including the data
analysis results and the correlation established between TDS concentrations and
conductivity shall be maintained on site.
(3) Following completion of the report, the cooling water may either be sampled daily or
monitored continuously for conductivity, and the result converted to TDS with the use
of the established correlation.
(4) The correlation shall be re-validated annually with the analysis of a single cooling water
sample for TDS and conductivity. The measured TDS value shall be compared to the
correlation TDS value (i.e., the TDS value derived from the measured conductivity and
the established correlation). If the measured TDS value is not within plus or minus one
standard deviation of the correlation TDS value, a new correlation shall be developed
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according to paragraph B. of this condition.
C. Cooling tower PM emissions shall be determined using the cooling tower water circulation
rate, cooling tower design drift, and the measured or estimated TDS.
AF 31. Primary in-plant roads and parking areas shall be
paved with a cohesive hard surface and cleaned
as necessary using sweeping and enforced
reduced speed limits to maintain compliance with
all applicable TCEQ rules.
32. Unpaved areas and roads, including storage yards

shall be sprinkled with water or dust suppressant
chemicals as necessary and have enforced
reduced speed limits to control dust emissions and
maintain compliance with all applicable TCEQ
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rules.
Demonstration of Continuous Compliance
33. Upon being informed by the TCEQ Executive

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Director that the staff has documented visible

emissions from this facility exceeding opacity of
emissions stated in SC 6 the holder of this permit
shall conduct stack sampling analyses as
appropriate or take immediate corrective action to
demonstrate compliance.
34. Upon request by the TCEQ Executive Director or

the TCEQ Regional Director having jurisdiction,
the holder of this permit shall perform stack
sampling and/or other testing as required to
establish the actual pattern and quantities of air
contaminants being emitted into the atmosphere to
demonstrate compliance with the MAERT and with
emission performance levels as specified in the
special conditions and/or otherwise prove
satisfactory equipment performance. Sampling
Special Conditions
Page 9
must be conducted in accordance with the TCEQ
Sampling Procedures Manual and in accordance
with the applicable EPA 40 CFR procedures. Any
deviations from those procedures must be
approved by the TCEQ Executive Director or the
appropriate TCEQ Regional Director prior to
conducting sampling.
35. Visible emissions observations for wet scrubbers

exhausting at EPN’s 8, 9, 11, 17 and 38 shall be
made once per day and recorded in accordance
with the requirements specified in 40 CFR §
64.7(c). (DRAFT)
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Initial Determination of Compliance
36. To demonstrate compliance with the MAERT and

with emission performance levels as specified in
the special conditions, the holder of this permit
AF shall perform stack sampling and/or other testing
as required to establish the actual pattern and
quantities of air contaminants being emitted into
the atmosphere from EPNs 8 and 29: (DRAFT)
A. Air contaminants from EPN 8 to be sampled and analyzed include (but are not limited to) CO
and NH3.
B. Air contaminants from EPN 29 to be sampled and analyzed include (but are not limited to)
PM, PM10, PM2.5, NOx, CO, and VOCs.
C. Sampling shall be accomplished within 60 days of achieving maximum production but not
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later than 180 days after initial startup.
Sampling Requirements
37. The holder of this permit is responsible for

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providing sampling and testing facilities and

conducting the sampling and testing operations at
their own expense. Sampling ports and platforms
shall be incorporated into the design of the
stack(s) according to the specifications set forth in
the attachment entitled “Chapter 2, Stack
Sampling Facilities” prior to stack sampling.
Alternate sampling facility designs may be
submitted for approval by the TCEQ Regional
Office with jurisdiction.
38. Sampling shall be conducted in accordance with

the TCEQ Sampling Procedures Manual and EPA
Test Methods in 40 CFR part 60, Appendix A and
40 CFR Part 51, Appendix M.
A. Test methods to be used are as follows:

Special Conditions
Page 10
(1) Appendix A, Method 5, per TCEQ Lab Method for the concentration of PM;
(2) Appendix A, Method 5 or 17, for the filterable concentration of PM (front-half catch);
(3) Appendix A, Method 7E for the concentrations of NOx and O2, or equivalent methods;
(4) Appendix A, Method 9 for opacity;
(5) Appendix A, Method 10 for the concentration of CO;
(6) Appendix A, Method 22, for visual determination of fugitive emissions from material
sources;
(7) Appendix M, Method 202, or Appendix A, Reference Method 5, modified to include
back-half condensables, for the concentration of PM10; and
(8) Appendix M, Methods 201A or Appendix A, Reference Method 5, for the filterable
concentration of PM10 (front-half catch);
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B. Any variations from these procedures must be approved by the Executive Director of the
TCEQ or his designated representative prior to sampling.
39. A pretest meeting shall be held with personnel

from the TCEQ before the required tests are
AF performed. The TCEQ Regional Office with
jurisdiction shall be notified not less than 45 days
prior to sampling to schedule a pretest meeting.
The notice shall include:
A. Date for pretest meeting;

B. Date sampling will occur;
C. Points or sources to be sampled;
D. Name of firm conducting sampling;
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E. Type of sampling equipment to be used; and
F. Method or procedure to be used in sampling.
The purpose of the pretest meeting is to review the necessary sampling and testing procedures, to
provide the proper data forms for recording pertinent data, and to review the format procedures for
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submitting the test reports.
40. Alternate sampling methods and representative

unit testing may be proposed by the permit holder.
A written proposed description of any deviation
from sampling procedures or emission sources
specified in permit conditions or TCEQ or EPA
sampling procedures shall be made available to
the TCEQ prior to the pretest meeting. Such a
proposal must be approved by the TCEQ Regional
Office with jurisdiction at least two weeks prior to
sampling.
41. Requests to waive testing for any pollutant

specified shall be submitted, in writing, for
approval to the TCEQ Office of Air, Air Permits
Division in Austin.
Special Conditions
Page 11
42. During stack sampling emission testing, the
facilities shall operate at maximum represented
production/throughput rates. Primary operating
parameters that enable determination of
production rates shall be monitored and recorded
during the stack test. These parameters are to be
determined at the pretest meeting.
If the plant is unable to operate at the maximum represented production/throughput rates during
testing, then additional stack testing shall be required when the production rate exceeds the
previous stack test production rate by +10 percent unless otherwise determined, in writing, by the
TCEQ Executive Director.
43. Requests for additional time to perform sampling

shall be submitted to the TCEQ Regional Office
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with jurisdiction. Additional time to comply with the
applicable federal requirements requires EPA
approval, and requests shall be submitted to the
AF TCEQ Regional Office with jurisdiction.
44. Copies of the final sampling report shall be

forwarded to the TCEQ within 60 days after
sampling is completed. Sampling reports shall
comply with the attached provisions of Chapter 14
of the TCEQ Sampling Procedures Manual. The
reports shall be distributed as follows:
One copy to the TCEQ Regional Office with jurisdiction.
One copy to the TCEQ Office of Air, Air Permits Division in Austin.
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One copy to each appropriate local air pollution control program with jurisdiction.
45. If, as a result of stack sampling, compliance with

the permitted emission rates cannot be
demonstrated, the holder of this permit shall adjust
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any operating parameters so as to comply with

Special Condition No. 1 and the permitted
emission rates.
46. If the holder of this permit is required to adjust any

operating parameters for compliance, then
beginning no later than 60 days after the date of
the test conducted, the holder of this permit shall
submit to the TCEQ, on a monthly basis, a record
of adjusted operating parameters and daily
records of production sufficient to demonstrate
compliance with the permitted emission rates.
Daily records of production and operating
parameters shall be distributed as follows:
One copy to the TCEQ Regional Office with jurisdiction.

Special Conditions
Page 12
One copy to the TCEQ Office of Air, Air Permits Division in Austin.
Recordkeeping Requirements
47. Records shall be maintained at this facility site and

made available at the request of personnel from
the TCEQ or any other air pollution control
program having jurisdiction to demonstrate
compliance with permit limitations. These records
shall be totaled for each calendar month, retained
for a rolling 60-month period, and include the
following:
A. A daily record of operating hours, amount of iron ore processed, and hot briquetted iron
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produced in tons per 24-hour period. From this data, average hourly throughput and
production shall be calculated; (03/18)
B. A record of annual iron ore throughput and hot briquetted iron production in tons on a rolling
12-month basis; (03/18)
C.
D.
AF
Annual natural gas usage for the facility (MMscf), on a rolling 12-month basis;
Records of the inspection, maintenance, malfunction, and repair of abatement equipment.
Inspections of capture systems and abatement devices shall be recorded as they occur;
E. Records required by NSPS Subpart IIII and MACT Subpart ZZZZ;
F. Quarterly observations for visible emissions and/or opacity determinations as required by
Special Conditions Nos. 6 and 7;
G. A daily record of loading and unloading hours for the Solid Binder Bin at the Fines Recycling
Plant; (DRAFT)
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H. Records required by SC 29 to include (1) time, date, and duration of loss of flare pilot flame,
(2) hourly values of flow and composition of the vent stream, and (3) hourly VOC mass
emission rate if a VOC monitor is used;
I. Records required by SC 30 to include TDS and conductivity sampling;
J. Daily observations for visible emissions required by SC 35; and
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K. Records shall be kept in sufficient detail to allow emission rates of Hazardous Air Pollutants
(HAPS) to be accurately determined from all emission points having the potential to emit
HAPS. Using this recorded data, a report shall be produced for the emission of HAPs (in tons
per year) over the previous 12 consecutive month. The required records shall be kept with
examples of the method of data reduction including units, conversion factors, assumptions,
and the basis of the assumptions.
Greenhouse Gases Special Conditions
48. The facility shall combust as fuel and use as

relevant raw material pipeline quality natural gas in
all sources except for the emergency engines.
49. The permit holder shall determine the pipeline

quality natural gas fuel gross calorific value (GCV)
Special Conditions
Page 13
[high heat value (HHV)], carbon content and if
applicable, molecular weight, shall be determined,
at a minimum, monthly by the procedures
contained in 40 CFR § 98.34(b)(3). Records of
the fuel GCV shall be maintained for a minimum
period of five years. Upon request, the permit
holder shall provide a sample and/or analysis of
the fuel that is fired in any unit covered by this
permit at the time of the request, or shall allow a
sample to be taken for analysis by TCEQ or any
air pollution control program personnel with
jurisdiction.
50. Pipeline quality natural gas shall be exempt from

the requirement of SC 49 provided the permit
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holder receives and maintains quarterly records of
the vendor’s analysis, and the data is of sufficient
quality to yield further analysis as required above.
51. The permit holder shall utilize insulation materials

AF 52.
where feasible to reduce heat loss.
The permit holder shall maintain a minimum

overall efficiency of less than or equal to 13
dekatherms of natural gas/ton (11.79 mmBtu/ton)
of HBI produced on a 12-month rolling average
basis, calculated monthly. Heat input is on the
higher heating value basis. Natural gas use
includes all uses of natural gas at the site,
including during periods of start-up, shutdown,
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maintenance and idle time. Any time when natural
gas is used shall be included. Total HBI
production shall include all HBI passing through
the shaft furnace, including commercial and off
specification or unsaleable product. The
calculations to demonstrate compliance shall be
made each month and the 12-month rolling values
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shall be updated by the last day of the following

month.
53. The permit holder shall calibrate and perform

preventative maintenance checks of the natural
gas flow meters and document at the minimum
frequency established per the manufacturer’s
recommendation, or at the interval specified per
40 CFR § 98.34(b)(1)(ii). The flow meters must be
located at the natural gas receiving station and
prior to natural gas distribution to the facility.
54. The permit holder shall calculate, on a monthly

basis, the amount of CO2 emitted from the
consumption (fuel and raw material) of natural gas
in tons/yr using equation C-2a in 40 CFR Part 98
Special Conditions
Page 14
Subpart C, converted to short tons. Compliance
shall be based on a 12-month rolling basis to be
updated by the last day of the following month.
55. The permit holder shall calculate the CO2e

emissions on a 12-month rolling basis, based on
the procedures and Global Warming Potentials
(GWP) contained in Greenhouse Gas Regulations,
40 CFR Part 98, Subpart A, Table A-1, as
published on November 29, 2013 (74 FR 71948).
The record shall be updated by the last day of the
following month.
56. The permit holder shall determine the entire HBI

production quantity for each month by the last day
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of the following month. Such production data shall
include subtotals by type of HBI produced,
including all on-spec and off-spec material that
AF passes through the shaft furnace.
Reformer Main Flue Ejector Stack (EPN 29)
57. The reformer furnace shall be designed and

operated in accordance with the following
requirements:
A. The reformer furnace shall have fuel metering for natural gas (auxiliary fuel) and top gas.
The permit holder shall measure and record the fuel flow rates using an operation non-
resettable elapsed flow meter or by recording the flow rate date in an electronic format with
individual flow measurements being taken no less frequently than once every 15 minutes.
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Electronic data may be reduced to hourly averages for recordkeeping.
B. The permit holder shall install, operate, and maintain an O2 analyzer in the furnace flue gas at
a location downstream of the radiant sections of the furnace.
C. The oxygen analyzer shall:
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(1) be zeroed and spanned daily and corrective action taken when the 24-hour span drift
exceeds two times the amounts specified in the Performance Specification No. 3, 40
CFR Part 60, Appendix B. Zero and span is not required on weekends and plant
holidays if instrument technicians are not normally scheduled on those days.
(2) be quality-assured at least semiannually using cylinder gas audits (CGAs) in
accordance with 40 CFR Part 60, Appendix F, Procedure 1, § 5.1.2, with the following
exception: a relative accuracy test audit is not required once every four quarter (i.e.,
two successive semiannual CGAs may be conducted). An equivalent quality-
assurance method approved by the EPA may also be used.
Successive semiannual audits shall occur no closer than four months. Necessary
corrective action shall be taken for all CGA exceedances of ± 15 percent accuracy and
any continuous emissions monitoring system downtime in excess of 5 percent of
incinerator operating time. These occurrences and corrective actions shall be reported
to the TCEQ, Region 14 office on a quarterly basis. Supplemental stack concentration
measurements may be required at the discretion of the regional office.
Special Conditions
Page 15
D. The fuel gas meters, and oxygen analyzer shall have a minimum 95% on-stream time or
greater when the reformer is being fired. Missing data shall be supplied using good
engineering practices and documenting methods used.
E. The reformer furnace shall not exceed the one-hour maximum firing rate of 1,591 mm/Btu/hr.
This one-hour maximum firing rates shall be determined daily.
F. Natural gas to the reformer fuel supply and as raw material to the reformer shall be recorded
daily and summed monthly.
G. The permit holder shall on a monthly basis, determine the total CO2 and CO2e emissions from
EPN 29 based on flue gas composition and the actual measured flows through EPN 29.
H. The permit holder shall calculate, on a monthly basis, the amount of CH4 and N2O emitted
from combustion of natural gas in tons/yr using CH4 and N2O emission factors from AP-42,
Chapter 1 Section 4, Table 1.4-2, converted to short tons. This emission rate includes the
reformer and the seal gas system and will be apportioned according to the total auxiliary fuel
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emissions excluding the seal gas system emissions (SC 58.B).
Seal Gas System: Charge Hopper (EPN 17), Bottom Seal Gas Vent (EPN 8) and Briquetting Wet
Scrubber (EPN 9)
AF 58. The Seal Gas System shall be designed and
operated in accordance with the following
requirements:
A. Reformer flue gas bleed-off to be used as seal gas shall be measured using an operation non-
resettable elapsed flow meter or by recording the flow rate data in an electronic format with
individual flow measurements being taken no less frequently than once every 15 minutes.
Electronic data may be reduced to hourly averages for recordkeeping purposes and monthly
averages for emission calculations purposes.
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B. The permit holder shall use flow and pressure or other comparable engineering methods to
apportion the actual flow of seal gas through each of the 3 EPNs identified in this special
condition.
C. The permit holder shall calibrate and perform preventative maintenance checks of the flue
gas flow meter, pressure, and other, if any, necessary meters and document at the minimum
frequency established per the manufacturer’s recommendations, or at the interval specified
D
per 40 CFR § 98.34(b)(1)(ii)

D. The permit holder shall calculate, on a monthly basis, the amount of CO2, CH4 and N2O
emitted from EPNs 8, 9 and 17 in tons/yr using the data collected in SC 57.G and H and 58.
A and B.
E. The permit holder shall calculate each month the CO2e emissions on a 12-month rolling
basis, based on the procedures and Global Warming Potentials (GWP) contained in
Greenhouse Gas Regulations, 40 CFR Part 98, Subpart A, Table A-1, as published on
November 29, 2013 (74 FR 71948). The record shall be updated by the last day of the
following month.
Process Water Degasser (EPNs 30a and 30b)
59. The process water degasser shall be designed

and operated in accordance with the following
requirements:
Special Conditions
Page 16
A. The process water degasser water inlet shall be measured for temperature, pressure and the
top gas scrubber water inlet shall be measured for water flow using operational non-
resettable elapsed meters or by recording the data in an electronic format with individual
measurements being taken no less frequently than once every 15 minutes. Electronic data
may be reduced to hourly averages for recordkeeping purposes. (DRAFT)
B. The permit holder shall calibrate and perform preventative maintenance checks for the
monitoring equipment in this special condition and document the checks at the minimum
frequency established per the manufacturer’s recommendation, or at the interval specified
per 40 CFR § 98.34(b)(1)(ii).
C. The permit holder shall calculate, on a monthly basis, the amount of CO2, CH4 and N2O
emitted from EPN 30a and 30b, in tons/yr., using the parameters monitored in Item SC 59.A.
and the Henry’s Law coefficient for the appropriate greenhouse gas. Compliance shall be
based on a 12-month rolling basis to be updated by the last day of the following month.
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D. The permit holder shall calculate the CO2e emissions on a 12- month rolling basis, based on
the procedures and Global Warming Potentials (GWP) contained in Greenhouse Gas
Regulations, 40 CFR Part 98, Subpart A, Table A-1, as published on November 29, 2013 (74
FR 71948). The record shall be updated by the last day of the following month.
Emergency Engines (EPNs 34 and 35)
AF 60. The Fire Water Pump (EPN 35) and Emergency
Generator (EPN 34) shall be operated in
accordance with the following requirements:
A. The Fire Water Pump and Emergency Generator are each limited to 100 hours of non-
emergency operation per year. The emergency firewater pump engine shall not exceed 240
horsepower and the emergency generator shall have a power output not to exceed 2,500
kW. Compliance with the 100-hour, non-emergency operational requirement is determined
on a 12-month rolling basis.
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B. The Fire Water Pump and Emergency Generator shall meet all applicable requirements in 40
CFR Part 60 IIII, Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines.
C. The permit holder shall install and maintain an operational non-resettable elapsed time meter
for the Fire Water Pump and Emergency Generator.
D
D. The permit holder shall maintain a file of all records, data measurements, reports and
documents related to the operation of the Fire Water Pumps and Emergency Generator,
including, but not limited to, the following:
(1) all records or reports pertaining to maintenance performed;
(2) all records relating to performance tests and monitoring of the emergency generator
and fire pump equipment;
(3) records of each diesel fuel oil delivery, documents from the fuel supplier certifying
compliance with the fuel sulfur content limit specified in SC 2.E;
(4) fuel heat input values and hours of operation required in SC 60.A; and all other
information required by this permit recorded in a permanent form suitable for
inspection; and,
(5) The file must be retained for not less than five years following the date of such
measurements, maintenance, reports, and/or records.
Special Conditions
Page 17
E. Compliance with the Annual Emission Limit shall be demonstrated on a 12-month total,
rolling monthly, calculated in accordance with 40 CFR §98.33(a)(1)(ii).
Fugitive Components (EPN FUG)
61. The permit holder shall implement a 28PI, physical

inspection-based, Leak Detection and Repair
(LDAR) program for detecting leaks in natural gas,
top gas, and seal gas piping components,
including valves and flanges. (DRAFT)
A. The program elements and methods shall be documented in the form of written procedures
to be followed.
B. Physical inspections shall be performed weekly, sitewide.
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C. Any component found to be leaking using the 28PI LDAR program (or other means) shall be
repaired within 15 days. Records must be kept of the component found to be leaking, the
apparent cause of the leak (if discernable), the date the component was discovered leaking
and the date the repairs were effective. Records shall be kept for 5 years.
D.
AF
Records of the weekly inspection results shall be maintained on site for 5 years.
Continuous Emissions Monitoring Systems (CEMS)
62. As an alternative to SC 49, the permit holder may

install a CO2 CEMS, stack gas moisture monitor,
and volumetric stack gas flow monitoring system
with an automated data acquisition and handling
system for measuring and recording CO2
emissions discharged to the atmosphere, and use
these values to show compliance with the annual
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emission limits in the MAERT for EPNs 29, 17, 8,
and 9. A single monitoring system may be shared
between these stacks, provided at least one cycle
of measurement can accurately be made for each
stack once each fifteen minutes,
D
63. The permit holder shall ensure that all required

CO2, stack gas moisture monitor, and stack gas
flowrate monitoring system/equipment are
installed and all certification tests are completed
on or before the earlier of 90 unit operating days
or 80 calendar days after the date the unit
commences operation.
64. The permit holder shall ensure compliance with

the specifications and test procedures for CO2
emission monitoring systems at stationary
sources, 40 CFR Part 75, or 40 CFR Part 60,
Appendix B, Performance Specification numbers I
through 9, as applicable.
Special Conditions
Page 18
65. The permit holder shall meet the appropriate
quality assurance requirements specified in 40
CFR Part 60, Appendix F for the CO2 emission
monitoring system.
Recordkeeping and Reporting Requirements
66. In order to demonstrate compliance with the GHG

emission rate for each emission unit, for the
sitewide energy efficiency measure, and with the
BACT requirements for each emissions unit, the
permit holder shall monitor and record the
following parameters and summarize the data on a
calendar month basis.
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A. Records required in SC 48-61 D, including data collected, maintenance activities performed
(where required), and calculation methods used to make the various demonstrations of
compliance called for by the Special Conditions;
B. Daily record of DRI and HBI process operating hours and hot briquetted iron produced
C.
hour of the day;
AF
(including off spec DRI/HBI) in tons per 24-hour period. Records shall include operating
status (normal operations, startup, shutdown, malfunction, maintenance, idle, etc.) for each
Annual hot briquetted iron production in tons on a rolling 12-month basis;

D. Record of operating hours (and total by month) for each of the emergency engines;
E. Total natural gas into the plant for each month (MMscf) and maintained on a rolling 12-month
basis;
F. Natural gas usage for each source, using continuous fuel/raw material flow monitors (a group
of equipment can utilize a common flow meter, as long as actual usage is allocated to the
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individual equipment based upon actual operating hours and maximum utilization rate);
G. For each calendar month, calculations of the 12-month rolling GHG emission rates for
comparison to the MAERT limits;
H. Time, date, and duration of any loss of the flare pilot flame;
D
I. NSPS IIII certification statements for emergency engines; and

J. The permit holder shall also maintain site-specific procedures for preventative maintenance
practices, vendor-recommended operating procedures and O&M manuals, and the 28PI
LDAR program documentation. These manuals shall be maintained with the permit and
located on-site and retained for 5 years after the last use of the individual methods.
67. Malfunction Reporting
A. The permit holder shall notify the TCEQ, by mail, within 48 hours following the discovery of
any failure of air pollution control equipment, process equipment, or of a process to operate
in a normal manner, which results in an increase in GHG emissions above the allowable
emission limits stated in the MAERT.
B. Within 10 days of the restoration of normal operations after any failure described in SC 67 A
(above), the permit holder shall provide a written supplement to the initial notification that
includes a description of the malfunctioning equipment or abnormal operation, the date of the
Special Conditions
Page 19
initial malfunction, the period of time over which emissions were increased due to the failure,
the cause of the failure, the estimated resultant emissions in excess of those allowed in the
MAERT, and the methods utilized to mitigate emissions and restore normal operations.
C. Compliance with this malfunction notification provision shall not excuse or otherwise
constitute a defense to any violation of this permit or any law or regulation such malfunction
may cause.
68. The permit holder shall maintain records of the

following events:
A. All records or reports pertaining to significant maintenance performed.

B. Start date and time and end date and time, and duration of each startup, shutdown,
malfunction, maintenance event and idle time event of the reformer and furnace.
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C. All incidents of process gas leaks past any seal gas leg, including the date, time, duration,
and cause of each event.
D. All instances where the required minimum data collection by monitoring systems was not
met, and the methods used to supply missing data, including relevant example calculations.
A.
AF 69. Records retention and format.
All required records must be maintained for at least 5 years following the date of such
measurements, maintenance activity, or report unless otherwise noted in a specific condition
of this permit.
B. Data may be kept in any suitable format, including electronic, provided they are promptly
available upon request to the TCEQ or any air pollution control program personnel with
jurisdiction. Where calculation methods are used to determine any record, example equations
and methods must be retained along with the relevant records.
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C. Records of any stack tests or performance tests shall be retained for the life of the permit.
D. The permit holder shall maintain records and submit a written report of all excess emissions
or malfunction events (identified in SC 67, above) to the TCEQ semiannually, except when:
more frequent reporting is specifically required by an applicable subpart; or the Administrator
or authorized representative, on a case by-case basis, determines that more frequent
reporting is necessary to accurately assess the compliance status of the source. The report is
D
due on the 30th day following the end of each semi-annual period and shall include the
following:
(1) Time intervals, data and magnitude of the excess emissions, the nature and cause (if
known), corrective actions taken, and preventive measures adopted;
(2) Applicable time and date of each period during which the monitoring equipment was
inoperative (monitoring down-time);
(3) A statement in the report of a negative declaration; that is; a statement when no excess
emissions occurred or when the monitoring equipment has not been inoperative,
repaired or adjusted; and
(4) Any failure to conduct any required source testing, monitoring, or other compliance
activities.
Excess emissions shall be defined as any period in which the facility emission exceeds a
maximum emission limit or fails to meet a minimum control requirement or work practice
standard set forth in this permit.
Special Conditions
Page 20
Excess emissions indicated by GHG emission source certification testing or compliance
monitoring shall be considered violations of the applicable emission limit for the purpose of
this permit.
Performance Testing Requirements
70. The permit holder shall perform an initial stack test

to establish the actual quantities of air
contaminants being emitted into the atmosphere
from the Reformer Main Flue Ejector Stack (EPN
29) to determine the initial compliance with the
CO2 emission limits established in this permit.
Sampling shall be conducted in accordance with
40 CFR 60.8 and EPA Method 3a or 3b for the
concentration of CO2.
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71. Within 60 days after achieving the maximum
production rate at which the affected facility will be
operated, but not later than 180 days after initial
startup of the facility, performance tests(s) shall be
AF conducted and a written report of the performance
testing results furnished to the TCEQ. Additional
sampling may be required by the TCEQ.
A. The permit holder shall submit a performance test protocol to the TCEQ no later than 30 days
prior to the test to allow review of the test plan and to arrange for an observer to be present
at the test. The performance test shall be conducted in accordance with the submitted
protocol, and any changes required by the TCEQ.
B. Performance tests shall be conducted under such conditions to ensure representative
performance of the affected facility. The permit holder shall make available to the TCEQ such
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records as may be necessary to determine the conditions of the performance test.
C. The owner or operator shall provide the TCEQ at least 30 days prior notice of any
performance test, except as specified under other Subparts, to afford the TCEQ the
opportunity to have an observer present and/or to attend a pre-test meeting. If there is a
delay in the original test date, the permit holder shall provide at least 7 days prior notice of
the rescheduled date of the performance test.
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D. The permit holder shall provide, or cause to be provided, performance testing facilities as
follows
(1) Sampling ports adequate for test methods applicable to this facility,
(2) Safe sampling platform(s),
(3) Safe access to sampling platform(s), and
(4) Utilities for sampling and testing equipment.
E. Unless otherwise specified in this permit, each performance test shall consist of three
separate runs using the applicable test method. Each run shall be conducted under the
conditions specified in the applicable test method. For purposes of determining compliance
with an applicable test method, the arithmetic mean of the results of the three runs shall
apply.
F. The permit holder shall determine if a compliance strategy is required as follows:
Special Conditions
Page 21
(1) Multiply the CO2 hourly average emission rate determined during the initial
performance test while operating under maximum operating test conditions by 8,760
hours; If the calculated CO2 emission total does not exceed the tons per year (TPY)
specified the MAERT, no compliance strategy needs to be developed. If the calculated
CO2 emission total exceeds the tons per year (TPY) specified in the MAERT, the
facility shall;
(a) Document the exceedance in the test report; and
(b) Explain within the report how the facility will assure compliance with the CO2
emission limit listed in the MAERT.
G. Emissions testing, as outlined above, shall be performed every three years, or more
frequently if identified above, to verify continued performance with the permitted emission
limits.
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Date: DRAFT
AF
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D
Emission Sources - Maximum Allowable Emission Rates
This table lists the maximum allowable emission rates and all sources of air contaminants on the applicant’s property
covered by this permit. The emission rates shown are those derived from information submitted as part of the application
for permit and are the maximum rates allowed for these facilities, sources, and related activities. Any proposed increase
in emission rates may require an application for a modification of the facilities covered by this permit.
Air Contaminants Data

Emission Point No. (1) Source Name (2) Air Contaminant Name (3) Emission Rates (6)
lbs/hour TPY (4)
1 Dock Ore Unloading PM 0.28 1.22

and Product Loading
Gantry Crane (5)
PM10 0.13 0.58
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PM2.5 0.02 0.09
4A Oxide Unloading PM 0.07 0.31

Transfer Fabric Filter
Stack AF PM10 0.07 0.31
PM2.5 0.05 0.23
4B Oxide Unloading and PM 0.07 0.31

Product Loading
Fabric Filter Stack
PM10 0.07 0.31
PM2.5 0.05 0.23
5A Oxide Pellet Transfer PM 0.07 0.31

(Pre-Storage) Fabric
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Filter Stack
PM10 0.07 0.31
PM2.5 0.05 0.23
5B Oxide Pellet Transfer PM 0.07 0.31

(Post-Storage) Fabric
Filter Stack
D
PM10 0.07 0.31
PM2.5 0.05 0.23
6 Oxide Pellet Transfer PM 0.05 0.22

(Post-Storage) Fabric
Filter Stack PM10 0.05 0.22
PM2.5 0.04 0.17
Project Number: 302181

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7A Oxide Day Bin Filling PM 0.13 0.57

Fabric Filter Stack
PM10 0.13 0.57
PM2.5 0.10 0.43
7B Oxide Day Bin PM 0.64 2.82

Discharge Fabric Filter
Stack
PM10 0.64 2.82
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PM2.5 0.48 2.12
7C Oxide Day Bin Off PM 0.12 0.53

Spec Fabric Filter
Stack
PM10 0.12 0.53
7D
AF
Oxide Tower Transfer
Fabric Filter Stack
PM2.5
PM
PM10
0.09
0.05
0.05
0.40
0.22
0.22
PM2.5 0.04 0.17
16 Furnace Charge PM 0.01 <0.01

Hopper Loading Silos
Fabric Filter Stack
PM10 0.01 <0.01
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PM2.5 0.01 <0.01
17 Charge Hopper Wet PM 0.13 0.59

Scrubber Stack
PM10 0.13 0.59
D
PM2.5 0.10 0.44
NOx 2.02 8.84
SO2 0.25 1.10
CO 1.83 8.03
VOC 0.18 0.81
NH3 0.02 0.10

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29 Reformer Main Flue PM 14.82 64.92

Ejector Stack
PM10 12.72 55.72
PM2.5 12.72 55.72
NOx 83.96 367.74
SO2 10.48 32.10
CO 76.33 334.31
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VOC 7.69 33.67
n-Hexane 0.41 1.80
8 Furnace Dedusting PM 2.50 10.95

(BSG Dust Collection)
AF
Wet Scrubber Stack
PM10 2.50 10.95
PM2.5 0.50 2.19
NOx 2.02 8.84
SO2 0.25 1.10
CO 1500.00 6570.00
VOC 0.18 0.81

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NH3 0.65 2.85
38 Hot Pressure Relief PM 0.63 0.10

Vent (Flare)
PM10 0.63 0.10
D
PM2.5 0.63 0.10
NOx 33.71 6.16
SO2 0.03 0.01
CO 622.27 104.37
VOC 0.29 0.06
Pb <0.01 <0.01

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9 Briquetter Dedusting PM 3.97 17.38

Scrubber Stack
PM10 3.97 17.38
PM2.5 0.79 3.48
NOx 1.01 4.42
SO2 0.13 0.55
CO 0.92 4.02
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VOC 0.09 0.40
NH3 1.77 7.73
11 HBI Cooling Conveyer PM 1.90 8.34

Scrubber Stack
AF PM10 1.90 8.34
PM2.5 0.95 4.17
NH3 8.01 35.11
14 HBI Pile (5) PM 0.32 1.39
PM10 0.13 0.56
PM2.5 0.04 0.16

R
36 Remet/Fines Storage PM 0.17 0.74
(5)
PM10 0.04 0.20
PM2.5 0.01 0.02

D
30a Process Water

Degasser (5) CO 21.72 95.13
NH3 2.78 12.18
H2S 0.01 0.06
30b Process Water

Degasser (5) CO 2.54 11.11
NH3 0.14 0.61
H2S 0.01 0.05
33 Salt Water Cooling PM 13.91 60.91

Project Number: 302181 Tower (5)
PM10 0.06 0.28
Page
39 Paved Road Fugitive PM - 1.08

Dust (5)
PM10 - 0.21
PM2.5 - 0.03
34 Emergency Generator PM 0.47 0.02
PM10 0.47 0.02
PM2.5 0.47 0.02
T
NOx 32.09 1.60
SO2 0.04 <0.01
CO 3.80 0.19
35
AF
Fire Pump
VOC
PM
PM10
0.99
0.03
0.03
0.05
<0.01
<0.01
PM2.5 0.03 <0.01
NOx 2.25 0.11
SO2 <0.01 <0.01

R
CO 0.27 0.01
VOC 0.07 <0.01
BFL-1 FPR Bag Filter Stack PM 0.98 4.29

and Dryer Exhaust
D
PM10 0.51 2.25
PM2.5 0.24 1.05
NOx 1.56 6.82
SO2 0.01 0.04
CO 1.31 5.73
VOC 0.09 0.38
BVF-1 FRP Bin Vent Filter 1 PM 0.09 0.07

(Solid Binder Bin) (7)
PM10 0.04 0.03
PM2.5 0.01 0.01
BVF-2 FRP Bin Vent Filter 2 PM <0.01 <0.01

Page
PM2.5 <0.01 <0.01
BVF-3 FRP Bin Vent Filter 3 PM <0.01 <0.01

(Pellet Dust Bin) (8)
PM10 <0.01 <0.01
PM2.5 <0.01 <0.01
DP-2 FRP Briquette Curing PM 0.07 0.30

Bin (Drop Point 2) (8)
PM10 0.03 0.14
T
PM2.5 <0.01 0.02
ALL All Sources All HAPS - 2.05
NOx
SO2
PM
AF
(1) Emission point identification - either specific equipment designation or emission point number from plot plan.
(2) Specific point source name. For fugitive sources, use area name or fugitive source name.
(3) VOC - volatile organic compounds as defined in Title 30 Texas Administrative Code § 101.1
- total oxides of nitrogen
- sulfur dioxide
- total particulate matter, suspended in the atmosphere, including PM10 and PM2.5, as represented
PM10 - total particulate matter equal to or less than 10 microns in diameter, including PM2.5, as
represented
PM2.5 - particulate matter equal to or less than 2.5 microns in diameter
CO - carbon monoxide
NH3 - ammonia
H2S - hydrogen sulfide
R
n-Hexane - n-Hexane
Pb - lead
HAP - hazardous air pollutant as listed in § 112(b) of the Federal Clean Air Act or Title 40 Code of
Federal Regulations Part 63, Subpart C
(4) Compliance with annual emission limits (tons per year) is based on a 12-month rolling period.
(5) Emission rate is an estimate and is enforceable through compliance with the applicable special condition(s) and
permit application representations.
D
(6) Planned startup and shutdown emissions are included. Maintenance activities are not authorized by this permit and
will need separate authorization unless the activity can meet the conditions of 30 TAC 116.119.
(7) Particulate matter emissions are from bentonite.
(8) Particulate matter emissions are from iron oxide.
Date: DRAFT

Permit Number 108113, PSDTX1344M2 and GHGPSDTX43
This table lists the maximum allowable emission rates of greenhouse gas (GHG) emissions, as defined in Title 30 Texas
Administrative Code § 101.1, for all sources of GHG air contaminants on the applicant’s property that are authorized by
this permit. The emission rates shown are those derived from information submitted as part of the application for permit
and are the maximum rates allowed for these facilities, sources, and related activities. Any proposed increase in emission
rates may require an application for a modification of the facilities authorized by this permit.
Air Contaminants Data

Emission Point No. (1) Source Name (2) Air Contaminant Emission Rates
Name (3)
TPY (4)
17 Charge Hopper Fabric Filter Stack CO2 (5) 57,567.63
CH4 (5) 1.10
T
N2O (5) 0.31
AF CO2e 57,686.71
29 Reformer Main Flue Ejector Stack CO2 (5) 1,674,797.96

CH4 (5) 32.10
R
N2O (5) 8.93
CO2e 1,678,262.28
8 Furnace Dedusting (BSG Dust CO2 (5) 57,567.63
Collection) Wet Scrubber Stack
CH4 (5) 1.10
D
N2O (5) 0.31

CO2e 57,686.71
38 Hot Pressure Relief Vent (Flare) CO2 (5) 6,876.22
CH4 (5) 17.11
N2O (5) <0.01
CO2e 7,304.31
9 Briquetter Dedusting Scrubber CO2 (5) 28,783.82
Stack
CH4 (5) 0.55
N2O (5) 0.15
CO2e 28,843.36
Page
30a Process Water Degasser (5) CO2 (5) 1,468.00

CH4 (5) 13.52
CO2e 1,806.03
30b Process Water Degasser (5) CO2 (5) 193.16
CH4 (5) 1.93
CO2e 241.45
34 Emergency Generator CO2 (5) 196.54
CH4 (5) <0.01
T
N2O (5) <0.01
CO2e 197.23
35 Fire Pump CO2 (5) 12.83
AF CH4 (5) <0.01
N2O (5) <0.01
CO2e 12.88
FUGGHG Methane Containing Piping CO2 (5) --
Fugitives
CH4 (5) 4.01
CO2e 100.33
(1) Emission point identification - either specific equipment designation or emission point number from plot plan.
R
(2) Specific point source name. For fugitive sources, use area name or fugitive source name.
(3) CO2 - carbon dioxide
N2O - nitrous oxide
CH4 - methane
HFCs - hydrofluorocarbons
PFCs - perfluorocarbons
SF6 - sulfur hexafluoride
D
CO2e - carbon dioxide equivalents based on the following Global Warming Potentials (1/2015):
CO2 (1), N2O (298), CH4(25), SF6 (22,800), HFC (various), PFC (various)
(4) Compliance with annual emission limits (tons per year) is based on a 12-month rolling period. These rates include
emissions from maintenance, startup, and shutdown.
(5) Emission rate is given for informational purposes only and does not constitute enforceable limit.
Date: DRAFT

Preliminary Determination Summary
voestalpine Texas LLC
I. Applicant
Voestalpine Texas LLC
2800 Kay Bailey Hutchison Rd
Portland, TX 78374-7400
II. Project Location

Direct Reduced Iron Hot Briquetting Facility
2800 Kay Bailey Hutchison Road
San Patricio County
Portland, Texas 78374
III. Project Description
voestalpine Texas, LLC, submitted an amendment request for their state issued NSR and PSD
permit to reflect as-built conditions at their facility and increase permitted emission rates to be
consistent with those found during source testing. In addition, the applicant has requested to
incorporate their EPA issued GHG PSD Permit and numerous, existing Permit by Rule (PBR)
authorizations. Greenhouse emissions are authorized under GHG Permit No. GHGPSDTX43.
Planned startup and shutdown emissions were previously authorized under the NSR and PSD
permit. The applicant has represented emissions from routine maintenance are authorized under
PBR No. 106.263 or claimed under 30 Texas Administrative Code § 116.119, De Minimis
Facilities or Sources.
IV. Emissions
Air Contaminant Proposed Allowable Emission Rates (tpy)
VOC 36.19
NOx 404.56
SO2 34.92
CO 7132.90
PM 177.94
PM10 102.99
PM2.5 75.02
H2S 0.11
NH3 58.58
n-hexane 1.80
Pb <0.01
HAPs 2.05
Permit Numbers: 108113, PSDTX1344M2, and GHGPSDTX43
Page 2
CO2 1,827,463.79
CH4 71.44
N2O 9.73
CO2 Equivalents
1,832,141.29
(CO2e)
CO2e - carbon dioxide equivalents based on global warming potentials of

CH4 = 25, N2O = 298, SF6=22,800.
V. Federal Applicability
The following chart illustrates the annual project emissions for each pollutant and whether this
pollutant triggers PSD or Nonattainment (NA) review.
Pollutant Project Major Mod NA PSD Triggered

Emissions Trigger Triggered Y/N
(tpy) (tpy) Y/N
25 for NA
VOC 0.04 No No
40 for PSD
25 for NA No No
NOx 3.20
40 for PSD
No No
SO2 0.12 40
CO 2929.37 100 No Yes
PM 96.17 25 No Yes
PM10 37.50 15 No Yes
PM2.5 37.46 10 No Yes
H2S 0.11 10 No No
San Patricio County is in attainment or unclassified for all criteria pollutants. The facility is an
unnamed major source. The proposed project constitutes a major modification at an existing
major source for PSD because the total projected increases of CO and particulates were greater
than their corresponding significance levels; therefore, PSD review was applicable for non-GHG
NSR regulated pollutants. As shown in the table below, because the project increases of CO2e
are less more than 75,000 tpy, PSD review was not triggered for GHG emissions.
Major Source or Major Mod

Pollutant Project Emissions (tpy) PSD Triggered Y/N
Trigger Level (tpy)
CO2e 4,414.54 75,000 No

Page 3
VI. Control Technology Review

A Best Available Control Technology (BACT) evaluation was conducted for each criteria pollutant
emitted from each of the modified emission sources at the Portland facility. Each of these
evaluations, which follow TCEQ Tier I presumptive BACT or a full Tier Ill evaluation for technical
feasibility and cost effectiveness, is described below.
Process Water Degasser (EPNs 30a and 30b)
Direct contact coolers provide much of the gas cooling in the DRI plant. The gases being cooled
are under pressure, so a portion of the CO, C02, NH3, and H2S are absorbed into the cooling water.
Due to the direct contact of process water with CO and process gases, some gas constituents are
dissolved in process water in the top of the top of the gas scrubber that is at an elevated process
gas pressure.
In order to reduce the fugitive emissions at the clarifier and to reduce scaling in process water
ducts, a forced degassing unit will be installed. The process water degasser will use pressurized
air to strip the process water of the dissolved gases prior to the clarifier. During this degassing
process, CO, C02, NH3, and H2S are released. However, the flow and concentration of these
compounds are irregular since entry to and from the pressurized DRI process is episodic in
nature.
This section performs a detailed, step-by-step BACT analysis for control of NH3 and H2S
emissions from the process water degasser at the voestalpine facility. There are no changes to
CO emissions for this source with this amendment, so there is no change needed in the CO
BACT analysis.
Proposed Emissions Reduction Option and Review of BACT Methods
Emissions of NH3 from the process water degassers are 2.92 lb/hr and 12.79 tpy and emissions
of H2S from the process water degassers are 0.02 lb/hr and 0.11 tpy. voestalpine proposes BACT
for NH3 and H2S as good design methods and good operating practices for the process water
degassers.
Tier I Analysis for the BACT Proposal
TCEQ has not published a Tier I BACT NH3 and H2S for routine or maintenance, startup, and
shutdown (MSS) emissions from a DRI process water degasser. voestalpine has reviewed the
TCEQ's current BACT guidelines for process vents and found that the minimum acceptable
control is a flare, any oxidizer, adsorber, absorber/scrubber, etc., and appropriate control device
efficiency will be required. Therefore, voestalpine conducted a detailed search in the USEPA's
RACT/BACT/LAER Clearinghouse (RBLC) database. No established BACT was found for NH3
and H2S emissions from water degassers in the RBLC. Therefore, to demonstrate BACT, a Tier Il
analysis was considered.
Tier II Analysis for the BACT Proposal
While there was no established BACT for NH3 and H2S, a review of previously accepted BACT
emission reduction levels for CO emissions from sources in other process/industry types found
that the generally accepted emissions reduction level regardless of industry type could vary.
Therefore, to evaluate BACT, a Tier Ill analysis was considered.
Tier III Analysis for the BACT Proposal

Page 4
Step 1 — Identify Potential Control Technologies

A search of USEPA's RBLC database revealed no entries for the control of NH3 and H2S
emissions from the process water streams at DRI plants.
The following list of control technologies represent technologies that could be used for the control
of NH3 and H2S emissions from process water streams.
1. Flare
2. Good Design Methods and Good Operating Practices
Flare
Flaring is a direct combustion control process that is used for the destruction of combustible
gases, normally VOCs and H2S. Typically, flares are used to control emissions from intermittent
sources or emergency relief vents; however, flares are receiving increasing use on continuous
operating sources. Flares are capable of achieving high levels of VOC and H2S destruction if
proper attention is paid to combustion process control.
Good Design Methods and Good Operating Practices
Good design methods and good operating practices can be used to reduce emissions of NH3 and
H2S in the process water degassers. By employing good operating practices, NH3 and H2S
emissions may be greatly reduced.
Step 2 — Eliminate Technically Infeasible Options
Both control methods outlined in Step 1 are technically feasible.
Step 3 — Rank Remaining Technically Feasible Control Options
1. Flare -98%
2. Good Design Methods and Good Operating Practices — 50%
Step 4 — Evaluate Remaining Control Technologies
Flare
Direct combustion of the NH3 and H2S in a flare or similar could be a viable technology; however,
the concentration of NH3 and H2S are only 0.005% (50 ppm) and 0.00005% (0.5 ppm) of the
exhaust stream, while water vapor is 26.8% of the exhaust stream, with the remainder being
primarily air. Because of the low contaminant concentrations in the exhaust gas, and the low
heating value of that gas, a significant amount of fuel gas would need to be added to ensure
complete combustion and overcome the water content of the exhaust gas. Secondarily
combustion of ammonia would result in a commensurate increase in NOX emissions, which has
its own environmental impact as a precursor to ground-level ozone formation. Because of the
secondary environmental impact and the significant cost and emissions associated with all the
additional fuel gas required to combust the trace amounts of NH3 and H2S in the exhaust, the
flare is not considered a practical option for controlling emissions from the process water
degasser.
Good Design Methods and Good Operating Practices

Page 5
Good design methods and the use of good operating practices (including pH control and other
water treatment) can be relatively effective at reducing NH3 and H2S emissions generated from
the process water degassers.
Step 5 - Selection of BACT
BACT for NH3 and H2S from the process water degassers is proposed as good design methods
and the use of good operating practices.
Cooling Tower (EPN 33)
TCEQ Tier I BACT for PM emissions from cooling towers is identified as a drift rate of 0.0005%,
and the installed cooling tower meets this BACT limit. As such, voestalpine is requesting no
change to the currently established BACT in its existing permit.
Furnace Deduster (EPN 8)
CO is present in seal gas that is emitted from the seal gas vents because it is simply reformer
flue gas diverted for retaining the reducing gas within the reduction furnace. Control of CO from
the seal gas vents is most appropriately addressed at combustion within the reformer. This
section performs a detailed, step-by-step BACT analysis for control of CO emissions from the
seal gas vents at the voestalpine facility.
Proposed Emissions Reduction Option and Review of BACT Methods
voestalpine is proposing a CO BACT of no additional control for the seal gas vents. BACT for CO
was already determined as good combustion practices for the reformer flue gas, and no
additional control is feasible for the use of a small portion of this flue gas used as seal gas.
Tier I Analysis for the BACT Proposal
TCEQ has not published a Tier I BACT for CO emissions from a DRI seal gas vent. voestalpine
has reviewed the TCEQ's current BACT guidelines for process vents and found that the minimum
acceptable control is a flare, any oxidizer, adsorber, absorber/scrubber, etc., and appropriate
control device efficiency will be required. The TCEQ's current MSS BACT requirements are the
same as BACT requirements.
In the previous permit application, the flaring and oxidation technologies were determined to be
technologically and economically infeasible due to the high dust loading in the gas stream and the
difficulty in controlling CO emissions at the concentration they are at in the duct, without adding
significant fuel gas. As such, they are not being considered with this amendment.
Therefore, voestalpine has conducted a detailed search in the USEPA's RBLC database.
Documentation found in this research is presented in Table 1 below.
The BACT identified for CO emissions from the seal gas vent at a similar DRI plant (Cleveland-
Cliffs) was replacing the seal gas blanket on the DRI with a Nitrogen blanket. This blanket would
have the direct impact of eliminating the CO emissions associated with the blanket gas
(approximately 60%). This facility has not been constructed yet and the technology has not been
demonstrated long term at a full-scale basis at the facility in the RBLC database.
Tier II Analysis for the BACT Proposal
A review of previously accepted BACT emission reduction levels for CO emissions from sources
in other process/industry types found that the generally accepted emissions reduction level
Page 6
regardless of industry type can vary widely. Therefore, to demonstrate BACT, a Tier Ill analysis
was considered.
Tier III Analysis for the BACT Proposal
Step 1 — Identify Potential Control Technologies
A search of recently issued permits for HBI plants noted that one facility was authorized in 2018,
the IronUnits LLC — Toledo HBI facility identified below.
Table 1. Summary of RBLC Data for CO Emissions from the Seal Gas Vents at DRI Plants.
RBLC ID Number Control Type and
Process Description Emission Limits
Company, Date Efficiency
IronUnits LLC - Seal Gas BACT-PSD: CO Limit
Toledo HBI Toledo, Vents/Bottom Seal 43.00 lb/hr and Nitrogen Seal Gas
OH 02/09/2018 Gas 188.34 tpy
The following list of control technologies represent technologies that have been used for the
control of CO emissions from the seal gas vent:
1. Nitrogen Bottom Gas Seal

2. Good Combustion Practices
Nitrogen Bottom Gas Seal
The nitrogen bottom gas seal is used to replace the process gas commonly used at other HBI
plants. The process gas contains primarily C02 and water vapor, but also approximately 1 wt%
CO. By replacing the process gas with Nitrogen on the bottom seal, CO emissions from EPN 8
would be reduced by approximately 60%. Emissions of CO would still occur through off-gassing
from the DRI pellets, and this off-gassing from the pellets represents approximately 40% of the
CO emissions.
Good Combustion Practices
Good combustion practices are used to reduce emissions of carbon monoxide, as well as other
pollutants, by optimizing conditions in the combustion zone of a fuel-burning source. CO
emissions from the burning of fuels are usually due to the incomplete combustion of hydrocarbon
fuel. Good combustion practices typically entail introducing the proper ratio of combustion air to
the fuel, maintaining a minimum temperature in the firebox of the combustor, or a minimum
residence time of fuel and air in the combustion zone. By employing good combustion practices,
CO emissions may be greatly reduced.
Step 2 — Eliminate Technically Infeasible Options
Good combustion practices is technically feasible and has not been eliminated.
Replacing the bottom seal gas with nitrogen has not been demonstrated at full scale operation at
an HBI production plant. Therefore, it should not be considered established BACT until it has
been proven in practice.
Step 3 — Rank Remaining Technically Feasible Control Options
1. Good Combustion Practices - 50%

Page 7
Step 4 — Evaluate Remaining Control Technologies
Good Combustion Practices

Good combustion practices can be relatively effective at reducing CO emissions generated from
the incomplete combustion of hydrocarbon or CO fuels, because the technique maximizes
combustion within the unit. The combustible components of the top gas fuel used in the reformer
are primarily of CO and hydrogen, mixed with a quantity of natural gas to provide stable
combustion characteristics and the necessary heat input to the unit. Good combustion practices
will aim to completely combust the CO in the fuel.
Step 5 - Selection of BACT
voestalpine is proposing no additional control for the seal gas vents. BACT for CO was already
determined as good combustion practices for the reformer flue gas, and no additional control is
feasible for the use of a small portion of this flue gas used as seal gas.
Reformer Main Flue Ejector Stack (EPN 29)
The existing BACT limits for the various pollutants emitted from the Reformer are as follows:
• PM: 0.044 gr/dscf for the process gas used as fuel using a high-energy wet scrubber on
the process gas before combustion and good combustion practices.
• SO: 0.002 lb/MMBtu purchase of natural gas containing no more than 21000 gr
sulfur/MMscf.
• NOx: 0.058 lb/MMBtu and the use of low-NOx burners.
• CO: 0.078 lb/MMBtu and good combustion practices.
• VOC: 0.005 lb/MMBtu and good combustion practices.
With this amendment, there will be no physical changes made to the equipment. The only change
is to include the contribution from combustion particulate in the PM/PM10/PM2.5 emission rates.
As such, voestalpine requests the same existing BACT for PM.
Hot Pressure Relief Vent Flare (EPN 38)
For vent gas control, flares are identified as a possible control option and a flare was approved as
VOC BACT for the initial permitting of this facility. With this project, voestalpine requests no
change to the established BACT of a flare to control this process vent. For PM, CO, and NOX for
the flare, BACT is established as good combustion practices and the use of a low-Nitrogen fuel
gas. Since there were no physical changes to the flare approved with this permitting action,
Voestalpine is requesting that this BACT of good combustion practices and low-nitrogen fuel be
maintained as BACT.
Charge Hopper (EPN 17)
During design, it was found that the hot gases flowing would damage the fabric filter. Due to
these operational issues, it was recommended to utilize a wet scrubber dust collection system to
control dust emissions. The wet scrubber discharge will have a PM concentration of at 18
mg/Nm3 (0.0079 gr/dscf), which exceeds the current TCEQ Tier I BACT of 0.01 gr/dscf for
particulate control. As such, voestalpine is proposing as BACT the use of a wet scrubber with an
outlet grain loading of 0.0079 gr/dscf.
Page 8
Fines Recycling Plant (EPN BFL-1, BVF-1, 2, & 3)
The current TCEQ Tier I BACT for PM emissions from solid material handling includes dust
collectors that meet an outlet grain loading of 0.01 gr/dscf. The dust collectors on these sources
all exceed this requirement, with an outlet loading of 0.002 gr/dscf. As such, voestalpine requests
the BACT for these sources be established at the outlet grain loading rate of 0.002 gr/dscf.
VII. Air Quality Analysis
The air quality analysis (AQA) is acceptable for all review types and pollutants. The results are
summarized below.
A. De Minimis Analysis
A De Minimis analysis was initially conducted to determine if a full impacts analysis would
be required. The De Minimis analysis modeling results indicate that 1-hr and 8-hr CO
exceed the respective de minimis concentrations and require a full impacts analysis. The
De Minimis analysis modeling results for 24-hr and annual PM10 and 24-hr and annual
PM2.5 (NAAQS and Increment) indicate that the project is below the respective de minimis
concentrations and no further analysis is required.
The PM2.5 De Minimis levels are the EPA recommended De Minimis levels. The use of the
EPA recommended De Minimis levels is sufficient to conclude that a proposed source will
not cause or contribute to a violation of a PM2.5 NAAQS or PM2.5 PSD increments based on
the analyses documented in EPA guidance and policy memoranda1.
While the De Minimis levels for both the NAAQS and increment are identical for PM2.5 in the
table below, the procedures to determine significance (that is, predicted concentrations to
compare to the De Minimis levels) are different. This difference occurs because the
NAAQS for PM2.5 are statistically based, but the corresponding increments are exceedance-
based.
Table 2. Modeling Results for PSD De Minimis Analysis in Micrograms Per Cubic
Meter (µg/m3)
Averaging De Minimis
Pollutant GLCmax (µg/m3)
Time (µg/m3)
PM10 24-hr 1.30 5
PM10 Annual 0.20 1
PM2.5 (NAAQS) 24-hr 0.64 1.2
PM2.5 (NAAQS) Annual 0.14 0.2
PM2.5 (Increment) 24-hr 0.73 1.2
PM2.5 (Increment) Annual 0.15 0.2
1
www.tceq.texas.gov/permitting/air/modeling/epa-mod-guidance.html
Page 9
CO 1-hr 2073 2000
CO 8-hr 688 500
The 24-hr and annual PM2.5 (NAAQS) GLCmax are based on the highest five-year
averages of the maximum predicted concentrations determined for each receptor. The
GLCmax for all other pollutants and averaging times represent the maximum predicted
concentrations over five years of meteorological data.
To evaluate secondary PM2.5 impacts, the applicant provided an analysis based on a Tier 1
demonstration approach consistent with the EPA’s Guideline on Air Quality Models.
Specifically, the applicant used a Tier 1 demonstration tool developed by the EPA referred
to as Modeled Emission Rates for Precursors (MERPs). The basic idea behind the MERPs
is to use technically credible air quality modeling to relate precursor emissions and peak
secondary pollutants impacts from a source. Using data associated with the worst-case
hypothetical source, the applicant estimated 24-hr and annual secondary PM2.5
concentrations of 0.01 µg/m3 and 0.0002 µg/m3, respectively. When these estimates are
added to the GLCmax listed in the table above, the results are less than the De Minimis
levels.
B. Air Quality Monitoring
The De Minimis analysis modeling results indicate that 8-hr CO exceeds the respective
monitoring significance level and requires the gathering of ambient monitoring information.
The De Minimis analysis modeling results indicate that 24-hr PM10 is below its respective
monitoring significance level.
Table 3. Modeling Results for PSD Monitoring Significance Levels

Pollutant Averaging Time GLCmax (µg/m3) Significance (µg/m3)
PM10 24-hr 1.30 10
CO 8-hr 688 575
The GLCmax for all pollutants and averaging times represent the maximum predicted
concentrations over five years of meteorological data.
The applicant evaluated ambient CO and PM2.5 monitoring data to satisfy the requirements
for the pre-application air quality analysis.
Background concentrations for CO were obtained from the EPA AIRS monitor 482450628
located at Port Arthur, Jefferson County. The high second high (H2H) 1-hr concentration
from the most recent three years of monitoring data (2017-2019) was used for the 1-hr and
8-hr value (1031 µg/m3). Using the H2H 1-hr concentration for the 8-hr averaging time is
conservative. The use of this monitor is reasonable based on a comparison of county-wide
emissions, population, and land use.
Background concentrations for PM2.5 were obtained from the EPA AIRS monitor 483550032
located at 3810 Huisache St., Corpus Christi, Nueces County. The applicant calculated a
Page 10
three-year average (2016-2018) of the 98th percentile of the annual distribution of 24-hr
average concentrations for the 24-hr value (26 µg/m3). The applicant calculated a three-
year average (2016-2018) of the annual concentrations for the annual value (8.6 µg/m3).
The use of this monitor is reasonable based on a comparison of county-wide emissions,
population, and land use.
The background concentrations for CO noted above were also used in the NAAQS
analysis.
C. National Ambient Air Quality Standards (NAAQS) Analysis
The De Minimis analysis modeling results indicate that 1-hr and 8-hr CO exceed the
respective de minimis concentration and require a full impacts analysis. The full NAAQS
modeling results indicate the total predicted concentrations will not result in an exceedance
of the NAAQS.
Table 4. Total Concentrations for PSD NAAQS (Concentrations > De Minimis)

Total Conc. =
Averaging GLCmax Background [Background + Standard
Pollutant
Time (µg/m3) (µg/m3) GLCmax] (µg/m3)
3
(µg/m )
CO 1-hr 3177 1031 4208 40000
CO 8-hr 1574 1031 2605 10000
The GLCmax are the maximum H2H predicted concentrations across five years of
meteorological data.
The De Minimis analysis modeling results indicate that 24-hr PM10 and 24-hr and annual
PM2.5 (NAAQS) are less than the de minimis concentrations and no further analysis is
required.
D. Increment Analysis
The De Minimis analysis modeling results indicate that PM2.5 (Increment) and PM10 are less
than the respective de minimis concentrations and no further analysis is required. PSD
increments do not exist for CO.
E. Additional Impacts Analysis
The applicant performed an Additional Impacts Analysis as part of the PSD AQA. The
applicant conducted a growth analysis and determined that population will not significantly
increase as a result of the proposed project. The applicant conducted a soils and
vegetation analysis and determined that all evaluated criteria pollutant concentrations are
below their respective secondary NAAQS. The applicant meets the Class II visibility
analysis requirement by complying with the opacity requirements of 30 TAC Chapter 111.
The Additional Impacts Analyses are reasonable and possible adverse impacts from this
project are not expected.
The ADMT evaluated predicted concentrations from the proposed project to determine if
emissions could adversely affect a Class I area. The nearest Class I area, Big Bend
National Park, is located approximately 605 kilometers (km) from the proposed site.
Page 11
The predicted concentrations of SO2, PM10, PM2.5, and NO2 for all averaging times, are all
less than de minimis levels at a distance of 0.6 km from the proposed sources in the
direction of the Big Bend National Park Class I area. The Big Bend National Park Class I
area is an additional 604.4 km from the location where the predicted concentrations of SO2,
PM10, PM2.5, and NO2 for all averaging times are less than de minimis. Therefore, emissions
from the proposed project are not expected to adversely affect the Big Bend National Park
Class I area.
F. Minor Source NSR and Air Toxics Review
Table 5. Project-Related Modeling Results for State Property Line

Pollutant Averaging Time GLCmax (µg/m3) De Minimis (µg/m3)
SO2 1-hr 0.03 20.42
H2S 1-hr 0.7 2
Table 5. Modeling Results for Minor NSR De Minimis

Pollutant Averaging Time GLCmax (µg/m3) De Minimis (µg/m3)
SO2 1-hr 0.03 7.8
SO2 3-hr 0.03 25
NO2 1-hr 3.9 7.5
NO2 Annual 0.1 1
The 1-hr SO2 and 1-hr NO2 GLCmax are based on the highest five-year averages of the
maximum predicted concentrations determined for each receptor. The GLCmax for 3-hr
SO2 and annual NO2 are the maximum predicted concentrations associated with five years
of meteorological data.
The primary NAAQS for 24-hr and annual SO2 have been revoked for San Patricio County
and are not reported above.
The justification for selecting the EPA’s interim 1-hr NO2 and 1-hr SO2 De Minimis levels
was based on the assumptions underlying EPA’s development of the 1-hr NO2 and 1-hr
SO2 De Minimis levels. As explained in EPA guidance memoranda2,3, the EPA believes it is
reasonable as an interim approach to use a De Minimis level that represents 4% of the 1-hr
NO2 and 1-hr SO2 NAAQS.
Table 6. Minor NSR Site-wide Modeling Results for Health Effects

Pollutant & Averaging GLCmax GLCmax
ESL (µg/m3)
CAS# Time (µg/m3) Location
2
www.epa.gov/sites/production/files/2015-07/documents/appwso2.pdf
3
www.tceq.texas.gov/assets/public/permitting/air/memos/guidance_1hr_no2naaqs.pdf
Page 12
ammonia Southern
1-hr 74 180
7664-41-7 Property Line
The applicant provided pollutant specific modeling for ammonia, which included both
production and MSS emissions to compare to the ESL. The GLCmax location is listed in
Table 3, above.
G. Greenhouse Gases
EPA has stated that unlike the criteria pollutants for which EPA has historically issued PSD
permits, there is no National Ambient Air Quality Standard (NAAQS) for GHGs, including no
PSD increment. The global climate-change inducing effects of GHG emissions, according
to the “Endangerment and Cause or Contribute Finding”, are far-reaching and multi-
dimensional (75 FR 66497). Climate change modeling and evaluations of risks and impacts
are typically conducted for changes in emissions that are orders of magnitude larger than
the emissions from individual projects that might be analyzed in PSD permit reviews.
Quantifying the exact impacts attributable to a specific GHG source obtaining a permit in
specific places and points would not be possible [EPA’s PSD and Title V Permitting
Guidance for GHGs at 48]. Thus, EPA has concluded in other GHG PSD permitting actions
it would not be meaningful to evaluate impacts of GHG emissions on a local community in
the context of a single permit.
The TCEQ has determined that an air quality analysis would provide no meaningful data
and has not required the applicant to perform one. As stated in the preamble to TCEQ’s
adoption of the GHG PSD program, the impacts review for individual air contaminants will
continue to be addressed, as applicable, in the state's traditional minor and major NSR
permits program per 30 TAC Chapter 116.
VIII. Conclusion
The applicant demonstrated the project meets all applicable rules, regulations and requirements
of the Texas and Federal Clean Air Acts. An amended air permit should be issued.

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TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

NOTICE OF APPLICATION AND PRELIMINARY DECISION

AIR QUALITY PERMIT NUMBERS 108113, PSDTX1344M2, AND GHGPSDTX43

Notice Issuance Date: June 7, 2021

1. This permit authorizes only those sources of

2. Fuel shall be limited as specified and use of any

3. Upon request by the Executive Director of the

the holder of this permit shall provide a sample

4. The emergency generator and fire pump engines

5. The emergency generator and fire pump engines

A. Subpart A - General Provisions; and

6. Opacity of particulate matter emissions from the

7. Opacity of particulate matter emissions from the

8. There shall be no visible fugitive emissions leaving

9. Plant operations and production shall be limited to

11. Fabric filter baghouses designed to meet an outlet

Plant: cyclone separator, briquetting plant, dosing

13. Bin vent filters designed to meet and outlet grain

14. A wet scrubber designed to meet an outlet grain

15. The HBI conveyors shall employ water sprays to

16. The reformer shall be equipped with low NOx

Table 1: Reformer Emission Limits

PM, PM10, and PM2.5 20 mg/Nm3 dry at 3% O2 1-day hourly average

CO 173 mg/Nm3 dry at 3% O2 1-day hourly average

VOC (as total hydrocarbons) 11 mg/Nm3 dry at 3% O2 1-day hourly average

NOx 110 mg/Nm3 dry at 3% O2 30-day continuous average

17. During startup and shutdown, the reduction

18. Dock ore unloading operations shall employ

19. All conveyors at the Fines Recycling Plant shall be

20. The following sources shall employ hooded

22. Iron ore shall be stored in enclosed storage.

23. Replaced or used fabric filter bags shall be placed

24. All air pollution abatement equipment shall be

25. All hood, duct, and collection systems shall be

26. The hoods and ductwork for the emission capture

27. This facility shall not create a nuisance as defined

Table 1: Authorizations Incorporated by Reference

29. The flare controlling emissions from the Hot

30. The cooling water used by the cooling tower

32. Unpaved areas and roads, including storage yards

Demonstration of Continuous Compliance

33. Upon being informed by the TCEQ Executive

Director that the staff has documented visible

34. Upon request by the TCEQ Executive Director or

35. Visible emissions observations for wet scrubbers

36. To demonstrate compliance with the MAERT and

37. The holder of this permit is responsible for

providing sampling and testing facilities and

38. Sampling shall be conducted in accordance with

A. Test methods to be used are as follows:

39. A pretest meeting shall be held with personnel

A. Date for pretest meeting;

submitting the test reports.

40. Alternate sampling methods and representative

41. Requests to waive testing for any pollutant