Republic Steel violated the Clean Air Act, the Title V permit requirements, and the Standards of Performance for Steel Plants: Electric Arc Furnaces and Argon-Oxygen Decarburization Vessels Constructed After August 17, 1983 (?NSPS AAa?), 40 C.F.R. ? 60.270a et seq., at its Canton, Ohio facility. Specifically, Republic violated the emission limit for lead from the baghouse controlling emissions from the facility's two electric arc furnaces during a stack test conducted from August 5 to 8, 2008. In addition, Republic violated the 3% opacity limit on three days in 2009 and 2010 and the pressure drop requirements across two of the baghouses at the Facility on 12 days from 2008 to 2010. Republic also failed to check and record pressure drop across the baghouse, visible fugitive particulate emissions, and furnace pressure on several occasions from 2008 through 2010.
On November 10, 2010, EPA and Republic met to discuss the August 27, 2010, FOV. During the meeting, Republic representatives stated that the August 2008 stack test failure was an anomaly. Republic performed a stack test in November 2008 that shows compliance with its Title V permit emission limit for lead. During the meeting, EPA requested Republic to show that the lead emission limit violation of August 2008 was in fact an anomaly and not a reoccurring event. Subsequently, EPA issued a Section 114 information request requiring Republic to conduct a stack test. In June 2011, Republic conducted the stack test