COW believes that the potential to emit is at least 1.82 tons per year.  This is based on an eyeball calculation of what is believed to be an error by the Indiana Department of Environmental Management.  The discovery of the apparent omission was made by Ronald J. Van Mersbergen, a retired US EPA employee that COW hired as a part of the process to have only a clean mill built.

And as of 22 June 2000, the opinion that counts is that of the US EAB which ordered IDEM to recreate, recalculate, and serve for public comment everything in the permit in re lead.

    There are, of course, several other opinions on the matter:
0.45 tons per year was IDEM’s advertized amount.
0.60 is what triggers some control action.
0.59 is IDEM’s “revised ” post-comment estimate.
4.03 is the opinion of J. Phyllis Fox, Ph.D., an expert not hired by COW, based on filed stack test reports from a score of steel mills.
1.08 maximum, 0.54 tpy minimum is US EPA Region 5’s estimate in their first amicus brief, in which they state:

“Amici are concerned that our conservative estimate is so close to the significance threshold for lead, but we cannot say with certainty that SDI’s total lead emission will exceed this threshold.”

    .pdf page 173 of the 220-page permit package that IDEM publishes is annotated in red below.  The apparent error is very easy to see when it is illustrated.
  

Revised 25 January 2001, page assembled 21 June 2000